Privacy Policy

This Privacy Policy (“Policy”) applies to all websites, systems, and other services operated by the affiliates of The Pennant Group (“Pennant”), including without limitation Pennant Services (“Pennant Services”). Any reference to “we”, “us”, or “our” in this Policy shall refer to Pennant. This Policy has been created in order to demonstrate and inform you of our firm commitment to privacy. The Policy describes how we collect, protect and use information we receive from visitors to www.pennantgroup.com and Pennant and Pennant Services, patients/residents, prospective patients/residents, or employees (which includes but is not limited to, current employees, job applicants, or sub-contracted employees) collectively referred throughout this Policy as (“consumer”).  This Policy applies to information collected through Pennant Services as well as information collected through any other means, including information you may provide to directly other than Pennant Services. This Policy does not address the use of information that is subject to the Health Insurance Portability and Accountability Act (“HIPAA”). For information about how The Pennant Group and it affiliates handle “protected health information” under HIPAA, please see our HIPAA Notice of Privacy Practice. 

If you are a California resident, for more information about your additional privacy rights, please see the section of this Policy title “California Privacy Rights”. 

CONTENTS OF THIS POLICY 

1. The Information We Collect 
2. How We Collect Information 
3. How We Use and Disclose Collected Information 
4. Categories of Information We Collect and Disclose 
5. Sale and Disclosure of Personal Information for Targeted Advertising 
6. Retention of Personal Information 
7. Your Choices Regarding Collection, Use and Sharing of Personal Information 
8. California Privacy Rights 
9. Exercising Your Rights 
10. Security 
11. External Links 
12. Consent and Jurisdiction 
13. Modifications to our Privacy Policy 
14. Contact Us 

THE INFORMATION WE COLLECT 

Pennant Services collects directly from consumers the following types of personal 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:  

• 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. 
• Employment related information – this may include but is not limited to: compensation, bonuses, benefits, attendance, evaluations, performance reviews, discipline, personnel files, expenses, education, corporate credit card details, membership in professional organizations, professional certifications, work eligibility in order to comply with legal requirements, current and past employment history, employee preferences, such as preferred meals, seating and other travel preferences, desired work hours, work space preferences and preferred work supplies. 
• Personal Information Categories From Cal. Civ. Code § 1798.80(e) – this may include but not limited to: photographs and physical description, medical information and benefits 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 advertisement, IP Addresses assigned to your computer by your Insert Service Provider.  Web servers automatically identify your computer by its IP address. We use your IP address to help diagnose problems with our server, to administer Pennant Services, avoid hacking attacks on Pennant Services including our website servers, and may use it to gather broad demographic information. 
• 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: precise physical location, 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 on a Pennant Services owned or managed community premises. 
• 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. 

• Anonymous Information – Anonymous Information is aggregate data that websites use to administer their website. It may include such information as your browser type or your Internet Protocol (IP) address. We may from time to time retain third parties to help us collect and aggregate visitor information on our website and through Pennant Services. 
• Cookie Information – As is the case with many websites, Pennant Services use a technology called “cookies”, which are small data files that are downloaded onto your computer. The use of cookies is standard on the Internet, and allows us to tailor your visits to Pennant Services 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. Although most web browsers automatically accept cookies, you can change your browser to prevent cookies or notify you whenever you are sent a cookie. Even without accepting a cookie, you can still access most of the features on Pennant Services. 
• 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; 
• Your racial or ethnic origin, religious or philosophical believes, or union membership; 
• Contents of your mail, email, and text messages unless Pennant Services is the intended recipient of the communication; 
• Genetic data; 
• Biometric information used to identify a consumer; 
• Health information; and 
• Information regarding a consumer’s sex life or sexual orientation. 

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 Pennant Services 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 Act (“CCPA”), such as health or medical information covered under 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”). 

Sensitive Personal Information does not include publicly available information. 

When you submit your information on Pennant Services, you agree to be contacted by a Pennant Services Representative at the telephone number you’ve provided, in response to your inquiry, between the hours of 7AM and 11PM ET. You agree that we may use automatic telephone dialing systems and technology to contact you by phone or text message at the telephone number provided, and send you email notifications regarding promotions and related material on senior living. 

HOW WE COLLECT INFORMATION 

There are several different ways Pennant Services collects your personal information.  The categories of sources in which may have collected your personal information includes the following: 

• Website cookies.  The use of website cookies is standard on the Internet, and allows us to tailor your visits to Pennant Services 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; 
• Directly from you via conversations, your interaction on our website, mail, e-mail, faxes, voicemails, and any documentation provided by you; 
• Business transactions where we may buy, merge or partner with other companies or businesses, and in doing so, we would acquire consumer information.  
• Directly from you via employment applications or employment contracts; 
• 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; and 
• Government agencies 

HOW WE USE AND DISCLOSE COLLECTED INFORMATION 

• The personal information collected by us may be used in a several ways including the following business and commercial purposes: 
• Providing our services; 
• Providing customer service; 
• Providing you with promotional materials such as notifying you regarding certain services we provide, programs we provide and events that we are having; 
• Understanding what information and services consumers want the most; 
• Providing business support to Pennant Services operations; 
• Performing analytics and quality control; 
• To conduct internal investigations and audits; 
• Researching and testing features and improvements; 
• Detecting and preventing fraud and security incidents; 

