Website Privacy Policy

 

This Privacy Policy (this “Privacy Policy”) discloses the privacy practices of Welltower, Inc. (“our”, “us” or “we”) of 4500 Dorr Street, Toledo, OH 43615 with respect to our collection and use of United States residents’ Personal Information (defined below), including on our websites such as www.www.eszhu.com and any related mobile sites or applications (the “Site”).

We are committed to protecting your privacy. Please read this Privacy Policy as it provides important information regarding your use of the Site, our data and privacy practices, and explains your rights. You acknowledge that this Privacy Policy is part of the Terms of Use for the Site (the “Terms of Use”), and by accessing or using the Site, you accept and agree to be bound by the Terms and Use and this Privacy Policy.  If you do not agree to the Terms of Use and this Privacy Policy, please do not access or use the Site.

We reserve the right to change, revise or modify this Privacy Policy at any time and from time to time without notice to you.  Such changes, revisions or modifications shall be effective immediately when we post them.  You acknowledge and agree that it is your responsibility to review the Site and this Privacy Policy periodically and to be aware of any changes, revisions or modifications.  If we make a significant or material change in the way we use or share your Personal Information, you will be notified via email or a notice on the Site. Your continued use of the Site after such changes, revisions or modifications will constitute your acceptance and acknowledgment of the changed, revised or modified privacy policy and agreement to abide and be bound by it as changed, revised or modified.

Last updated: April 3, 2020

 

  1. Personal Information Collected.

In order to better provide you with services, we may collect, process and store personal information about you.

Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device or household (“Personal Information”). It does not include de-identified or aggregate information, or public information lawfully available from governmental records. When you engage in certain activities on the Site, such as registering for an account or requesting services, we may ask you to provide certain information about yourself by filling out and submitting an online form.  It is completely optional for you to engage in these activities; however, we may ask that you provide us personal information. Depending upon the activity, some of the information we ask you to provide are in mandatory fields and some are in voluntary fields.  If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. In addition from obtaining personal information directly from you, we may also obtain information: from your employer; from an agent/third party acting on your behalf, such as a distributor, one of our affiliated operating companies, a lead referral service, or a data provider who collected information from you directly or indirectly; through publicly available sources; or, where we have cameras on our premises capturing individuals’ images and movements, from the use of our CCTV cameras.

The following list describes the categories of Personal Information we may have collected about you in the past 12 months:

  • Address and other identifiers – such as name, postal address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers
  • Unique and online identifiers – such as IP address, device IDs, or other similar identifiers
  • “Demographic and family information – such as age, date of birth, race, gender, sex, ethnicity, nationality, place of birth, citizenship, immigration status, disability, military and veteran status, marital status and dependent information.”
  • Financial information
  • Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • Education or other professional information
  • Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology) information
  • Geolocation Information
  • Inferences drawn from CCPA PI – such as individual profiles, preferences, characteristics, behaviors

We may collect this information directly from you, from your employer, from an agent or third party acting on your behalf, from publicly available sources, from third party data brokers, or from the use of our CCTV cameras for certain premises where they are installed for security purposes.

  

  1. How We Share Your Personal Information.

We may share information with:

  • Professional advisers, including accountancy and legal firms, in order to provide us with advice;
  • Service providers, including to provide and support our data management, analytics, security, and storage systems;
  • Group companies, for business and operational purposes; and
  • Transaction (merger and acquisition) partners, including to facilitate the diligence, negotiation, and completion phases of transactions contemplated by us, our parent company, or affiliated operating companies.

We provide some of our services through contractual arrangements with affiliates, services providers, partners, and other third parties.  We and our service partners may use your Personal Information to operate our sites and to deliver our services.  Third parties with whom we share your Personal Information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.

Occasionally, we may be required to share your Personal Information with third parties for legitimate business purposes, or to comply with legal obligations.  For example, we may share Personal Information when we believe in good faith that an applicable law requires it; at the request of law enforcement, judicial authorities (i.e. upon receipt of a court order or subpoena), appropriate governmental authorities; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety or security of third parties, visitors to our Sites, our businesses, or the public. Additional disclosures of your Personal Information to third parties for legitimate business purposes or to comply with legal obligations may include us sharing:

  • Online identifiers with third party providers in order to debug errors in our system
  • Commercial information with accountancy and legal firms to carry out our obligations arising under our contract with you and to enforce the same

We do not grant access to your Personal Information to any other third parties unless we say so in this Privacy Policy or unless the law requires it. In the past 12 months, we have not sold your Personal Information to any other entity, and we do not sell Personal Information to third parties.

 

  1. Collecting the Personal Information of Minors.

Our products and services are not directed to minors under the age of 16 and we do not knowingly collect or sell the Personal Information of minors.

 

  1. Updating and Correcting Your Personal Information.

We believe you should have the ability to access and, where appropriate, edit the Personal Information that you have provided to us.  You may change any of your Personal Information in your account online.  You may also access and correct your personal information and privacy preferences by writing us at:

Welltower Inc. 4500 Dorr Street Toledo, Ohio 43615-4040 Attn: Website Administrator

Please include your name, address, and/or e-mail address when you contact us. We encourage you to promptly update your Personal Information if it changes.

