Privacy Policy
Effective date: November 15, 2018
Comfort Assurance Group, LLC, dba Comfort Long Term Care ("CAG", "us", "we", or
"our") operates the https://www.comfortltc.com/ website (hereinafter referred
to as the "Service").
This page informs you of our policies regarding the collection, use and
disclosure of personal data when you use our Service and the choices you have
associated with that data.
We use your data to provide and improve the Service. By using the Service, you
agree to the collection and use of information in accordance with this policy.
Unless otherwise defined in this Privacy Policy, the terms used in this
Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.comfortltc.com/
Definitions
* Service
Service is the https://www.comfortltc.com/ website operated by CAG.
* Personal Data
Personal Data means data about a living individual who can be identified
from those data (or from those and other information either in our
possession or likely to come into our possession).
* Usage Data
Usage Data is data collected automatically either generated by the use of
the Service or from the Service infrastructure itself (for example, the
duration of a page visit).
* Cookies
Cookies are small files stored on your device (computer or mobile device).
* Data Controller
Data Controller means the natural or legal person who (either alone or
jointly or in common with other persons) determines the purposes for which
and the manner in which any personal information are, or are to be,
processed.
For the purpose of this Privacy Policy, we are a Data Controller of your
Personal Data.
* Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who
processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process
your data more effectively.
* Data Subject (or User)
Data Subject is any living individual who is using our Service and is the
subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to
provide and improve our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you
("Personal Data"). Personally identifiable information may include, but is not
limited to:
* Email address
* First name and last name
* Phone number
* Address, City, State, ZIP/Postal code, Province, Country
* Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or
promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from us by
following the unsubscribe link or instructions provided in any email we send
or by contacting us.
Usage Data
We may also collect information on how the Service is accessed and used
("Usage Data"). This Usage Data may include information such as your
computer's Internet Protocol address (e.g. IP address), browser type, browser
version, the pages of our Service that you visit, the time and date of your
visit, the time spent on those pages, unique device identifiers and other
diagnostic data.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our
Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored
on your device. Other tracking technologies are also used such as beacons,
tags and scripts to collect and track information and to improve and analyse
our Service.
You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be
able to use some portions of our Service.
Examples of Cookies we use:
* Session Cookies. We use Session Cookies to operate our Service.
* Preference Cookies. We use Preference Cookies to remember your preferences
and various settings.
* Security Cookies. We use Security Cookies for security purposes.
Use of Data
Comfort Assurance Group, LLC, dba Comfort Long Term Care uses the collected
data for various purposes:
* To provide and maintain our Service
* To notify you about changes to our Service
* To allow you to participate in interactive features of our Service when
you choose to do so
* To provide customer support
* To gather analysis or valuable information so that we can improve our
Service
* To monitor the usage of our Service
* To detect, prevent and address technical issues
* To provide you with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or inquired about unless you have opted
not to receive such information
Legal Basis for Processing Personal Data under
the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), CAG's legal basis for collecting
and using the personal information described in this Privacy Policy depends on the
Personal Data we collect and the specific context in which we collect it.
Comfort Assurance Group, LLC, dba Comfort Long Term Care, may process your
Personal Data because:
* We need to perform a contract with you
* You have given us permission to do so
* The processing is in our legitimate interests and it is not overridden by
your rights
* To comply with the law
Retention of Data
Comfort Assurance Group, LLC, dba Comfort Long Term Care will retain your
Personal Data only for as long as is necessary for the purposes set out in
this Privacy Policy. We will retain and use your Personal Data to the extent
necessary to comply with our legal obligations (for example, if we are
required to retain your data to comply with applicable laws), resolve disputes
and enforce our legal agreements and policies.
CAG will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used
to strengthen the security or to improve the functionality of our Service, or
we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and
maintained on — computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ from
those of your jurisdiction.
If you are located outside the United States and choose to provide information to
us, please note that we transfer the data, including Personal Data, to the United
States and process it there.
Your consent to this Privacy Policy followed by your submission of such
information represents your agreement to that transfer.
