Last updated: April 3, 2020
In order to better provide you with services, we may collect, process and store personal information about you.
Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device or household (“Personal Information”). It does not include de-identified or aggregate information, or public information lawfully available from governmental records. When you engage in certain activities on the Site, such as registering for an account or requesting services, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities; however, we may ask that you provide us personal information. Depending upon the activity, some of the information we ask you to provide are in mandatory fields and some are in voluntary fields. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. In addition from obtaining personal information directly from you, we may also obtain information: from your employer; from an agent/third party acting on your behalf, such as a distributor, one of our affiliated operating companies, a lead referral service, or a data provider who collected information from you directly or indirectly; through publicly available sources; or, where we have cameras on our premises capturing individuals’ images and movements, from the use of our CCTV cameras.
The following list describes the categories of Personal Information we may have collected about you in the past 12 months:
We may collect this information directly from you, from your employer, from an agent or third party acting on your behalf, from publicly available sources, from third party data brokers, or from the use of our CCTV cameras for certain premises where they are installed for security purposes.
We may share information with:
We provide some of our services through contractual arrangements with affiliates, services providers, partners, and other third parties. We and our service partners may use your Personal Information to operate our sites and to deliver our services. Third parties with whom we share your Personal Information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.
Occasionally, we may be required to share your Personal Information with third parties for legitimate business purposes, or to comply with legal obligations. For example, we may share Personal Information when we believe in good faith that an applicable law requires it; at the request of law enforcement, judicial authorities (i.e. upon receipt of a court order or subpoena), appropriate governmental authorities; 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 third parties, visitors to our Sites, our businesses, or the public. Additional disclosures of your Personal Information to third parties for legitimate business purposes or to comply with legal obligations may include us sharing:
Our products and services are not directed to minors under the age of 16 and we do not knowingly collect or sell the Personal Information of minors.
We believe you should have the ability to access and, where appropriate, edit the Personal Information that you have provided to us. You may change any of your Personal Information in your account online. You may also access and correct your personal information and privacy preferences by writing us at:
Welltower Inc. 4500 Dorr Street Toledo, Ohio 43615-4040 Attn: Website Administrator
Please include your name, address, and/or e-mail address when you contact us. We encourage you to promptly update your Personal Information if it changes.
We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards.
Access by you to your Personal Information may be available through a password and unique customer ID selected by you. We recommend that you do not divulge your password to anyone. In addition, your Personal Information resides on a secure server that only selected personnel and contractors have access to via password. Personal information that you provide that is not Personal Information also resides on a secure server and is only accessible via password. Since this information is not accessible from the outside, you will not be asked to select a password in order to view or modify such information.
While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security. As a result, while we strive to protect your Personal Information, you acknowledge that (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
When you use the Site we may store “cookies” on your computer in order to facilitate and customize your use of the Site. A “cookie” is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. The cookies make your use of the Site easier, make the Site run more smoothly, and help us to maintain a secure Site. You are always free to decline our cookies if your browser permits, but some parts of the Site may not work properly if you do so.
We do not respond to browser or do-not-track signals.
Residents of certain states may have the following additional privacy rights.
Right to request disclosure of information we collect and share about you
We are committed to ensuring that you know what information we collect about you. Subject to certain exceptions, you can submit a request to us for the following information, with respect to Personal Information we have collected about you in the last 12 months:
Subject to certain exceptions, you also may have the right to request the deletion of Personal Information we have collected from you.
Upon your request, we will delete the Personal Information we have collected about you, except for situations where specific information is necessary for us to: provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
California Shine the Light. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year.
For requests for access or deletion, we will first acknowledge receipt of your request within 10 days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfil, we’ll let you know. We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
If you maintain a password-protected account with us, we will verify your identity using a two-step process. We will first ask you to log into your account, and we will then ask you to separately authenticate your identity by asking you a series of questions. If we are unable to verify your identity through your password-protected account with a reasonable degree of certainty appropriate to the nature of your request, for security reasons, we may ask you to verify your identity in accordance with the additional requirements described below.
If you do not have an account with us and are requesting to delete or have access to specific pieces of Personal Information, we may need to ask you several questions to verify your identity by matching your answers to information we maintain about you. Additionally, depending on the nature of your request, we may require that you provide a declaration attesting to your identity, signed under penalty of perjury. If we are unable to verify your identity with a degree of certainty required, we will not be able to fulfil to the request. We will notify you to explain the basis of the denial. Additionally, we will treat the request as one seeking disclosure of the categories of Personal Information we have collected about you and endeavor to verify your identity using the less-stringent standards applicable to such requests.
Authorized Agents – Additional Verification Required. You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process to verify your identity and provide us with proof of the agency relationship.
Household Requests — There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above. If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.
If you have questions on the processing of your Personal Information, would like to exercise any of your rights, or have a complaint, please contact us here: firstname.lastname@example.org or call us toll free at 877-670-0070, or write us at:
4500 Dorr Street
Toledo, Ohio 43615-4040
Attn: Website Administrator
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 at 877-670-0070 or contact email@example.com.
The information contained on the Site is subject to change without notice. If we make a significant or material change in the way we use or share your Personal Information, you will be notified via email or a notice on the Site.
Last modified: April 3, 2020