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The Springs Living Privacy Policy

 

Introduction

Thank you for visiting The Springs Living’s (“Springs Living”, “we” or “us”)) Internet website ("Site") located at the URL https://www.thespringsliving.com. This Privacy Policy details certain policies implemented throughout Springs Living governing Springs Living's collection and use of personally identifiable information about users of our Site and our services.

We value the privacy and secure processing of your data very highly. Transparency concerning the use of your data is crucial for building trust, goodwill, and a strong relationship. That is why we will tell you how we collect and process your data in this Privacy Policy. This ensures that you as a user always know what kind of and how much personal information we have about you and what we use it for.

Privacy Policy Updates

Due to the Internet's rapidly evolving nature, Springs Living may need to update this Privacy Policy from time to time. If so, we will post our updated Privacy Policy on our Site along with a change notice on the Site. We may also send registered users of our services a notice that this Privacy Policy has been changed. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of this Site and/or services and/or your continued provision of personally identifiable information to us after the posting of such notice will be subject to the terms of the then-current Privacy Policy.

Information Collection

You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site, we may require you to submit your personally identifiable information to us and we may invite you to submit questions, comments and request information.

Due to the nature of some of our services, you may provide us with personally identifiable information such as your name, email address, username, password, address, phone number, and other contact information that you voluntarily transmit with your communication to us.

Use of the Springs Living App Platform

When you sign up for The Springs Living App platform, we will collect Registration information, including your name, email address, and other details you provide us (birth date, phone number, Springs Living community address).

When you place an order via The Springs Living App platform, you do so within your Service Community, which is deemed responsible for the proper execution of the service delivery. If any financial data is requested, the processing thereof will be handled through external e-commerce payment software. Such data will not be communicated to The Springs Living App and will be handled by the third party payment service providers only.

Other information that we may collected includes:

  • Information provided when filling out a form on our website, or when filling in specific Cubes;
  • Information provided when subscribing to our newsletter;
  • Information provided when placing orders on The Springs Living App platform;
  • Information provided in the context of surveys or any other marketing communication;
  • Information provided in connection with the use of certain websites that are associated with The Springs Living App platform, such as Cubigo or Zendesk, with which our support department can assist you with any questions or problems you may encounter when using The Springs Living App platform;
  • Any other information that you send to us, such as when you contact us with questions or comments.

When you use The Springs Living App platform, we may collect other information only with your explicit permission. This other information enables us to offer you additional features and services. We only collect such information when you expressly choose to share it with us.

Here are some examples:

  • Your specific location: When accessing and using the Springs Living App platform, we will never collect or use your specific device location for services you select without first getting your explicit permission. Please note that when you access our Site, your geolocation may be collected through Google Analytics (see below) and aggregated across Springs Living Site users for our analysis and advertising efforts.
  • Your microphone: By using the microphone, you will be able to control The Springs Living App platform with your voice. Nevertheless, we will never access or use your microphone unless you give us explicit permission to do so. Even if you permit us to do so, you will always have the ability to disable access to the microphone.

As part of your use of the Cubes on The Springs Living App platform, and depending on which services you choose to utilize, other sensitive personal information may be collected to provide better services to you or to enhance your experience. For example, the use of certain Cubes may provide access and collection of information such as health, medications, religion, etc. If you do not wish to share this information, you may refrain from using the Cubes that require them.

Data Collection Method

Most personal data that we collect is supplied by yourself as a user, for example, when registering or using The Springs Living App platform. We may also collect your information automatically from your computer system or mobile device, such as described below under the sections entitled Cookies and Third Party Data Collection & Analytics Tools.

Depending on the kind of profile you opt for and the Cubes you use, third parties such as caregivers, family, acquaintances, etc., may also provide us additional personal data about you.

Users can update their personal information through their account at The Springs Living App. Users may also cancel their accounts at any time. Account cancellations are processed by our support team. To cancel your account from The Springs Living App you may send a written request to app@thespringsliving.com or contact the support channels, reachable through the contact form in our support center through The Springs Living App.

Management of Collected Personal Information

We collect certain personal information from our Site as discussed in this Privacy Policy to enhance customer experience and our operations such as customer relationship management, sales, direct marketing, shipping and invoicing. We are Data Controllers of data we collect and use from our website.

We also manage the process of data on The Springs Living App platform.

The Springs Living App platform provides its users access to a community of third-party service providers (the “Service Community”) which comprises service providers that help you with services you need and choose to use. The Service Community and its related service providers may offer their services and products on The Springs Living App platform through specific Cubes.

