This Privacy Policy ("Policy") provides information about data Long-Term Care Consultants, LLC ("us," "we," or "our(s)") collects, uses, and shares, and our commitment to using the personal data we collect in a respectful fashion.

This Privacy Policy applies to personal information we obtain from our users at www.snfclinic.com and any other products we offer (the "Services" or the "Website").

When you access or use our Services, you acknowledge that you have read this Policy and understand its contents. Your use of our Services and any dispute over privacy is subject to this Policy and our Terms and Conditions, including any applicable limitations on damages and the resolution of disputes.

We may update this Policy at any time as we deem appropriate. It is therefore important that you check back from time to time and make sure that you have reviewed the most current version of this Policy.

Why Do We Collect Information and Data?

We rely on certain information to run our business. In some instances, this information may include data that could be used to identify a particular individual, otherwise referred to as "Personal Information." In this Policy, we will provide multiple examples of how Personal Information we collect may be used and why it is important. Some of the reasons that we collect Personal Information include to:

  • Provide our products and Services and improve them over time;
  • Personalize and manage our relationship with you, including providing customer support;
  • Investigate, respond to, and manage inquiries or events; and
  • Work with and respond to law enforcement and regulators.

What Kinds of Personal Information Do We Collect?

The following are examples of the type of Personal Information that may be collected. The specific kind of information collected will depend on the Services used:

  • Authentication information (including email address and password);
  • Device information (including unique identifiers for computers, tablets or phones to confirm their eligibility for use of the Services);
  • Session and use data (including access point information and location information for the purpose of enabling the Services to connect users to the best available connection).
  • Usernames for billing/eligibility purposes and advertising.
  • Data created during your access of the Services ("Session Data"), including aggregate usage statistics, is generally not personally identifying. On the other hand, some of this Session Data either alone or when combined or linked with your Personal Information, may allow your identity to be discovered. In such cases, we treat the combined data as Personal Information. In many cases, Session Data is gathered automatically by systems or technology such as cookies.

How Do We Collect Information?

We collect information from our users in order to provide the Services to you on their behalf, automatically through your use of our Services, and, in some cases, directly from you.

For personal data subject to the European Union's General Data Protection Regulation ("GDPR"), we rely on several legal bases to process the data. These include when the processing is necessary to perform a contract, for compliance with a legal obligation to which we are subject, and for our legitimate business interests, such as in improving, personalizing, and developing the Services, and promoting safety and security as described above.

Site Information Collected Automatically

When you use or interact with the Website, we receive and store information generated by your activity, like Session Data, and other information automatically collected from your browser or mobile device. This information may include your IP address; browser type and version; preferred language; geographic location using IP address, the location of an access point you access while using the Website, or the GPS or wireless technology on your device; operating system and computer platform; purchase history; the full Uniform Resource Locator (URL) clickstream to, through, and from the Website, including date and time; any searches you conducted; and areas of the Website that you visited. We also may log the length of time of your visit and the number of times you visit and purchase or use the Services. We may assign you one or more unique identifiers to help keep track of your future visits. In most cases, this information is generated by various tracking technologies. Tracking technologies may include "cookies," "flash LSOs," "web beacons," or "web bugs," and "clear GIFs."

A "cookie" is a small piece of data sent from a website to your internet browser. These cookies help your browser communicate with the Website. Cookies will help the Website perform better by remembering preferences set by you, such as your login information. We also use cookies for site analytics (how we measure visits to the Website). This helps us understand how the Website is being used and how we can improve it.

How Do We Use Personal Information?

We will use Personal Information only for purposes related to providing you with the Services or otherwise to improve the Services. We will use and process your Personal Information (a) in connection with provisioning of the Services; (b) to incorporate your data into databases controlled by us for administration, provisioning, billing and reconciliation, verification of your identity, maintenance, support and product development, fraud detection and prevention, customer and customer use analysis and reporting, and customer-directed application of policies as part of our service delivery. We may also use Session Data to contact third parties in connection with inappropriate use of the Services or violation of our policies or applicable laws or regulations.

We may use Personal Information for, without limitation, the following:

  • Analyze your behavior when using the Services to customize preferences;
  • Establish and manage your account(s);
  • Provide customer support, manage subscriptions, and respond to requests, questions, and comments;
  • Customize, measure, and improve the Website, our products, services, and advertising;
  • Prevent, detect, identify, investigate, respond, and protect against potential or actual claims, liabilities, prohibited behavior, and criminal activity;
  • Comply with and enforce applicable legal requirements, agreements, and policies;
  • Perform other activities consistent with this Policy and the Terms and Conditions; and
  • Report usage data to regulators.

