Soter Senior Living & Family Advocates

SOTER, LLC SENIOR LIVING & FAMILY ADVOCATES

privacy policy

Soter, LLC will assist you in finding senior living care services, after you, or a person authorized on your behalf, have read and understood our Privacy Policy and have consented to its terms and conditions. Soter will not sell your name, email address or other information, except to third parties which may provide or offer the services you've requested from us or as otherwise described below under Disclosure of Personal Information. This privacy policy explains the collection, use, and disclosure practices of this web site owned and/or operated by Soter, LLC. We may update this statement occasionally. We would ask that you check the date of our privacy policy whenever you visit the Site to see whether it has been modified since your last access of said Site.

I - PersONAL INFORMATION

A. COLLECTING - Our Senior Living Advisors may ask you to provide personal information such as your name, address, email, phone number and zip code, and other personal information, and may or may not include any other information provided by or for you, and/or provided by any other person authorized to act on your behalf ("Personal Information"). We may collect and store any personal information, including information gathered over the phone. In the event of valid demands or requests from courts, governments and law enforcement, we might be required to disclose certain information. To reiterate, for services provided on or in connection with our Site, we may ask you to provide personal information such as name, address, email, phone number and zip code, and may or may not include other information provided by or for you, and/or provided by any other person for whom you may be seeking services ("Personal Information"). In addition thereto, we may use Web site analytics or other technologies, to collect information about your visit to the Site, including the pages you view, the links you click and other actions taken in connection with the Site and our services. Periodically, we may obtain both personal and non-personal information about you from other businesses, business partners, contractors and other third parties which supplements the other Personal Information we collect, use and disclose, and may collect certain standard information that your browser sends to the Web sites you visit, including Web site addresses, access times, browser type and language, and referring Web site addresses.

B. USE - By using our site, and accessing the “pricing” information, you consent to the collection, use and disclosure of your Personal Information in accordance with the terms and conditions of this Privacy Policy. Such Personal Information is used to provide you with the services you have requested from us

and to provide services to the senior housing and care providers who have contracted with us ("Participating Communities") to be part of our referral information service program in relation to the services that we provide you. In addition, we may use Personal Information to send you periodic email, surveys, and similar communications about products and services offered by us or third parties, to respond to customer inquiries, and to operate and improve our Sites and services. On occasion, we may also use Personal Information for our own internal business purposes including statistical, design or operational purposes, such as to estimate our audience size, understand demographics, and measure patterns.

II. DISCLOSURE

Soter, LLC may disclose or share Personal Information about you with other people including:

A. HIPPA and Participating Communities. Under the Partnership Agreement, each Participating Community is bound by HIPPA Laws, and has also agreed to implement privacy and security practices and procedures comparable to, or at least as stringent as, those implemented by us and not to disclose Personal Information to any third party. We may disclose Personal Information to one or more Participating Communities so that they may learn about the specific senior living care services that you are seeking and determine how they can assist you. Participating Communities may contact you directly by email, telephone, regular mail, in person visits or other means, based on your preference and as specified by you to the Senior Living Advisor during the initial collection of your Personal Information. We do not control how these Participating Communities use or disclose your Personal Information. However, per our Agreement with each Participating Community, such Community has agreed to limit its use of your Personal Information to (a) providing senior living and/or care services to such residents; and (b) its own internal evaluation of potential residents.

B. Internal Operations and Analysis. We may disclose Personal Information for our own internal statistical, design or operational purposes, such as to estimate our audience size, measure aggregate patterns, and understand demographic trends among our users. We may outsource these tasks and disclose Personal Information about you to third parties.

C. Legal Compliance. We may disclose Personal Information when we believe it is appropriate to comply with the law; to enforce or apply this Privacy Policy or our other policies or agreements; to protect our or our users' rights, property or safety; to protect our users from fraudulent, abusive or unlawful use of, our Sites; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

D. Third Party Providers. We may disclose or share Personal Information to one or more third parties with whom we have contracted to provide services to us. We may also disclose Personal Information to one or more third parties who are interested in providing services or products to you. We do not control how these third parties use or disclose your Personal Information.

