Thank you for visiting the VED LIVING™ website located at www.vedliving.com (the “Site”). The Site is an Internet property of VED LIVING, LLC. (“VED LIVING™,” “we” or “us”). This VED LIVING™ Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when you: (a) access or use the Site; (b) register to become a Member; and/or (c) use the VED LIVING™ Offerings including, without limitation, the Services and/or Promotions. Capitalized terms not defined here in shall have the meaning set forth in the VED LIVING™ Website Terms and Conditions (“Terms and Conditions”). IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE AND/OR VED LIVING™ OFFERINGS.1. Information We Collect We collect three basic types of information and data, personal information, non-personal information, and aggregate data.2. Personal Information Collected For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information from end-users primarily in three (3) ways: (1) when you register to become a Member on the Site; (2) when you provide information in connection with your use of the VED LIVING™ Offerings; and (3) when you register to become a Member, or otherwise utilize certain aspects of the VED LIVING™ Offerings, through and/or in connection with an account that you already have with certain third-party social media websites (“Social Media Websites”), such as Facebook®.In addition, when you access and/or use the Site and/or VED LIVING™ Offerings , we may collect certain usage data, such as: (a) the number of times that you visit the Site; (b) the specific VED LIVING™ Offerings accessed, as well as the frequency and duration of use associated with same; and (c) other data associated with your access to, and use of, the Site and/or VED LIVING™ Offerings (collectively, “Usage Data”).3. Site Registration The personal information that you must supply on the Site in order to obtain access to the VED LIVING™ Offerings as a Member may include, without limitation: (a) your full name; (b) your e-mail address; (c) your date of birth; (d) your home address; (e) your user name and password; and (h) any and all other information requested on the applicable registration form (collectively, “Site Registration Data”).4. Social Media Website Registration/Use The personal information that you make available to VED LIVING™ when you register via your Facebook® account, or utilize certain VED LIVING™ Offerings in connection with your Facebook® account, may include, without limitation, depending on the privacy settings associated with your Facebook® account: (a) all or some of the inf ormation that comprises Site Registration Data as set forth above; (b) your Facebook® ID; (c) your Facebook® profile name; (d) your Facebook® profile picture; (e) your education history (as included in your Facebook® account); (f) your interests(as included in your Facebook® account); (g) the Facebook® photographs included in your Facebook® account; (h) gender; and (i) any and all other information made

 

available to VED LIVING™ by and through your Facebook® account (collectively, “Facebook® Registration Data”). For purposes of this Privacy Policy, “Facebook” shall mean Facebook Inc. Facebook® is a registered trademark of Facebook Inc. Twitter. Please be advised that VED LIVING™ is not in any way affiliated with Facebook, and the VED LIVING™ Offerings are neither endorsed, nor sponsored, by Facebook.5. Use of Personal Information We reserve the right to utilize your Usage Data, and share same with third parties: (a) to assist us , and such third parties, in studying, evaluating and improving the Site and/or VED LIVING™ Offerings; (b) determine your preferences and/or tailor the Site and/or VED LIVING™ Offerings to your need; and/or (c) so that we can promote the Site and/or VED LIVING™ Offerings to third parties (using Usage Data on an aggregate and anonymous basis in that instance). Other than in connection with the limited use of Usage Data as specified in the preceding sentence, VED LIVING™ will never sell, rent, exchange or barter your personal information to or with any third party for financial gain or marketing purposes. Where you register as a Member, we use the personal information that you make available to personalize your experience with the Site, facilitate the delivery of the applicable VED LIVING™ Offerings to you and for verification purposes. You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site and/or VED LIVING™ Offerings, and to keep you informed of our other products and services. In addition, if you identify yourself to us by sending us an email or some other communication with questions or comments, we may use such information (including personal information) to respond to your questions or comments, and we may file your questions or comments for future reference.The personal information that you submit to VED LIVING™ remains your property, but by making that personal information available to VED LIVING™, you grant VED LIVING™ the right, subject to applicable state and federal law, to use that personal information to bring you certain promotional offers from VED LIVING™, and its third party partners, that VED LIVING™ believes may be of interest to you. If you wish to stop receiving future communications from us, please see the Opt-Out/Unsubscribe section below.We may permit our third-party agents, service providers, vendors and subcontractors to access your personal information, but they are only permitted to do so in connection with performing services for us and/or to operate the Site and/or VED LIVING™ Offerings. They are not authorized to use that personal information for their own benefit.We may also supplement the information that we collect with information from other sources to assist us in evaluating and improving the Site and/or VED LIVING™ Offerings, and to determine your preferences so that we can tailor the Site and/or VED LIVING™ Offerings to your needs.We reserve the right to release current or past personal information: (i) in the event that we believe that the Site and/or VED LIVING™ Offerings is/are being or has/have been used in violation of the Terms and Conditions or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by

