California Consumer Privacy Notice

Updated: February 1, 2023

This California Consumer Privacy Act Notice (“Notice”) provides additional information to California consumers (“you, “consumer”) whose personal information is processed by Brookdale Senior Living Inc. and its affiliated entities (“Brookdale”, “we”, “us” or “our”) pursuant to the California Consumer Privacy Act (“CCPA”) and The California Privacy Rights Act of 2020 (“CPRA”), collectively referred to herein as (“California Consumer Privacy Laws”). This Notice also addresses the California Shine the Light Law. This Notice only applies to California consumers and supplements the Brookdale Privacy Policy. This Notice does not address the use of information that is subject to the Health Insurance Portability and Accountability Act (“HIPAA”). For information about how Brookdale handles “protected health information” under HIPAA, please see our Notice of Privacy Practices.

Collection and Use of Personal Information

The California Consumer Privacy Laws define personal information as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Personal information does not include:

(1) De-identified or aggregated information;

(2) information that is lawfully made available from federal, state, or local government records, or information that Brookdale has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience; and

(3) information excluded from the California Consumer Privacy Laws, such as health or medical information covered under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), medical information governed by the California Confidentiality of Medical Information Act, personal information disclosed pursuant to the Driver’s Privacy Protection Act of 1994 (“DPPA”), financial information covered under the Fair Credit Reporting Act (“FCRA”) or Gramm-Leach Bliley Act (“GLBA”).

In the preceding 12 months Brookdale has collected the following information from or about you and may have shared or disclosed this information. Further information about our collection and uses of this data is included in a table and following sections below.

Identifiers – this may include but is not limited to: your contact information, real name, alias, postal address, email address, online identifier or username, telephone number, social security number, driver’s license number, insurance policy number, or other similar identifiers;
Contact and Financial Information – this may include but is not limited to: bank account number, debit card number, credit report information, and health information;
Internet and Electronic Network Activity Information – this may include but is not limited to: browsing history, search history, and information regarding Consumer’s interaction with our website or advertisements;
Protected Characteristics - this may include but is not limited to: sex, race, ethnicity, military/veteran status, marital status, religion, and disability;
Geolocation data - this may include but is not limited to: physical location by designated market area, device location, movements, or travel patterns.
Commercial Information – this may include but is not limited to: transaction information, records of purchase history or purchase tendencies;
Audio, Electronic, or Visual Information – this may include but is not limited to: video recording in communications or surveillance in our communities and audio recordings;
Inferences from Personal Information Collected – this may include but is not limited to: creating consumer profiles reflecting preferences and predispositions;
Education Information – this may include but is not limited to education history, professional qualifications, work history and prior employer information; and
Sensitive Personal Information (“SPI”) – Sensitive Personal Information is personal information that reveals:
- Social security number, driver’s license, state identification card or passport number;
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- Your precise geolocation; and
- Your racial or ethnic origin, religious or philosophical believes, or union membership.

The categories of sources from which Brookdale has collected your personal information include the following:

Directly from the consumer;
Website cookies: The use of website cookies is standard on the Internet, and allows us to tailor your visits to the Site to your individual preferences. We may also contract with third party service providers who assign cookies to conduct site tracking for us. These companies use cookies solely to provide us with data about site traffic.
Vendors, such as marketing advertising vendors, data analytic vendors, website analytic providers, professional service vendors, customer service vendors, banking and financial partners, and marketing firms;
Social Media Platforms and Networks;
Healthcare providers;
Referral agencies;
Government agencies; and
Other categories as described in the Brookdale Privacy Policy.

Brookdale collects personal information from you for the following business or commercial purposes:

Providing our services;
Providing customer service;
Providing business support to Brookdale operations;
Performing analytics and quality control;
Researching and testing features and improvements;
Detecting and preventing fraud and security incidents;
Debugging or repairing technical errors;
Marketing our services;
Developing and managing relationships with current or new business partners, vendors and other business partner personnel; and
Other business purposes described in the Brookdale Privacy Policy.

Brookdale in the preceding 12 months may have disclosed and shared your information with the following categories of third parties for the business or commercial purposes described in this notice:

Internet service providers;
Analytics providers;
Advertising networks;
Healthcare providers;
Professional services providers;
Government agencies; and
Brookdale subsidiaries

CATEGORIES OF INFORMATION WE COLLECT AND DISCLOSE

The following chart provides information about the types of personal information we collect, the sources of the information, the purposes for which we used the information, whether the information has been disclosed for a business purpose, and the categories of third parties with whom we have shared this information in the last 12 months.