Concerning the personal data collected by the Service Community on the Cubes, only they are responsible for the collected data. In its capacity as a manager of The Springs Living App, we act solely as a processor of such data for the Service Community. This means that The Springs Living processes such personal data solely according to the instructions of the individual Service Community’s service providers. Therefore, as the manager of The Springs Living App platform, the Springs Living is considered a Data Processor and not a Data Controller. End users will be provided an opportunity to opt-in to use the services of (and therefore disclose personal information to) each member of the Service Community.

In legal terms, a “Data Controller” is the natural or legal person who determines the purpose and means for the processing of personal data. The “Data Processor” only processes personal data on behalf of the Data Controller.

Purpose of Data Collection & Processing

Through The Springs Living App platform, we offer digital services to achieve the following:

  • To connect residents and their families with their Springs Living community and its staff;
  • To provide access to quality services in terms of comfort, well-being, leisure, and healthcare;
  • To inform residents and their families on the news and activities in the Springs Living community;
  • To follow up on requested services; and,
  • To support healthcare professionals in provisioning of health care services.

All the information we collect when you visit The Springs Living App platform is related to the provision of services via The Springs Living App platform and its features.

Therefore, we collect information for the following specific purposes:

  • Information we need so that you can use The Springs Living App platform;
  • Information we can use in the future to provide new solutions and improved experiences if you choose to share that Information; and Information we need so that we can offer you the best possible support when using The Springs Living App platform.

Information we need so that you can use the platform -

We collect your data first of all to create and maintain your account on The Springs Living App, to ensure the proper functioning of The Springs Living App platform, and to deliver the services and/or products (or have them delivered) that you order from or via The Springs Living App platform.

For instance, you can use The Springs Living App platform to:

  • Communicate with your Springs Living community, staff, caregivers, family or acquaintances, and vice versa;
  • Receive the necessary information to follow up on the requested services; and,
  • Set up communication between you, your family, the Springs Living community, Service Community (i.e., service providers) and its staff.

Information we need to provide new experiences -

Based on the personal data we have about you, and to optimize our services, we may analyze, evaluate, and assess your preferences and needs. It should be noted that these activities may qualify as ‘profiling’ under national and European regulations on personal data protection.

We also use the personal data and information we collect to:

  • Customize your experience as a user;
  • Determine the kind of content and offers you are most interested in and inform you about them;
  • Offer you a better service, answer more of your questions, and meet your needs better;
  • Provide you with information;
  • Process your queries and orders quickly; and
  • Communicate with you on various topics such as events, news items, and Platform feedback.

We never sell, trade, or transfer your data to/with any third parties, unless we inform you about this in advance and you give us your explicit permission to do so.

We do share your contact details with website hosting partners or other third parties that help us conduct our business or operate our website and The Springs Living App platform, or that provide services directly to you. This mostly – but not only – includes service providers and product vendors that have a Cube on The Springs Living App platform. These partners are also obliged to keep this information confidential. Furthermore, we may share your data when we are legally obliged or entitled to do so.

Certain information that cannot lead to the identification of a natural person, such as website/platform statistics and similar data, may be shared with external parties for marketing, advertising or other purposes.

Cookies

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's “help” file.

On our Site, we use session cookies to make it easier for you to navigate the Site by remembering your locale preferences and to improve and track the overall Site experience. For our Site, we set a persistent cookie to authenticate your login and authorization to use the services. Persistent cookies enable us to track, store and target the interests of our users to enhance the experience on our Site. If you reject cookies, you may still use our Site, but your ability to use some areas of our Site may be limited.

Information Use

We may use your personally identifiable information to deliver our services or information you have requested, verify your authority to enter certain password protected areas of the Site, verify that you are a customer or prospective customer, send you information that you have signed up to receive, notices about our products and/or services that you have used or that may be of interest to you and notices about events, and improve the content and general administration of the Site and our services.

If you are a user of our services, we may use your personally identifiable information to provide the services to you.

Protecting Your Data Collected Through The Springs Living App Platform

We strive to protect the information of our users.

When using The Springs Living App platform, your password is the first level of protection for your user account. You should therefore use a unique and strong password, restrict access to your browser and computer, and log out after using The Springs Living App platform. Furthermore, we always take the appropriate technical and organizational measures consistent with industry practice to protect your data against accidental or unwanted destruction, loss, modification, access, or any other unauthorized processing.

