Privacy Policy

Last Updated: September 9, 2026

NOTICE: We may “sell” or “share” certain personal data, as those terms are defined under applicable privacy laws, including through advertising technologies, and we may process personal data for targeted advertising.

Sunshine Retirement Living LLC, together with the senior living communities it owns or manages that link to this policy (collectively, “Sunshine,” “Company,” “we,” “our,” or “us“), respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when you interact with our websites, senior living communities, communications, recruiting and employment processes, and other services that link to this policy (our “Services“), and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Services, including through our website at sunshineretirementliving.com and community pages that link to this policy.
• In communications, including email, text, chat, telephone calls, and other electronic messages, between you and the Services or our personnel.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• In connection with inquiries about our communities, care surveys, tours, recruiting and job applications, employment, benefits administration, and related interactions described in this policy.

It does not apply to information collected by:

• Any website, application, or service operated by a third party that does not link to this policy, even if it is accessible from or linked through the Services; or
• Any third party, including through any application, content, or advertising that may link to or be accessible from or through the Services, except to the extent we receive personal data from that third party and process it as described in this policy.
• Protected health information governed by HIPAA and covered by a separate Notice of Privacy Practices.

We may provide additional or different privacy policies that are specific to certain features, services, activities, or categories of information.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you acknowledge the privacy practices described in this policy. Where applicable law requires consent for a particular processing activity, we will obtain consent as required. This policy may change from time to time (see Changes to Our Privacy Policy), and we will provide any additional notice or obtain any consent required by applicable law.

Children’s and Minors’ Data

Except for our recruiting and employment activities, our Services are not intended for children under the age of 18, and we do not knowingly collect personal data from children under 14. Individuals who are at least 14 years old may submit job applications where permitted by law. If an applicant who is under 18 receives an offer of employment, we may request documentation to verify age and employment eligibility. We use information from minor applicants only for recruiting, hiring, employment, legal compliance, and related purposes. We do not knowingly sell or share the personal data of consumers under 16 or use it for targeted advertising without any consent required by applicable law. If we learn that we collected personal data from a child in a manner not permitted by law, we will take appropriate steps to delete it.

The Personal Data That We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, online identifiers, employment information, or other information that can reasonably be linked to you or your household.

The types and categories of personal data we collect or process depend on how you interact with us and may include:

• Account and contact information, including name, home or mailing address, email address, telephone or cellular number, username, password or other account credentials, and other contact information you provide us.
• Demographic and protected-class information, including age or date of birth, gender, race or ethnicity, citizenship, marital status, disability information, veteran or military status, and other information collected voluntarily or as required for equal employment opportunity, affirmative action, diversity reporting, or legal compliance.
• Location information, including general geographic location derived from an IP address or information you provide, such as city, state, or ZIP code. We use this information to identify nearby communities or work locations and for advertising and marketing.
• Device and online activity information, including IP address, cookie and device identifiers, operating system and version, browser type and settings, pages visited, session duration, clicks, scrolling, traffic source or referrer, and other information about your interaction with the Services.
• Content and communications, including information you submit through web forms, chat or lead-capture tools, care surveys, emails, text messages, telephone calls, reviews, scheduling tools, and other communications with us.
• Health, care-needs, and benefits information, including limited information submitted through care surveys about health, personal hygiene, medication management, or level of care; and information used to administer employee benefits, leave, reasonable accommodations, workers’ compensation, post-offer medical examinations, or drug testing where permitted by law.
• Employment and education information, including employment history, work experience, qualifications, references, education, licenses, certifications, screening-question responses, background-screening information, and information regarding job performance and employment.
• Identity and eligibility information, including Social Security number, driver’s license, passport, state identification card, employment-eligibility documentation, identity-verification information, answers to security questions, and other government or identifying information.
• Financial and payroll information, including banking and financial account information used for payroll, direct deposit, retirement, and benefits administration.
• Biometric information, including encrypted mathematical templates generated from employee fingerprints for optional biometric authentication at ADP Workforce Now time clocks. The time clocks do not store actual fingerprint images, and employees may use an employee identification number/PIN instead of fingerprint authentication.
• Audio, visual, and other sensory information, including photographs, video surveillance footage in common areas, and recordings of meetings, calls, or other communications where applicable.
• Inferences and profile information, including information reflecting preferences, interests, engagement with our website and communications, selected living options, likelihood of interest in a community, and prospect scores or segments used to prioritize and personalize outreach.

