California Privacy Policy
Effective Date: Jan. 1, 2022, Last Updated: September 18, 2023

This California Privacy Policy (“Policy”) applies only to California residents (“you” or collectively, “Consumers”) as defined by the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) (collectively, “California Privacy Laws”). Vivante Newport Mesa and Vivante Newport Center (“Vivante”) are managed and operated by Integral Senior Living (“ISL”). Any reference to “we”, “us”, or “our” in this Policy shall refer to Vivante and, where the context requires, ISL and Vivante, collectively.

This Policy is intended as a supplement to other privacy policies or notices issued by Vivante and/or ISL. In the event of a conflict between any other policies, statements, or notices, this Policy will prevail as to California Consumers and their rights under California Privacy Laws.

This Policy describes your rights under California Privacy Laws and how we use, collect, and share your personal information (“PI”). The terms used in this Policy have the same definitions as the terms in the California Privacy Laws.

If you are an employee, independent contractor, job applicant, or former employee/independent contractor, please visit ISL’s Employee Privacy Policy.

Our Practices Regarding Your Personal Information

The table below describes the PI we may have collected about you in the preceding twelve months, including the categories of PI, the sources of PI, our purposes for collecting PI, and third parties with whom we may have shared the PI. Depending on your level of interaction with us, we may not have collected your PI from all of the categories. If we collect any of your Sensitive Personal Information (“SPI”), we only use your SPI as necessary to provide the goods and services you have requested.

In the past twelve months, we have not sold any PI. Our business focuses on providing care to seniors and we do not typically collect, sell, or share the information of Consumers under 16 years of age.

Category	Examples of PI Collected	Sources of PI	Purposes for PI Collection	Categories of third parties with which the PI is shared, if shared
Commercial Information / Purchase Details	Records of purchase history or purchase tendencies.	Directly from Consumer.	(1) Fulfilling Consumer requests; (2) managing Consumer safety; (3) processing payments/financing, advertising and incentivizing purchases.	Business Partners (e.g., banking partners offering financing), External Auditors and Government Entities.
Sensory Data	Closed circuit TV, video recording in communications.	Directly from Consumer and Service Providers (e.g. video recording agencies).	(1) Corporate research and development; (2) quality assurance; (3) safety and security.	Service Providers (e.g., customer service / video or call recording agency).
Customer / Individual Records	Bank account number, debit card number, credit report information, health information, criminal record information, background check information.	Directly from Consumer and Service Providers (e.g., customer service providers), healthcare providers, referral agency(ies), and Government Entities.	(1) Managing interactions and transactions; (2) corporate research and development; (3) performing services; (4) processing interactions; (5) managing security and Consumer safety; (6) fulfilling Consumer requests; (7) processing payments/financing, advertising and incentivizing purchases.	Service Providers (e.g., customer service agencies, marketing firms, data analytics firms), healthcare providers, referral agency(ies), banking partners, External Auditors, Government Entities.
Identifiers	Real name, alias, postal address, email address, online identifier or username, telephone number, social security number, driver’s license number, passport number, insurance policy number, or other similar identifiers.	Directly from Consumer and Service Providers (e.g. customer service providers), healthcare providers, referral agency(ies), Government Entities.	(1) Managing interactions and transactions; (2) corporate research and development; (3) performing services; (4) processing interactions; (5) managing security and Consumer safety; (6) fulfilling Consumer requests; (7) processing payments/financing, advertising and incentivizing purchases.	Service Providers (e.g., customer service agencies, marketing firms, data analytics firms, referral agency(ies)), healthcare providers, banking partners, External Auditors, Government Entities.
Internet Usage Information	Browsing history, search history, and information regarding Consumer’s interaction with an Internet Web site, application or advertisement.	Directly from Consumer, Service Providers (e.g. website provider, marketing firm), and Data Resellers.	(1) Managing interactions and transactions; (2) corporate research and development; (3) security; (4) debugging.	Service Providers (e.g., website hosts).
Geolocation Data	Precise physical location, movements, or travel patterns.	Directly from Consumer and Data Resellers.	(1) Managing interactions and transactions; (2) performing services; (3) corporate research and development; (4) personalizing services; (5) safety and security; (5) debugging; (6) selling services; (7) customer service; (8) auditing; (9) detecting security incidents or abnormalities, internal research.	Service Providers (e.g., website hosts, marketing agencies).
Inferences from PI Collected	Creating consumer profiles reflecting preferences and predispositions.	Directly from Consumer, Service Providers (e.g., marketing firm, referral agency(ies)), Data Resellers.	(1) Performing services; (2) corporate research and development, including advertising and incentivizing purchases.	Service Providers (marketing firms, referral agency(ies)).
Protected Characteristics	Sex, race, ancestry, ethnicity, age, date of birth, military or veteran status, marital status, sexual orientation, gender, gender identity, religion or creed, and disability.	Directly from Consumer and/or referral agency(ies).	(1) Processing interactions and transactions, and personalizing services; (2) processing payments/financing; (3) personalizing services; (4) processing medical and government paperwork.	Service Providers, External Auditors and Government Entities.

