Privacy Policy

LEGAL
ASPEN SENIOR LIVING

PRIVACY POLICY

Last updated on 20 July 2022

This Privacy Policy applies to the website(s) and mobile applications (together, the “Sites”) provided by Aspen Senior Living (“Aspen”), and/or associates, and/or collaborative partners, and/or affiliate companies ASPEN (“ASPEN”, “we”, “us”) who act as data controllers ^[1] with respect to the personal data you share with ASPEN under this Policy.

The Sites include www.aspenseniorliving.com  and additional websites or mobile applications produced and managed by ASPEN and other websites of controlled ASPEN that link to this Privacy Policy. By providing personal information to us, you agree to this Privacy Policy.

ASPEN knows that your privacy is important to you and takes user privacy very seriously. We are committed to protecting your personal data ^[2] (i.e. any information you provide to us from which you can be identified) in accordance with this Privacy Policy.

ASPEN reserves the right, at its sole discretion, to alter and update this Privacy Policy from time to time. We therefore invite you to review the current version of the Privacy Policy each time you return to our Sites.

1. INFORMATION WE COLLECT AND HOW WE USE IT

ASPEN might collect personal data from you such as your name, contact details, occupation, company or university affiliation, industry, region/country, relationship to ASPEN, reason for contacting ASPEN, topics you are interested in and any other information you choose to share. By browsing our Sites or sending us information, you explicitly consent to ASPEN processing your personal data in accordance with this Privacy Policy. ASPEN might use your personal data to fulfil your request, send you marketing communications, process your job application or manage any products and services.

ASPEN collects personal data from you when you request information from ASPEN and/or supply, information through the Sites, such as when you fill out a subscription form or consulting expertise inquiry, opt in to receive emails from ASPEN, agree to participate in surveys, and/or purchase products and services from ASPEN.

Personal data we collect might include your name, e-mail address, title, occupation, company or university affiliation, industry, region/country, relationship to ASPEN, reason for contacting ASPEN, topics you are interested in, any other background information provided with an application and any other information contained in messages you send us.

By browsing our Sites and submitting this information to us, you explicitly agree to ASPEN using your personal data for the purposes and in the manner described in this Privacy Policy. Please do not send us any information you do not wish ASPEN to use.

ASPEN will use your personal data to fulfil your request, provide you with the information you requested and/or send you marketing communications. If you have applied for a job at ASPEN, your data will be processed for the purposes of evaluating and processing your application and candidacy for the position to which you have applied. We may also use your information to analyze and improve our recruiting and onboarding processes as well as to communicate with you about ASPEN events and to send you publications that we think may be of interest to you. More detail can be found in the Job Applicants section.

ASPEN may collect personal data and may disclose such information to third party service providers in aggregate for marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to personally identify you.

You do not have to provide us with any personal data.  However, if you do not, we may be unable to handle your request or to provide you with the services you are requesting.

ASPEN will keep your personal data for as long as needed to handle your request or for as long as we have a relationship with you. If you have applied for a role with ASPEN, ASPEN will keep your personal data associated with your application for a period of up to five years.

Please note that ASPEN is not responsible for any information you may disclose publicly in any chat rooms, message boards, or similar web pages, including those hosted on or linked to our Sites. You should keep in mind that, whenever you publicly disclose information about yourself online (for example, via message boards or chat rooms), such information could be collected and used by people whom you do not know. In addition, certain message boards and similar user forums may display IP addresses along with the message poster’s name and message. ASPEN bears no responsibility for any action or policies of any third parties who collect any information users may disclose on the message boards, chat areas or other user forums, if any, on the Sites.

1. USE OF COOKIES ON THE SITES

Our Sites may use cookies or other technology to obtain certain types of information about you. You can disable or delete cookies by going to the Help section of your browser but certain functionalities of our Sites might not work properly if you do so.

We may use cookies or other technology (“cookies”) to obtain certain types of information when you browse our Sites. “Cookies” are small text files that are stored by your browser on your computer’s hard drive. Cookies can be placed on your computer directly by one of our Sites (first party cookies) or by another website (third party cookies).

We may use cookies to keep track of your visit to our Sites, speed up navigation and improve your experience of the site, (for instance by remembering some of your preferences or choices, the last pages you visited or searches you carried out or by keeping you logged in).

