VILLAS OF HOLLY BROOK

PRIVACY POLICY

Villas of Holly Brook Senior Living, LLC and its affiliated communities, collectively referred to as “Villas of Holly Brook,” “Villas,” “we,” “us,” or “our,” respect your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information obtained through our website, our online forms, and other interactions covered by this policy.

This Privacy Policy applies to website visitors, prospective residents, family members, representatives, job applicants, vendors, and others who communicate with Villas. It does not replace any Notice of Privacy Practices that may apply to protected health information maintained by a Villas community subject to the Health Insurance Portability and Accountability Act, commonly known as HIPAA.

1. INFORMATION WE COLLECT

We may collect personal information that you provide directly to us, including:

• Name, email address, telephone number, and mailing address
• The Villas community or geographic area in which you are interested
• Information submitted when requesting information, contacting an advisor, or scheduling a tour
• Information about assisted living, memory care, respite care, or other services in which you or a family member may be interested
• Information concerning a prospective resident’s preferences, living situation, health, diagnosis, mobility, memory, or care needs when voluntarily provided
• Communications sent to Villas through website forms, email, telephone, social media, or other channels
• Employment application information, including employment history, education, qualifications, professional licenses, references, and other information provided during the application process
• Vendor or business contact information
• Information submitted when registering for events, subscribing to communications, or responding to surveys

Please do not submit Social Security numbers, financial account information, complete medical records, or other highly sensitive information through a general website contact form or ordinary email.

2. INFORMATION COLLECTED AUTOMATICALLY

When you use our website, we and our service providers may automatically collect certain technical information, including:

• Internet Protocol address
• Browser and device type
• Operating system
• General geographic location derived from an Internet Protocol address
• Pages viewed and links selected
• Date, time, and duration of website visits
• Referring website or source
• Interactions with website forms and features
• Cookie identifiers and similar technical information

We may collect this information through cookies, pixels, web beacons, analytics tools, and similar technologies. The technologies used may depend on the cookie preferences you select.

3. COOKIES AND SIMILAR TECHNOLOGIES

We use necessary cookies to operate and secure our website, support navigation, operate forms, and remember your privacy preferences. Necessary cookies cannot be disabled through our cookie preference system.

With your consent, we may also use functional, analytics, or advertising cookies to remember preferences, understand how visitors use our website, improve website performance, and measure the effectiveness of communications or advertising.

You may accept all optional cookies, reject all optional cookies, or manage your preferences by category. You may change your selection at any time through the Cookie Preferences link located in the website footer.

Disabling optional cookies may affect certain website features. Additional information about the cookies currently used on our website is available through the Cookie Preferences tool.

4. HOW WE USE PERSONAL INFORMATION

We may use personal information to:

• Respond to questions and requests
• Communicate with prospective residents, family members, and representatives
• Provide information about communities, services, availability, pricing, and care options
• Schedule tours, meetings, or follow-up communications
• Assist individuals and families in evaluating senior-living options
• Process employment applications and communicate with applicants
• Manage vendor and business relationships
• Operate, maintain, secure, and improve our website
• Understand how visitors use our website
• Measure the effectiveness of our communications and advertising
• Detect and prevent fraud, misuse, security incidents, and technical problems
• Maintain appropriate business and communication records
• Comply with applicable laws, regulations, legal proceedings, and governmental requests
• Protect the rights, safety, property, and interests of Villas, our residents, employees, and others
• Complete a merger, acquisition, financing, sale, restructuring, or other business transaction

5. HEALTH AND CARE-RELATED INFORMATION

A prospective resident or family member may voluntarily provide information about health conditions, memory loss, mobility, medications, diagnoses, or care needs when asking about Villas services.

We use this information to respond to the inquiry, identify potentially appropriate services, and help the individual or family evaluate available senior-living options.

Submitting information through our website does not establish a resident-provider relationship and should not be used to seek emergency assistance or medical advice. If you are experiencing a medical emergency, call 911 or contact an appropriate healthcare provider.

Some Villas communities or operations may be subject to HIPAA for certain activities. When HIPAA applies, protected health information is handled according to the applicable Notice of Privacy Practices and not solely under this website Privacy Policy.