Comfort Assurance Group, LLC, dba Comfort Long Term Care will take all the
steps reasonably necessary to ensure that your data is treated securely and in
accordance with this Privacy Policy and no transfer of your Personal Data will
take place to an organisation or a country unless there are adequate controls
in place including the security of your data and other personal information.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, CAG may be required to disclose your
Personal Data if required to do so by law or in response to valid requests
by public authorities (e.g. a court or a government agency).
Legal Requirements
Comfort Assurance Group, LLC, dba Comfort Long Term Care may disclose your
Personal Data in the good faith belief that such action is necessary to:
* To comply with a legal obligation
* To protect and defend the rights or property of CAG.
* To prevent or investigate possible wrongdoing in connection with the
Service
* To protect the personal safety of users of the Service or the public
* To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of
transmission over the Internet or method of electronic storage is 100% secure.
While we strive to use commercially acceptable means to protect your Personal
Data, we cannot guarantee its absolute security.
(You can read more about tools we use to secure your data by clicking here.)
Our Policy on "Do Not Track" Signals under the
California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can
set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings
page of your web browser.
Your Data Protection Rights under the General
Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain
data protection rights. CAG aims to take reasonable steps to allow you to correct,
amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if
you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
* The right to access, update or delete the information we have on you.
Whenever made possible, you can access, update or request deletion of your
Personal Data directly within your account settings section. If you are
unable to perform these actions yourself, please contact us to assist you.
* The right of rectification. You have the right to have your information
rectified if that information is inaccurate or incomplete.
* The right to object. You have the right to object to our processing of
your Personal Data.
* The right of restriction. You have the right to request that we restrict
the processing of your personal information.
* The right to data portability. You have the right to be provided with a
copy of the information we have on you in a structured, machine-readable
and commonly used format.
* The right to withdraw consent. You also have the right to withdraw your
consent at any time where CAG relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to
such requests.
You have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information, please contact
your local data protection authority in the European Economic Area (EEA).
Service Providers
We may employ third party companies and individuals to facilitate our Service
("Service Providers"), provide the Service on our behalf, perform Service-
related services or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for any other
purpose.
Analytics
We may use third-party Service Providers to monitor and analyse the use of our
Service.
* Google Analytics
Google Analytics is a web analytics service offered by Google that tracks
and reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other Google
services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to
Google Analytics by installing the Google Analytics opt-out browser add-
on. The add-on prevents the Google Analytics JavaScript (ga.js,
analytics.js and dc.js) from sharing information with Google Analytics
about visits activity.
For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
https://policies.google.com/privacy?hl=en
Behavioral Re-marketing
Comfort Assurance Group, LLC, dba Comfort Long Term Care uses or may use
re-marketing services to advertise on third party websites to you after you visited
our Service. We and our third-party vendors use cookies to inform, optimize and
serve ads based on your past visits to our Service.
* Google Ads (AdWords)
Google Ads (AdWords) re-marketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize
the Google Display Network ads by visiting the Google Ads Settings page:
http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser
Add-on - <https://tools.google.com/dlpage/gaoptout> \- for your web
browser. Google Analytics Opt-out Browser Add-on provides visitors with
the ability to prevent their data from being collected and used by Google
Analytics.
For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
https://policies.google.com/privacy?hl=en
* Facebook
Facebook re-marketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by
visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions
from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral
Advertising established by the Digital Advertising Alliance. You can also
opt-out from Facebook and other participating companies through the
Digital Advertising Alliance in the USA
http://www.aboutads.info/choices/ , the Digital Advertising Alliance of
Canada in Canada http://youradchoices.ca/ or the European Interactive
Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/ ,
or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit
Facebook's Data Policy: https://www.facebook.com/privacy/explanation .
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If
you click a third party link, you will be directed to that third party's site.
We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Children's Privacy
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone
under the age of 18. If you are a parent or guardian and you are aware that
your Child has provided us with Personal Data, please contact us. If we become
aware that we have collected Personal Data from children without verification
of parental consent, we take steps to remove that information from our
servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any
changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior
to the change becoming effective and update the "effective date" at the top of
this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
* By visiting this page on our website:
https://www.comfortltc.com/contact.html
Effective date: November 15, 2018
Comfort Assurance Group, LLC, dba Comfort Long Term Care ("CAG", "us", "we", or
"our") operates the https://www.comfortltc.com/ website (hereinafter referred
to as the "Service").
