PRIVACY POLICY

Effective Date: July 1, 2024

This Privacy Policy describes how Atria Senior Living Inc., our subsidiaries, and our affiliates, which include Holiday by Atria and Coterie Luxury Senior Living, (“Atria,” “us,” “we,” or “our”) process Personal Information collected through our websites (including atriaseniorliving.com, holidayseniorliving.com, coterieseniorliving.com, atriacares.com, atriahomecare.com, atriaretirement.ca, and atriacareers.com), and other information we collect online (the “Sites”).

This Privacy Policy only applies to online services, such as websites and apps, that we own, provide, or maintain and that link to this Privacy Policy.

Please read this Privacy Policy and our Terms of Use carefully before using the Sites. By using the Sites or otherwise providing Personal Information to us, you agree to the Sites’ Terms of Use and consent to Atria’s data collection, use, and disclosure practices, other activities as described in this Privacy Policy. If you do not agree, please discontinue use of the Sites.

Personal Information We Collect and Why We Collect It How We Collect Your Personal Information
How We Use Personal Information
How We Disclose Personal Information
Your Choices About Tracking and Communications from Us
Links to Non-Atria Websites
Mobile Apps
Email Communications
Text/SMS Messages
Security
Age Restrictions
Nevada Privacy Notice
California Privacy Notice
Texas Privacy Notice
International Visitors
Changes to This Policy
How to Contact Us

Personal Information We Collect and Why We Collect It

“Personal Information” is information that is linked or be linkable to you and includes “Personal Data” as defined in applicable privacy law.

We collect the following types of Personal Information through our Sites. Atria may use your Personal Information for any purposes not inconsistent with Atria’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including the purposes listed below.

Identification and Contact Information, including your name, title, alias, postal address, phone number, email address, government identification numbers, social media usernames;
Registration and Profile Information, including username and password for our Sites, and security question/answer combinations;
Transaction and Financial Data, including payment information, credit card number, income, and expenses;
Commercial Information, including services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
Health and Insurance Information, including policy number, medical diagnosis, and accessibility requirements;
Demographic Information, including your age, birth date, gender, and languages spoken;
Electronic Network Activity and Usage Information, including IP address, device identifier, network connected hardware data, browser type and language, operating system, internet or mobile network provider, information about your use of the Sites, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, information related to your interactions with our websites, social media pages, emails, online chat, text message communications, and advertisements;
Geolocation Data, including your physical location based on information you provide directly or inferred from your IP address;
Audiovisual Information, including audio data collected when you call our customer service numbers;
Professional or Employment-Related Information, including identification number and position title; and
Communications, including the contents of your communications via phone, email, text message, chat, or other means (such as survey responses, reviews, and comments on our blog and social media pages).

We may use and share information for any purpose if it is publicly available, de-identified, or aggregated with other information so that it can no longer identify you.

How We Collect Your Personal Information

We collect your Personal Information through various means, including when you directly provide it to us and automatically through your use of our Sites. We may also collect Personal Information about you from our Service Providers and from other parties. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use features of our Sites.

Information that You Provide

We collect Personal Information about you directly when you:

Register or maintain an account with us;
Schedule a tour;
Apply for a job;
Contact us using our online form;
Submit forms and other information through our Sites;
Enter search terms or other information through our Sites;
Subscribe to receive our notifications;
Exchange communications with us by mail, email, phone, etc.;
Post comments to our online communities;
Obtain customer Sites or technical support;
Post reviews or other information about our products or services; and
Connect with us via social media.

Information Collected Automatically

We use cookies, log files, web beacons, pixels, and and other tracking technologies (collectively, “Cookies”) to collect and store Electronic Network Activity and Usage Information about you and your interactions with the Sites. Such information may include IP address, device ID, or other unique identifiers; details about your use of the Sites (including referring URL, clicks, cursor movement, and scrolling activity); and general information about Site traffic data, performance, and related statistics.

We may combine automatically collected information with other Personal Information we obtain about you, which may include data we obtain from third parties. Cookies may be used to collect Personal Information about your online activities over time and across different online services.

Information We Collect from Other Sources

Atria may also obtain information about you from other sources, including our Service Providers. We also may obtain your Personal Information from our affiliates. In some circumstances, we obtain Personal Information about you from third parties, including business partners, resellers, and data brokers, some of which may sell the information to us. To understand your rights and choices regarding Personal Information collected by other companies, please consult the privacy policies of the businesses that you interact with.

