Data Privacy Policy

This Website consent, acknowledgement, and data privacy policy (the “Site Acknowledgement” or
“Acknowledgement”) of Senior Lifestyle and its affiliates (“Company,” “we,” “us,” or “our”) describes our
privacy practices regarding personal information we collect, including from persons (“you” or “your”) who
access our Website (collectively, the “Site”).

PURPOSE.

The purpose of this Acknowledgement is to inform you about the types of personal information
we gather about you, including personal information gathered when you visit the Site, and personal
information we may receive from third parties or affiliates in addition to that online information, how we
may use that information, whether we disclose that information to anyone, and the choices you have
regarding our use of, and your ability to correct, the information. This Acknowledgement does not cover
information that is exempted from privacy notification requirements, including information about
employees, contractors, job applicants and information processed exclusively in the context of a business
person acting in a business capacity.

YOUR CONSENT AND ACKNOWLEDGEMENT CHANGES.

PLEASE READ THIS ENTIRE ACKNOWLEDGEMENT
CAREFULLY. BY USING THE SITE, YOU EXPRESSLY CONSENT, WITHOUT QUALIFICATION, TO THE
COLLECTION, USE, AND DISCLOSURE OF INFORMATION, INCLUDING PERSONAL INFORMATION, AS
DESCRIBED IN THIS ACKNOWLEDGEMENT. IF YOU DO NOT AGREE TO THE TERMS OF THIS
ACKNOWLEDGEMENT, YOU ARE NOT AUTHORIZED TO USE THE SITE.
Company may amend this Acknowledgement from time to time. We will post those changes on the
website. In certain cases, you may be notified via email or by a notice on our website.

PERSONAL INFORMATION COLLECTED IN THE PAST 12 MONTHS.

We may collect, process, and store
various types of Personal Information. For purposes of this Acknowledgement, “Personal Information”
means information that identifies, relates to, describes, is reasonably capable of being associated with, or
could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not
include de-identified or aggregate information, or public information lawfully available from
governmental records.

Personal Information we collect may include: your name, email addresses, postal addresses, postal codes,
user Internet Protocol (IP) addresses, social security/insurance number, driver’s license number, prior
addresses, monthly rent paid at prior residences, employers, job titles, income, telephone numbers, credit
card information, bank account information and routing numbers, date of birth, gender, age, marital
status, user name and password (if you choose to become a registered user of the Site or our products
and services), emergency contact information, information about your pets, information about your
vehicles including license plate numbers, and other information either desirable or necessary to provide
quality services to our residents and visitors. We may also collect information about you such as your use
of the Site and communication preferences.

We do not and will not sell your Personal Information.

INFORMATION DISCLOSURE.

We may disclose the information we collect from and about you (1) to our
business partners, if the disclosure will enable them to perform a business, commercial, professional, or
technical support function for us; (2) as necessary if we believe that there has been a violation of our
rights or the rights of any third party; (3) to respond to judicial process or provide information to law
enforcement or regulatory agencies or in connection with an investigation on matters related to public
safety, as permitted by law, or otherwise as required by law; and (4) as described to you at the point of
collection.

ADDITIONAL INFORMATION ABOUT HOW WE COLLECT AND SHARE YOUR PERSONAL INFORMATION.

With respect to each of the categories of data above, we may also collect and share Personal Information
with third parties to comply with legal obligations; when we believe in good faith that an applicable law
requires it; at the request of governmental authorities or other third parties conducting an investigation;
to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an
emergency; or otherwise to protect the rights, property, safety, or security of our business, third parties,
visitors to our websites and mobile apps, or the public. We may also share Personal Information with any
person to whom we transfer any of our rights or obligations under any agreement, or in connection with
a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by
operation of law, or who is otherwise deemed to be our successor or transferee.

USE OF COOKIES AND OTHER TECHNOLOGIES.

Like many other website operators, Company may use
cookies, pixel tags, or other technologies to automatically or passively collect certain information to
customize content specific to your interests and track your use of the Site. “Cookies” are text files that are
placed on your computer and may be used to store your Personal Information. Cookies may be stored on
your computer when you visit our website. These cookies provide statistical data that may help us to
improve our Site and deliver better and more customized services. “Pixel tags” are tiny graphic images on
that help us analyze customer online behavior and measure the effectiveness of our website and
advertising. In addition to cookies and pixel tags, Company may use other now known or later developed
technologies, to assist Company in observing the behavior of users visiting the Site. This Site may use Lead
Attribution or Marketing Attribution to assess the conversions of different channels that generate leads.
These technologies access individual user information but the information is used only to compile
aggregated statistics about the Site’s usage.

We also work with third-party business partners that use tracking technologies to deliver advertisements
on our behalf both online and offline. These companies may collect information about your visits to our
website and your interaction with our advertising and other communications. This Site may use Google
Analytics (and in the future may use other similar sites or services), a web analytics service provided by
Google, Inc. (“Google”), to better assist Company in understanding how the Site is used. Google Analytics
may place cookies on your computer that will generate information that we select about your use of the
Site, including your computer’s IP address. That information will be transmitted to and stored by Google.
The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on
Site activity for Company’s use, and providing other services relating to Site activity and usage. Google
may also transfer this information to third parties where required to do so by law, or where such third
parties process the information on Google’s behalf. The use of cookies by Google Analytics is covered by
Google’s Acknowledgement: https://www.google.com/policies/privacy/. If you wish to prevent your data
from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on
available at https://tools.google.com/dlpage/gaoptout/.

You can choose to delete existing cookies, allow or block cookies, and set preferences for certain websites
in your browser’s settings. When you opt out through one of these websites, an “opt-out” cookie is stored
in your web browser indicating that you do not want to receive targeted advertisements. If you delete
cookies generally, you will need to opt out again. Even if you opt out, you still may receive advertising
from us that is not customized based on your service or usage information, or advertising from other third
parties. Please note you may not be able to use the full functionality of the Site if you choose to block all
cookies.

APPLICABLE LAWS AND REGULATIONS.

Additional federal, state, and local laws and regulations, such as
California Consumer Privacy Act (CCPA), may apply. You may take advantage of the following rights:

  1. You may request, up to two (2) times each year, that we disclose to you the Personal Information
    that we have collected about you, the categories of sources from which your Personal Information
    is collected, the business or commercial purpose for collecting your Personal Information, the
    categories of Personal Information that we disclosed for a business purpose, any categories of
    Personal Information that we sold about you, the categories of third parties with whom we have
    shared your Personal Information, and the business or commercial purpose for selling your
    Personal Information, if applicable.
  2. You may request that we delete any Personal Information that we have collected from or about
    you. Note that there are some reasons we will not be able to fully address your request, such as
    if we need to complete a transaction for you, to detect and protect against fraudulent and illegal
    activity, to exercise our rights, or to comply with a legal obligation.
  3. You can make a request for disclosure or deletion.

To take advantage of any of these rights, you may contact us by email at
DataRemoval@seniorlifestyle.com.

In each case, we may need to request additional information from you for verification purposes. We value
your privacy and will not discriminate in response to your exercise of your privacy rights. We will respond
to your request within the timeframe required by the applicable law, after proper verification, unless we
need additional time, in which case we will let you know.

For purposes of compliance with applicable law, in addition to the further details as described throughout
this Acknowledgement, we make the following disclosures:

  1. We collect the following categories of Personal Information: Identifiers/Contact Information,
    characteristics of protected classifications under state or federal law, payment card information
    associated with you, commercial information, Internet or other electronic network activity
    information, and inferences drawn from the above.
  2. We disclose the following categories of Personal Information for a business purpose:
    Identifiers/Contact Information, characteristics of protected classifications under state or federal
    law, payment card information associated with you, commercial information, Internet or other
    electronic network activity information, and inferences drawn from the above.

EMAIL AND TEXT MANAGEMENT.

If you provide your email address or phone number, you may receive
emails, calls, and/or texts from Company for a variety of reasons. We respect your desire to manage email
and text correspondence. If you have an account with Company on the Site, you can select your
preferences through your account settings. You can also manage your receipt of certain types of
communication by following the instructions included in the email we send you. Please note that, even if
you unsubscribe from certain email correspondences, we may still need to email you with information
relating to your unit, the management of the property, and other important transactional or
administrative information.

THIRD-PARTY WEBSITES.

This Acknowledgement applies solely to information collected by Company. This
Acknowledgement does not apply to other websites that are accessible through this Site, including but
not limited to any third-party websites. Third party sites have separate and independent privacy policies;
therefore, we have no responsibility or liability for the content and activities of these linked sites.
Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

ACCESSING, REVIEWING AND CHANGING YOUR CONTACT INFORMATION.

This Site may offer you an individual account, as an account holder, you can see, review, and change most of your contact
information associated with your Account Profile by logging into your account and editing your Account
Profile. With some exceptions, you may have the right to see what Personal Information we hold about
you. We may be able to help you identify what records we might have about you. We may need to confirm
your identity before providing you with this access, and if we cannot verify your identity with the degree
of certainty required, we will not be able to respond to your request. If we cannot give you access, we
will tell you within forty-five (45) days of receipt of your request and provide you with a reason, as best
we can, as to why we cannot give you access. For assistance, please contact us by email at
DataRemoval@seniorlifestyle.com.

MOBILE INFORMATION.

Mobile information will not be shared with third parties/affiliates for
marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data
and consent; this information will not be shared with or obtained from any third parties.

Do Not Track.

“Do Not Track” is a privacy preference that users can set in certain web browsers. We
may not respond to browser or do not track signals.

ACCESSIBILITY.

We are committed to ensuring that our communications are accessible to people with
disabilities. To make accessibility-related requests or report barriers, please contact us by email at
DataRemoval@seniorlifestyle.com.

CONTACTING US.

If you have questions regarding this Acknowledgement or use of information
collected, please contact us by email at DataRemoval@seniorlifestyle.com.

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