Privacy Policy 

Clover Care Memory Living

Sacramento, California 

Effective Date: [Insert Date]

Last Updated: [Insert Date]

Introduction

Clover Care Memory Living ("Clover Care," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website [www.clovercarememory.com], use our online services, enroll in our staff courses, participate in our family community, or interact with us via text message or other communications.

This Privacy Policy applies to all visitors, users, families, prospective residents, residents, staff members, and others who access or use our services.

Please read this Privacy Policy carefully. By using our website or services, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, do not use our services.

1. Information We Collect

We collect several types of information from and about users of our services:

A. Personal Information You Provide to Us

We collect information that you voluntarily provide when you:

• Request information about our memory care services
• Schedule a tour or consultation
• Submit a waitlist or deposit form
• Complete an application for residency
• Sign up for our email newsletter or download resources
• Enroll in staff training courses
• Join our online family community
• Contact us via phone, email, text, or contact forms
• Participate in surveys or provide feedback

This information may include:

• Contact Information: Name, email address, phone number, mailing address
• Relationship Information: Your relationship to a prospective or current resident
• Resident Information: Prospective or current resident's name, age, medical history, diagnosis, care needs, and other health information (Protected Health Information or "PHI" under HIPAA)
• Financial Information: Payment information, insurance details, deposit information
• Account Information: Username, password, and preferences for our online family community or staff portal
• Communication Preferences: How you prefer to be contacted (email, phone, text)
• User-Generated Content: Posts, comments, photos, or other content you share in our family community

B. Information Collected Automatically

When you visit our website or use our online services, we automatically collect certain information, including:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Information: Pages viewed, time spent on pages, links clicked, access times and dates
• Location Information: General geographic location based on IP address
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to collect information about your browsing behavior (see Section 8 below)

C. Information from Third Parties

We may receive information about you from third parties, including:

• Healthcare providers, physicians, and specialists (with proper authorization)
• Insurance companies or benefit providers
• Referral sources (geriatric care managers, hospitals, social workers)
• Family members or legal representatives of prospective or current residents
• Background check services (for staff applicants only)

2. How We Use Your Information

We use the information we collect for the following purposes:

A. To Provide Our Services

• Process tour requests, applications, and admissions
• Coordinate care for residents, including medical, dietary, and activity planning
• Communicate with families about their loved one's care and wellbeing
• Provide access to our online family community platform
• Deliver staff training courses and continuing education
• Process payments and manage billing
• Respond to your inquiries and provide customer support

B. To Improve Our Services

• Analyze usage patterns to improve our website and online platforms
• Develop new services, features, and educational content
• Conduct research and analysis to enhance care quality
• Gather feedback through surveys and evaluations

C. To Communicate With You

• Send administrative information (appointment confirmations, policy updates, service changes)
• Provide care updates and family communications
• Send marketing communications about our services (with your consent)
• Deliver newsletters, resources, and educational content
• Send text messages for appointment reminders, updates, or urgent communications (with your consent)

D. For Legal and Safety Purposes

• Comply with legal obligations, including HIPAA and California privacy laws
• Protect the rights, property, and safety of Clover Care, our residents, families, and staff
• Prevent fraud, security breaches, or illegal activities
• Respond to legal requests from law enforcement or regulatory agencies
• Enforce our Terms of Service and other agreements

E. With Your Consent

• For any other purpose disclosed to you at the time we collect your information
• As otherwise permitted or required by applicable law

3. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

We may share your information in the following circumstances:

A. Service Providers

We share information with trusted third-party service providers who perform services on our behalf, including:

• Website hosting and maintenance providers
• Payment processors (Stripe, PayPal, etc.)
• Email service providers (for newsletters and communications)
• SMS/text messaging platforms
• Learning management system providers (for staff courses)
• Online community platform providers
• Customer relationship management (CRM) systems
• Analytics providers

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

B. Healthcare Providers and Care Coordination

With proper authorization, we share resident health information (PHI) with:

• Physicians, specialists, and other healthcare providers
• Pharmacies and medical equipment suppliers
• Hospice and palliative care agencies
• Hospitals and emergency services
• Health insurance companies for billing and coverage verification

C. Legal Requirements and Protection

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with legal processes (subpoenas, court orders, regulatory requests)
• Enforce our Terms of Service or other agreements
• Protect the rights, property, and safety of Clover Care, residents, families, or staff
• Investigate fraud, security issues, or illegal activities
• Respond to emergency situations involving health or safety

D. Business Transfers

If Clover Care is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change and how it affects your information.

