Privacy Policy

Who we are

Straight Path Senior Living Marketing, LLC ("Straight Path," "we," "us") operates a senior living directory serving Southwest Florida. Our website helps families find and compare assisted living, memory care, independent living, and related senior care communities, and helps communities reach families who are searching.

This policy applies to information collected through our website and related services. It does not apply to the practices of the senior living communities, elder law attorneys, or other providers listed on our site, each of which has its own privacy practices.

Information we collect

Information you give us

• Contact and inquiry details. When you fill out a form, request information about a community, or ask us to help with your search, we collect what you provide: name, email address, phone number, ZIP code, and details about the care you are looking for (for example, the type of care, timeframe, budget range, and whether you are searching for yourself or a loved one).
• Account information. If you create an account, we collect your name, email address, and password (stored in hashed form), along with the communities you save as favorites or add to a comparison.
• Provider information. If you represent a senior living community or professional service and list with us, we collect your business contact information, community details, licensing information, and billing information.
• Communications. If you email, call, or message us, we keep a record of that correspondence.

Information collected automatically

• Usage data. Pages you view, listings you open, searches and filters you use, and links you click. This includes when you reveal a community's phone number or click through to a community's website.
• Device and connection data. IP address, browser type, operating system, device type, referring page, and approximate location derived from your IP address.
• Cookies and similar technologies. Described in the Cookies and tracking section below.

Information from other sources

We display publicly available data about licensed communities from government sources such as the Florida Agency for Health Care Administration and the Centers for Medicare & Medicaid Services. We may also receive information from communities that list with us and from service providers we use to operate the site.

How we use information

We use the information we collect to:

• Respond to your inquiries and help you find senior living options that fit your needs
• Connect you with communities or professionals you ask to hear from
• Create and manage your account, including saved favorites and comparisons
• Show you communities near you and personalize search results by location
• Operate, maintain, and improve the website, including analyzing how listings and features are used
• Report engagement (such as listing views and phone reveals) to the communities that list with us
• Send you information about your inquiry, our services, and senior living resources, where permitted
• Detect, prevent, and address fraud, abuse, and technical issues
• Comply with legal obligations and enforce our terms

How we share information

We do not sell your personal information. We share it in the following circumstances:

• With communities and providers you ask us to contact. When you request information about a specific community or ask us to connect you with providers, we share your inquiry details with them so they can follow up. Once shared, their use of your information is governed by their own privacy practices.
• With service providers. We use third-party companies to host our website and data, process forms, send email and text messages, manage customer relationships, provide analytics, and process payments for providers who list with us. These companies may access information only as needed to perform services for us.
• Aggregated engagement data. We share summary statistics with listed communities (for example, how many times their listing was viewed or their phone number revealed). This data does not identify you personally.
• For legal reasons. We may disclose information if required by law, subpoena, or court order, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business transfers. If Straight Path is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.
• With your consent. For any other purpose you agree to.

Cookies and tracking

We use cookies, browser storage, and similar technologies to make the site work and understand how it is used:

• Essential. Keep you signed in, remember your saved favorites and comparisons, and support site security.
• Location. With your permission, we may use your browser's location or your IP address to show communities near you. You can decline the browser prompt and search by ZIP code instead.
• Analytics. Help us understand traffic, which listings are viewed, and how features are used so we can improve the site.
• Marketing. We may use pixels from platforms such as Google and Meta to measure the effectiveness of our advertising.

Most browsers let you block or delete cookies through their settings. Blocking essential cookies may prevent parts of the site, such as saved favorites, from working.

How long we keep information

We keep personal information for as long as needed to fulfill the purposes described in this policy. Inquiry records are kept while we are assisting with your search and for a reasonable period afterward. Account information is kept until you delete your account or ask us to remove it. We may retain some information longer where required by law or to resolve disputes.

