We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information”). We collect Personal Information through a variety of touch points, such as when you visit our website and associated community pages (“Website”), engage with us at one of our communities (“Communities”), or if interact with us through other channels (collectively, the “Services”).
II. INFORMATION WE COLLECT ON OUR WEBSITE
When you visit our Website, we collect Personal Information from directly if you engage with certain features and automatically.
i. Information you provide directly to us.
We collect Personal Information on our Website from you when you:
- Apply for employment at Cascade. When you apply for employment at Cascade, we will collect your personal identifiers (name, physical address, and telephone number) and professional or employment related information (employment history, educational history, and resume). We use this Personal Information to assess and manage your application and to communicate with you about your application.
- Apply to be a volunteer. When you apply to be volunteer at Cascade, you will be required to provide us with personal identifiers (name, physical address, telephone number, email address, emergency contact information, and reference information). In order to volunteer, you will also need to provide us with customer records information (health and medical information). We use this Personal Information to assess and manage your volunteer application.
- Contact us. When you send us a question or inquiry, you will need to provide us with your personal identifiers (name and email address) and any other information you choose to include in your correspondence. We use this Personal Information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you have with the Services.
- Create a Cascade account. To create a Cascade account for our payment portal, you will need to provide personal identifiers (name, physical address, and telephone number). We use this Personal Information to create and manage your Cascade account.
- Make a payment. If you take advantage of our Website to make resident payments, you will provide personal identifiers (name, physical address, and email address) and customer records information (payment card number, expiration date, and CVV). We use this Personal Information to process your payment. The payment is facilitated by our payment processor, Washington Trust Bank.
- Request a brochure or tour. If you request a brochure or schedule a tour, you will need to provide us with personal identifiers (name, physical address, telephone number, and email address). We use this Personal Information to send you the brochure as requested or schedule the requested tour. We may also use this Personal Information to send you marketing communications we feel may be of interest to you.
We may also use the Personal Information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE USE YOUR INFORMATION.
ii. Information collected automatically.
In addition to the Personal Information you provide directly to us, we may also collect information from you automatically as you use the Website. This includes the following internet or other electronic network activity information:
- Usage information. This includes information about your interaction with the Website, such as pages you access, the frequency of access, what you click on while on our Website, and when you accessed the Website.
- Location information. Information about your location, which may be determined through your IP address.
- Device information. This includes information about the device you are using, such as hardware model, operating system, browser type, browser language, and your preferences.
- Essential cookies. We use essential cookies to authenticate users, prevent fraudulent use of the Website, and to enable our Website and its features to function properly.
- Functional cookies. We use functional cookies to provide enhanced functionality and personalization, remember your preferences, diagnose server and software errors, and in cases of abuse, track and mitigate the abuse.
- Analytics cookies. We and our third-party providers use analytics cookies to recognize and count the number of visitors to the Website, see how visitors interact with the Website, see how visitors engage with different functions, and see when visitors are using the Website. We use this information to improve the Website.
- Advertising cookies. We and our third-party providers use advertising cookies to identify and store behaviors that users take when visiting our Website. These cookies are used in order to: (i) identify you as a prospect for our services; (ii) deliver advertisements that are more relevant to you and your interests; (iii) limit the number of times you see an advertisement; and (iv) help measure the effectiveness of our advertising campaign. The use of advertising cookies may be considered a sale under the California Consumer Privacy Act. To opt-out of collection of your information via cookies, follow the instructions below and in YOUR INFORMATION CHOICES.
Particular cookies to note for our Website visitors include:
- Facebook Pixel. We use Facebook Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our Website by clicking on the Facebook ad. The Facebook Pixel stores a cookie on your device to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the information collected through the Facebook Pixel. However, the information collected via the Facebook Pixel is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy. The Facebook Pixel also allows Facebook and its partners to show you advertisements on and outside of Facebook. This sharing may constitute a sale under the California Consumer Privacy Act. You can opt-out of displaying Facebook ads by visiting your Facebook Ad Settings, and you can clear and control the information third parties share with Facebook in your Off-Facebook Activity page. If you do not have a Facebook account, you can opt-out of Facebook ads through the Digital Advertising Alliance here.
- Crazy Egg. We also use Crazy Egg to help us understand how users engage with our Website, such as where a user clicks or scrolls on a page. To accomplish this, Crazy Egg will deposit a cookie in your browser. You can learn more about Crazy Egg here. You can opt-out of Crazy Egg here.
III. INFORMATION WE COLLECT AT OUR COMMUNITIES
We also collect Personal Information from you or your designated representative at our Communities in certain instances. These instances include:
- Resident applications. When you apply to become a resident at one of our Communities, we will collect your personal identifiers (name, Social Security number, date of birth, physical address, email address, and telephone number), your customer records information (medical and health information), and your protected classifications (military or veteran status, gender, medical condition(s), age, and any disability you may have). We use this Personal Information to assess and manage your resident application and to communicate with you about the Communities and your application. If you become a resident at one of our Communities, we will also use this Personal Information to assess, manage, and provide resident care, engage in incident reporting, and to communicate with you.
- Resident screening. For certain Communities, we are required to conduct resident screening as required by housing authorities. To do so, we will collect your consumer records information (financial account information and your income). We use this Personal Information to conduct the required resident screening and to comply with applicable law.