This page informs you of our policies regarding the collection, use and
disclosure of personal data when you use our Service and the choices you have
associated with that data.
We use your data to provide and improve the Service. By using the Service, you
agree to the collection and use of information in accordance with this policy.
Unless otherwise defined in this Privacy Policy, the terms used in this
Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.comfortltc.com/
Definitions
* Service
Service is the https://www.comfortltc.com/ website operated by CAG.
* Personal Data
Personal Data means data about a living individual who can be identified
from those data (or from those and other information either in our
possession or likely to come into our possession).
* Usage Data
Usage Data is data collected automatically either generated by the use of
the Service or from the Service infrastructure itself (for example, the
duration of a page visit).
* Cookies
Cookies are small files stored on your device (computer or mobile device).
* Data Controller
Data Controller means the natural or legal person who (either alone or
jointly or in common with other persons) determines the purposes for which
and the manner in which any personal information are, or are to be,
processed.
For the purpose of this Privacy Policy, we are a Data Controller of your
Personal Data.
* Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who
processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process
your data more effectively.
* Data Subject (or User)
Data Subject is any living individual who is using our Service and is the
subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to
provide and improve our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you
("Personal Data"). Personally identifiable information may include, but is not
limited to:
* Email address
* First name and last name
* Phone number
* Address, City, State, ZIP/Postal code, Province, Country
* Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or
promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from us by
following the unsubscribe link or instructions provided in any email we send
or by contacting us.
Usage Data
We may also collect information on how the Service is accessed and used
("Usage Data"). This Usage Data may include information such as your
computer's Internet Protocol address (e.g. IP address), browser type, browser
version, the pages of our Service that you visit, the time and date of your
visit, the time spent on those pages, unique device identifiers and other
diagnostic data.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our
Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored
on your device. Other tracking technologies are also used such as beacons,
tags and scripts to collect and track information and to improve and analyse
our Service.
You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be
able to use some portions of our Service.
Examples of Cookies we use:
* Session Cookies. We use Session Cookies to operate our Service.
* Preference Cookies. We use Preference Cookies to remember your preferences
and various settings.
* Security Cookies. We use Security Cookies for security purposes.
Use of Data
Comfort Assurance Group, LLC, dba Comfort Long Term Care uses the collected
data for various purposes:
* To provide and maintain our Service
* To notify you about changes to our Service
* To allow you to participate in interactive features of our Service when
you choose to do so
* To provide customer support
* To gather analysis or valuable information so that we can improve our
Service
* To monitor the usage of our Service
* To detect, prevent and address technical issues
* To provide you with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or inquired about unless you have opted
not to receive such information
Legal Basis for Processing Personal Data under
the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), CAG's legal basis for collecting
and using the personal information described in this Privacy Policy depends on the
Personal Data we collect and the specific context in which we collect it.
Comfort Assurance Group, LLC, dba Comfort Long Term Care, may process your
Personal Data because:
* We need to perform a contract with you
* You have given us permission to do so
* The processing is in our legitimate interests and it is not overridden by
your rights
* To comply with the law
Retention of Data
Comfort Assurance Group, LLC, dba Comfort Long Term Care will retain your
Personal Data only for as long as is necessary for the purposes set out in
this Privacy Policy. We will retain and use your Personal Data to the extent
necessary to comply with our legal obligations (for example, if we are
required to retain your data to comply with applicable laws), resolve disputes
and enforce our legal agreements and policies.
CAG will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used
to strengthen the security or to improve the functionality of our Service, or
we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and
maintained on — computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ from
those of your jurisdiction.
If you are located outside the United States and choose to provide information to
us, please note that we transfer the data, including Personal Data, to the United
States and process it there.
Your consent to this Privacy Policy followed by your submission of such
information represents your agreement to that transfer.