How We Use Personal Information

We may use the information we collect about you through the Sites for various purposes, including to:

Personalize and improve your online experience, such as by providing you with content that may interest you and making navigation on our Sites easier;
Respond to your emails or other requests, inquiries, comments, or questions (to respond effectively we may share information with others, for instance, a specific Atria community or regional staff member who can best handle your request);
Monitor and analyze trends, usage, and activities of visitors to, and users of, the Sites;
Send you marketing materials and advertisements;
Improve the Sites, our marketing, and products or services we may offer;
Contact you regarding your use of the Sites;
Verify and/or authenticate your identity;
Provide you with information that we believe may be useful to you, such as information about products or services offered by us or by others;
Prevent fraud or other misuse of the Sites, including protecting our rights and the rights of affiliates or related third parties;
Maintain records of our transactions and communications;
Comply with applicable laws, regulations, or legal process as well as industry standards and our company policies;
Prevent, investigate, identify, or take any other action with regard to any suspected or actual fraudulent or illegal activity or any activity that violates our policies; or
For any other purpose, with your consent.

We also may use the information we obtain about you in other ways for which we provide notice at the time of collection.

In addition, as described above, we use Cookies for purposes, such as recognizing your device when you visit the Sites, monitoring your activity as you navigate the Sites, or analyzing your use of the Sites. This information may be used to track your activity over time on various websites and services, as well as across different devices you may use to access the Internet and our Sites. In general, our Sites use cookies and other tracking technologies as follows:

Where necessary to run our Sites, for example by allowing you to log in or schedule a tour;
To optimize the functionality of our Sites, including by personalizing content for you, greeting you by name and remembering your preferences (e.g., your choice of language or region);
For analytics purposes, including to help us understand how our website is used, to see what products most interest you, and determine how best to market our products to you;
For purposes of ad targeting and marketing, including to collect information about your browsing behavior on our Sites in order to show you interest-based advertising when you visit other websites or use social media;
To determine if you open or act upon our email messages (information on unsubscribing from our commercial email communications is provided below); and
To obtain information about your interactions with our online advertisements, such as whether you clicked on an ad and the website where you may have seen the ad.

How We Disclose Personal Information

We may disclose your Personal Information, as described above, for any purposes not inconsistent with this Privacy Policy, our written statements at the point of collection, or applicable law. In general, we share Personal Information as follows:

Within our group of companies including with our affiliates, subsidiaries, locations, and brands.
With our agents, vendors, consultants, and other service providers (collectively, “Service Providers”) in order for them to provide their services to us. For example, we may share your Personal Information to provide customer service, operate and improve our business and the Sites, improve our products and customer service, help run our promotions (including coupons and rewards programs), process payments, perform auditing and quality control, communicate with you, and otherwise operate our business.
With third parties for marketing purposes, to improve our products and Sites, or to provide you with other products and services that may interest you.
With our advertising partners for the purposes of ad targeting, remarketing, and customized advertising content.
As necessary, for the following purposes: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety, or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.
With our insurers and professional advisers for the purposes of managing risks, exercising or defending against legal claims, and otherwise obtaining professional advice.
With third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

Interactive Features on Our Sites

We may engage vendors to provide certain interactive features on our Sites. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on our Sites to answer questions and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.

Social Features on Our Sites

Certain functionalities on the Sites permit interactions that you initiate between the Sites and certain third-party Sites, such as social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Sites and a third-party Sites; “liking” or “sharing” Atria’s content; logging in to the Sites using your third-party Sites account; and to otherwise connect the Sites to a third-party Sites (e.g., to pull or push information to or from the Sites). If you use Social Features, information you post or provide access to may be publicly displayed on the Sites or by the third-party Sites that you use. Similarly, if you post information on a third-party Sites that references the Sites (e.g., by using a hashtag associated with Atria or one of our brands in a tweet or status update), your post may be used on or in connection with the Sites or otherwise by Atria and/or our affiliates. Also, both Atria and the third party may have access to certain information about you and your use of the Sites and any third-party service.

Analytics

Our website uses analytics technology provided by our Service Providers to understand how users interact with the site, improve our web experience, and better market our products. Analytics services in use on our website include Google Analytics, Heap, and Hotjar. We use information from Google Analytics to implement Google advertising features such as interest-based advertising, audience targeting, and display advertising. For more information on how Google Analytics uses data, visit https://support.google.com/analytics/answer/6004245. These analytics services use cookies and other Tracking Technologies to collect information about how you use the Sites. Personal Information collected by these analytics services (e.g., your IP address and other Electronic Network Activity and Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere). See below for more information on your choices regarding analytics services.