Our Sites may use cookies such as Google Analytics to carry out some analytics on and enhance our Sites. These cookies help us understand, for example, how you use our Sites, which pages are the most visited or where people visiting our Sites are located.

We may also use cookies to enable you to share content on networking or social media sites or for marketing and promotional purposes where you have subscribed to our marketing communications from ASPEN.

The “help” section of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies, and how to disable or delete cookies altogether.

If you choose to disable cookies, certain functionalities of our Sites might not work.

1. WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with other companies of ASPEN and/or associates, and/or collaborative partners, and/or affiliate companies of ASPEN as well as with other third parties that might be located in a different country than your country of residence. ASPEN will not share or sell your data to any third party for their own use.

We may share your personal data with others, such as:

• carefully selected third party service providers, such as marketing service providers (if you have subscribed to our marketing communications), IT systems providers, recruitment service providers, background check providers, data cleansing providers or event organizers, so they can provide services to ASPEN;
• law enforcement authorities or other government bodies when we are required to do so
• Third parties, other than law enforcement authorities or government bodies, will only handle your personal data on behalf of ASPEN for the purposes described in this Policy. ASPEN will not sell or otherwise share your personal data with such third parties for their own use.
• The companies of ASPEN and/or associates, and/or collaborative partners, and/or affiliate companies of ASPEN and other third parties we share your information with may be located in other countries, including countries that do not offer the same protection to your personal data as the country in which you reside. Where that is the case, ASPEN ensures that your personal data is protected by using appropriate legal mechanisms. If you reside in the European Union, such mechanisms include using contracts or wording approved by the European Commission (called “Standard Contractual Clauses”) ^[3]or, in the case of US-based companies, working with companies that are Privacy Shield certified.
• to facilitate your participation in interactive features you may choose to use on our Websites and personalize your experience on the Websites by presenting content tailored to you;
• to correspond with you, notify you of events or changes to our service, or otherwise to fulfill your requests and respond to your queries and requests for information, which may include marketing to you; and
• for the purposes of providing professional services to you via ASPEN applications; such services will be subject to additional terms and conditions of use including privacy;
• for our business purposes, such as data analysis, audits, fraud monitoring and prevention, and developing new products, enhancing, improving or modifying our Websites, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• Responding to your request for information, order, or support
  When you contact us (online or offline) in connection with a request for information, to order a product or service, to provide you with support, or to participate in a forum or other social computing tool, we collect information necessary to fulfill your request, to grant you access to the product or service, to provide you with support and to be able to contact you. For instance, we collect your name and contact information, details about your request and your agreement with us and the fulfillment, delivery and invoicing of your order and we may include client satisfaction survey information. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you.
• When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit our websites. For ordering of most services and products, we require you to have registered with ASPEN. Registration may also allow you to customize and control your privacy settings.
• Contacting employees of our clients, prospects, partners, and suppliers
  In our relationship with clients or prospects, partners and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfillment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.
• Visitor information
  We register individuals visiting our sites and locations (name, identification, and business contact information) and use camera supervision for reasons of security and safety of persons and belongings, as well as for regulatory purposes.
• Marketing
  Most information we collect about you comes from our direct interactions with you. When you register for an event we may collect information (online or offline) in relation to the event organization, and during an event, such as participation in sessions and survey results. We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes. You can choose to receive information by email, telephone or postal mail about our products and services, or sign-up for subscriptions. When visiting our websites or using our services we may provide you with personalized information. You can always opt-out from receiving personalized communication by sending an e-mail to privacy@aspenseniorliving.com .
• Where we reference that we use your personal information in connection with a request, order, transaction or agreement (or preparing for the same), or to provide you with services that you requested (such as a website), we do this because it is necessary for the performance of an agreement with you.
• Where we reference that we use your personal information in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party’s legitimate interests, or with your consent.

1. LINKS TO OTHER WEBSITES

Our Sites may contain links to third party websites that are governed by their own terms and privacy policies. ASPEN does not bear any liability and responsibility for the content or your use of these websites.

The Sites may contain links to third party websites, including social network sites. Such websites are governed by their own terms of use and privacy policies, which you should review before browsing or submitting information to them. ASPEN is not responsible for the privacy practices of such websites. In addition, a link to a third party website does not mean that ASPEN endorses or accepts any responsibility for the content or the use of such web site. ASPEN shall not bear any liability and responsibility for such content or for your use of these websites.