- Assessment and care planning. In order to provide personalized resident care, we will collect customer records information (medical and health information), protected classifications (marital status and military or veteran status), educational information (educational history), as well as inferences drawn from your preferences and behaviors (food and activities) to create a profile about you. We use this Personal Information to assess, manage, and provide personalized resident care.
- Purchases. Our Communities permit residents to purchase personal care items. In doing so, we will collect personal identifiers (name) and customer records information (payment card number, expiration date, and CVV). We use this Personal Information to process your purchase and to provide you the requested product.
- Security. At our Communities, we will collect visual information (CCTV footage) and audio information (audio recordings) collected from our security cameras. We use this Personal Information to monitor the Communities and to ensure the security and safety of residents and staff.
IV. HOW WE SHARE YOUR INFORMATION
We share your Personal Information for the purposes set forth below:
Within Cascade. We share your Personal Information within the Cascade corporate family, including with subsidiaries or affiliates, for legitimate business purposes, to efficiently carry out our business, and to the extent permitted by law. We also share your Personal Information with Cascade management and staff as appropriate to facilitate resident care.
With health care providers. At your direction and with your consent, we will share your Personal Information with resident health care providers or insurance companies as required to facilitate your resident care at our Communities.
With service providers. We share Personal Information with service providers that assist us in providing the Services. These service providers include our payment processor, IT support, website hosting provider, communication provider, and marketing provider.
In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share Personal Information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would share Personal Information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
With third parties. We may need to disclose your Personal Information to third parties, such as emergency personnel, legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, and to comply with our legal obligations.
With Your Consent. Apart from the reasons identified above, we may request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.
Sharing in the Preceding Twelve (12) Months
For a business purpose. In the preceding twelve (12) months, Cascade has disclosed the following categories of Personal Information for a business with the following categories of third parties:
- We have disclosed your internet or other electronic network information to our data analytics providers and IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair Website errors.
- We have disclosed your personal identifiers, customer records information, and internet and other electronic network activity information to service providers that perform services on our behalf. These service providers include our payment processor, IT support, marketing provider, and communication provider.
For a sale. The use of certain analytics and advertising cookies on our Website may constitute a sale under the California Consumer Privacy Act. As such, in the preceding twelve (12) months, Cascade has sold your internet or other electronic network activity collected via cookies to data analytics providers and ad networks. You may opt-out of the use of these cookies by following the instructions
V. YOUR INFORMATION CHOICES
Correct or view your information. You can login to your Cascade account to correct or view certain information you have provided to us and which is associated with your account.
Online advertising. To opt-out of interest based advertising generally or to learn more about the use of this information by our service providers you can visit the Network Advertising Initiative or the Digital Advertising Alliance.
Facebook Pixel. You can opt-out of displaying Facebook ads by visiting your Facebook Ad Settings, and you can clear and control the information third parties share with Facebook in your Off-Facebook Activity page.
Google Analytics. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.
Crazy Egg. You can opt-out of Crazy Egg here.
Cookies. Cookies can be removed by following your web browser’s directions. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Website may not function properly if the ability to accept cookies is disabled. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, click here. If you choose to opt-out, we will place an “opt-out cookie” on your device. The “opt-out cookie” is browser and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for strictly necessary cookies that are required for our Website to function. If the cookie is removed or deleted, if you upgrade your browser, or if you visit us from a different device, you will need to return and update your preferences.
Marketing communications. You may opt-out of receiving marketing communications from us by clicking the “unsubscribe” link provided with each communication. Please note that Cascade will continue to send you notifications necessary to the Services and any assistance you request.
VI. CALIFORNIA RESIDENTS
The California Consumer Privacy Act (CCPA) grants certain rights to California residents. To the extent the CCPA applies to the processing of your personal information by Cascade, you are entitled to the following rights:
- Right to access. You have the right to request what Personal Information we have collected, used, disclosed, and sold about you within the preceding twelve (12) months. You may make a request for access twice within a twelve-month period.
- Right to deletion. You have the right to request the deletion of your Personal Information that we collect or maintain, subject to certain exceptions.
- Right to opt-out. You have the right to opt-out of the sale of your Personal Information to third parties. Cascade does not have actual knowledge that it sells Personal Information of minors under the age of sixteen (16) years.
- Right to non-discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.
To exercise your right to access or delete your Personal Information, you may submit a request by email to [email protected] or by telephone at 888-835-6997. To opt-out of the sale of your Personal Information, follow the instructions in YOUR INFORMATION CHOICES.
For requests submitted via telephone or email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the Personal Information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual
VII. NEVADA RESIDENTS
If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of certain of your Personal Information. We do not currently sell any of your Personal Information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales, as defined by Nevada law, by contacting us at [email protected].
VIII. DO NOT TRACK DISCLOSURE
We do not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. For further details, visit https://www.eff.org/issues/do-not-track.
We implement and maintain reasonable security measures to protect the Personal Information we collect and store from unauthorized access, loss, misuse, destruction, or modification. These security measures include access controls, encryption, and anti-virus and anti-malware monitoring. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of your Personal Information we have collected from you.
X. CHILDREN’S PRIVACY
The Services are not intended for individuals under the age of eighteen (18) years.