Visiting Angels Privacy Notice

This policy is effective and was last updated: October 2024.

This Privacy Notice applies to information collected from online users of this website ("Site"). In this policy, you can learn what kind of information we collect, when and how we might use that information, how we protect the information, and choices you have with respect to your personal information. By using or accessing the site, you agree to the terms and conditions of use, including without limitation the terms of this Privacy Notice. If you do not agree to the collection or use and disclosure of your information or personal information as set forth herein, you may not use this Site.

This Privacy Notice IS NOT the same as a NOTICE OF HIPAA PRIVACY PRACTICES, which discusses how Visiting Angels manages client's Protected Health Information (PHI) among other things. Your Visiting Angels Notice of Privacy Practices is available through a link located on the homepage of your Visiting Angels' local Site. You may also call the offices at the phone number on the Site's homepage and ask for a copy of the Notice of HIPAA Privacy Practices at any time.

Contents

1. General tracking information
2. Automated Tracking
3. What Personal Information We Collect
4. Use of Personal Information We Collect
5. Sharing of Personal Information
6. Links to Third Party Websites
7. Security
8. Opt-Out
9. Use of Browser's Settings and Signals
10. Visitors Who Reside Outside the United States
11. State Privacy Laws
12. Children's Online Privacy Protection Act (COPPA)
13. Can-SPAM Act
14. Changes to this Privacy Notice
15. Disclaimer
16. Review
17. Contact Us

1. General tracking information

Automatic Information Collection and Use

Particular information is collected by your browser, such as your operating system name and version, Internet browser type, computer type (Windows or Mac), screen resolution, and version. We may collect similar information, such as your device type and unique device identifier, if you access the webpage through a mobile device and to understand how you use our website. We use this information to ensure that the website functions properly and gives you the best customer experience.

Web-Based Tracking Technologies

Pixel tags, web beacons and other web-based technologies may be used in connection with some of our web pages and HTML-formatted e-mail messages to track the actions of users and email recipients, measure the success of our marketing campaigns, and compile statistics about the Service usage.

At times, we might use third-party advertising companies to send advertisements regarding goods and services that may be of interest to you when you access and use our website. We use information based on your access to and use of our website. These third parties, such as Google or Meta, may use unique cookies, web beacons, pixels, and other technologies to collect or receive information from the web and other places on the Internet to develop information to enable us to create targeted advertisement and measure the effects of our ads.

Opting out of Web-Based Tracking Technology

For more information on these practices and to learn how to opt out of it in your desktop and mobile browsers on the device that you are using, visit:

• https://optout.aboutads.info/#/
• https://optout.networkadvertising.org/

You may also download the APPChoices app to opt-out in mobile apps at:

www.aboutads.info/appchoices.

If you would like to opt-out from the use of your information by Google Analytics, you may use the Google Analytics opt-out browser add-on designed for this purpose, which is available here:

https://tools.google.com/dlpage/gaoptout.

IP Address

Your computer IP address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP address is identified and logged automatically in our server log files whenever a user visits the website, along with the time of the visit and the pages visited. Collecting IP addresses is common practice and is done automatically by many online services. We use IP addresses for purposes of ensuring a good customer experience, such as calculating website usage levels, diagnosing server problems, and administering the site. We may also derive your approximate location from your IP address.

2. Automated Tracking

Technologies such as cookies, beacons, tags, and scripts are used by Visiting Angels and our affiliates, our marketing, testing and quality assurance partners, or our analytics, information technology and web monitoring service providers. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Mobile applications may also use cookies. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you and to improve marketing, analytics, or site functionality. We use Local Storage, also referred to as HTML LS, to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use Local Storage to collect and store information. Various browsers may offer their own management tools for removing HTML LS's.

We partner with third party ad networks to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner may use cookies, IP addresses, cookie identifiers, website activity, and/or Web beacons to collect non­personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests.

Do Not Track

The website does not take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set your browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page.

3. What Personal Information We Collect

If you choose to register on our Site, you will be asked to provide Personal Information which may include your name, mailing address, e-mail address, and phone number. We do not actively share Personal Information gathered from our Web servers. When you register, we will place your name in our mailing list and will send you an e-mail to the address you have provided to confirm your registration on our Site. For information on how to activate Do Not Track, visit privacybadger.org.

