Privacy Policy
Last Updated: April 24, 2023
Introduction
This Privacy Policy applies to information collected, stored, or shared by all of the following companies (collectively referred to as the “Company” or “we”):
This Privacy Policy does not apply to Oasis Senior Advisors which has a separate Privacy Policy.
This Privacy Policy describes the type of information about you (“Personal Data”) that we may collect from you or that you may provide in connection with services provided by the Company (“Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy applies to the information we collect:
Please note that we may use, maintain, or disclose your Personal Data, including Personal Financial Data, even if you are no longer using our Website or our Services.
Please read this Policy carefully to understand our policies and practices regarding your Personal Data and how we will treat and collect it. By accessing, visiting, or using the Services, you acknowledge your understanding of this Privacy Policy. If you do not agree with the contents of this Privacy Policy, you should not access, visit, and/or use the Service.
This Privacy Policy may be modified at any time without prior notice to you. Your continued access, visitation, and/or use of the Service will constitute your acceptance of any changes or revisions to this Privacy Policy. The date at the top of this page will change when the Policy is revised, and such date change will be your notification that this Policy has changed.
Definitions of Terms Used in this Policy
“CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.
“Device” means any computer, tablet, mobile phone, or any other device capable of accessing the Service.
“Personal Data” means 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, Device, or household. Anonymous, de-identified, or aggregate information is not Personal Data.
“Sensitive Personal Information” means personal information that reveals (a) consumer’s Social Security or other state identification number; (b) a consumer’s 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; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
“Service” or “Services” means the utilization of the website, mobile site, application, email/text/SMS campaign, event, and/or other activity, offering, or publication provided by us, and any other action taken by us in relation to the Site or your use of the Site.
“Service Provider” has the same meaning as set forth in the CCPA, which in general means a for-profit legal entity to whom we disclose Personal Information for processing on our behalf for a “business purpose” (as defined in the CCPA) pursuant to a written contract.
“Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Data, including clients or partners who advertise, market and sponsor their goods and services, consumer data suppliers and resellers, data enrichment providers and aggregators, social media and social networking services, advertisers, and any other businesses that assist us with our Services.
“We,” “Us,” “the Company” and “Our”, whether capitalized or not, refers to SilverAssist, and its subsidiaries, affiliates and other related entities.
“You” or “Your,” whether capitalized or not, means all those who access, visit and/or use the Service.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under the age of 16 may provide any information to or on our Website. We do not knowingly collect Personal Data from children under 16. If you are under the age of 16, do not use or provide any information on our Website or on or through any of its features, register on our Website, use any of the interactive or public comment features of our Website, or provide any Personal Data to the Company, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under the age of 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at info@silverassist.com.
Information We Collect and Receive About You
We may receive or collect several types of Personal Data (each, a “Personal Data Category”), such as the information described below, information you provide to us, as well as information we collect through automatic data collection technologies as described below (e.g., usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies).
| Personal Data Category | Examples |
| Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
| Characteristics of protected classifications under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy, or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
| Internet or other electronic network activity information | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement |
| Professional or employment-related information | Current employment information |
| Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
While we generally do not obtain biometric, insurance, or medical information, we may do so when such Personal Data is necessary to offer you certain services or where otherwise permitted by law.
How We Acquire Your Personal Data
Personal Data You Provide. You may provide Personal Data to us:
Personal Data Acquired from Third Parties. We may acquire your Personal Data from third parties. For example, we may purchase or otherwise acquire Personal Data from third-party consumer data suppliers/resellers, data aggregators, advertising networks, data analytics providers, internet service providers, operating systems and platforms, data brokers, business contact databases, government entities, and our parent, subsidiaries, affiliates, and other related entities.
Personal Data Automatically Collected. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please contact us at info@silverassist.com if you would like to opt out of behavioral tracking on this website and learn how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. Otherwise, please note that we do not respond to browser do-not-track (DNT) signals.
The information we collect automatically includes statistical data and helps us improve the Website and deliver a more personalized service to you. It also enables us to (a) estimate the number of users of our Website and usage patterns; (b) store information about user’s preferences so that the Website can be customized for users; (c) recognize users when they return to the Website; and/or (d) present search results more quickly.
Various technologies used for such automatic data collection may include:
How We Use Personal Data
In addition to the uses described above, we may also use Personal Data for other lawful business purposes such as customer service support. For example, we may use Personal Data to confirm and complete transactions requested by you, verify information you provide to us, provide you with administrative notices, provide you with information, products, or Services that you request from us, notify you about changes to our Website or Services, and contact you ourselves or through our partners by telephone, email, mail, or other communications with updates, promotional materials, surveys, offers, quotes, personalized information, and other information from us or our business partners.
How We Disclose Personal Data
Third Parties with Whom We May Share Your Personal Data.
We may disclose your Personal Data to the following categories of third parties:
Service Providers. We may share your Personal Data with Service Providers that perform services for us, but only for the purpose of and to the extent necessary to perform those services.
Third-Party Businesses. We may sell, share, and transfer Personal Data to the following types of Third-Party Businesses:
In all such cases, your Personal Data may be used by us and by such Third-Party Business(es) for its own purposes, each pursuant to its own policies.