Security

We use reasonable administrative, technical, and physical safeguards to protect your information, including encrypted connections, access controls on our databases, and hashed passwords. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Your choices and rights

• Access, correct, or delete. You can update account information by signing in, or contact us to access, correct, or delete personal information we hold about you.
• Email and text marketing. You can unsubscribe from marketing emails using the link in any message. Reply STOP to opt out of text messages. We may still send transactional messages related to your inquiry or account.
• Location. You can revoke location permission in your browser or device settings at any time.
• Cookies. See the Cookies and tracking section.
• Do Not Track. Our site does not currently respond to Do Not Track browser signals.

Depending on where you live, you may have additional rights under applicable privacy laws. To exercise any right, contact us using the details below. We may need to verify your identity before responding.

Children

Our website is intended for adults. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, contact us and we will delete it.

Third-party sites

Our site links to community websites, government resources such as Medicare Care Compare, and other third parties. We are not responsible for the content or privacy practices of those sites. Review their policies before providing information.

Changes to this policy

We may update this policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. Significant changes may also be communicated by email or a notice on the site. Continued use of the site after changes take effect means you accept the updated policy.

Contact us

2. Definitions

"Facility"

Any assisted living facility, memory-care community, independent-living community, nursing facility, continuing-care community, adult family-care home, or other senior-living provider displayed on Straight Path.

"Facility-Provided Image"

Any photograph, video, logo, graphic, floor plan, rendering, or other visual material supplied to Straight Path by or on behalf of a Facility.

"Straight Path Image"

Any photograph or other visual material created, commissioned, or otherwise obtained by Straight Path for use on the Straight Path platform.

"Public-View Exterior Image"

A photograph of the exterior of a Facility taken from a location where the photographer is lawfully permitted to be, such as a public roadway, sidewalk, or other lawful vantage point.

"Resident"

Any current or former resident, patient, client, or occupant of a Facility.

"Employee"

Any employee, contractor, volunteer, healthcare professional, or other person working at or providing services to a Facility.

3. General Image Standards

Straight Path will use reasonable efforts to ensure that Images displayed on its platform:

• Are reasonably accurate representations of the Facility or subject depicted;
• Do not intentionally misrepresent the condition, services, amenities, or appearance of a Facility;
• Do not contain identifiable residents or other individuals unless appropriate permission has been obtained or the person falls within an applicable legal exception;
• Do not expose private, confidential, medical, financial, security-sensitive, or personally identifying information;
• Do not contain inappropriate, offensive, discriminatory, or misleading content;
• Do not intentionally reveal private resident rooms, records, medication information, care information, identification badges, schedules, security systems, access codes, or similar sensitive information;
• Do not knowingly infringe another person's copyright, trademark, privacy, publicity, or other rights; and
• Are used consistently with any applicable agreement between Straight Path and the Facility.

Straight Path may crop, resize, compress, format, or make minor technical modifications to Images for website, mobile, advertising, or other digital-display purposes.

Straight Path will not intentionally alter an Image in a manner that materially misrepresents the Facility.

4. Non-Subscribing Facilities

Straight Path may create informational listings for Facilities that do not maintain a paid subscription with Straight Path.

For a non-subscribing Facility, Straight Path may use:

• Facility name and publicly available factual information;
• A Public-View Exterior Image taken by Straight Path;
• Other Images for which Straight Path has independently obtained appropriate rights or permission; and
• Images that are otherwise lawfully available for Straight Path's intended commercial use.

4.1 Public-View Exterior Images

Straight Path personnel may photograph the exterior of a non-subscribing Facility from a lawful public vantage point.

Straight Path should avoid intentionally photographing:

• Identifiable residents;
• Residents receiving care;
• Private areas;
• Residents inside windows;
• Private resident rooms;
• Medical or care activities;
• License plates where reasonably avoidable;
• Security systems or access controls;
• Private documents or information; or
• Any other material that could reasonably create a privacy or security concern.

A public-vantage-point photograph does not constitute permission for Straight Path personnel to enter private property.

4.2 No Implied Endorsement

A non-subscribing Facility listing must not state or imply that:

• The Facility is a Straight Path customer;
• The Facility has endorsed Straight Path;
• The Facility has approved the listing;
• The Facility has approved the photograph;
• The Facility has paid Straight Path; or
• Straight Path is affiliated with, owned by, or operated by the Facility.

Where appropriate, Straight Path may identify the listing as an informational or non-subscribing listing.

4.3 Removal Requests

A Facility may contact Straight Path to request removal or replacement of an Image.

Straight Path may evaluate the request based on copyright ownership, privacy rights, contractual rights, applicable law, and the circumstances surrounding the Image.

Straight Path may remove or replace an Image as a business decision without admitting liability or wrongdoing.

5. Subscribing Facilities

A Facility purchasing a Straight Path subscription or other paid service must provide Straight Path with the rights necessary to display and use Images supplied by or on behalf of the Facility.

As a condition of submitting Images, the Facility represents and warrants that it has obtained all permissions, licenses, releases, and other rights reasonably necessary for Straight Path to use the Images in accordance with this Policy and the applicable subscription agreement.

5.1 Facility Authorization

The Facility grants Straight Path a non-exclusive, worldwide, royalty-free license to host, store, reproduce, display, publish, distribute, resize, crop, format, modify for technical purposes, and use the Images in connection with the Facility's Straight Path listing and Straight Path's marketing of its platform and services.

The license should remain effective for the duration of the Facility's subscription and for a reasonable period thereafter necessary to remove, archive, back up, or otherwise discontinue the Images.

Straight Path may also retain copies of Images where reasonably necessary for legal, accounting, backup, archival, compliance, or recordkeeping purposes.

5.2 Facility Representations

By submitting an Image, the Facility represents and warrants that:

• It owns the Image or possesses sufficient rights to license it to Straight Path;
• Its submission does not violate another person's copyright;
• It has obtained appropriate releases for identifiable individuals appearing in the Image when required;
• It has obtained any necessary permissions from photographers, agencies, contractors, vendors, or other rights holders;
• It has authority to grant Straight Path the license described above; and
• The Image does not knowingly contain confidential or legally protected information that Straight Path is prohibited from displaying.

5.3 Indemnification

Under the Straight Path subscription agreement, the Facility agrees to defend, indemnify, and hold harmless Straight Path and its owners, officers, employees, contractors, agents, and affiliates from claims arising out of:

• An Image supplied by the Facility;
• The Facility's lack of ownership or licensing rights;
• An alleged copyright violation relating to a Facility-provided Image;
• An alleged unauthorized use of an individual's likeness resulting from the Facility's failure to obtain an appropriate release;
• The Facility's unauthorized disclosure of resident information; or
• Other rights violations caused by the Facility's submission of an Image.

6. Exterior Photographs Taken by Straight Path

Straight Path may photograph Facility exteriors for use in Facility listings.

6.1 Lawful Location

Straight Path personnel should take exterior photographs only from locations where they are legally permitted to stand. Examples may include public sidewalks, public roads, public rights-of-way, and other locations where Straight Path has permission to photograph.

Straight Path personnel should not enter a Facility's private property solely to obtain a photograph unless they have permission or another lawful basis for doing so.

6.2 Residents and Employees

Straight Path personnel should make reasonable efforts to avoid intentionally photographing identifiable residents or employees when taking exterior listing photographs.

If an identifiable person is incidentally captured, Straight Path should evaluate whether the person is recognizable and whether the photograph will be used for a commercial or advertising purpose.

Florida law generally restricts commercial or advertising use of an individual's photograph or likeness without consent, subject to statutory exceptions.

Accordingly, Straight Path's preferred practice is:

7. Facility-Provided Photographs

Facility-provided Images may be used only after the Facility has accepted responsibility for having the necessary rights and permissions.

Straight Path may request documentation supporting the Facility's rights when circumstances reasonably warrant it.

Straight Path is not required to independently investigate the ownership history of every Image submitted by a subscribing Facility.

7.1 Third-Party Photographers

If a Facility hires a professional photographer, the Facility should obtain written permission allowing the Facility to sublicense the Images to Straight Path for the uses contemplated by the subscription agreement.

Payment to a photographer does not necessarily mean the customer owns the copyright. Copyright generally initially belongs to the photographer, subject to applicable work-made-for-hire or written-transfer rules.

7.2 Stock Photography

Facilities should not submit stock photographs unless the applicable license permits the Facility to sublicense or authorize Straight Path's intended use.

7.3 Internet Images

Facilities must not submit photographs copied from Google Images, other Facility websites, real-estate websites, social-media accounts, photographers' websites, stock-photo websites without appropriate licensing, or other third-party sources unless the Facility possesses the necessary rights.

Straight Path personnel should likewise avoid copying third-party photographs simply because they appear publicly online.

8. Resident Privacy and Releases

Straight Path recognizes that senior-living residents may have heightened privacy considerations.

Facility-provided Images containing an identifiable Resident should generally require a written photo/video release or other legally sufficient authorization before Straight Path uses the Image for commercial or advertising purposes.

The Facility is responsible for determining whether the person signing the release has authority to provide consent.

8.1 Resident Release

The release should authorize photography and/or video; commercial use; advertising use; website publication; social-media publication; digital advertising; printed marketing materials; cropping and formatting; continued use for the authorized purposes; and use by Straight Path and its authorized contractors/service providers.

The release should identify Straight Path or otherwise clearly authorize the use of the individual's likeness by Straight Path.

8.2 Residents With Legal Representatives

If a Resident lacks legal capacity to provide the required consent, the Facility must obtain authorization from the person's legally authorized representative where legally required.

Straight Path should not independently determine who has legal authority to consent for a resident.

The Facility should maintain documentation demonstrating the authority of the person providing consent.

8.3 Resident Rooms and Private Spaces

Straight Path should not intentionally publish photographs of a resident's private room or other private space where the photograph could reasonably reveal private information without appropriate authorization.

Florida long-term-care guidance specifically recognizes resident privacy and states that photographs or recordings of a resident or the resident's private space without appropriate written consent can violate privacy/confidentiality rights.

9. Employee and Staff Releases

Identifiable employees, contractors, and other personnel appearing prominently in an Image should generally provide written consent before Straight Path uses the Image for commercial advertising or promotional purposes.

A Facility should not submit an employee photograph to Straight Path for commercial use unless the Facility has obtained the appropriate authorization or has another legally sufficient basis for the intended use.

Employees should not be represented as endorsing Straight Path unless they have expressly authorized such representation.

10. Incidental Appearance of Members of the Public

Straight Path recognizes that individuals may occasionally appear incidentally in photographs.

Straight Path personnel should make reasonable efforts to avoid intentionally capturing identifiable individuals who are not relevant to the subject of the photograph.

Where an individual is merely incidental to a photograph and is not identified or otherwise presented as endorsing Straight Path, the legal analysis may differ. Florida's commercial-use statute contains an exception concerning photographs of a person solely as a member of the public when the person is not named or otherwise identified in connection with the use.

Because the photograph will be used commercially, Straight Path should nevertheless favor obtaining a release or removing/blurring an identifiable person whenever reasonably practical.

11. Medical and Confidential Information

Straight Path will not intentionally publish Images containing medical records; medication records; resident names associated with medical information; treatment information; care plans; identification numbers; passwords; access codes; private correspondence; financial information; incident reports; computer screens displaying confidential information; or other confidential or sensitive information.

Facilities are responsible for reviewing Images before submission and should not submit Images containing protected or confidential information.

Straight Path may remove an Image immediately if it reasonably believes that the Image creates a privacy, confidentiality, security, or legal concern.

12. HIPAA and Health Information

Straight Path does not intend to obtain or publish protected health information merely through ordinary Facility listing photographs.

Facilities should not submit photographs containing protected health information or other confidential health information.

Nothing in this Policy should be interpreted as creating a determination that Straight Path is or is not a "business associate" under HIPAA in a particular circumstance. That determination depends on the specific services, relationships, and information involved.

Where HIPAA or another privacy law applies, the Facility remains responsible for complying with its obligations concerning residents and protected information.

13. Copyright Ownership

Straight Path will use only Images that it owns, has permission to use, or otherwise has a legally sufficient right to use.

Original photographs are generally protected by copyright from the moment they are created. The photographer is generally the initial copyright owner, subject to applicable work-made-for-hire and contractual rules.

Straight Path Employees

Where a Straight Path employee creates a photograph within the scope of employment, Straight Path should maintain documentation establishing the employment relationship and the company's ownership rights.

Independent Photographers

Straight Path should use written agreements with independent photographers specifying ownership or licensing rights.

Where Straight Path intends to own commissioned photographs, the agreement should contain appropriate written copyright-assignment or work-made-for-hire language where legally applicable.

14. Trademarks and Facility Branding

Straight Path may display a Facility's name and, where appropriately authorized, its logo or other branding.

A Facility's name or logo should not be displayed in a manner that falsely suggests sponsorship, endorsement, partnership, accreditation, ownership, government approval, or another relationship that does not actually exist.

For subscribing Facilities, the subscription agreement may expressly authorize use of the Facility's name, logo, trademarks, service marks, and branding for purposes related to the Facility's Straight Path listing and marketing.

15. Accuracy and Misrepresentation

Straight Path should not knowingly use an Image in a way that materially misrepresents the Facility. For example, Straight Path should not:

• Use a photograph of a different Facility as though it depicts the listed Facility;
• Use an outdated photograph in a way that creates a materially misleading impression;
• Digitally alter a Facility photograph to falsely depict amenities that do not exist; or
• Use a photograph of a model or different property while representing it as an actual Facility.

Straight Path may use reasonable cropping, resizing, color correction, compression, and formatting.

16. Artificially Generated or Enhanced Images

Straight Path should not represent an AI-generated or materially AI-altered image as an actual photograph of a Facility.

If an Image has been materially altered or generated, Straight Path may identify it as a rendering, illustration, conceptual image, or other appropriate designation.

Facility-provided AI-generated Images should be clearly identified before publication where necessary to prevent a misleading impression.

17. Removal, Replacement, and Dispute Procedure

A Facility, resident, employee, photographer, copyright owner, or other person may contact Straight Path regarding an Image.

Straight Path may request identification of the Image; the requester's name and contact information; evidence of ownership; evidence of authorization; evidence of a privacy or publicity right; evidence of copyright ownership; or other information reasonably necessary to evaluate the request.

Straight Path may temporarily remove an Image while investigating a legitimate dispute.

Straight Path may remove or replace an Image without admitting liability.

Nothing in this Policy prevents Straight Path from taking immediate action when an Image presents an apparent privacy, security, safety, or legal concern.

18. Facility Responsibility

Each subscribing Facility is responsible for ensuring that Images it submits to Straight Path comply with applicable law; copyright requirements; privacy requirements; publicity/right-of-likeness requirements; Facility policies; resident rights; employee rights; photographer agreements; and third-party licensing restrictions.

The Facility should maintain records of releases, licenses, assignments, and other permissions supporting its right to submit Images to Straight Path.

Straight Path may request such documentation when reasonably necessary.

19. No Waiver of Legal Rights

This Policy is intended to establish operational standards and contractual expectations. It does not waive any rights or obligations that cannot legally be waived.

If any provision conflicts with applicable federal, state, or local law, the applicable law controls to the extent required.

Straight Path may amend this Policy from time to time.