4. Use of Personal Information We Collect

We require Personal Information from you in order to learn more about how you use the Site; to measure areas of interest in our network and the services we provide; to understand the needs of our customers; to provide you with better service; and to help us with internal record keeping. If you register, your registration information may be used by Visiting Angels and our Franchisees and Master Franchisees for internal research purposes and may be compiled as part of our internal database system. In addition, we may send correspondence to the e-mail and/ or street address you provide to us when registering on our Site. This correspondence may include newsletters, promotional offers, information on new features and services we provide, Site updates, responses to your e-mails, comments and opinions, and may also be used as a means of providing technical support. We may also offer you the opportunity to receive information via SMS or text messaging. Note that when you choose to receive information via SMS or text, you may reply STOP at any time if you change your mind. Additionally, message rates based on your carrier may apply. By agreeing to receive SMS messages you are agreeing to the terms of service and this Privacy Notice. You will have an opportunity to limit these uses at the time your Personal Information is collected. You also may limit the correspondence by following the instructions in the "Opt-Out" Section below.

5. Sharing of Personal Information

We do not sell or share your Personal Information to third parties. We will not provide or sell any Personal Information to marketing research or bulk advertising sales companies.

We may provide your Personal Information to companies that provide services to help us with our business activities such as offering customer service. We will share your Personal Information with our Franchisees and Master Franchisees who are bound to protect such information from disclosure or misuse. These companies are authorized to use your Personal Information only as necessary to provide these services to us. They are contracted and will keep your information safe and only use it in the manner to support your customer experience. We will not share mobile information with third parties/affiliates for marketing/promotional purposes. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Sharing when required by law

We reserve the right to disclose your Personal Information to law-enforcement personnel and agencies when requested to do so or as required by law such as to comply with a subpoena or if Visiting Angels is involved in a merger, acquisition, or sale of all or a portion of its assets. In any of these situations, registered users will be notified by e-mail of our intent to disclose information. We may also disclose Personal Information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may have breached our Terms of Use, or who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users, or anyone else who could be harmed by such activities.

We may also disclose Personal Information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may have breached our Terms of Use, or who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users, or anyone else who could be harmed by such activities.

Mobile Subscriber Information

Your mobile information will NEVER be shared with other parties under any circumstances. This includes no sharing with Third-Parties, affiliates, or for marketing or promotional purposes.

We will not share mobile information with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Text Messages

You authorize us to contact you, including by sending text messages directly or through a conduit text messaging service and other communication to a cell phone using an automatic dialing system or an artificial or prerecorded voice message, at any number you provide. You acknowledge that any text messages or prerecorded messages sent by us may contain sales or marketing content. You may revoke your consent for us to contact you at a specified telephone number by communicating your revocation to us through any reasonable means.

Ring Central

Ring Central is one of our service providers that we have hired to improve your experience as a customer of the company. Ring Central collects any information which you share with them as a service user including names, account numbers, and any other information (including but not limited to documents, SMS, pictures, transcripts, notes, recordings, voicemails, etc.) or other information you or another user or participant upload, provide, grant access to or otherwise implement. You control the content that is provided. Note that they may also collect

• Device information (such as IP address, ISP, device and operating system type, operating system and client version, type of microphone or speakers, and other related information)
• System logs, including usage logs, backend logs, client logs
• Internal feature usage analytics
• Cookie identifiers
• Traffic data about the communications that take place through the platform (such as chat, video conferencing) which include, network monitoring data, and call detail records produced by a telephone call or other telecommunications transactions. The call detail record contains various attributes of the call, such as time, duration, completion status, source number and destination number.
• Quality of Service data
• Fraud and threat analysis data
• Connection type and related information (e.g., connected over Wi-Fi)
• Geolocation information

They do not share your information with any third parties. For additional information on Ring Central’s Privacy Notice visit their Privacy Notice page: https://www.ringcentral.com/legal/last-update-july-29-2024/privacy-notice.html

6. Links to Third Party Websites

Occasionally we may include on our Site a hyperlink (a "Link") or a banner advertisement ("Banner Ad") containing a Link which allows you to connect to the home page of Third-Party website ("Third-Party Site"), the website of a Franchisee ("Franchisee Site") or the website of a Master Franchisee ("Master Franchisee Site"). Visiting Angels provides these Links to you as a convenient method of accessing information that may be useful or of interest to you. This Privacy Notice and the practices that we follow under this Privacy Notice do not apply to Third Party Sites, Franchisee Sites or Master Franchisee Sites that are operated independently from Visiting Angels.