We have also implemented several security measures to guarantee an appropriate level of security according to technological evolution, implementation costs, and the nature, scope, context, and purpose of the processing.

Data that we process through The Springs Living App is stored on secure servers, which are only accessible to a limited number of people who have special access rights to these systems in emergency cases. These technicians are also bound by a confidentiality agreement and must always use and handle personal data in accordance with The Springs Living App Privacy Agreement.

Furthermore, all personal data is encrypted by Secure Socket Layer (SSL) technology.

Moreover, we implement a variety of security measures to protect your data when you, as a user, enter your data or access your personal information. While we consider these policies and procedures to be adequate, there is still a risk that your data could be misappropriated. No method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee the absolute security of your data. If you have any questions about security on our site, you can send an email at app@thespringsliving.com.

Data Retention Period For Data Collected Through The Springs Living App Platform

With respect to the data we process through The Springs Living App platform, we store your data as long as your account remains active and no longer than necessary unless a longer retention period is required or allowed by law. Once you ask us to delete your profile, your data will be permanently and irrevocably removed from The Springs Living App platform unless a longer retention period is required or allowed by law.

Aggregated and de-identified users’ data may be used to assess and improve The Springs Living App platform and the services offered therein.

The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide requested services or information to you; (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them); or; (iii) whether retention is advisable in light of legal concerns (such as concerning applicable statutes of limitations, litigation or regulatory investigations).

Children's Privacy

Springs Living recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Neither our Site nor our services are intended for children under the age of 13. Springs Living does not target its services or this Site to children under 13. Springs Living does not knowingly collect personally identifiable information from children under the age of 13.

Can children use the Springs Living App platform?

Persons under the age of 18 can only use The Springs Living App platform if they submit written permission from a parent or legal guardian who has read this Privacy Policy. In the case of underage users, the parents or legal guardians are fully responsible for all actions taken by the minor. We are committed to protecting the privacy of children. We do not target The Springs Living App platform or our website to children less than 18 years of age or knowingly collect information from children to sell products or services.

Third Party Data Collection & Analytics Tools

Beyond the personally identifiable information you voluntarily provide to us, Springs Living utilizes analytics tools including third party technologies, such as Google Analytics, to collect non-personally identifiable information utilizing cookies. Certain types of information, including geolocation, device type, onsite website usage and behavior, demographic data, and purchase history, is collected and aggregated across Springs Living Site users for our analysis and advertising efforts.

Springs Living uses Remarketing with Google Analytics and Google Adwords to display relevant advertisements to users who have previously visited our Site. Referred to as remarketing or retargeting, Springs Living may utilize previous session information to serve display advertisements to you on the Site and based on such session information Google may set a cookie and serve ads to you on third party websites on the Google Display Network. Third party vendors such as Google may display Springs Living ads on websites across the Internet. Aggregated user data may be utilized to create remarketing/retargeting “lists,” or groups of users with similar onsite behaviors or demographics.

Springs Living also uses Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting and Interest-Based Advertising to display advertisements to users based on their inferred interests and demographics. Springs Living does not run interest-based advertising campaigns that collect personally identifiable information.

Users may learn more about Google Analytics use of cookies by visiting the Google Privacy and Terms page at http://www.google.com/policies/. You may opt out of being tracked by Google Analytics by i) Turning off cookies in the preferences settings in your browser ii) Downloading the Google Analytics opt-out browser add on available at: https://tools.google.com/dlpage/gaoptout/ iii) Opting out of user interest and demographic categories in the Settings for Google Ads feature to manage or opt out of Google interest based ads at: or iv) Managing cookies used for online advertising across multiple companies at the US-based Network Advertising Initiative at http://www.networkadvertising.org/choices/.

When using The Springs Living App platform or ordering services via Cubes, you may access and employ services of outside third party service providers. These third party service providers may independently collect personal data from you. You may refer to their company Privacy Policies to determine what and how personal information they collect.

 

Links to Third Party Sites

The Site may provide links to other Websites or resources over which Springs Living does not have control ("External Websites"). Such links do not constitute an endorsement by Springs Living of those External Websites. You acknowledge that Springs Living is providing these links to you only as a convenience, and further agree that Springs Living is not responsible for the content of such External Websites. Your use of External Websites is subject to the terms of use and privacy policies located on the linked to External Websites.

Aggregate Information

The Site may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, IP addresses, External Web Sites (defined below) linked to and other aggregated data collected through our services and we may analyze this data for trends and statistics in the aggregate but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Site, track users' movement, and gather broad demographic information for aggregate use.