6. EMPLOYMENT INFORMATION

When you apply for employment, Villas or an employment-platform provider may collect information necessary to evaluate your qualifications, communicate with you, conduct legally permitted screenings, and administer the hiring process.

An employment platform linked from our website may maintain its own privacy policy and terms. We encourage applicants to review those terms before submitting information.

7. HOW WE DISCLOSE INFORMATION

We may disclose personal information to:

• Villas communities, affiliates, employees, and representatives who need the information to perform their responsibilities
• Website-hosting, information-technology, cybersecurity, email, telephone, and communications providers
• Customer relationship management and inquiry-management providers
• Employment, applicant-tracking, background-screening, and human-resources providers
• Analytics, marketing, and advertising providers, subject to applicable law and your cookie preferences
• Attorneys, accountants, insurers, consultants, and other professional advisers
• Government agencies, regulators, law enforcement, courts, and other parties when disclosure is legally required or reasonably necessary to protect safety or legal rights
• A purchaser, lender, investor, successor, or adviser involved in a potential or completed business transaction

We do not disclose personal information to third parties for their independent purposes except as described in this policy, as authorized by you, or as permitted or required by law.

Certain analytics or advertising activities may be treated as a “sale,” “sharing,” or use for targeted advertising under some state privacy laws, even when Villas does not receive money in exchange for the information. Where required, eligible individuals may opt out through our Cookie Preferences or privacy-request process.

8. THIRD-PARTY LINKS AND SERVICES

Our website may contain links to employment platforms, social media websites, maps, videos, payment services, or other websites operated by third parties.

Villas does not control the privacy or security practices of those third parties. Information submitted directly to a third-party website is governed by that party’s privacy policy and terms.

Our website may use services such as embedded maps, videos, social media features, or website-security tools. These services may collect technical information when they are loaded or used.

9. DATA SECURITY

Villas uses reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, loss, misuse, alteration, or disclosure.

No website, electronic communication, or information system can be guaranteed to be completely secure. Visitors should not send highly sensitive or confidential information through ordinary email or general website contact forms.

10. RETENTION OF INFORMATION

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this policy, maintain appropriate business records, resolve disputes, enforce agreements, and satisfy legal, regulatory, insurance, and operational requirements.

Retention periods may vary depending on the type of information, the purpose for which it was collected, and applicable legal requirements.

11. YOUR PRIVACY CHOICES

You may:

• Change your optional cookie selections through the Cookie Preferences link
• Unsubscribe from promotional emails by following the unsubscribe instructions included in those emails
• Ask Villas to stop certain marketing communications
• Request information about our privacy practices

Depending on where you live and whether applicable legal requirements are met, you may also have the right to request access to, correction of, or deletion of certain personal information, obtain a copy of certain information, or opt out of certain targeted advertising, sales, or sharing.

Villas may need to verify your identity before completing a privacy request. We may deny or limit a request when permitted by law, including when information must be retained for legal, safety, employment, resident-care, or recordkeeping purposes.

Villas will not unlawfully discriminate against an individual for exercising an applicable privacy right.

12. CHILDREN’S PRIVACY

Our website is intended for a general adult audience and is not directed to children under 13. We do not knowingly collect personal information directly from children under 13 through the website.

If we learn that a child under 13 has submitted personal information without appropriate authorization, we will take reasonable steps to delete it.

13. EMAILS, TELEPHONE CALLS, AND TEXT MESSAGES

If you provide contact information, Villas may use it to respond to your inquiry and communicate with you about communities, services, tours, employment, or other matters relevant to your request.

Consent to receive marketing communications is not a condition of purchasing services. You may ask us to discontinue promotional communications at any time. Operational, transactional, or legally required communications may continue when appropriate.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our services, technology, business practices, or legal obligations.

When we make changes, we will revise the effective date displayed at the beginning of the policy. Material changes may also be communicated through an additional website notice when appropriate.

15. CONTACT US

Questions, concerns, and privacy requests may be submitted to:

Villas of Holly Brook Senior Living, LLC
Email: inquiry@villasofhollybrook.com
Telephone: 217-686-4321
Website: www.villasofhollybrook.com

Please include “Privacy Request” in the subject line of an email. Do not include Social Security numbers, financial account information, medical records, or other highly sensitive information in an initial privacy request.