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The Ventas Group Privacy Statement

Effective date: August 24, 2021

Thank you for entrusting The Ventas Group with your personal information. Holding on to your private information is a serious responsibility, and we want you to know how we’re handling it.

Summary

We only collect the information you choose to give us, and we process it with your consent, or on another legal basis; we only require the minimum amount of personal information that is necessary to fulfill the purpose of your interaction with us; we don’t sell it to third parties; and we only use it as this Privacy Statement describes. We comply with the EU-US and Swiss-US Privacy Shield Frameworks and we are compliant with the General Data Protection Regulation (GDPR). No matter where you are, where you live, or what your citizenship is, we provide a high standard of privacy protection to all our users around the world, regardless of their country of origin or location.

Please read on for more details!

What Information The Ventas Group Collects and Why

Categories of Personal Information

“User Personal Information” is any personal information about one of our users which could, alone or together with other information, personally identify them. Information such as a user name and password, an email address, a real name, and a photograph are examples of “User Personal Information.” User Personal Information includes Personal Data as defined in the General Data Protection Regulation.

“Technical Information” may include information we collect from website browsers, such as web server logs, or other log information, such as User session or activity logs. Technical Information may be connected to User Personal Information such as a username or an email address, or to other potentially personally-identifying information like Internet Protocol (IP) addresses.

User Personal Information does not include aggregated, non-personally identifying information. We may use aggregated, non-personally identifying information to operate, analyze, improve, and optimize our website and service.

Information From Website Browsers

If you’re just browsing the website, we collect the same basic information that most websites collect. We use common internet technologies, such as cookies and web server logs, to collect Technical Information. This is stuff we collect from everybody.

The information we collect about all visitors to our website includes the visitor’s browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.

Why We Collect This Information

  • We will use your email address to communicate with you, if you’ve said that’s okay, and only for the reasons you’ve said that’s okay. Please see our section on email communication for more information.
  • We collect Technical Information to better understand how our website visitors use The Ventas Group, and to monitor and protect the security of the website.
  • We collect personal information from third parties for the purposes for which it was authorized to be collected. For example, you may authorize The Ventas Group to contact you for marketing purposes via a third party’s platform. If we need to use your personal information for other purposes, we will ask your permission first.
  • We use your User Personal Information and Technical Information for internal purposes, such as to maintain logs for security reasons, for training purposes, and for legal documentation and compliance.
  • We limit our use of your User Personal Information to the purposes listed in this Privacy Statement. If we need to use your User Personal Information for other purposes, we will ask your permission first.

What Information The Ventas Group Does Not Collect

We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information.

The Ventas Group does not knowingly collect information from or direct any of our content specifically to children under 13. Other countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not use The Ventas Group without obtaining your parents’ or legal guardians’ consent.

How We Share the Information We Collect

We do not share, sell, rent, or trade User Personal Information with third parties for their commercial purposes.

We do not host advertising on The Ventas Group. We may occasionally embed content from third party sites, such as YouTube, and that content may include ads. While we try to minimize the amount of ads our embedded content contains, we can’t always control what third parties show. Any advertisements on individual The Ventas Group Pages are not sponsored by, or tracked by, The Ventas Group.

We do not disclose User Personal Information outside The Ventas Group, except in the situations listed in this section or in the section below on Compelled Disclosure.

Tracking and Analytics

We use a number of third party analytics and service providers to help us evaluate our users’ use of The Ventas Group; compile statistical reports on activity; and improve our content and website performance. We only use these third party analytics providers on certain areas of our website, and all of them have signed data protection agreements with us that limit the type of personal information they can collect and the purpose for which they can process the information. In addition, we use our own internal analytics software to provide features and improve our content and performance.

How Kim Fredrich LLC Secures Your Information

The Ventas Group takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information.

In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected users without undue delay.

No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

The Ventas Group’s Global Privacy Practices

We store and process the information that we collect in the United States in accordance with this Privacy Statement (our subprocessors may store and process data outside the United States). However, we understand that we have users from different countries and regions with different privacy expectations, and we try to meet those needs even when the United States does not have the same privacy framework as other countries’.

We provide a high standard of privacy protection — as described in this Privacy Statement — to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business, working with our Data Protection Officer as part of a cross-functional team that oversees our privacy compliance efforts. Additionally, if our vendors or affiliates have access to User Personal Information, they must sign agreements that require them to comply with our privacy policies and with applicable data privacy laws.

In particular:

  • The Ventas Group provides clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal information using consent as a basis.
  • We collect only the minimum amount of personal information necessary for our purposes, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
  • We offer you simple methods of accessing, correcting, or deleting the User Personal Information we have collected.
  • We provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement. These are the Privacy Shield Principles, but they are also just good practices.

Cross-border Data Transfers

The Ventas Group complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of User Personal Information transferred from the European Union, the UK, and Switzerland to the United States.

If there is any conflict between the terms in this privacy statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program visit the Privacy Shield website.

How We Respond to Compelled Disclosure

The Ventas Group may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.

In complying with court orders and similar legal processes, The Ventas Group strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

How We, and Others, Communicate With You

We will use your email address to communicate with you, if you’ve said that’s okay, and only for the reasons you’ve said that’s okay. For example, if you contact our Support team with a request, we will respond to you via email.

Depending on your email settings, The Ventas Group may occasionally send notification emails about changes in a repository you’re watching, new features, requests for feedback, important policy changes, or offer customer support. We also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There’s an unsubscribe link located at the bottom of each of the marketing emails we send you.

Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email.

Resolving Complaints

If you have concerns about the way The Ventas Group is handling your User Personal Information, please let us know immediately. We want to help. You may contact us at kim@kimfredrich.com.

Dispute Resolution Process

In the unlikely event that a dispute arises between you and The Ventas Group regarding our handling of your User Personal Information, we will do our best to resolve it. If we cannot, we have selected to cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals, and with the Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving disputes with Swiss individuals. Please contact us if you’d like us to direct you to your data protection authority contacts.

Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority.

Independent Arbitration

Under certain limited circumstances, EU, EEA, Swiss, and UK individuals may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please read more about Privacy Shield. Arbitration is not mandatory; it is a tool you can use if you choose to.

We are subject to the jurisdiction of the U.S. Federal Trade Commission (FTC).

Changes to our Privacy Statement

Although most changes are likely to be minor, The Ventas Group may change our Privacy Statement from time to time. We will provide notification to Users of material changes to this Privacy Statement through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address you have specified.