E. Aggregated Information and Business Transfers. We may share aggregated, anonymous information that includes or is based on information about you with third parties. This is information that is combined with the information of other users and does not directly identify you. Depending on the circumstances, we may or may not charge third parties for this aggregated information. In addition, we also may not be able to limit the third parties’ use of the aggregated information. We may disclose Personal Information as part of any merger, acquisition, debt financing, sale of company assets or other business transaction.

III. NON-PERSONAL INFORMATION

If aggregate information is ever linked with your Personal Information, such information will be treated as Personal Information for the purposes of this Privacy Policy as long as it is linked. Please note that non-personal information collected at the Site may be used and disclosed to improve the performance, functionality and content of the Site. For example, we may collect and analyze collected aggregate information to determine how many visitors arrived at certain pages of the Site, how long they stayed on those pages, and where they went afterwards. This information allows us to determine which pages might be the most interesting to our users and enables us to provide you with a richer experience on the Site. Additionally, we may use non-personal information to improve the performance of the Site and to customize the content, features and layout of the Site pages for you. Occasionally we share aggregate information with third parties, such as our advertisers and business partners, for marketing and promotional purposes. We may supplement aggregate information collected from the Site with similar information obtained from companies with whom we have marketing or other business relationships and other third party sources.

IV. THIRD PARTIES

As herein set forth, please note that we may provide links to third party Web site from our Site as a service to our users, but we have no ability to control, and are not responsible for, the privacy and data collection, use, and disclosure practices of such sites and the privacy policies of such Web sites may differ from the Site. Therefore, we encourage you to review and understand the privacy policies of such Web sites before providing them with any information. These other Web sites may also solicit your personal information, send their own cookies to you, and collect your data. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. Always be aware of where you end up. In Internet Explorer 8, you can delete cookies by selecting "Tools", "Delete browsing history". Then select the control box "Cookies" and click the "Delete" button. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.

V. SECURITY

We use reasonable security measures to store and maintain Personal Information to protect it from loss, misuse, alteration or destruction by any unauthorized party while under our control. Please note that while we make reasonable efforts to protect Personal Information, no transmission of data over the Internet is 100% secure. All Internet users should take care with how they handle and disclose personal information. Refer to the Federal Trade Commission website: http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to help protect yourself against identity theft.

VI. ADVERTISING COMPANIES

Third party advertisers or ad networks may use cookies or other technologies on our Site for various purposes, including measuring the effectiveness of their ads and analyzing and personalizing ads or other content delivered to you. We have no ability to control the privacy and data collection, use, and disclosure practices of such Web sites and the privacy policies of such Web sites may differ from the Site. Therefore, we encourage you to review and understand the privacy policies of such Web sites before providing them with any information.

VII. PRIVACY RIGHTS

Companies that collect personally identifiable information from California residents and disclose such information to third parties for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having their information shared with third parties. We have elected the second option and you may request that your personally identifiable information not be shared with third parties by sending your request, including your full name, email address and postal address to: Soter Senior Living and Family Advocates, 2197 Julian Avenue-N.E., Palm Bay, FL 32905.

viii. Automatic dialing/DO NOT TRACK DISCLOSURES

You agree to be contacted by a Senior Living Advisor and by our senior living partners and other partners to explore options at the telephone number you have provided. You agree we, our senior living partners and other partners may use automatic telephone dialing systems and technology to contact you by call or text message at the telephone number provided, even if you previously registered on a Do Not Call registry. No action is taken in response to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. Although we use Google Analytics and other third party tracking tools for our Sites, we are not aware if third parties collect personally identifiable information about an individual consumer’s online activities when a consumer uses our Sites.

iX. improving site and services

In addition, we may use Web site analytics tools, or other technologies, like cookies and Web beacons, to collect information about your visit to the Site, including the pages you view, the links you click and other actions taken in connection with the Site and our services. We also may collect certain standard information that your browser sends to every Web site you visit, such as your IP address, browser type and language, access times and referring Web site addresses. We also periodically may obtain both personal and non-personal information about you from other businesses, business partners, contractors and other third parties which supplements the Personal Information we collect, use and disclose. Please be advised that the practices described in this Privacy Policy apply to Personal Information gathered over the telephone by our Senior Living Advisors, online at our Site, and/or Personal Information that you may submit to us offline during the course of our dealings with you, Web site maintained by other companies, or organizations to which we may link, and to Personal Information we may collect further from third parties.