Some of the information identified above, including government identifiers, account credentials, financial information, biometric information, health information, protected-class information, and personal data of known minors, may be considered sensitive personal data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with any required notice or consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, employment-related functions, or information.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
• Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services, including date and time; pages or communities that you view or search for; page response times; download errors; length of visits; page interactions, such as scrolling, clicks, and mouse-overs; and methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you request information, schedule or attend a tour, submit a care survey, communicate with us, sign up to receive communications, apply for a position, complete recruiting or employment forms, provide employment-eligibility documents, enroll in benefits, provide payroll information, or otherwise submit information to us. Job applicants may apply through the Careers page on our website, which redirects to ADP Workforce Now Recruiting, or through job boards and recruiting platforms such as Indeed and ZipRecruiter.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system and browser type, general location, logs, communication data, and information collected through cookies, web beacons, pixels, tags, session-replay technologies, dynamic-number insertion, and other tracking technologies, including which resources and Services features you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). Using automatic collection technologies helps us improve our Services, understand how users interact with them, measure advertising, and deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device or by using our cookie preference controls. However, if you select this setting, you may be unable to access certain features of the Services.
• Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons, also referred to as clear gifs, pixel tags, and single-pixel gifs, that permit Sunshine, for example, to count users who have visited those parts or opened an email and for other related statistics, such as recording the popularity of certain content and verifying system and server integrity.
• Pixels, tags, analytics, and similar technologies. We use technologies and services such as Google Analytics 4, Google Tag Manager, Hotjar, TalkFurther, Meta Pixel, LinkedIn tags, and similar tools to understand site use, measure and personalize advertising, capture inquiries, match displayed telephone numbers to traffic sources, and support other functions described in this policy.

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such purposes through Your Privacy Choices or as described below. Please note that some Services features may be unavailable as a result.

When you interact with the Services, third parties may use automatic collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, advertising networks, advertising servers, and social media platforms.
• Analytics, session-replay, call-tracking, and lead-capture providers.
• Website hosting, content-delivery, domain-name, and technology providers.
• Your device manufacturer and internet or mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data, or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, devices, and other online services. They may use this information to provide you with interest-based advertising or other targeted content, perform cross-device matching within their platforms, measure advertising, or provide their services to us.

We do not control third parties’ tracking technologies or how they may be used. If you have questions about an advertisement or other targeted content, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that information with information we collect directly from you. For example, we may obtain information from advertising and analytics providers; customer-relationship and lead-management providers; chat and lead-capture providers; job boards and recruiting platforms; applicant-tracking, background-screening, learning-management, payroll, benefits, retirement, unemployment-claims, scheduling, survey, communications, and other service providers; references; public records; and other business partners. These providers may include ADP Workforce Now, Indeed, ZipRecruiter, First Advantage, Relias, ADP CaseBuilder, UnitedHealthcare or UMR, Principal, Symetra, Empower Retirement, DailyPay, SurveyMonkey, Microsoft, Calendly, and similar providers.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and any content, features, information, products, or services that we make available through the Services.
• Respond to inquiries, communicate with you, schedule tours or meetings, identify communities or services that may be relevant to you, and evaluate requested care or service needs.
• Fulfill any other purpose for which you provide the information.
• Recruit, evaluate, and communicate with job applicants; verify qualifications, identity, employment eligibility, licenses, and certifications; conduct background screening where applicable; and make and administer hiring decisions.
• Administer employment, payroll, direct deposit, benefits, retirement, timekeeping, training, leave, accommodations, workers’ compensation, unemployment claims, post-offer examinations, drug testing, and related human-resources functions.
• Comply with equal employment opportunity, affirmative action, diversity-reporting, record-retention, and other federal, state, and local legal obligations.
• Improve our Services, including by analyzing information and creating aggregated data to develop, maintain, analyze, improve, optimize, measure, and report on our Services and how users interact with them.
• Promote our Services, business, communities, and offerings by publishing advertising on our own Services and placing ads on third-party services. We may use information to model, segment, score, target, offer, market, and advertise our Services, including by developing prospect profiles and scores to prioritize and personalize outreach.
• Carry out our obligations and enforce our rights arising from contracts or other relationships with you.
• Maintain the safety, security, and integrity of our Services, facilities, personnel, and business; prevent fraud and misuse; and investigate or respond to security incidents.
• Comply with law, respond to legal process, and establish, exercise, or defend legal claims.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about preferences, allowing us to customize the Services according to individual needs and interests.
• Improve navigation and recognize users when they return to the Services.
• Measure the effectiveness of advertising and communications and understand the sources of inquiries.

We may also use your information to contact you about our communities, services, and other offerings that may be of interest to you. You may opt out of promotional emails by using the unsubscribe link in the message, and you may opt out of promotional text messages by following the instructions in the message. For more information, see Your Rights and Choices About Your Information.

We use location information to identify communities or work locations near you, customize content, and support targeted advertising and marketing.