E. With Your Consent

We may share your information with third parties when you provide explicit consent or direct us to do so.

F. Aggregated or De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, marketing, or other purposes.

4. Your Privacy Rights

Depending on your location and applicable law, you may have the following rights regarding your personal information:

A. California Residents (CCPA/CPRA Rights)

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have the right to:

Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, our purposes for collecting it, and the categories of third parties with whom we share it.

Right to Delete: Request deletion of your personal information, subject to certain exceptions.

Right to Correct: Request correction of inaccurate personal information.

Right to Opt-Out of Sale/Sharing: We do not sell personal information. If this changes, we will update this policy and provide an opt-out mechanism.

Right to Limit Use of Sensitive Personal Information: Request limits on our use of sensitive personal information (health data, precise geolocation, etc.).

Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

To exercise these rights, contact us at:

• Email: [email protected]
• Phone: 916-886-0154
• Mail: Clover Care Memory Living, Attn: Privacy Officer, [Address], Sacramento, CA [ZIP]

We will verify your identity before processing your request. You may designate an authorized agent to make a request on your behalf.

B. HIPAA Rights (Protected Health Information)

If you are a resident or family member of a resident, you have rights under the Health Insurance Portability and Accountability Act (HIPAA) regarding Protected Health Information (PHI):

Right to Access: Request copies of your (or your loved one's) medical records and health information.

Right to Amend: Request corrections to inaccurate or incomplete health information.

Right to an Accounting: Request a list of certain disclosures of health information we have made.

Right to Request Restrictions: Request limits on how we use or disclose health information (though we are not always required to agree).

Right to Confidential Communications: Request that we communicate with you by alternative means or at alternative locations.

Right to a Paper Copy of This Notice: Request a paper copy of our HIPAA Notice of Privacy Practices.

For more information about your HIPAA rights, please see our separate HIPAA Notice of Privacy Practices provided upon admission or available at [link].

C. General Rights (All Users)

Access and Portability: Request a copy of the personal information we hold about you in a portable format.

Correction: Request that we correct inaccurate information.

Deletion: Request deletion of your information, subject to legal and operational requirements.

Opt-Out of Marketing: Unsubscribe from marketing emails by clicking the "unsubscribe" link in any email or contacting us directly.

Opt-Out of Text Messages: Reply STOP to any marketing text message, or contact us to be removed from SMS lists.

5. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your information from unauthorized access, use, disclosure, alteration, or destruction.

Our security measures include:

• Encryption of data in transit (SSL/TLS) and at rest
• Secure password policies and multi-factor authentication for staff and user accounts
• Regular security audits and vulnerability assessments
• Limited access to personal information on a need-to-know basis
• Employee training on privacy and security practices
• Secure disposal of physical and electronic records containing personal information

However, please note: No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

You are responsible for: Maintaining the confidentiality of your account login credentials and notifying us immediately of any unauthorized access to your account.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary based on the type of information:

• Prospective resident inquiries: Retained for up to 2 years after last contact, or until you request deletion
• Current resident records: Retained during residency and for at least 7 years after discharge (or longer as required by California law and HIPAA)
• Staff training records: Retained for the duration of employment and 7 years thereafter
• Marketing and communication records: Retained until you opt-out or request deletion
• Website usage data: Typically retained for 12-24 months

When information is no longer needed, we securely delete or anonymize it in accordance with our data retention and destruction policies.

7. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will delete that information promptly.

If you believe we have collected information from a child under 18, please contact us at [email protected].

8. Cookies and Tracking Technologies

A. What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They help websites remember your preferences and improve your experience.

B. How We Use Cookies

We use cookies and similar tracking technologies to:

• Remember your preferences and settings
• Authenticate your login to our family community or staff portal
• Analyze website traffic and usage patterns
• Deliver relevant content and advertising
• Improve website functionality and user experience

C. Types of Cookies We Use

Essential Cookies: Necessary for the website to function properly (e.g., security, authentication).

Analytics Cookies: Help us understand how visitors use our website (e.g., Google Analytics).

Functional Cookies: Remember your preferences and personalize your experience.

Marketing Cookies: Track your browsing activity to deliver targeted advertising (only with your consent).