X. GENERAL PROVISIONs and consent

A. Services. We use Personal Information to provide you with the services you have requested from us and to provide services to the senior living and care providers who have contracted with us ("Participating Communities") by signing our Partnership Agreement for Information Services (Partnership Agreement") and agreeing to be part of our referral information service program in relation to the services that we provide you. Based on the Personal Information that we have collected, we will provide you with the information about one or more of our Participating Communities whom we identify as options for your consideration. The Participating Communities then may contact you directly regarding their facilities or services. We will work with both you and the Participating Communities in your search. We may share Personal Information with one or more third parties with whom we have contracted to provide services to us. Our contracts with these parties specify the purpose(s) for which Personal Information has been shared with them and the limited purpose(s) for which the Personal Information may be used by them. Our contracts with these parties also require that they implement privacy and security practices and procedures comparable to, or at least as stringent as those implemented by us, that they do not disclose Personal Information to any other third party, and that they comply with all applicable laws, including privacy laws.

B. Links. Please be advised that we may provide links to third party Web sites from our Site as a service to our users, but we have no ability to control, and are not responsible for, the privacy and data collection, use, and disclosure practices of such sites and the privacy policies of such Web sites may differ from the Site. Therefore, we encourage you to review and understand the privacy policies of such Web sites before providing them with any information. These other Web sites also may send their own cookies to you, collect your data or solicit your Personal Information. Always be aware of where you end up.

C. Questions and Concerns. If you have any questions or concerns about this Privacy Policy or the privacy practices of our Site, please contact us at [email protected] or call us at 321-419-0041.

D. Governing Law. The Site is published in the United States. We attempt to comply with local data protection, privacy and consumer rights laws to the extent they may apply to our services. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your Personal Information to the Site.

E. Changes in Privacy Policy. As we continue to develop our Site, we may add new services and features to our Site. In the event that these additions affect our Privacy Policy, this Privacy Policy will be updated appropriately, and we encourage you to check the date of our Privacy Policy whenever you visit the Site to determine if it has been modified since your last visit. We will post changes prominently so that you will know what Personal Information we gather, how we might use that Personal Information, and whether we will disclose it to anyone. We, however, recommend that you read this Privacy Policy each time you use our Site in case you missed our notice of changes to the Privacy Policy. We will not materially change our policies and practices to make them less protective of Personal Information we have previously collected without your express consent.

F. Access to Your Personal Information. Upon written request, you may access your Personal Information that is in our possession and request a correction or update of any such information.

G. Opt-Out of Soter, LLC Communications. We may periodically send you newsletters and other communications that promote the use of our services. When you receive our newsletters, you may indicate a preference to stop receiving further newsletters by following the opt-out instructions that we include in the newsletter we send you. However, if you wish to opt-out of communications with Participating Communities, you must contact them directly as we do not control communications from Participating Communities.

XI. ACKNOWLEDGEMENT, AUTHORIZATION & CONSENT

You hereby confirm that you have read and understood this Privacy Policy and by using our site, and accessing the “pricing” information, you consent to the collection, use and disclosure of your Personal Information in accordance with the terms and conditions of this Privacy Policy. You hereby further confirm that you are: a senior seeking living and care services for yourself; or an individual authorized to act on behalf of a senior seeking living and care services and possess legal documents such as a Power of Attorney or Guardianship or hold other proof of being the substitute decision maker of the senior seeking living and care services.

(Effective Date: April, 2018)