Who We Disclose Your Information To

We may disclose aggregated information about our users and information that does not identify any individual without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries, affiliates, and the senior living communities we own or manage.
• To contractors, service providers, and other third parties we use to support our organization and who are required to process personal data in accordance with applicable contractual and legal obligations. These parties include website, hosting, customer-relationship and lead-management, chat and lead-capture, analytics, advertising, communications, scheduling, survey, recruiting, background-screening, learning-management, payroll, benefits, retirement, insurance, legal, security, and other professional and operational providers.
• To advertisers, advertising networks, analytics providers, social media platforms, and similar parties for advertising delivery, measurement, analytics, cross-device matching, targeted advertising, and related purposes, subject to your rights and choices under applicable law.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale of a community or property, management transition, or other sale or transfer of some or all of Sunshine Retirement Living’s assets or operations, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal data transferred in such a transaction may include contact lists associated with a community or business.
• To fulfill the purpose for which you provide it, including to benefit providers, background-screening providers, recruiting platforms, or other parties involved in providing a requested service or administering employment.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to a government or regulatory request.
• To enforce or apply our terms of use Terms of Use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, safety, or security of our organization, our residents, prospective residents, applicants, employees, or others, including for fraud prevention, cybersecurity, and risk reduction.

The categories of personal data we may disclose include:

• Account and contact information.
• Demographic and protected-class information.
• Location information.
• Device and online activity information.
• Content and communications.
• Health, care-needs, and benefits information.
• Employment and education information.
• Identity and eligibility information.
• Financial and payroll information.
• Biometric information.
• Inferences and profile information.

For purposes of applicable state privacy laws, the categories of personal data that we may “sell” or “share” for targeted advertising or related analytics include certain identifiers, such as cookie, device, or online identifiers; commercial or service-interest information; device and online activity information; general location information; and non-sensitive inferences or profile information. We do not sell or share health or care-needs information, or health-related inferences, for targeted advertising. The categories of recipients include advertisers, advertising networks, analytics providers, and social media platforms. We do not operate as a data broker or sell personal data as our primary business. Transfers made as part of a merger, acquisition, sale of a community or property, or similar transaction are addressed separately above and may not be treated as a “sale” under applicable law.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can also manage non-essential tracking technologies through Your Privacy Choices. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or may not function properly. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to online services indicating that you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services do not respond to DNT signals. Instead, you can use the other controls described in this policy.
• Promotions by Sunshine. If you do not wish us to use your information to promote our communities or services, you can opt out by using the unsubscribe link in promotional emails, following the opt-out instructions in text messages, or contacting us at info@sunshineret.com.
• Targeted Advertising, Sale, and Sharing. You may opt out of the use or disclosure of personal data for targeted advertising or activities treated as a sale or sharing under applicable law by using Your Privacy Choices or by contacting us as described below. We will honor applicable browser-based opt-out preference signals as described below.

Location data choices:

• Location Data. You can limit the collection of location information by adjusting your browser or device privacy settings. We generally derive approximate location from IP addresses or use location information you provide, rather than collecting precise real-time device location. If you block location information, some Services features may be less personalized or may not function properly.

Your State Privacy Rights

Depending on your state of residence and applicable law, you may have rights regarding your personal data, including rights to access and obtain a portable copy of your personal data, correct inaccuracies, request deletion, opt out of certain sales, sharing, targeted advertising, or profiling, limit or withdraw consent to certain uses of sensitive personal data, appeal certain decisions regarding privacy requests, and receive non-discriminatory treatment for exercising your privacy rights. The exact scope of these rights, and the exceptions that may apply, vary by state. For additional information about state-specific privacy rights, please see our State Privacy Notice at State Privacy Notice.

To exercise any applicable rights, please email info@sunshineret.com, call 866-712-1087, or use online privacy request form. Employment-related requests may also be sent to hrteam@sunshineret.com. To appeal a decision regarding a consumer-rights request, send an email to info@sunshineret.com with “Privacy Request Appeal” in the subject line and describe the decision you are appealing.

We may need to verify your identity and request before completing certain requests. We will use personal data provided in connection with a request only to verify the requestor’s identity or authority and to respond to the request. You may use an authorized agent to submit a request where permitted by law, but we may require proof that the agent is authorized to act for you and may also require you to verify your identity directly with us.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) or other opt-out preference signals that can communicate your request to opt out from certain types of data processing, including data “sales” or “sharing” as defined under certain laws. When we detect a legally recognized signal, we will process it as required by applicable law. Because these signals are browser- and device-specific, you may need to enable the signal on each browser or device you use.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. These measures may include access controls, physical safeguards, administrative policies, and encryption in storage and transmission. However, no website, application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send through those channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking reasonable steps to protect your credentials and personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or as otherwise legally permitted or required, such as maintaining the Services, operating our organization, administering recruiting and employment, providing requested services, complying with record-retention and other legal obligations, resolving disputes, and supporting safety, security, and fraud prevention. We consider our legal and business obligations, potential risks of harm, the nature and sensitivity of the information, and the purposes for which it is processed when deciding how long to retain personal data. At the end of the applicable retention period, personal data will be deleted, destroyed, or deidentified, subject to legal and technical limitations.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any changes as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

Sunshine Retirement Living LLC
1080 Mount Bachelor Dr., #200
Bend, OR 97702
Email: info@sunshineret.com
Employment-related email: hrteam@sunshineret.com
Toll-free telephone: 866-712-1087