Affiliates. We share your Personal Data with our parent, subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, and others, for all purposes described in this Section.
Marketing Communications. We may use your Personal Data to communicate with you about new features, events or Services offered by us and Third-Party Businesses, including our advertising, marketing, and sponsorship clients.
Health, Safety, and Legal Requests. We may share your Personal Data for purposes of health, safety, and other matters in the public interest. We may also share your Personal Data to cooperate with official investigations or legal proceedings brought by or otherwise involving government and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also use Personal Data to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.
Transfer or Sale of Our Business. If the Company or its parent, subsidiaries, affiliates, or other related entity or entities is involved in a business transaction, including the purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization, or financing involving the Company or its parent, subsidiaries, affiliates or other related entity or entities, we may share your Personal Data in connection with such transaction. We may also share your Personal Data to legal, financial, insurance, or other advisors in connection with such business transaction or management of all or part of our business or operations.
Aggregated Data. We may disclose aggregated information about you without restriction. We may take Personal Data and de-identify it either by combining it with information about other individuals (aggregating Personal Data with information about other individuals) or by removing characteristics (such as your name) that make the information personally identifiable to you (de-identifying Personal Data). We reserve the right to share, loan, rent, sell, or otherwise disclose such information to third parties at any time, for any lawful purpose, without notice or compensation to you.
Categories of Personal Data We Disclose
We may disclose your Personal Data to a third party for a business purpose. In the preceding 12 months, we have disclosed the following Personal Data Categories for a business purpose:
Categories of Personal Data We Sell
In the preceding 12 months, we have sold the following Personal Data Categories for a business purpose:
Accessing and Making Choices About Personal Data
Cookies. As stated above, a cookie is a small file placed on the hard drive of your computer. We and our partners, including advertisers and Service Providers, use cookies to help us know when you are logged on, provide you with features based on your preferences, and understand how you interact with and use our Website. You may refuse to accept browser cookies by activating the appropriate setting on your individual browser. If you refuse cookies, you may still use the Website, but you may be unable to access certain parts or features of the Website. Unless you have refused cookies, our system will issue cookies when you direct your browser to our Website. Third-party partners of our Website also use cookies to collect and store information about your use of the site or to display advertising based on your browsing and navigation activity.
Requests for Quotes, Information, and Services from Service Providers
Data Security
Security Measures. We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Data. Such measures include the following:
While we try to prevent accidental loss and unauthorized access, use, alteration, and disclosure of Personal Data with certain physical, electronic, and managerial procedures, no method of transmission or electronic storage is 100% secure, and we cannot guarantee full security.
Your contribution is important to protect the security of your access to our Services. You are responsible for maintaining the confidentiality of your password and for restricting access to your computer, and you agree to accept responsibility for all activities that occur on your account or with your password. In the event that the confidentiality of your account or password is compromised in any manner, you will notify SilverAssist immediately. SilverAssist reserves the right to take any and all action, as it deems necessary or reasonable, to ensure the security of the Website and your account. You can help prevent unauthorized access by following these security tips:
No Liability for Breach. You use our Website and Services at your own risk, and we do not promise or guarantee, and you should not expect, that Personal Data will always remain private. In the event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use, or disclose Personal Data.
Breach Notification. If we believe the security of your Personal Data in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.
Rights of California Residents. The CCPA grants residents of California certain rights with respect to their Personal Data.
Special Notification Regarding Personal Financial Data
Federal law gives consumers the right to limit some, but not all, sharing of your Personal Financial Data. Federal law gives you the right to limit only:
To limit such sharing of your Personal Financial Data, please contact us by email at privacy@silverassist.com or in writing at:
SilverAssist
ATTN: Legal Department
100 Bluegrass Commons Blvd.
Bldg. 1, Ste. 120
Hendersonville, TN 37075
Special Notification for California Residents — Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (“CCPA“), California residents have certain rights around Silver Assist’s collection, use, and sharing of their Personal Data, except that the rights granted to California residents under the CCPA do not apply to Personal Financial Data protected under Federal law.
California Do Not Track Disclosure: California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks, and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.
California residents have the following rights under the CCPA:
Exercising Your Rights Under the CCPA.
We will not discriminate against you for exercising your rights under the CCPA. We may take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.You may send your request for access to that Personal Data or request deletion by email to privacy@silverassist.com or in writing at:
Silver Assist
ATTN: Legal Department
100 Bluegrass Commons Blvd.
Bldg. 1, Ste. 120
Hendersonville, TN 37075
California’s “Shine the Light” law, California Civil Code §1798.83, gives California customers the right to prevent our disclosure of their Personal Data to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. Please submit such requests using the contact information above.
California privacy rights requests must include the reference “Request for California Privacy Information” in the subject line, and in the body of the message, and must include an email address or mailing address that we may use for the response. We reserve the right not to respond to requests submitted other than as specified above.
You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:
Make other internal and lawful uses of that information that are compatible with the context in which it was provided. You have the right to request that we limit the use and the sharing of your Sensitive Personal Information to what is reasonably commercially necessary to perform our Services.
If you opt out of the sale of your Personal Data, we may still share your Personal Data with third parties if those transfers are not sales, such as with our Affiliates or our Service Providers.
Response Timing and Procedures
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.