Advertising and Marketing

We use third-party advertising partners that may use their own Cookies and our Cookie data to show you personalized ads and to measure the effectiveness of these ads. We may provide these third-party advertisers with information about your use of our Sites as well as aggregate or non-personal information about users of our Sites. They may use this information to build or enhance their understanding of you and your interests to provide you with more relevant ads.

Your Choices About Tracking and Communications from Us

Cookies and Tracking Technologies

Our Sites offer a Cookie preference center that allows you to exercise your choices. Please click on the link at the bottom of the Site you are viewing to update your cookie preferences. Cookies may also generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. If you typically use more than one browser, you will need to disable or delete Cookies separately on each browser you use. Please review your browser’s Help menu for instructions, or visit allaboutcookies.org for more information. Please note that if you disable all cookies, some features of our Sites may not function properly and disabling Cookies may invalidate your other opt outs that rely on Cookies to function. Please be aware that disabling Cookies or limiting targeted advertising will not stop you from seeing advertisements online or in apps. The advertisements you see may, however, be less relevant to you.

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. We do, however, respond to the Global Privacy Control (“GPC”) signal for California residents wishing to opt-out of the “sale” or “sharing” of their Personal Information. For more information, please see our California Consumer Privacy Notice.

Analytics and Advertising Technologies

We may use certain third-party web analytics services, including Hotjar and Meta, to help us understand and analyze how visitors use the Sites and to serve ads on our behalf across the Internet. Some of our Services Providers offer tools that you can use to limit or opt out of their Cookies, including:

Facebook: To change your privacy and advertising settings with Facebook, login to your Facebook account and navigate to the Privacy Center at Meta’s Privacy Center or review your Ad Preferences at Facebook’s ad preferences page.
Google Analytics and Advertising: You may exercise choices regarding the use of cookies from Google Analytics by going to Google's opt-out page or downloading the Google Analytics Opt-Out Browser Add-on. For more information on how Google Analytics uses data it collects, visit Google's privacy page. We may also use advertising services provided by Google Ad Services. To learn more about the data Google collects for advertising and to opt out of certain ad targeting by Google, please visit Google's ad settings page.
Google reCAPTCHA: We have also implemented Google reCAPTCHA to protect our Sites from fraud and abuse. Your use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Use.
Microsoft: For more information regarding Microsoft’s data practices, including the Clarity, Bing Adds, and Xandr Cookies, visit Microsoft's privacy page.

You may choose not to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or the Network Advertising Initiative (“NAI”). To learn more about how you can exercise certain choices regarding interest-based advertising, including use of cross-device data for serving ads, visit the Digital Advertising Alliance's Consumer Choice tool. To learn more about the NAI and your opt-out options for their members, see networkadvertising.org/choices; to learn more about managing your browser’s opt outs, visit the Network Advertising Initiative’s opt-outs page. Please be aware that opting out only means that those selected members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).

In addition, we may serve ads on other online services that are targeted to reach people on those services who are also identified in one of more of our databases (“Matched List Ads”). This is done by using tracking technologies or by matching common factors between our databases and the databases of the other online services such as Facebook/Meta. We are not responsible for these third-party services, including without limitation the security of the data they hold about you. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, to find out what options Facebook offers you to control such ads.

Atria is not responsible for the effectiveness of any third parties’ opt-out options or the accuracy of their statements regarding their programs.

Links to Non-Atria Websites

This Site may include links to non-Atria websites for your convenience and information. These third-party websites may have their own privacy policies or notices, which we encourage you to review. This Privacy Policy applies solely to information collected through the Sites. Atria is not responsible for the privacy practices or content of any linked websites that we do not control.

Please note, if you visit our Careers page the information you submit will be processed by iCIMS, our third-party Sites provider. You may learn more about the iCIMS platform on this page, or view their privacy policy here.

Mobile Apps

You can stop all collection of data generated by use of our mobile apps by uninstalling them. To uninstall our apps, please follow the instructions from your operating system or device manufacturer. You may also be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., tracking across apps and websites owned by other online services, location-based services, push notifications, accessing calendars/contacts/photos, etc.) by adjusting the permissions in your mobile device and/or the app’s settings.

Email Communications

You may unsubscribe from our marketing email communications by clicking the “unsubscribe” link found in every commercial email we send, or by sending a request to unsubscribe to privacy@atriaseniorliving.com. If you opt-out of our marketing email communications, we may still send you email messages related to your account. Unsubscribing from our marketing communications will not affect the level or quality of service we provide to you.

