Effective date: January 1, 2023
Last updated: October 16, 2023
At Oasis Senior Advisors (“we, us, “OSA”), we respect your privacy and are committed to protecting it.
This Policy covers information we collect about you when you give it to us, visit our website (https://oasissenioradvisors.com) or visit any of our physical locations. It also covers information that we may receive from other persons or companies who have received your information and can share it with us.
If in any case our privacy practices differ from those explained in this Policy, we will let you know at the time we ask for or collect your information.
- What information we collect about you
- Children’s online privacy
- How we collect your information
- Cookies and automatic data collection technologies
- How we use your information
- Disclosure of your information
- Third party content, apps, and links
- Your rights and choices
- Data security
- California privacy rights
- Nevada privacy rights
- Washington privacy rights
- Contact us
What information we collect about you
We may collect the following types of information about you, which we have grouped together as follows:
- Identity Information. Examples include first name, last name, marital status, title, date of birth and gender.
- Contact Information. Examples include, physical address, email address and telephone numbers.
- Financial Information. Examples include insurance information or any payment information you provide to us.
- Technical Information. Examples include internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Geolocation Information. Examples include your imprecise geolocation identified via your zip code.
- Profile Information. Examples include your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Information. Examples include information about how you use our website, products, and services.
- Marketing and Communications Information. Examples include your preferences in receiving marketing materials (i.e., the Life Booklet) from us and our third parties and your communication preferences.
- User Content. Examples include photos, reviews, and other feedback that you provide to us on or through our social media pages or websites about our products, locations, and services. If you choose to provide User Content, it may be made available on public areas of our website or on or through our social media channels.
Some of the information we collect about you may be personal information, or personal data, that can be used to identify you including, for example, your name, email address, mailing address or delivery address. In some jurisdictions, certain unique identifiers like IP addresses and other usage or technical information may be considered personal information. Personal information does not include data where your identity has been removed so that we can no longer identify you (anonymous data), which we may use for any purpose.
Children’s online privacy
Our Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org or 1-888-455-5838.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the California Privacy Rights for more information.
How we collect your information
We collect information from and about you in the following ways:
- When you provide it to us. You may give us information about you by filling in forms or by communicating with us by email or otherwise. This includes information you provide when you complete the “Contact Us” form, register for an account, subscribe to one of our other communications, participate in one of our events, write a review, or when you otherwise contact us about our website, or services.
- From our websites and emails. As you interact with our website using our cookies, or our emails, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, web beacons, and other similar technologies. Our Cookies and automatic data collection technologies section contains more information and options to control or opt-out of certain data collection or uses.
- From others. We may receive information about you from third parties including, for example, our affiliated companies, business partners, subcontractors, analytics providers, service providers, and online providers such as X (formerly Twitter), Facebook, and Google Analytics. The information we may collect includes your feedback about our services on our social media accounts.
Cookies and automatic data collection technologies
Our websites use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized service when you browse our website. It also allows us to improve our websites by enabling us to:
- Estimate our audience size and usage patterns.
- Store your preferences so we may customize our websites according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our website.
The technologies we use for this automatic data collection may include:
Most web browsers include a Do-Not-Track (“DNT”) signal or similar mechanisms for your privacy preference. At this time, there is no technology standard for recognizing and implementing DNT signals that has been finalized. Given the state of technology, we do not respond to DNT signals. If a standard for a DNT signal is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
How we use your information
We may use your information to conduct our business operations including for the following purposes:
- To provide you with services you request from us.
- To provide you with the information or support that you request from us, including to send you information about our services and resources.
- To improve our website, products or services, customer relationships, franchise opportunities, and consumer experiences.
- To develop new services.
- To provide you with the information about services or franchise opportunities, or support that you request from us or to fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights and to protect our websites, customers, and other individuals including to protect against or identify possible fraudulent transactions.
- For any other purpose as may be permitted by law or that we describe when you provide the information.
We may use information that is not personal information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on the website.
Disclosure of your information
We may share non-personal information without restriction. We may share your personal information with:
- Any member of our corporate group, which means our subsidiaries, affiliates, our ultimate holding company and its subsidiaries, and affiliates.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To an actual or prospective buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, where one of the transferred assets is the personal information we hold.
- To fulfill the purpose for which you provide it.
- For any other purpose as may be permitted by law or that we describe when you provide the information.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- To enforce our Terms of Service and other agreements with you.
- To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection and credit risk reduction.
- To investigate suspected violations of any law, rule or regulation, or the terms or policies for our website.
We may also use your information to contact you about our own and third-parties’ products and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or opt-out as directed when you receive such an email from us. For more information, see Your rights and choices.
Some content or applications on our websites may be served by third parties. Our websites may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms.
Your rights and choices
Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.
- Marketing. If you do not want us to use your email address or other contact information to promote or recommend our own products and services, or third parties’ products or services, you can opt-out by replying to any promotional email we have sent you or following the opt-out links on that message. This opt-out may not apply to information provided to us as a result of a business transaction with us.