In addition, we may collect, use, and disclose your PI as required by applicable law.

California Privacy Rights

California Privacy Laws provide you with the following rights related to your personal information:

Right to Know About PI Collected, Disclosed, Shared, or Sold

You have the right to know what PI we collect, use, disclose, share, and/or sell. Our response is based on your request and may include the following information:

• The categories of PI we have collected about you.
• The specific pieces of PI we collected.
• The categories of sources from which we collected your PI.
• The business or commercial purposes for collecting or sharing (or, if applicable, selling) your PI.
• Any third parties we shared your PI with.
• Categories of PI sold about you in the prior 12 months or confirmation that we have not sold any of your PI.

We retain your PI for as long as it is reasonably necessary for the purposes described in this Policy and as required by law.  This generally means holding the information for as long as one of the following apply:

• Your PI is reasonably necessary to provide you with your requested goods and services, to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the PI;
• Your PI is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the PI was collected;
• Your PI is reasonably required to exercise and defend legal claims, or our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• Your PI may be maintained indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes.

Where PI is used for more than one purpose, we will retain it until the purpose with the latest period expires.

Right to Request Deletion of PI

You have the right to request that we delete any PI we collect or maintain about you, subject to certain exceptions. California Privacy Laws allow us to keep your PI that we need to provide you with services and transactions you have requested or are reasonably anticipated; for security purposes; for legitimate internal business purposes, including maintaining business records; to comply with applicable laws and regulations; to exercise and defend legal claims; and to cooperate with law enforcement.

Right to Correct

You have the right to request the correction of any inaccurate PI we maintain about you, taking into account the nature of the PI and the purpose of the processing of the PI.

Right to Opt-Out/“Do Not Sell” Rights

If we sell or share your PI, you have the right, at any time, to tell us to stop.  This includes the right to opt-out of the sale of your PI, and to request that we do not share your PI for cross-context behavioral advertising.  At the time this Policy was last updated, we do not sell any PI. To exercise your right to opt-out, please contact us through any of the methods listed below in the “Contact Us” section.

We typically only collect SPI to determine whether we are able to provide care to you or as part of our ongoing care services. We use your SPI in a reasonable and proportionate matter to provide you with the appropriate level of care. You have the right to limit the use or disclosure of SPI if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services. If you would like to exercise any rights related to your SPI, please contact us through any of the methods listed below in the “Contact Us” section.

For your convenience, you may also submit your privacy requests through our online privacy form.

Right to Non-Discrimination

If you choose to exercise any of your rights under California Privacy Laws, we will not discriminate against you.

Exercising Your Privacy Rights

To exercise any of your privacy rights, please see the “Contact Us” section or submit your privacy requests through our online privacy form. You may exercise your California privacy rights independently or through an authorized agent. All privacy rights requests are subject to an identification and verification process. We will not fulfill a privacy rights request unless we have been provided sufficient information for us to reasonably verify the identity of the requestor and the validity of the request. Before we share anything with your authorized agent, you will need to provide us with your written permission or other documentation, such as a valid Power of Attorney. Your authorized agent will also be required to verify his/her identity with us.

You may exercise your rights up to twice in any twelve month period, at no cost. We will confirm receipt of your request within ten business days of your request submission. California Privacy Laws provide us with forty-five calendar days to respond to your request. If your request is complex, we are allowed an additional forty-five days to respond. If we need additional time, we will let you know within the initial forty-five day period.

We will provide our response to your request in a readily usable format, which is usually electronic. If we cannot complete your request, we will explain why in our response.

Other California Notices
California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for our own direct marketing purposes.

If you would like to exercise your rights under Shine the Light, please contact us in any of the methods listed in the “Contact Us” section. You are allowed to exercise your “Shine the Light” rights once in a calendar year.

Contact Us
If you would like to exercise any of your privacy rights or contact us for more information, you can:

• Email us at privacy@vivanteliving.com, or
• Submit your privacy request through our online privacy form, or
• Call us at 1-888-335-5899, or
• Write to us at:
  Vivante
  c/o Nexus Companies
  1 MacArthur Place, Suite 300
  Santa Ana, CA 92707
  Attention: Privacy Inquiry

Vivante Newport Mesa (License No. 306004582) and Vivante Newport Center (License No. 306006180) are each licensed as a Residential Care Facility for the Elderly by the Community Care Licensing Division of the California Department of Social Services.

We are pledged to the letter and spirit of the Fair Housing Act and U.S. policy for achievement of Equal Housing Opportunity throughout the nation.  We encourage and support an affirmative advertising, marketing and rental program in which there are no discrimination or barriers to obtaining housing on the basis of race, color, religion, sex, handicap, family status or national origin.