Disclosure of Personally Identifiable Information

We may provide your personally identifiable information and the data generated by cookies and third party analytics tools and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you. For example, we engage with G5 Search Marketing, Inc. to assist us in creating and hosting this Site.

We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation or other government authority or to assist in any investigation, to protect our or our users' rights or to enforce our terms of use. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Springs Living participates or to a purchaser of all or substantially all of Springs Living's assets to which this Site relates.

Your Rights As A User of The Springs Living Website or App Platform

We process your data fairly and lawfully. This means that we only process your data for the legitimate purposes stated in this Policy. Furthermore, we ensure that the type and amount of personal information we collect is always relevant and in reasonable proportion to the purposes for which it is processed.

Right of Access

Anyone who proves their identity has the right to access the personal data we hold about them. This means that you have the right to request information about the data we process, the purposes for which we process it, the categories of personal data concerned, and the recipients we share your data with. You have the right to ask us to provide you with an overview of all personal data we hold and process about you, as well as the source from which we have obtained it, in an easily intelligible way.

Right To Rectification

When we process personal data, such data must be accurate. Therefore, you can always tell us to correct or delete inaccurate or incomplete data about you.

Since we cannot detect errors or omissions in your data, we rely on you to inform us of any inaccuracies or omissions and to make the necessary adjustments to your registration data.

Right To Object & Right To Be Forgotten

Any user can exercise their right to object to the processing of personal data for serious and legitimate reasons, free of charge. However, the user cannot object to the processing of personal data if the data is necessary to fulfill any contractual agreement between you and The Springs Living. The Springs Living will notify the user of the deletion of their data within thirty (30) days.

Exercising These Rights

You can exercise the above rights by sending us a written and signed request, including a copy of a government issued identification document, such as a driver's license or passport, to TSLapp@thespringsliving.com. We will respond to your request as soon as practicable.

If at any time, you no longer agree with the terms of this Privacy Policy, you may delete your profile or contact us by email at TSLapp@thespringsliving.com with a proper request to cancel your profile. Please note that we will not be able to process questions or contact you without your data.

You can unsubscribe from emails sent by The Springs Living App platform by clicking “Unsubscribe” at the bottom of the email. Important service-related emails will still be sent.

Security

We may employ industry standard procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Springs Living may use, without limitation, firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your personally identifiable information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding the use of their personal information. The California Consumer Privacy Act (“CCPA”) gives California residents the right to opt out of the “sale” of their personal information. We do not sell personal data in the traditional sense; that is, we do not generate revenue from disclosing your data. However, to provide you with the services or information you request, we may share information with third parties, or they may automatically receive certain limited information associated with you as part of your use of our services, as described above. We also may share information, including contact information, with third parties as outlined in this Privacy Policy, which might be considered a “sale” under California law.

California Consumers who wish to opt out of the sale of their data may opt-out by contacting us TSLapp@thespringsliving.com.

Colorado, Connecticut, Virginia, and Utah each provide their residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their residents with rights to:

  • Correct inaccuracies in their personal information.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Please note that we do not currently sell data triggering these statutes’ opt-out requirements. Nonetheless, to exercise any of these rights, please contact us at app@thespringsliving.com.

Notice To European Users

This Site and the services on this Site are targeted for users in the United States of America. Any information you enter on this Site may be transferred outside of the European Union to the United States of America which does not offer an equivalent level of protection to that required in the European Union. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union’s Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his consent to the transfer of personal information, regardless of the third country's level of protection. By using this Site or the services, you consent to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in the European Union and to the processing of that information by Springs Living on its servers located in the United States of America as described in this Privacy Policy.

Modifications To This Privacy Policy

Since we want to continuously improve our website, The Springs Living App platform, and our services, we occasionally adjust this Privacy Policy so that it is consistent with applicable laws, our business needs, and the needs of our users, visitors, and service providers.

Contact

In case you have any questions regarding The Springs Living App data privacy policy, please contact The Springs Living LLC be email at app@thespringsliving.com, by mail to 3330 SE Three Mile Lane McMinnville, OR 97128, or by phone at (503) 435-2323.

 

This Privacy Policy was last updated: 2024-06-21

This version of the Privacy Policy is effective as of: 2024-06-21

 app@thespringsliving.com, 3330 SE Three Mile Lane

McMinnville, OR 97128, 503-435-2323

 

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