1. SECURITY OF YOUR PERSONAL DATA

ASPEN has implemented appropriate technical and organizational security measures in order to protect your personal data from loss, misuse, alteration, or destruction.

ASPEN has implemented appropriate technical and organizational security measures in order to protect your personal data from loss, misuse, alteration, or destruction. Such measures include anonymizing ^[4] or pseudonymizing ^[5] data where possible. Authorized ASPEN personnel and third parties mentioned above will only have access to your personal data to the extent they need it to do their job or provide their services. Despite these precautions, however, ASPEN cannot guarantee that unauthorized persons will not obtain access to your information.

1. YOUR RIGHTS

Depending on where you reside you might have the right to request access to, rectification or erasure of your personal data and to object to or ask for the restriction of the processing of your personal data. You might also have the right to withdraw your consent and request that we stop processing or delete your personal data.

Depending on where you reside, you may be entitled to certain rights regarding the personal data ASPEN holds about you. For instance, you may have the right to request access to your information, obtain a copy of it as well as information about how we use it. You have the right to request that we correct incorrect, inaccurate or out-of-date information about you. You may also have the right to request that we stop processing your information and/or withdraw your consent to such processing and to ask us to delete your information.

If you receive marketing communications from ASPEN, you can opt out of receiving future emails from ASPEN or unsubscribe from participating in our programs.

If you wish to make a request about your personal data please contact us at privacy@aspenseniorliving.com. Please note that we will take reasonable steps to check your identity before handling your request.

If you think we are handling your information unlawfully, we encourage you to get in touch with us at privacy@aspenseniorliving.com. You may also have the right to lodge a complaint with your national supervisory authority.

1. JOB APPLICANTS

If you apply for a job at ASPEN, you will be asked to submit information to ASPEN such as your name, contact details, information about your education and work history and any other background information that might be relevant for your application or that you choose to share with ASPEN. If you do not provide this information to us, we might not be able to process your application.

ASPEN will use this information to assess your application and candidacy for the position to which you have applied. Without limiting the generality of the foregoing, this may include: (i) evaluating your skills and experience in relation to the qualification required for the job to which you have applied; and (ii) tracking feedback and interactions we have with you throughout the recruiting process. We may also use your information when analyzing our internal recruiting processes to determine (i) which recruit sources to focus on; (ii) how to improve integration and training programs for new hires with different educational backgrounds and work experience; and (iii) how to enhance our interview model to improve hiring quality. The information you provide may also be used to communicate with you about ASPEN events and to send you publications that we think may be of interest to you.

We might share your personal data with other companies in the ASPEN group as well as with third parties such as recruitment service providers, background check providers and IT system providers. These ASPEN companies and third parties might be located in a different country than your country of residence. In particular, if you apply for a consulting role, your data will be stored in a third party database hosted in the Netherlands.

We will keep your application data for up to five years. If you no longer wish for ASPEN to process your data or if you wish to exercise your rights, please contact ASPEN at privacy@aspenseniorliving.com.

1. CHILDREN

Our Sites are not directed at children 16 years of age or younger. ASPEN, therefore, will not intentionally collect information about anyone under the age of 16, and requests that no such information be submitted to us.

1. CONTACT

If you have any questions about this Privacy Policy or how ASPEN handles your personal data, please contact ASPEN’s Data Protection Officer:

Email: privacy@aspenseniorliving.com

Definitions

1. The data controller is the person or company that, together or jointly with others, determines the purposes (why) and means (how) of the processing of personal data.
2. Personal data is any information that relates to an individual who is identified or identifiable, for instance by reference to a name, an identification number or an online identifier.
3. Standard Contractual Clauses are an agreement that can be entered into by companies for transfers of personal data outside of the European Union. They are a mechanism approved by the European Commission to ensure adequate safeguards to personal data when it is transferred outside of the European Union.
4. Anonymizing means transforming data in such a way that it is no longer identifiable, i.e. the data can no longer be linked to an individual, even if combined with other information. Anonymous data is not considered “personal data”.
5. Pseudonymizing means transforming data in such a way that it is no longer identifiable without the use of additional information. Pseudonymous data is still considered “personal data”.