Next Chapter Living Consumer Health Data Privacy Policy

1. What Consumer Health Data Means

“Consumer health data” means personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health status. On our site, it can include care needs and health details, and information that shows you are seeking health care services, such as memory care or skilled nursing. It can be about you or about a person you are helping.

2. Consumer Health Data We Collect

• • Care and health details you include in a message, tour request or waitlist request, such as memory loss, mobility, diagnoses, medications or other care needs.
• • The type of care offered by the community you contact or call, such as memory care or skilled nursing, when it is linked to your request or call, and your contact details, phone number and caller ID name to the extent they show that you are seeking those services.
• • Care or health details you type into our AI search assistant or save in your account, such as searches by type of care.

3. Where It Comes From

• • You, when you fill out a form, call a community, use our search assistant or save information in your account.
• • A person who contacts communities for you, such as a relative, friend or professional.
• • Our phone provider, which gives us the caller ID name registered to a calling number. We do not look up caller ID names for calls from Washington, Nevada or Connecticut area codes.

4. Why We Collect and Use It

We collect and use consumer health data only to:

• • deliver your request to the community you choose, and connect your calls;
• • answer your searches, including through our AI search assistant, and provide account features you ask for, such as saved searches;
• • keep records of your request, your call and the connections we provide to communities, and resolve questions with communities about them;
• • check the quality of our service;
• • protect the security of our site and prevent fraud; and
• • comply with the law.

We do not use consumer health data for advertising or profiling, or to make decisions about you.

5. How We Process It

We store consumer health data in our systems and our service providers’ systems, primarily in the United States. We deliver it to the community you choose, limit access to people who need it and who are bound by duties of confidentiality, and delete it as Section 12 describes.

6. Consumer Health Data We Share, and With Whom

• • The community you choose. We share your request, including any care or health details in it, and for calls, the call record, including your phone number and any caller ID name we looked up. The community is an independent business and is responsible for its own handling of your information.
• • Service providers. Companies that host our site and data, run our phone and text message services, including caller name lookup, deliver email, and power our AI search assistant process consumer health data for us under contracts that allow them to use it only to provide services to us.
• • Lawyers, accountants, auditors and insurers, as needed for their services, under duties of confidentiality.
• • Others when required. We may disclose consumer health data when the law requires it, to protect someone’s safety, or as part of a merger or sale of our business, as our Privacy Policy explains.

We have no affiliates that receive consumer health data. We do not share consumer health data with data brokers. We do not send care or health details to our advertising agency or to advertising or analytics companies, and Section 9 describes the other steps we take to keep consumer health data away from them.

7. We Do Not Sell Consumer Health Data

We do not sell consumer health data. Communities pay us for advertising and connection services, not for your information, and what a community pays does not change if your request includes health details. When you ask us to contact a community, we send your request to that community at your direction. We will not sell consumer health data unless you first give the consent Connecticut law requires or sign a valid authorization that meets Washington or Nevada law.

8. How We Ask for Your Consent

• • Forms. We collect and share the care or health details in your request because you ask us to send them to the community you choose, which is the service you request. We also ask for your consent to collect those details and your consent to share them with that community before we do either, using the notices and any check boxes on the form. Agreeing to our Terms of Service is not that consent. Care and health details are optional, and you can send a request without them.
• • Calls. We do not record, transcribe or listen to calls, so we do not collect what you say on a call. When you call a community through a number on our site, we keep a record of the call, including your phone number and any caller ID name we look up, so we can connect the call and keep accurate records.
• • Withdrawing consent. You can withdraw your consent at any time by emailing [email protected] with the subject “Health Data Request,” or by replying to any email we send you about your request. We act on it within 15 days. Withdrawing stops future collection and sharing, but it cannot undo what a community has already received.

9. Location Tracking and Tracking Across Sites

We do not use a geofence, meaning a virtual boundary of 2,000 feet or less around a health care or senior living location, to identify or track people, to collect consumer health data, or to send notifications, messages or ads.

We do not send advertising or analytics companies care or health details. For visitors we identify as being in Washington, Nevada or Connecticut, our advertising and analytics tags do not load on our site. We identify location from IP addresses, which are not always accurate. We do not send ad measurement information about requests or calls to communities in those states, or about requests or calls we identify as coming from people in those states. Our advertising agency does not receive individual records about those requests or calls.

10. Your Rights

You have the right to:

• • confirm whether we collect, share or sell your consumer health data, and get a copy of it, including a list of every third party and affiliate with which we shared or sold it and an email address or other online way to contact each of them;
• • withdraw your consent to our collection and sharing of your consumer health data;
• • have us delete your consumer health data. We delete it within 30 days after we verify your request, and in any case within 45 days after we receive it unless we extend that period as described below. We tell the communities and service providers that received it to delete it, and we remove it from backups within six months. We may keep information only where the law allows;
• • review and correct your consumer health data; and
• • not be discriminated against for using these rights.

To make a request, email [email protected] with the subject “Health Data Request,” or write to us at the address in Section 15. You do not need an account. We verify requests by comparing the information you give us with our records, for example by sending a code to the phone number or email address we have for you. An authorized agent may make a request for you with your signed permission. We respond within 45 days, and we may extend that once by up to 45 more days if we tell you why within the first 45 days. Requests are free at least twice in any 12 month period.

11. Appeals

If we decline your request, you may appeal by emailing [email protected] with the subject “Appeal.” We will respond in writing within 45 days and explain what we did and why. If we deny your appeal, you may contact your attorney general:

• • Washington Attorney General: https://www.atg.wa.gov/file-complaint
• • Nevada Attorney General: https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/
• • Connecticut Attorney General: https://portal.ct.gov/ag/common/complaint-form-landing-page

12. How Long We Keep It

• • Care and health details in requests: 24 months after your last activity with us.
• • Records of requests and calls we connect, such as the date, the community and your name, phone number or email address: up to 7 years with our business records. If you ask us to delete your consumer health data, we remove your name, phone number and email address from these records.
• • Records a state law requires us to keep about a request: for the period that law sets.
• • What you type into our AI search assistant: up to 12 months, unless you save a search in your account.
• • Care or health details saved in your account: until you delete them or close your account.

We delete consumer health data sooner when you ask us to, as Section 10 describes.

13. Changes to This Policy

We will post any change to this policy with a new effective date and tell account holders by email before a material change takes effect. We will not collect, use or share consumer health data for a new purpose, or share it with a new type of recipient, without first asking for your consent.

14. Our Other Policies

Our Privacy Policy explains how we handle other personal information and describes your other privacy rights.

15. Contact Us

• • Next Chapter Living, Inc.
• • Mail: in care of our registered agent, as listed with the Delaware Division of Corporations
• • Email: [email protected], subject “Health Data Request”
• • Website: https://nextchapterliving.com