 

  1. Security of Personal Information.

We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards.

Access by you to your Personal Information may be available through a password and unique customer ID selected by you.  We recommend that you do not divulge your password to anyone.  In addition, your Personal Information resides on a secure server that only selected personnel and contractors have access to via password. Personal information that you provide that is not Personal Information also resides on a secure server and is only accessible via password.  Since this information is not accessible from the outside, you will not be asked to select a password in order to view or modify such information.

While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure.  Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented.  Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security. As a result, while we strive to protect your Personal Information, you acknowledge that (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

 

  1. Marketing.

We endeavor to good faith to adhere to self-regulatory advertising principles, such as the Digital Advertising Alliance’s Principles. If you are interested in learning more about and/or opting out of online behavioral advertising, sometimes called interest-based advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as www.youradchoices.com or aboutads.info. Please note that while we provide these links for your convenience, we do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

 

  1. Cookies.

When you use the Site we may store “cookies” on your computer in order to facilitate and customize your use of the Site.  A “cookie” is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us.  The cookies make your use of the Site easier, make the Site run more smoothly, and help us to maintain a secure Site.  You are always free to decline our cookies if your browser permits, but some parts of the Site may not work properly if you do so.

We do not respond to browser or do-not-track signals.

 

  1. Your Rights.

Residents of certain states may have the following additional privacy rights.

Right to request disclosure of information we collect and share about you

We are committed to ensuring that you know what information we collect about you.  Subject to certain exceptions, you can submit a request to us for the following information, with respect to Personal Information we have collected about you in the last 12 months: 

  • The categories of or specific pieces of Personal Information we’ve collected about you.
  • The categories of sources from which we collected the Personal Information.
  • The business or commercial purposes for which we collected or sold the Personal Information.
  • The third parties with whom we shared the information.

Subject to certain exceptions, you also may have the right to request the deletion of Personal Information we have collected from you.

Upon your request, we will delete the Personal Information we have collected about you, except for situations where specific information is necessary for us to: provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law.  The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.

You have the right to fair treatment.  We are committed to providing consumers control over their Personal Information. If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. In particular, this means that consumers who exercise their rights in accordance with this Privacy Policy will not be denied or charged different prices or rates for goods or services, nor will we offer a financial incentive or provided a different level or quality of goods or services that other consumers unless it is reasonably related to the value of the personal information to the business.

California Shine the Light.  California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year.

 

  1. How You Can Make an Access or Request Deletion of Your Personal Information.

You can log into your account to access or request deletion of certain information about yourself, or you can do so by using the contact details set out at the end of this Privacy Policy.

 

  1. How We Handle a Request to Exercise Your Rights.

For requests for access or deletion, we will first acknowledge receipt of your request within 10 days of receipt of your request.  We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances.  If we expect your request is going to take us longer than normal to fulfil, we’ll let you know.  We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests.  When this is the case, we will endeavor to provide you with an explanation as to why. 

 

  1. How We Verify Your Identity When You Submit an Access or Deletion Request.

If you maintain a password-protected account with us, we will verify your identity using a two-step process. We will first ask you to log into your account, and we will then ask you to separately authenticate your identity by asking you a series of questions.  If we are unable to verify your identity through your password-protected account with a reasonable degree of certainty appropriate to the nature of your request, for security reasons, we may ask you to verify your identity in accordance with the additional requirements described below.

If you do not have an account with us and are requesting to delete or have access to specific pieces of Personal Information, we may need to ask you several questions to verify your identity by matching your answers to information we maintain about you. Additionally, depending on the nature of your request, we may require that you provide a declaration attesting to your identity, signed under penalty of perjury. If we are unable to verify your identity with a degree of certainty required, we will not be able to fulfil to the request.  We will notify you to explain the basis of the denial. Additionally, we will treat the request as one seeking disclosure of the categories of Personal Information we have collected about you and endeavor to verify your identity using the less-stringent standards applicable to such requests.

Authorized Agents – Additional Verification Required.  You may designate an agent to submit requests on your behalf.  The agent can be a natural person or a business entity that is registered with the California Secretary of State.   If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process to verify your identity and provide us with proof of the agency relationship.

Household Requests — There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above.  If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.

 

  1. Privacy Policies of Third-Party Sites.

Except as otherwise discussed in this Privacy Policy, this document only addresses our collection, use and disclosure of Personal Information. Other sites accessible through the Site have their own privacy policies and data collection, use, and disclosure practices.  Please consult each site’s privacy policy.  We are not responsible for the policies or practices of third parties.

 

  1. Contact and Exercising Your Privacy Rights.

If you have questions on the processing of your Personal Information, would like to exercise any of your rights, or have a complaint, please contact us here: legalnotice@www.eszhu.com or call us toll free at 877-670-0070, or write us at:

Welltower Inc.

4500 Dorr Street

Toledo, Ohio 43615-4040

Attn: Website Administrator

 

  1. Accessibility of our Communications.

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 877-670-0070 or contact legalnotice@www.eszhu.com. 

The information contained on the Site is subject to change without notice. If we make a significant or material change in the way we use or share your Personal Information, you will be notified via email or a notice on the Site.

 

Last modified: April 3, 2020

 

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