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Sunday, September 07, 2008

SNAPforSeniors® Privacy Policy

This policy applies to all users of the SNAPforSeniors “Senior Housing Locator” or other similarly named service (“SNAP-Service”) through snapforseniors.com or any other affiliated or partner website in the SNAPforSeniors Distribution Network (“SNAP-Network”). The various websites that are part of the SNAP-Network are identified by the “powered by SNAPforSeniors” logo.

Your privacy is important to us. We recognize that when you provide us with information about yourself, or on behalf of a third party (the “Principal”) as their advocate (“Advocate”), you trust us to use this information responsibly. We believe this information should only be used to help us provide you with better service. That's why we have a policy to protect your personal information.

Our Commitment To Your Privacy
Your privacy is important to us. To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used.

We recognize that our service is sometimes used by Advocates on behalf of family members or other third parties. If you are an Advocate, you represent and warrant that you are fully authorized to provide the information you enter into SNAP-Service by the person or persons for whom you are an Advocate, and that you have, in each instance, permission or authority to forward the Principal’s information to a service provider. You also represent that the individual for whom you are an Advocate, or his or her duly authorized lawful guardian, is aware of your intentions to seek a service provider on their behalf and that they have authorized you to do so. If you are an Advocate, you further agree to indemnify, defend, and hold harmless SNAPforSeniors, Inc., and its officers, directors, employees, agents, contractors and shareholders (including attorneys’ fees and costs) from third party claims or actions that allege you were not permitted or authorized to use or disclose a third party’s information to us for use on the SNAP-Service.

The Information We Collect
This notice applies to all information collected on or submitted through any site in the SNAP-Network. If you register to create an account to access certain features of the SNAP-Service, we may collect personally identifiable information (about you or the Principal) from you that may include your, or the Principal’s name, age, zip code, e-mail address, and credit card billing information. Any personal and billing credit card info will be kept confidential and will not be sold, disclosed or used for any unauthorized purpose.

We may automatically collect IP addresses and website usage information from you when you visit a member of the SNAP-Network. We use non-identifying and aggregate information to better design our website and to gather intelligence related to general market trends. This information helps us evaluate how our visitors and subscribers use and navigate the SNAP-Service, including the number and frequency of visitors and subscribers, and the length of their visits.

How We Use Information
We may use the information you provide about you, the Principal, and your senior housing facility needs and wants in the following ways:

• to better understand the needs of our customers.
• to enable us to help you use the SNAP-Service more effectively
• to send you e-mail notifications about new or existing products and services,
special offers, or to otherwise contact you.

We will not disclose your contact information unless you authorize us to do so. The disclosure of personally identifiable information by Advocates is governed by the agreements and relationships between Advocates and their clients and is subject to the representations and warranties—and indemnification provisions—of this privacy policy.

We employ cookie technology. A cookie is a small file that is sent to your computer by a site's server. A cookie can be a record of your visit to a site, including information such as your User Name, registration information, time of last visit, pages viewed, etc. A cookie created by one site's servers can be retrieved only by that site's servers. Thus, cookies created by the SNAP-Service are not accessible to other sites.

Finally, we never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.

Our Commitment To Data Security
To prevent unauthorized access, maintain data accuracy, and to ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online and from our customers and business relationships in our business operations and in the management of our customer relationships.

Our Position Regarding HIPPA
The Health Insurance Portability and Accountability Act (commonly known as “HIPAA”) was signed into law on August 21, 1996. HIPAA affects virtually all areas of the healthcare industry and is designed to provide insurance portability, to improve the efficiency of healthcare by standardizing the exchange of administrative and financial data, and to protect the privacy, confidentiality and security of healthcare data. The various provisions of HIPAA are enforced via regulations promulgated by the U.S. Department of Health and Human Services (“HHS”). HHS has issued final regulations with respect to transaction and code standards and healthcare data privacy. HHS has also issued proposed regulations addressing technical and procedural security standards as well as certain other mechanisms to advance administrative simplification and the protection of patient health information.

In general, the HIPAA regulations apply to “covered entities” including healthcare providers, health insurance companies, and healthcare data clearinghouses, as well as to certain “business associates” of such covered entities. The SNAP-Service is not a covered entity. In addition, because it neither receives “protected health information” from covered entities nor acts on behalf of any covered entity in relation to the use or disclosure of protected health information, the SNAP-Service is not a business associate of any covered entity. Therefore, the SNAP-Service is not directly or indirectly subject to any HIPAA-related obligations.

However, at SNAPforSeniors, the confidentiality of our customers’ personal data has always been a fundamental concern, and thus we have set up a number of technological and administrative safeguards to protect the confidentiality of that data. In addition, SNAPforSeniors’ corporate policy is to observe applicable laws and regulations relating to healthcare data and to maintain the security and confidentiality of customer-specific information. SNAPforSeniors’ corporate policies are periodically reviewed and updated as part of our ongoing effort to protect the privacy of our customers’ data.

How To Contact Us
Should you have other questions or concerns about these privacy policies, please call us at +1-888-651-SNAP (7627) or send us an email at privacy@snapforseniors.com.


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