 

applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (iii) if VED LIVING™ is sold, merged or acquired;provided, however, that if VED LIVING™ is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as wellas any choices that you may have regarding your personal information.6.Cookies When an end-user visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable end-user’s computer or other device. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the VED LIVING™ Offerings, including for storing user preferences, improving ad selection and tracking Site-user trends (such as pages opened and length of stay at the Site). Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Eveninthe case where a user rejects a Cookie, he or she may still use the Site; provided, however, that certain functions of the VED LIVING™ Offerings and/or Site may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.7. IP Addresses/Browser Type We may collect certain non-personally identifiable information about you when you visit the Site, even if you are not a Member. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage, as well as to offer you products and services.8. Aggregate Data VED LIVING™ reserves the right to transfer and/or sell aggregate or group data about VED LIVING™ users (including Usage Data where same is not linked to personal information) for lawful purposes. Aggregate or group data is data that describes the demographics, usage or other characteristics of VED LIVING™ users as a group, without disclosing personally identifiable information.9. Location Information

 

When you use the Site, VED LIVING™ Offerings, the Services, or Promotions, we may collect location information either provided by a mobile device interacting with our Site or one of our applications, or associated with your IP address, where we are permitted by law to process this information.10. Third-Party Websites This Site may contain links to third-party owned and/or operated websites. VED LIVING™ is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and VED LIVING™ has no responsibility or liability relating to them.11. Security We endeavor to safeguard and protect our Members’ personal information. When Members make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). The privacy of your personal information is very important to us. When our registration process asks users to submit sensitive personal information (if any), and when we transmit such sensitive information, that information is encrypted and is protected with SSL encryption software.Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. The servers that we store personal information in are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. Please be advised,however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site is at your own risk.All of our Members’ personal information, not just the sensitive information mentioned above, is restricted in our offices. Only employees or third party agents who need the personal information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

 

12. Opt-Out/UnsubscribeTo opt-out of receiving e-mail advertising from us, you can follow the instructions at the end of the applicable e-mail message or e-mail us atsupport@vedliving.com.Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for VED LIVING™ Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving VED LIVING™ Offerings-related and inquiry response-related messages from VED LIVING™, you must cease requesting and/or utilizing the VED LIVING™ Offerings and cease submitting inquiries to VED LIVING™, as applicable.13. Identifying, Deleting and Updating Your Information At your request, we will inform you of what personal information we have on file for you. In addition,at your request, we will remove personal information that you have provided to us, or that we have collected. You may do so by contacting us via e-mail atsupport@vedliving.com;provided, however,that we ask individual Members to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes). Please be advised that deleting your personal information will terminate your access to the VED LIVING™Offerings including, without limitation, the Services and/or Promotions, and will require termination of your associated account. If you wish to continue using your account, as well as the VED LIVING™ Offerings, you may not delete the personal information that we have on f ile for you.Please be further advised that, after you delete your personal information, residual copies may take a period of time bef ore they are deleted from our active servers and may remain in our backup systems.16. Changes to this Privacy Policy VED LIVING™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, VED LIVING™ will notify Members by: (a) sending the modified policy to our Members via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use

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