Text/SMS Messages

You have the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you share with us. Once you opt-in, we may send you text messages (i) regarding your account; (ii) about our products and promotions (including advertisements, sales, and special offers); (iii) to investigate or prevent fraud; and (iv) to alert you in the event of an issue with any of your purchases. You do not have to opt-in to text messages and alerts to use and enjoy our Sites, services, or products. If you opt-in, standard text messaging charges may apply. You may choose to opt-out from our text messages and alerts at any time. To directly opt-out, follow the instructions on your device and we will unsubscribe you from text communications. If you opt-out, you will not receive any additional text messages via your mobile phone. For more information regarding our text messaging and alerts, please contact us at privacy@atriaseniorliving.com or 1 (502) 779-4700.

Security

We take commercially reasonable measures to protect Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and electronic storage are not completely secure, and Atria cannot guarantee the security of your Personal Information. You are responsible for maintaining the secrecy of any credentials used to access your account with us.

Age Restrictions

The Sites are not intended for children under the age of eighteen (18) and we do not knowingly collect personal information from children through the Sites.

Nevada Privacy Notice

Nevada law allows residents to opt out of the sale of certain Personal Information (“Covered Information”). At Atria, we do not sell Covered Information and we have no plans to change that practice. If you have questions about our practices related to Covered Information, you may submit your request to privacy@atriaseniorliving.com.

California Privacy Notice

California residents can learn more about their privacy rights in our California Consumer Privacy Notice. Job applicants can find additional disclosures in our California Careers Privacy Notice. If you are an Atria employee, please see our California Employee Privacy Notice for additional disclosures.

Texas Privacy Notice

This section is provided pursuant to the Texas Data Privacy and Security Act (“TDPSA”) and applies to Personal Information we collect from Texas consumers through the Sites and in other contexts, including offline.

Personal Information We Collect and Disclose

We may collect the Personal Information described in the “Personal Information We Collect and Why We Collect It” section above, both online and offline. Additionally, we may also collect the following Personal Information offline:

Biometric Information, including automatic measurements of biological characteristics used to establish identity, such as fingerprints, faceprints, and voiceprints
Audio, Electronic, Visual, or Similar Information, such as security footage

Texas Privacy Rights

Texas consumers have the following rights related to their Personal Information:

Right to Confirm. You have the right to confirm whether we are processing your Personal Information and to access that Personal Information.
Right to Delete. You have the right to request that we delete Personal Information we collected from you or about you, subject to certain exceptions.
Right to Correct. You have the right to request that we correct Personal Information we maintain about you that you believe is inaccurate.
Right to Opt Out of Sales, Targeted Advertising, and Profiling. You have the right to opt out of the sale of your Personal Information, to request that we do not disclose your Personal Information for targeted advertising, and to opt out of profiling in furtherance of decisions that produces legal or similarly significant effects concerning you. To opt out of the sale or disclosure of your Personal Information for targeted advertising through Cookies, please click the “Do Not Sell or Share My Personal Information” link in the footer of the Site. If you choose to use the Global Privacy Control (“GPC”) browser signal, you will only be opted-out of online sales or sharing of Personal Information, and will need to turn it on for each browser you use.
Right to Data Portability. You have the right to request to receive the Personal Information we hold about you in a portable format.
Right to Appeal. Texas consumers that have been denied one of the above enumerated rights have the right to request an appeal.

To submit a request related to your privacy rights, including an appeal request, please contact us at CAprivacyrequest@atriaseniorliving.com or call (800) 928-9145 and reference “Texas privacy request.”

Please note that when submitting a request, you may be asked to provide information so we can verify your identity before action is taken.

International Visitors

If you access the Sites from outside of the United States, please be aware that Personal Information collected through the Sites may be transferred to, processed, stored, and used in the United States. Data protection laws in the United States may be different from those of your country of residence. Your use of the Sites or provision of any Personal Information to us constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the United States as set forth in this Privacy Policy.

Changes to This Policy

By using our Sites, you consent to the terms of this Privacy Policy and our Terms of Use. We may change our Privacy Policy from time to time.

How to Contact Us

If you have a question about this Privacy Policy or about Atria’s information practices, you may email us at privacy@atriaseniorliving.com. You also may contact us at:

Atria Senior Living
Attention: Privacy Inquiry
300 East Market Street
Suite 100
Louisville, KY 40202