D. Third-Party Cookies

We may use third-party services that place cookies on your device, including:

• Google Analytics (website analytics)
• Facebook Pixel (advertising and analytics)
• Kajabi (learning management system and community platform)

These third parties have their own privacy policies governing their use of your information.

E. Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to:

• View and delete cookies
• Block third-party cookies
• Block all cookies (though this may affect website functionality)

To learn more about managing cookies, visit: www.aboutcookies.org

Note: If you disable cookies, some features of our website may not function properly.

F. Do Not Track Signals

Some browsers offer a "Do Not Track" (DNT) signal. Our website does not currently respond to DNT signals, as there is no industry standard for how to respond. We will update this policy if we adopt DNT practices in the future.

9. Text Messaging and SMS Communications

A. Consent to Receive Text Messages

By providing your mobile phone number and opting in to receive text messages from Clover Care, you consent to receive:

• Appointment reminders and confirmations
• Care updates and important notifications
• Marketing messages about our services (if you opt in)
• Alerts and emergency communications

Message frequency varies. You may receive up to [estimated number] messages per month, depending on the services you use.

B. Standard Messaging Rates Apply

Standard message and data rates from your wireless carrier may apply. Please contact your carrier for details about your messaging plan.

C. Opt-Out of Text Messages

You can opt out of text messages at any time by:

• Replying STOP to any text message from Clover Care
• Contacting us at [phone] or [email]

You will receive a confirmation text message confirming your opt-out. After opting out, you will no longer receive text messages from us, except as required by law (e.g., transactional or service-related messages).

D. Help and Support

For help or support with text messaging, reply HELP to any text message or contact us at 916-886-0154 or [email protected].

10. Online Family Community and Staff Portal

A. Community Guidelines

Our online family community and staff portal are designed to provide support, education, and connection. By participating, you agree to:

• Use the community respectfully and professionally
• Protect the privacy and confidentiality of other members
• Not share Protected Health Information (PHI) about residents without proper authorization
• Not post offensive, defamatory, or inappropriate content
• Comply with our Community Guidelines and Terms of Service

We reserve the right to monitor, moderate, and remove content or suspend accounts that violate these guidelines.

B. Content You Post

By posting content (text, photos, videos, comments) in our online community, you grant Clover Care a non-exclusive, royalty-free license to use, reproduce, modify, and display that content for the purposes of operating and promoting our community.
You retain ownership of your content and may delete it at any time. However, we may retain copies as required by law or for backup purposes.

C. Privacy Settings

You can control your privacy settings within the community platform, including:

• Who can view your profile
• Who can see your posts and comments
• Email notification preferences

We encourage you to review and adjust your privacy settings regularly.

11. Third-Party Links and Services

Our website may contain links to third-party websites, services, or applications (e.g., social media platforms, external resources, partner organizations).
We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.
Linking to a third-party site does not imply our endorsement of that site or its services.

12. California Shine the Light Law

California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes.

We do not share personal information with third parties for their direct marketing purposes without your explicit consent. If you have questions about this, contact us at [email protected].

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

When we make changes:

• We will update the "Last Updated" date at the top of this policy
• For material changes, we will notify you by email or by posting a prominent notice on our website
• Your continued use of our services after changes are posted constitutes your acceptance of the updated policy

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Clover Care Memory Living
Attn: Privacy Officer
[Address]
Sacramento, CA [ZIP Code]

Phone: 916-886-0154
Email: [email protected]
Website: www.clovercarememory.com

For HIPAA-related inquiries or to exercise your HIPAA rights, contact:
HIPAA Privacy Officer
[Same contact information]

For California privacy rights requests (CCPA/CPRA):
Email: [email protected]
Subject Line: "California Privacy Rights Request"

We will respond to your inquiry within 30 days (or 45 days for complex requests, with notice of the extension).

15. Definitions

Personal Information: Information that identifies, relates to, describes, or could reasonably be linked to you or your household.

Protected Health Information (PHI): Health information protected under HIPAA, including medical history, diagnoses, treatment plans, and other health-related data.

Sensitive Personal Information: Specific categories of personal information subject to additional protections under California law, including Social Security numbers, health data, precise geolocation, and financial account information.

Service Providers: Third-party companies or individuals that process information on our behalf under contract.

Cookies: Small text files stored on your device by websites to remember preferences and track activity.

Acknowledgment:

By using our website or services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.