Type of Information	Categories of Sources	Business or commercial purposes for collection	Disclosed for a Business Purpose?	Third parties to whom Disclosed for Business Purpose
Identifiers, e.g., contact information, real name, alias, postal address, email address, online identifier or username, telephone number, social security number, driver’s license number, insurance policy number, or other similar identifiers	Directly from the consumer; Website cookies; Vendors; Social Media Platforms and Networks; Healthcare providers; Referral agencies; and Government agencies	As described above, e.g., to provide you with services and for internal purposes.	Yes	Internet service providers; Analytics providers; Advertising networks; Healthcare providers; Professional services providers; Government agencies; and Brookdale subsidiaries
Contact and Financial Information – this may include but is not limited to: bank account number, debit card number, credit report information, health information	Directly from the consumer; Vendors; Social Media Platforms and Networks; Healthcare providers; Referral agencies; and Government agencies	As described above, e.g., to provide you with services, complete transactions and for internal purposes	Yes	Internet service providers; Healthcare providers; Professional services providers; Government agencies; and Brookdale subsidiaries
Internet and Electronic Network Activity Information – this may include but is not limited to: browsing history, search history, and information regarding Consumer’s interaction with our website or advertisements	Website cookies; Vendors; Social Media Platforms and Networks	As described above regarding cookies, e.g., for internal purposes and for marketing purposes	Yes	Internet service providers; Analytics providers; Advertising networks; and Brookdale subsidiaries
Protected Characteristics - this may include but is not limited to: sex, race, ethnicity, military/veteran status, marital status, religion, and disability	Directly from the consumer; Social Media Platforms and Networks; Healthcare providers; and Government agencies	As described above, e.g., internal reporting and analytics purposes	Yes	Analytics providers; Healthcare providers; Professional services providers; Government agencies; and Brookdale subsidiaries
Geolocation data - this may include but is not limited to physical location based upon your designated market area, device location, movements, or travel patterns	Platforms, including device applications	As described above regarding cookies, e.g., for internal purposes and for marketing purposes.	Yes	Internet service providers; Analytics providers; and Advertising networks
Commercial Information – this may include but is not limited to: transaction information, records of purchase history or purchase tendencies	Directly from the consumer; Website cookies; Vendors; Social Media Platforms and Networks; Healthcare providers; Referral agencies; and Government agencies	As described above, e.g., for internal purposes, and marketing purposes.	Yes	Internet service providers; Analytics providers; Advertising networks; Healthcare providers; Professional services providers; Government agencies; and Brookdale subsidiaries
Audio, Electronic, or Visual Information – this may video recording in communications and audio recordings	Directly from consumer, directly from facility locations; and Social Media Platforms and Networks; and Healthcare providers	Operational, safety and other operational and business purposes; for internal training and quality assurance purposes.	Yes	Healthcare providers; Professional services providers; Government agencies; and Brookdale subsidiaries
Inferences from Personal Information Collected – this may include but is not limited to: creating consumer profiles reflecting preferences and predispositions	The original sources are the above sources of the underlying data that is compiled.	As described above, in order to facilitate more targeted marketing, as well as for internal reporting and analytics purposes	Yes	Analytics providers; Advertising networks; and Brookdale subsidiaries
Sensitive Personal Information including: Social security number, driver’s license, state identification card or passport number; Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, or text messages where Brookdale is not the intended recipient	Directly from the consumer; Website cookies; Vendors; Social Media Platforms and Networks; Healthcare providers; Referral agencies; and Government agencies	To facilitate more targeted marketing, as well as for internal reporting and analytics purposes, and providing our services.	Yes	Healthcare providers; Professional services providers; Government agencies; and Brookdale subsidiaries

Sale and Disclosure of Personal Information for Targeted Advertising

In the last 12 months Brookdale may have, for the abovementioned business or commercial purposes, sold or disclosed the below categories of personal information for targeted advertising or cross-context advertising (under the California Consumer Privacy Laws, this is called “Sharing”):

Identifiers:
- Shared with Analytics Providers and Marketing and Advertising Providers
Internet and Electronic Network Activity Information:
- Shared with Analytics Providers and Marketing and Advertising Providers
Inferences from Personal Information:
- Shared with Analytics Providers and Marketing and Advertising Providers
Geolocation data:
- Shared with Analytics Providers and Marketing and Advertising Providers

You have the right to opt-out of Brookdale sharing your information as explained below in the “Your Privacy Rights” section of this Notice.

Your Privacy Rights

California Consumer Privacy Laws provide you with the following rights:

Right to Access. You have the right to access the personal information which Brookdale may have collected or retained about you. If requested through a verifiable request, Brookdale shall provide you with a copy of your personal information which we collect as permitted by the California Consumer Privacy Laws, the information shall be in a portable and, to the extent technically feasible, readily useable format, upon verifying your request. You may request to access your personal information collected by clicking here.
- When you exercise your right to access your information, you can expect the following:
  - We will verify your identity. You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested.
  - We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us 1-800-236-3454 or emailing us at partner@brookdale.com.
  - We will respond to your request within 45 days. If necessary, we may need additional time to respond, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  - In certain cases, a Request to Access may be denied. For example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone’s security. If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.
Right to Know. You have the right to know what personal information Brookdale has collected about you. Therefore, you have the right to submit a verifiable request to Brookdale requesting that we disclose the following, as defined by the California Consumer Privacy Laws:
- What personal information Brookdale has collected;
- The categories of personal information Brookdale has collected;
- The categories of sources from which your personal information was collected;
- The business purposes for collecting or sharing your personal information;
- The categories of third parties to whom Brookdale may disclose your personal information; and
- The specific pieces of personal information Brookdale has collected about you.
- When you exercise your right to know your information, you can expect the following:
  - We will verify your identity. You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested.
  - We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us 1-800-236-3454 or emailing us at partner@brookdale.com.
  - We will respond to your request within 45 days. If necessary, we may need additional time to respond, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  - In certain cases, a Request to Know may be denied. For example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone’s security. If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will without the information subject to denial.
Right to Deletion. You have the right to submit a verifiable request for deletion of personal information under certain circumstances. You may request to delete your personal information collected by clicking here.
- When you exercise your right to delete your information, you can expect the following:
  - We will verify your identity. You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested.
  - We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us 1-800-236-3454 or emailing us at partner@brookdale.com.
  - We will respond to your request within 45 days. If necessary, we may need additional time to respond, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  - There may be times in which Brookdale may deny your request to delete information due to legal reasons consistent with the California Consumer Privacy. If we deny a request, we will still try to provide you as much of the information as we can, but we will without the information subject to denial.
Right to Correct. You have the right to submit a verifiable request for correct inaccurate personal information. Brookdale will use commercially reasonable efforts to correct the identified inaccurate information upon receiving a verifiable request. You may request to correct your personal information collected by clicking here.
- When you exercise your right to correct your information, you can expect the following:
  - We will verify your identity. You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested.
  - We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us 1-800-236-3454 or emailing us at partner@brookdale.com.
  - We will respond to your request within 45 days. If necessary, we may need additional time to respond, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  - There may be times in which Brookdale may deny your request to correct information. If we deny a request, we will still try to provide you as much of the information as we can, but we will without the information subject to denial.
Right to Opt-Out of the Sale or Sharing of personal information. Brookdale does not sell personal information within the meaning of the California Consumer Privacy Laws. You do have the right to opt-out of disclosing and sharing your personal information obtained by Brookdale for cross-context behavioral advertising. You may request to opt-out by clicking here.
- When you exercise your right to correct your information, you can expect the following:
  - We will verify your identity. You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested.
  - We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us 1-800-236-3454 or emailing us at partner@brookdale.com.
  - We will respond to your request within 45 days. If necessary, we may need additional time to respond, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
Right to Limit Use of Sensitive Personal Information. You have the right to limit the use and disclosure of your SPI information obtained by Brookdale. You can make a request to limit the use or disclosure of your Sensitive Personal Information by clicking here.
- When you exercise your right to correct your information, you can expect the following:
  - We will verify your identity. You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested.
  - We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us 1-800-236-3454 or emailing us at partner@brookdale.com.
  - We will respond to your request within 45 days. If necessary, we may need additional time to respond, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
Right to Non-Discrimination. If you choose to exercise your privacy rights under the California Consumer Privacy Laws we will not charge you different prices or provide different quality of services unless those differences are related to your personal information or otherwise permitted by law.

Brookdale’s Commitment to Children’s Privacy

Protecting the privacy of children is very important to us. The Children’s Online Privacy and Protection Act of 1998 (“COPPA”) defines a “Child” as anyone under the age of 13. We strictly adhere to COPPA. For that reason, we do not collect or maintain information obtained through the Site from those we actually know are under 13, and no part of the Site is structured to attract anyone under 13. If we are made aware that we have collected personal information from a child under the age of 13 without verification of parental consent then Brookdale will delete that information. If you believe we have collected information from a child under the age of 13 please contact us via email at partner@brookdale.com.

Exercising Your Rights

You can exercise the rights mentioned in this notice by submitting a verifiable consumer request by filling out a request form by clicking here, calling toll-free at 1-800-236-3454 or emailing us at partner@brookdale.com. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of and or deletion of your personal information, we may require you to provide additional information to help us identify you.

California residents may designate an authorized agent to make a request on their behalf. We will deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us.

Brookdale’s Response to Requests

Brookdale will respond to your request within forty-five (45) days from the day we receive your verifiable consumer request. Dependent upon the number of requests and complexity of such requests, Brookdale may take up to a total of 90 days to respond where necessary. If additional time is needed to respond to a request, Brookdale will notify you within 45 days of the receipt of the request that additional time is needed and reason for delay.

Brookdale Retention of Personal Information

Brookdale will retain the information gathered in the above table as long as it is reasonably necessary for each disclosed purpose unless longer retention period is required by law. Please see our Privacy Policy (“Policy”) for more information about our information collection practices.

Contact Us Regarding Your Privacy Rights

We welcome your questions, comments and feedback pertaining to your privacy. In the event you have any questions and need to contact us regarding your privacy, please contact us by calling us at 1-800-236-3454, emailing us at partner@brookdale.com, visiting our website at https://www.brookdale.com/en/privacy-policy.html, or mailing us your concerns to:

Brookdale Senior Living Inc.
Attn: Privacy Compliance, Director
6737 W. Washington Street, Suite 2300
Milwaukee, WI 53214

California Shine the Light Law

If you are our customer and a California resident, you may ask us to provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To do so, email us at partner@brookdale.com or submit a request in writing to: