Last Update: February 15, 2024
Effective: February 15, 2024
What Is the Scope of this Statement?
The terms “we,” “us,” and “our” refer to the Company and its officers, directors, owners, employees, and agents.
The term “personal data” means any data that relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable. As used herein and in connection with our business, the term personal data may include:
● Names and contact information, including phone number, physical address, fax, and e-mail, all only to the extent provided by you (or on your behalf) to us;
● Potentially gender and nationality;
● Information about, from, or related to any senior living provider, organization, facility, institution, business, or company in which you live, with whom you are affiliated in any way, or from or about which you seek information, including as indicated in public information or as provided by you to us;
● Referral source data (i.e., how you ended up at the website);
● Any other similar information provided to us by you in connection with our services or through the website.
The term “processing” means any operation or set of operations performed on personal data. Processing includes but is not limited to, the collection of data, the organizing of data, the recording or saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or destruction of data, or the making available of data.
What Information We Collect About You
We may collect all types of personal data about you as described in Section 2 above under the definition of “personal data.” You agree that we may collect and process all such personal data that you provide to us, or that you manifestly make public through publication or otherwise, and/or any entity which retains us and provides to us to enable us to provide the services (the “Services”) for which we were retained by said customer and as otherwise set forth in the agreement related to such Services. In addition to the Services identified on the website, these Services may also include Services in connection with the use and management of the website and all content and services therein. You also hereby consent that we may use your personal data for the following additional purposes, which may be included in, or part of, the Services:
● Updating our records;
● In connection with any application for employment with the Company;
● Internal analysis for our business management purposes;
● Any statutory or regulatory purpose which requires the processing of your personal data;
● Legal and regulatory compliance;
● Fraud and crime prevention;
● Internal or external audits; and
● Any other purpose for which valid consent is obtained.
Please do not supply the following to us:
● Any other person’s personal data, unless the Company explicitly asks you to do so;
● Any categories of your personal data that the Company has not explicitly requested;
● Any confidential, proprietary, secret, or legally protected information that the Company does not explicitly request you to provide; and
● Any confidential, proprietary, secret, or legally protected information which is under any legal obligation to not provide to or share with the Company.
How We Collect Information About You
We collect information about you (including personal data) when:
You Give Us Information – You may provide us information when:
● you set up an account with us; you provide it to us by filling out forms;
● you send us e-mail; you provide information via phone or in person;
● you provide us with information in writing and send it to us other than via e-mail, phone, or in person (i.e., mail, FedEx, etc.);
● you provide information to or through our Waypoint Website Tools and the Waypoint
● you provide us with documentation;
● you provide us with information which may contain personal data;
● you provide it to us through our “Contact” page on the website;
● you provide it to us through our Login page;
● you provide it to us through our Waypointconverts.com website
● you provide it when subscribing to our Blog;
● you provide it to us when Scheduling a Time to Speak through the website;
● you provide it to us through social media;
● you provide us with information in connection with seeking employment with the
● We Collect Information Automatically – We automatically collect certain types of information when you visit our website (as explained below).
● A cookie is a file containing an identifier (a string of letters and numbers) sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
● Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
● Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
● Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your computer that are not removed through normal browser management tools. If we use FLASH cookies, we will only do so in a manner consistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service.
Cookies That We Use
● advertising – to help us display advertisements that will be relevant to you in connection with our Services;
To learn more about cookies, please visit http://www.allaboutcookies.org.
Cookies Used By Our Service Providers And Vendors
Google Analytics (see https://support.google.com/analytics/answer/6004245?hl=en and information therein).
● You should review the privacy and cookie policies of the above website(s) to learn more about the cookies that are used in connection with the above.
● The above website(s) and cookies may change from time to time as we use different vendors or service providers to provide some or all of the services offered or provided by the above services and websites or additional services we decide to include. While we will periodically update our list of such vendors and service providers, the above list may not be complete at any given time.
● Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
https://support.apple.com/guide/safari/view-a-privacy-report-ibrw35004465/mac and https://support.apple.com/guide/safari/prevent-cross-site-tracking-sfri40732/14.0/mac/11.0 (Safari)
● Some devices (i.e., your smartphone or tablet) allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from device to device and from version to version. To obtain more information about managing cookies on your device, please see https://www.allaboutcookies.org/mobile/.
● Blocking some or all cookies may have a negative impact on the usability of many websites, including our website and our services.
● These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message, which are used for such things as recording webpages or advertisements clicked on by a user or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online behavior and measure our website’s effectiveness and marketing.
● We may also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these devices on the website and/or in emails to use information obtained from them, such as pages viewed, emails opened, and items upon which you may click in emails. These third-party providers may also place cookies on your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources and the information we have about you. See above for more information on our cookies.
A web “server log” is a record of activity created by a computer that delivers certain web pages to your browser. Certain activities that you perform on our website may record information in server logs. For example, if you enter a search term on the website or enter your login information, the server log may record the search term, the link you clicked on to bring you to our website, and/or information about your browser, such as your IP address and the cookies set on your browser.
Search Queries on Our Website
We may provide you with options to search for information on our website. If you enter information in a search query box, we may store that information and aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.
Social Media Platforms
We may link to certain Company social media platforms on LinkedIn® or other platforms. When you engage with our content at or through these social media platforms, you may be asked to share certain information about these interactions with us. Please review the privacy policies/notices and privacy settings with each social media platform you use so you understand how this data and information may be used and choose your options for sharing such data and information.
How We Use Your Personal Data
● We may also use the information we collect internally in our business for many business purposes, such as to: (i) provide the Services you may seek or which are available on the website; (ii) provide aggregated or other data to third parties concerning the results of your reporting and monitoring on and through the website, with or without other aggregated data; (iii) analyze trends and conduct research; (iv) provide support and respond to questions from our users, website visitors and customers; (v) improve our website; (vi) learn about users’ and customers’ needs; (vii) contact users for research, informational, and marketing purposes, including customizing our website; (viii) track traffic patterns and website usage; (ix) provide customer service and technical support; (x) correlate information with other commercially available information to identify demographics, reporting and monitoring needs, trail conditions, user impact and any other service or information offered on or through the website; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices, network functioning, engineering, and troubleshooting issues; (xiii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiv) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the website, our partners or customers, or the public; and (xv) process or engage in a sale of all or part of our business/organization(s), or if we go through a reorganization or merger.
Providing Your Personal Data To Others
● We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings, ADR, or in an administrative or out-of-court procedure.
● We may disclose certain of your personal data to our suppliers and subcontractors pursuant to separate consent provided by you to us.
● We may disclose certain of your personal data to our vendors and subcontractors in connection with providing our Services or our other permitted uses as set forth herein.
● We may disclose your personal data to any senior living provider, organization, facility, institution, business, or company in which you live, with whom you are affiliated in any way, or from or about which you seek information on or through the website or any of our Services.
● The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for assisting us in providing our Services to you, storing data, and in connection with the administration of our business.
● In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or out-of-court procedure.
Retaining And Deleting Personal Data
● This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
● Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
● We will retain your personal data:
● to the extent your personal data that we hold was obtained from data you knowingly, intentionally, and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained in that form for as long as it is needed or required for the purposes for which we obtained the information from the public record, or as otherwise required by applicable law;
● to the extent your personal data that we hold was pulled by us and separated from data you knowingly, intentionally, and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained by us for as long as required by us for the purpose for which it was obtained and as required by our contractual requirements with third-party clients or as otherwise required by applicable law.
● In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the retention period based on our Services’ performance and any applicable industry and governmental standards.
● We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Your Rights – FOR CALIFORNIA RESIDENTS ONLY
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws.
Requests for Information
Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business with whom the California resident has an established business relationship certain information with respect to the types of personal information the business shares with third parties for those third parties’ direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at [email protected] with “REQUEST FOR CALIFORNIA PRIVACY INFORMATION” in the subject line and explicitly make such request. Be sure to provide sufficient information in the request to properly identify you and/or your family members to whom the request applies.
Do Not Track Disclosure
As required by Section 22575 of the California Business and Professions Code, the following disclosure is made to California residents and to residents of other states:
We collect various types of personal data about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us to disclose your categories or personal data, which we have shared with third parties, for the third parties’ direct marketing purposes during the prior year. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt out of our sharing your information with third parties with whom we do not share the same brand name if the third party will use such information for its direct marketing purposes.
If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below with the words “CALIFORNIA OPT-OUT” in ALL CAPS in the subject line or clearly set forth elsewhere. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third-Party Direct Marketing Opt-Out Form so you may request that your personal data not be disclosed to third parties for their direct marketing purposes.
Attention: PRIVACY OFFICER
P.O. Box 43
Guilford, CT 06437
Attention: PRIVACY OFFICER
Consumer Rights Under the California Consumer Privacy Act of 2018 (the CCPA) and the California Privacy Rights Act of 2020 (the CPRA)
To the extent the California Consumer Privacy Act is applicable, with certain exceptions and, including in connection with data subject to federal regulation (i.e., the Health Insurance Portability and Accountability Act (HIPAA), the Gramm-Leach Bliley Act California (GLBA), the Fair Credit Reporting Act (FCRA), the California Financial Information Privacy Act (CFIPA), the Federal Farm Credit Act of 1971, the Drivers’ Privacy Protection Act (DPPA), the Confidentiality of Medical Information Act (CMIA), certain laws concerning clinical trials data, the First Amendment and related law), contractual rights and obligations, and certain other exceptions, California residents have the following rights with respect to our data collection and data processing of California residents’ personal data (excluding de-identified or aggregate data) which is collected in California, processed in California, or part of a transaction occurring in California:
(1) The right to know whether your personal data was collected by us.