- Accessing, Updating and Deleting Your Information. If you have an account with us, you may have the ability to access your information and make updates to or delete your data. If not, you can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
- California Residents. If you are a California resident, you may have additional personal rights and choices with regard to your personal data. Please see Your California Privacy Rights for more information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. At this time, we do not engage in this type of disclosure.
The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse and unauthorized access, use, alteration, or disclosure. We will only retain your personal data for as long as reasonably necessary to fulfill the purpose of collecting it.
We also require our service providers and business partners to whom we disclose the information to do the same. When you use certain types of information, for example, when you provide us with your credit card or debit card information on our website, we will encrypt the transmission of that information using secure socket layer technology (SSL). We will continue to improve our physical, electronic, and administrative safeguards. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way.
Your California privacy rights
Categories of Information We Collect
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers:||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other contact information.||YES|
|B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||
A name, address, telephone number, credit card number, or debit card number.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Race, ethnicity, religious or philosophical beliefs, age, or sex (including gender).||YES|
|D. Commercial information.||Records products, services or services purchased, obtained, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, operating system, and web browser information.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current job history or job title.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
|L. Sensitive Personal Information||Social security numbers, driver’s license, state identification card, passport number, financial account login in combination with security or access code, password, or credentials, precise geolocation.||NO|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete, communications you send to us, or documents you provide to us, or when you interact with our services.
- Third parties. For example, from parties you direct to share your personal information with us.
- Technical and Communication Data from other parties. We may collect information from third-parties providers such as X (formerly Twitter), Facebook, and Google Analytics. The information we may collect includes your feedback about our Services on our Twitter account, Facebook page, and LinkedIn.
We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal information but is not considered personal information as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing our websites and Services. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Notice.
Reasons for Collecting and Using Your Personal Information
We collect and use your personal information for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, to provide you with services you request from us.
- To provide information to respond to your specific request.
- To provide you with support, including technical support and address your concerns, and monitor and improve our goods and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- When collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosing Personal Information
We may disclose your personal information to service providers and contractors for business purposes. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both retain that personal information as confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for a Business Purpose
- We have disclosed the following categories of personal information with our affiliated companies, service providers and public or government (including enforcement) authorities for our business purposes:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category F: Internet or other similar network activity.
- Category H: Sensory data.
In the preceding twelve (12) months, we have disclosed the categories of personal information identified above for a business purpose to the following categories of persons:
- Service providers.
Selling or Sharing of Personal Information
In the preceding twelve (12) months, we have not sold or shared personal information. We do not sell or share personal information as defined under California law, as such, we do not have actual knowledge of our selling or sharing personal information belonging to consumers under 16 years of age.
Sensitive Personal Information
We do not use or disclose sensitive personal information as defined under Cal. Civ. Code § 1798.140(ae) in any way that is not permitted under Cal. Civ. Code § 1798.121.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion, and Correction Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
We will retain your personal information as reasonably necessary for the disclosed purpose. The retention periods for each category of personal information, including sensitive information, vary depending on compliance with relevant laws, your request for deletion, and our retention policies. For example, we may need to retain your personal information to comply with our legal or reporting obligations in accordance with the laws or to defend against claims. Consequently, it is not possible for us to provide a definitive length of time. Our retention periods are determined by using and balancing the following criteria:
- The volume, nature, and sensitivity of your information;
- The potential risk of unauthorized access, use or disclosure, or misappropriation;
- The purposes for which we process your personal information; and
- The retention obligations under applicable legal requirements.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion, and Correction Rights below), we will delete (and direct our service providers/contractors to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide goods or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform services for you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
If you think some of the personal information we have about you is incorrect, you have the right to request that we correct the personal information in compliance with applicable data protection law. To exercise this right, please see Exercising Access, Data Portability, Deletion, and Correction Rights below.
Exercising Access, Data Portability, Deletion, and Correction Rights
To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by:
- Emailing us at: email@example.com
- Calling us at 1-888-455-5838.
- Use the following link to submit your request: https://www.oasissenioradvisors.com/ccpa-request/
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create a business relationship with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address from which you submit it.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.
Personal Information Security
The security of your personal information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse and unauthorized access, use, alteration, or disclosure. We will only retain your personal information for as long as reasonably necessary to fulfill the purpose of collecting it.
We also require our service providers and business partners to whom we disclose the information to do the same. When you use certain types of information, for example, we encrypt the transmission of certain sensitive or financial information using secure socket layer technology (SSL). We will continue to improve our physical, electronic, and administrative safeguards. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way.
Notice of Financial Incentives
We do not offer financial incentives or pricing discounts for providing your personal information or registering an account with us.
Notice to Nevada residents
Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we do not have plans to sell this information.
Notice to Washington residents (Consumer Health Data Privacy Notice)
You may have additional rights regarding the security and privacy of your consumer health data under Washington’s My Health My Data Law. Please review our Consumer Health Data Privacy Notice, which you can find here.