• Debugging or repairing technical errors; 
• Marketing our services; 
• Managing personnel; 
• Recruiting purposes such as evaluating applicants’ qualifications for employment, communicating with applicants, for diversity and inclusion purposes, and for record keeping purposes. 
• Security and internal identification purpose; 
• Conducting legal analysis; 
• To comply with any applicable laws, regulations or statutory requirements; 
• Business transfers; in the unlikely event that a portion or substantially all of Pennant Services’ assets are sold or transferred to a third party, personal information would likely be transferred business assets; 
• Developing and managing relationships with current or new business partners, vendors and other business partner personnel 

CATEGORIES OF INFORMATION WE COLLECT AND DISCLOSE 

The following chart provides information about the types of personal information we collect, the categories of sources from whom we collected the information, the business or commercial purposes for which collected 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. 

Sale and Disclosure of Personal Information for Targeted Advertising 

Pennant Services does not directly sell your personal information, we may share your personal information with third parties outside of Pennant Services as described below.  Certain states have adopted laws that contain a broad definition of “sale” or “share” and may view certain disclosures of personal information as sales or sharing under their respective definitions.  

For California consumers, in the previous 12 months, we have disclosed your personal information for cross-contextual or behavioral targeted advertising (which may constitute as “sale” or “sharing” under the California law), and we may continue to disclose, the following categories of personal information for the identified business or commercial purpose: 

RETENTION OF PERSONAL INFORMATION 

Pennant Services 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.  

YOUR CHOICES REGARDING COLLECTION, USE AND SHARING OF PERSONAL INFORMATION 

Pennant Services supports the right of our visitors to choose. If you decide that you do not wish to receive special offers or promotional communications, you can contact us at the address provided below, indicating that you would like to opt-out and no longer want to receive information relating to Pennant Services.  

Depending on your state of residency, you may have rights regarding your personal information, which are described below, and may include rights to correct, amend or delete your personal information. If you wish to exercise these rights, or make a request regarding your personal information, please contact us by email or postal mail at the addresses below or as described in the Exercising Your Rights section. 

If you have consented to a use of your personal information and would like to revoke that consent, or would like to opt out of emails or other marketing, please contact us. Although it is not always possible to remove or modify certain information, we will make reasonable efforts to do so. 

To make such a request, you may contact us online, by mail or by telephone at this link: 

Pennant Services, Inc. 

Attn:  Compliance Department 

1675 E. Riverside Dr. Suite #200 

Eagle, ID 83616 

Pennant Compliance Hotline:  1-866-987-3715 (accessible 24 hours a day/7 days a week) 

CALIFORNIA PRIVACY RIGHTS 

The CCPA, which was amended by the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to herein as the (“California Consumer Privacy Laws”), are laws that are intended to give California consumers more control, personal rights, and protections regarding the personal information that businesses collect about them.  The following rights can be exercised by California consumers regarding their personal information gathered by Pennant Services: 

• Right to Access.  California consumers have the right to access the personal information which Pennant Services may have collected or retained about them.  If requested through a verifiable request, Pennant Services 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.  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 1-866-987-3715 or online by clicking here. 

• 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 Pennant Services has collected about you.  Therefore, you have the right to submit a verifiable request to Pennant Services, by clicking here, requesting that we disclose the following, as defined by the California Consumer Privacy Laws: 

• What personal information Pennant Services has collected; 
• The categories of personal information Pennant Services 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 Pennant Services may disclose your personal information; and 
• The specific pieces of personal information Pennant Services 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 1-866-987-3715 or online by clicking here. 
• 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: 

• After you request deletion, you will need to confirm that you want your information deleted. 
• 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 1-866-987-3715 or online by clicking here. 
• 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 Pennant Services may deny your request to delete information due to legal reasons consistent with the California Consumer Privacy Laws. 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.  Pennant Services 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: 

• You will need to specify the information you believe we have recorded incorrectly. 
• 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 1-866-987-3715 or online by clicking here. 
• 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 most cases, you will need to submit documentation to support your requested correction. For example, if you believe your mailing address is incorrect in our records, you will need to provide evidence of the correct mailing address. If we deny your request, we will explain why we denied it. 

• Right to Opt-Out of the Sale or Sharing of Personal Information.  Pennant Services 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 Pennant Services for cross-context behavioral advertising.  You may request to opt-out by clicking here.  
• Right to Limit Use of Sensitive Personal Information.  You have the right to limit the use and disclosure of your SPI (defined above) obtained by Pennant Services.  You can make a request to limit the use or disclosure of your Sensitive Personal Information by clicking here.  
• 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. 

Please note that these specific California privacy rights does not apply if all of the personal information Pennant Services collects is exempt from the California Privacy Laws.  The California Privacy Laws do not apply to personal information that is publicly available or information that is already protected by other 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”).  The California Privacy Laws also do not apply to de-identified or aggregated information.  

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, online by clicking here or submit a request in writing to: 

Pennant Services, Inc. 

Attn:  Compliance Department 

1675 E. Riverside Dr. Suite #200 

Eagle, ID 83616