We are not responsible for the content, accuracy, or opinions expressed on any Franchisee Site, Master Franchisee Site or Third-Party Site or for the privacy practices of our Franchisees, Master Franchisees or any third party. We will not, and are under no obligation to, investigate, monitor or check the Franchisee Sites, Master Franchisee Sites or Third-Party Sites for accuracy or completeness, or for any obscene, scandalous, inflammatory, pornographic, indecent, profane, defamatory or unlawful content or materials. Inclusion of any Link or Banner Ad to a Third-Party Site, or Franchisee Site or Master Franchisee Site that is placed on our Site does not imply approval or endorsement of the Third-Party Site, Franchisee Site or Master Franchisee Site. You understand and agree that by clicking on a Link to a Third-Party Site, Franchisee Site, or Master Franchisee Site you have left this Site, and the Visiting Angels Privacy Notice stated on this Site is no longer in effect.

Our Site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini programs that run on our Site. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy Notice of the company providing it.

7. Security

We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Our hardware, software, and security infrastructure as well as our internal standards for this Site to meet current industry standards and technology. In addition, we will be using standard Secure Sockets Layer (SSL) certificates to secure all pages used for inputting user Personal Information. However, due to the open communication nature of the Internet, we cannot guarantee that communications between us will be free from unauthorized access by third parties.

8. Opt-Out

You may choose to have your name taken off of our registration list, cease receiving correspondence or newsletters from us, or you can update or delete the Personal Information that you have provided to us, via one of the following methods:

• Using the opt-out option in e-mails you receive from us
• Sending us an e-mail at: customersupport@visitingangels.com
• Writing to us at: Living Assistance Services, Inc., 937 Haverford Road, Suite 200, Bryn Mawr, PA 19010; or calling us toll free at: 1.800.365-4189

We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Use of Browser's Settings and Signals

As stated under "2. Automated Tracking," we use cookies to help gather information about visitors to our Site for demographics and to provide a better, more personalized experience for visitors and users of our Site. When you visit our Site, you may use browser settings that reject cookies or tracking, or alert you when a cookie is placed through your browser. However, if you use such browser settings, you may not be able to use or access all of the features and functionality of our Site. When you visit our Site, you may also use browser settings that block ads. However, if you use such browser settings, you may not be able to use or access all of the features and functionality of our Site. We reserve the right to change this Notice and to further limit the features and functions of this Site, or to completely limit access to this Site, in response to such browser setting limitations in the future without prior notice. (See "Changes to this Privacy Notice," below.)

10. Visitors Who Reside Outside the United States

We welcome users of this site from other countries outside of the United States. We may transfer your personal information to our service providers and others located in the U.S. or other countries for the purposes described in this Privacy Notice. Different countries have different privacy laws and requirements, and some, including the U.S., provide less legal protection for your personal information than others. Regardless of the country in which your personal information is collected, used, transferred or stored, information collected through this site will be protected by the terms of this Privacy Notice.

https://www.visitingangels.com/gdpr

11. State Privacy Laws

We are committed to respecting your privacy rights and complying with applicable state privacy laws in the US.

Depending on where you live, you may have additional rights and choices regarding your personal information under the local laws. The following state laws have gone into effect in recent years:

• California. The California Privacy Rights Act of 2020 (CPRA), and California Consumer Privacy Act (CCPA), which grants California residents the right to access, delete, correct, and opt out of the sale or sharing of their personal information, as well as the right to limit the use of their sensitive personal information and the right to non-discrimination for exercising their privacy rights.
• The California Consumer Privacy Act (CCPA)
  

  The Cal. Civ. Code §1798.135: Do Not Sell My Info Act requires companies to include certain disclosures including "Do Not Sell My Info" links on their websites and mobile applications. Our company does not sell information that identifies who you are to anyone.