Comfort Assurance Group, LLC, dba Comfort Long Term Care will take all the
steps reasonably necessary to ensure that your data is treated securely and in
accordance with this Privacy Policy and no transfer of your Personal Data will
take place to an organisation or a country unless there are adequate controls
in place including the security of your data and other personal information.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, CAG may be required to disclose your
Personal Data if required to do so by law or in response to valid requests
by public authorities (e.g. a court or a government agency).
Legal Requirements
Comfort Assurance Group, LLC, dba Comfort Long Term Care may disclose your
Personal Data in the good faith belief that such action is necessary to:
* To comply with a legal obligation
* To protect and defend the rights or property of CAG.
* To prevent or investigate possible wrongdoing in connection with the
Service
* To protect the personal safety of users of the Service or the public
* To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of
transmission over the Internet or method of electronic storage is 100% secure.
While we strive to use commercially acceptable means to protect your Personal
Data, we cannot guarantee its absolute security.
(You can read more about tools we use to secure your data by clicking here.)
Our Policy on "Do Not Track" Signals under the
California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can
set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings
page of your web browser.
Your Data Protection Rights under the General
Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain
data protection rights. CAG aims to take reasonable steps to allow you to correct,
amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if
you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
* The right to access, update or delete the information we have on you.
Whenever made possible, you can access, update or request deletion of your
Personal Data directly within your account settings section. If you are
unable to perform these actions yourself, please contact us to assist you.
* The right of rectification. You have the right to have your information
rectified if that information is inaccurate or incomplete.
* The right to object. You have the right to object to our processing of
your Personal Data.
* The right of restriction. You have the right to request that we restrict
the processing of your personal information.
* The right to data portability. You have the right to be provided with a
copy of the information we have on you in a structured, machine-readable
and commonly used format.
* The right to withdraw consent. You also have the right to withdraw your
consent at any time where CAG relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to
such requests.
You have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information, please contact
your local data protection authority in the European Economic Area (EEA).
Service Providers
We may employ third party companies and individuals to facilitate our Service
("Service Providers"), provide the Service on our behalf, perform Service-
related services or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for any other
purpose.
Analytics
We may use third-party Service Providers to monitor and analyse the use of our
Service.
* Google Analytics
Google Analytics is a web analytics service offered by Google that tracks
and reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other Google
services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to
Google Analytics by installing the Google Analytics opt-out browser add-
on. The add-on prevents the Google Analytics JavaScript (ga.js,
analytics.js and dc.js) from sharing information with Google Analytics
about visits activity.
For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
https://policies.google.com/privacy?hl=en
Behavioral Re-marketing
Comfort Assurance Group, LLC, dba Comfort Long Term Care uses or may use
re-marketing services to advertise on third party websites to you after you visited
our Service. We and our third-party vendors use cookies to inform, optimize and
serve ads based on your past visits to our Service.
* Google Ads (AdWords)
Google Ads (AdWords) re-marketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize
the Google Display Network ads by visiting the Google Ads Settings page:
http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser
Add-on - <https://tools.google.com/dlpage/gaoptout> \- for your web
browser. Google Analytics Opt-out Browser Add-on provides visitors with
the ability to prevent their data from being collected and used by Google
Analytics.
For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
https://policies.google.com/privacy?hl=en
Facebook re-marketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by
visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions
from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral
Advertising established by the Digital Advertising Alliance. You can also
opt-out from Facebook and other participating companies through the
Digital Advertising Alliance in the USA
http://www.aboutads.info/choices/ , the Digital Advertising Alliance of
Canada in Canada http://youradchoices.ca/ or the European Interactive
Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/ ,
or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit
Facebook's Data Policy: https://www.facebook.com/privacy/explanation .
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If
you click a third party link, you will be directed to that third party's site.
We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Children's Privacy
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone
under the age of 18. If you are a parent or guardian and you are aware that
your Child has provided us with Personal Data, please contact us. If we become
aware that we have collected Personal Data from children without verification
of parental consent, we take steps to remove that information from our
servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any
changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior
to the change becoming effective and update the "effective date" at the top of
this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
* By visiting this page on our website:
https://www.comfortltc.com/contact.html