We also process certain information as an integral part of our Services. When using the Services, software may operate in the background of your computer system or device environment to perform specific tasks including:

  • Determining the quality of available network access points;
  • Intrusion detection, prevention, and protection;
  • Network defense; and
  • Data encryption.

We respect the importance of privacy. Other than as provided in this Policy, we do not sell your Personal Information, nor do we share it with unaffiliated third parties for their own marketing use, unless we have your consent or we are required by law to do so. Generally, we may disclose the information we collect, including Personal Information, in order to facilitate our provision of the Services or communications with customers (e.g., to service providers who perform functions on our behalf), to operate our business, to advertise or promote our Services, to facilitate changes to or transfers of our business, as required by law, or with your consent.

We may share Personal Information in the following ways:

  • Current and future users for the purposes described in this Policy, such as to (a) provide services (e.g., registration, and customer support); (b) help detect and prevent illegal acts and violations of our policies, the Terms and Conditions, and applicable laws or regulations; and (c) guide our decisions about our products, services, and communications;
  • Authorized service providers who perform services for us (including cloud services, data storage, customer support, and bill collection). Our contracts with our service providers include commitments that they agree to limit their use of Personal Information and to comply with privacy and security standards at least as stringent as the terms of this Policy. Remember that if you provide Personal Information directly to a third-party, such as through a link on from the Services, the processing is typically based on their standards, which may not be the same as ours;
  • If we believe disclosure is necessary and appropriate to prevent physical, financial, or other harm, injury, or loss, including to protect against abuse and fraud.
  • To legal, governmental, regulatory, or judicial authorities, as instructed or required by those authorities or applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigating suspected illicit activity (including identifying those who use the Services for illegal activities). We reserve the right to report to law enforcement agencies and regulatory bodies activities that we in good faith believe to be illegal.
  • In connection with, or during negotiations of, an acquisition, merger, asset sale, or other similar business transfer that involves substantially all of our assets or functions where Personal Information is transferred or shared as part of the business assets, provided that we will continue to take measures to protect the confidentiality of Personal Information and give affected users notice before transferring any personal information to a new entity.
  • With others after obtaining your consent. If we want to share Personal Information other than as permitted or described in this Policy, we will provide you with a choice to opt-in to such sharing and you may choose to instruct us not to share the information.

We do not share your Personal Information with non-affiliated third parties for their own marketing use without your permission.

We may disclose to third parties Session Data or non-Personal Information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual.

We use administrative, organizational, technical, and physical safeguards to protect the Personal Information we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our website, data centers, systems, and other assets for security vulnerabilities.

We use commercially reasonable protection technology such as encryption (when you provide us with information such as login credentials), firewalls and other security procedures to help protect the accuracy and security of your Personal Information and Session Data and to help prevent unauthorized access or improper use.

Because we provide the Services to you pursuant to contract, individual users should contact their employer directly to request correction, access, or deletion of Personal Information associated with your account. If the employer then requests that we comply with your request, we will respond to the request within 30 business days.

We retain your Personal Information while your account is in existence or as needed to provide you the Services. This includes data you or others have provided to us and data generated from your use of the Services. In some cases, we choose to retain certain information in a de-identified or aggregated form.

Our Services may contain links to other websites or services for your convenience and information. These websites or services may be operated by companies not affiliated with us. Linked websites or services may have their own privacy policies or notices, which we strongly suggest you review if you visit those websites. We are not responsible for the content, privacy practices, or use of any websites that are not affiliated with us.

We do not control the third-party sites that may be accessible through the Website or through the use of the Services. Thus, this Policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site and before providing any information to any third-party, you should inform yourself of the privacy policies and practices of the third-party, and should take those steps necessary, in your discretion, to protect your privacy.

With regards to any handling of an individual's Personal Information, we act primarily as a processor on behalf of said individual's employer, who acts as the controller. If applicable, please direct any inquiries to your employer that engaged use to provide you with the Services.

For instances in which we act as a controller of your Personal Information, or if you have questions or concerns regarding this Privacy Policy, please contact us by email at website@snfclinic.org or by writing to us at:

Long-Term Care Consultants, LLC
Attn: Legal Department
5962 La Place Court, Suite 165
Carlsbad, CA 92008