(2) The right to request the categories and specific pieces of personal data that we have collected about you in the past 12 months, the categories of sources for which that information is collected, the business purposes for collecting or selling/sharing the information, and the categories of third parties with whom the information is shared or sold.
(3) The right to know what information we are collecting about you and the purposes for which it is being used.
(4) The right to not allow us to sell or share any of your personal information.
See opt-out options and the “Do Not Sell/Share My Information” button located here.
(5) The right to limit our use of your sensitive personal information.
See “Limit the Use of my Sensitive Personal Information” button located here.
(6) The right to have your personal information deleted, subject to certain exceptions.
These exceptions may include:
Complete the transaction for which we collected the personal information, provide a good or service you requested, take reasonably anticipated actions within the context of our ongoing business relationship with you, or otherwise perform our contract with 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 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
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.
(7) The right to have your personal information corrected, subject to certain exceptions.
(8) The right to know the length of data retention.
See Section 12 of this Policy.
(9) The right not to be discriminated against for exercising the above rights.
We will not discriminate against you if you exercise any of the above rights. However, as explained, some or all of our Services necessarily require us to process your personal information and share your personal information with certain third parties in connection with providing the Services. Therefore, and as explained above, the exercise by you of certain of the above rights may impact our ability to provide the services to you.
TO THE EXTENT APPLICABLE, AND TO EXERCISE ANY OF THE ABOVE RIGHTS, PLEASE CONTACT US AT ANY OF THE BELOW AND INCLUDE THE WORDS “CCPA/CPRA RIGHTS” IN ALL CAPS IN THE SUBJECT LINE, OR BE CLEAR BY PHONE THAT YOU WANT TO EXERCISE YOUR CCPA RIGHTS and CLEARLY LET US KNOW WHAT RIGHTS YOU SEEK TO EXERCISE.
P.O. Box 43
Guilford, CT 06437
Attention: PRIVACY OFFICER
Your Choices About Information We Collect
● If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. Please note that if you do not provide us with certain personal information, the Company may be unable to provide you with its Services, or those Services may not be as good as they otherwise could be.
● If you seek access to your personal information in our possession or seek to correct, update, or supplement such information, please contact us at the below contact information with the words “PERSONAL INFORMATION CORRECTION/UPDATE” in your request, and clearly state what you are requesting:
P.O. Box 43
Guilford, CT 06437Attention: PRIVACY OFFICER
With a copy (including the words “Waypoint – PRIVACY” in the subject line) to
P.O. Box 43
Guilford, CT 06437
Attention: PRIVACY OFFICER
P.O. Box 43
Guilford, CT 06437
Attention: PRIVACY OFFICER
With a copy (including the words “Waypoint – PRIVACY” in the subject line) to:
P.O. Box 43
Guilford, CT 06437
Attention: PRIVACY OFFICER
You may opt out of our various communications as follows:
E-mail Communications: (1) Click the unsubscribe link located in our emails or (2) call us at (877) 929-7648 and clearly set forth your request.
Third-Party Sharing: (1) e-mail us at [email protected] with the words “THIRD-PARTY E-MAIL REMOVAL” in the subject line, or (2) by calling us at (877) 929-7648 and clearly setting forth your request.
Note that removal from third-party lists may take up to 3 months to be effective.
Text/SMS Message Consent and Opt-Out: If you choose, you can provide your mobile phone number to receive text message alerts from the Company. By providing your mobile phone, you are consenting to receive automated marketing text messages from us, but you can always purchase products from the Website without providing this consent. Message and data rates may apply, and you should check the rates of your mobile carrier. You can opt-out of Waypoint text marketing communications by texting STOP to the SMS number used by the Company to contact you.
We may share your mobile phone number with our service providers to help us with the above activities, but not for their own marketing. We do not guarantee the availability or performance of this text/SMS service, including liability for transmission delays or message failures.
Please note that even once we comply with any of your requests as set forth above, de-identified and aggregate data, including your personal data, may still be shared, but it will not be identified or identifiable to you.
Privacy of Children Who Visit the Website
We recognize the importance of children’s safety and privacy. The website is not designed to attract children and is not intended for use by any children under the age of 18. We do not request or knowingly collect any personally identifiable information from children under the age of 18. If you are under the age of 18, you do not have permission to use this website or our Services.
We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information and to protect you against the criminal misuse of that information.
While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure. No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that the information you share on the website will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software.
Questions / Changes in Notice