  • We do not target our marketing at people under the age of 16.
  • Additionally, we would require opt-in or parental consent before selling any of your personal information. You will not be discriminated against if you choose to opt-out.
  • If you opt-in, however, you will have certain benefits made available to you including marketing campaigns, special pricing, discounts and other benefits.
  • You have the right to opt-out of certain marketing activities if you choose to. You may opt-out at any time by following the information in the Opt-Out section below.
• Colorado. The Colorado Privacy Act (CPA), which grants Colorado residents the right to access, delete, correct, and opt out of the processing of their personal information for targeted advertising, sale, or certain other purposes, as well as the right to data portability and the right to non-discrimination for exercising their privacy rights.
• Connecticut. The Connecticut Data Privacy Act (CDPA), which grants Connecticut residents the right to access, delete, correct, and opt out of the sale or sharing of their personal information, as well as the right to data portability and the right to non-discrimination for exercising their privacy rights.
• Utah. The Utah Consumer Privacy Act (UCPA), which grants Utah residents the right to access, delete, correct, and opt out of the processing of their personal information for targeted advertising, sale, or certain other purposes, as well as the right to data portability and the right to non-discrimination for exercising their privacy rights.
• Virginia. The Virginia Consumer Data Protection Act (VCDPA), which grants Virginia residents the right to access, delete, correct, and opt out of the processing of their personal information for targeted advertising, sale, or profiling, as well as the right to data portability and the right to non-discrimination for exercising their privacy rights.
• Oregon. Our company is fully committed to complying with the laws of Oregon. This includes the Oregon Consumer Privacy Act effective July 2024, which grants consumers the right to access, correct, delete, opt out of processing for profiling/targeted advertising purposes, right to portability, to opt-out of sales, opt in for sensitive data processing and right against automated decision making.
• Texas. Our company is fully committed to complying with the laws of Texas. This includes the Texas Data Privacy and Security Act effective July 2024, which grants consumers the right to access, correct, delete, opt out of processing for profiling/targeted advertising purposes, right to portability, to opt-out of sales, opt in for sensitive data processing and right against automated decision making.

If you are a resident of any of these states and would like to exercise your rights under these laws, please reach out to us via information in the Contact Us section below.

12. Children's Online Privacy Protection Act (COPPA)

We are committed to protecting the privacy of children who use the Technology and encourages parents and guardians to talk to their children about safe and responsible use of their information and content on the Internet. In accordance with the Children’s Online Privacy Protection Act (COPPA); 15 U.S.C. § 91 et seq.), the company does not knowingly collect any Personal Information from children under 13 years of age without prior verifiable parental consent. Further, the company does not: (a) market directly to any person under 16 years of age; (b) publishes information or content from any person under 16 years of age; and (c) target communications to any child under 16 years of age. Any person under 16 years of age who wishes to access or use our services must obtain their parent or guardian’s prior consent prior to any such use.

13. Can-SPAM Act

Emails and CAN-SPAM Act. We value your privacy and respect your right to choose what kind of messages you receive from us. That’s why we follow the rules and regulations of the FTC Controlling the Assault of Non-Solicited Pornography And Marketing Act (CAN-SPAM Act), a federal law that sets the standards for commercial email. Here are some of the things we do to comply with the CAN-SPAM Act:

(a) We use accurate and honest information in our email headers, such as the sender’s name, email address, and subject line.

(b) We clearly identify our messages as advertisements or solicitations unless you have given us your express consent to receive them.

(c) We provide you with a valid physical postal address where you can contact us.

(d) We include a clear and easy way for you to opt out of receiving future emails from us, such as a link or an email address. We honor your opt-out requests promptly and without hassle.

(e) We monitor our email campaigns and ensure that they are sent by us or by authorized third parties on our behalf.

We take our compliance with the CAN-SPAM Act seriously and we strive to maintain a good relationship with our customers. If you have any questions or concerns about our email practices, please feel free to email us at the address under Contact Us.

14. Changes to this Privacy Notice

We reserve the right to change or revise this Privacy Notice at any time without prior notice. The changes will be effective as of the revised date posted at the top of this policy. The changes we make will apply only to the personal information we collect after we have posted the revised version. Your use of this web site following any such change constitutes your consent to the terms of the revised Privacy Notice. For this reason, it is important to review this Privacy Notice regularly.

15. Disclaimer

The data contained in our Site is for informational purposes only and is not represented to be error free. The company attempts to ensure that the data provided or otherwise displayed on our Site is accurate. However, the Site and its contents are provided on an "as is, as available" basis. Use of the Site and its contents is at your sole risk. We do not warrant that any functions of the Site will be uninterrupted or error-free, that defects will be corrected, or that the Site will be free from viruses or other harmful components. Visiting Angels makes no warranties, either express or implied, concerning the content of the Site, including the accuracy, completeness, reliability or suitability of the Site.

16. Review

We review and update our privacy notice annually. Our last review is posted at the top of this notice.

17. Contact Us

For questions or concerns regarding your privacy, please contact us at: customersupport@visitingangels.com.