Privacy Policy

1. Introduction

Welcome to The Alton ("we," "our," or "us"). We are committed to protecting your privacy and maintaining the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website thealton.com (the "Site").

By using our Site, you consent to the data practices described in this policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Site.

2. Information We Collect

2.1 Personal Information You Provide

We may collect personal information that you voluntarily provide when you:

• Fill out contact forms or inquire about our services
• Request information about tours or admission
• Subscribe to newsletters or communications
• Call or email us directly

This information may include: name, email address, phone number, postal address, relationship to potential resident, and any other information you choose to provide in your inquiry.

2.2 Automatically Collected Information

When you visit our Site, we automatically collect certain information about your device and browsing activity, including:

• Device Information: IP address, browser type and version, device type, operating system, screen resolution
• Usage Data: Pages visited, time spent on pages, referring/exit pages, click patterns, mouse movements, keyboard behavior
• Location Data: Approximate geographic location based on IP address
• Cookies and Tracking Technologies: As detailed below

3. Tracking Technologies and Cookies

We use cookies, web beacons, and similar tracking technologies to collect information and improve your experience on our Site. Cookies are small data files stored on your device.

3.1 Types of Cookies We Use

• Essential Cookies: Necessary for the Site to function properly
• Analytics Cookies: Help us understand how visitors use our Site (via Google Analytics)
• Advertising Cookies: Used to deliver relevant advertisements and track ad performance (via Google Ads)
• Security Cookies: Used for fraud prevention and protecting user security (via Google reCAPTCHA)

You can control cookie preferences through your browser settings. However, disabling cookies may limit your ability to use certain features of our Site. We honor browser-based signals such as Global Privacy Control (GPC) for automated opt-out preferences.

4. Google Services and Third-Party Tools

Our Site uses several Google services to improve functionality, security, and user experience. Your use of our Site involves the collection and processing of data by Google as described below.

4.1 Google reCAPTCHA

We use Google reCAPTCHA to protect our Site from spam, abuse, and automated bot activity. reCAPTCHA collects hardware and software information and sends it to Google for analysis. This includes:

• IP address
• Cookies stored on your device
• Referrer URL and page you're visiting
• Your browser and operating system information
• Mouse movements, clicks, and keyboard behavior
• JavaScript objects and screen resolution
• Date and language settings
• Screenshots of your browser window (reCAPTCHA v3)
• Google account information (if you're logged into a Google account)

Information collected by reCAPTCHA is subject to Google's Privacy Policy and Terms of Service. We use reCAPTCHA based on legitimate interest in protecting our Site and users from fraudulent activity.

Google reCAPTCHA Links:
Privacy Policy: https://policies.google.com/privacy
Terms of Service: https://policies.google.com/terms

4.2 Google Analytics

We use Google Analytics 4 (GA4) to analyze how visitors use our Site and improve user experience. Google Analytics collects information such as:

• Pages visited and time spent on each page
• How you arrived at our Site (referral source)
• Device type, browser, and operating system
• Geographic location (city/region level, based on anonymized IP)
• User interactions and engagement metrics

Privacy Features: Google Analytics anonymizes IP addresses by default. We have configured GA4 to disable collection of granular device and location parameters where possible. GA4 processes EU user data within the EU to comply with data protection requirements.

Google Analytics Links:
Google Analytics Terms: https://marketingplatform.google.com/about/analytics/terms/
Google Privacy Policy: https://policies.google.com/privacy
Opt-out: https://tools.google.com/dlpage/gaoptout

4.3 Google Ads and Remarketing

We use Google Ads to deliver relevant advertisements and measure advertising effectiveness. Google Ads uses cookies and similar technologies to:

• Show you relevant ads based on your interests and browsing history
• Track conversions and measure ad performance
• Create remarketing audiences to show ads to previous Site visitors
• Prevent you from seeing the same ads repeatedly

You can opt out of personalized advertising through Google's Ad Settings or by visiting the Network Advertising Initiative opt-out page.

Google Ads Links:
Google Ads Settings: https://adssettings.google.com/
NAI Opt-Out: https://optout.networkadvertising.org/

5. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your inquiries and provide information about our services
• To schedule tours and process admission inquiries
• To communicate with you about The Alton and memory care services
• To improve our Site functionality and user experience
• To analyze Site usage and visitor behavior
• To deliver relevant advertisements and marketing communications
• To protect against fraud, spam, and abuse
• To comply with legal obligations and enforce our terms

6. Information Sharing and Disclosure

We may share your information in the following circumstances:

6.1 Third-Party Service Providers

We share information with trusted third-party vendors who perform services on our behalf, including:

• Google LLC: For analytics, advertising, and security services (as detailed above)
• Email Service Providers: To send communications and newsletters
• Marketing and Advertising Partners: To deliver targeted advertisements
• Web Hosting and Technical Support: To maintain and operate our Site

These service providers are contractually bound to protect your information and use it only for the purposes we specify.

6.2 Legal Requirements and Protection

We may disclose your information when required by law or to:

• Comply with legal processes, court orders, or government requests
• Enforce our terms and conditions
• Protect the rights, property, or safety of The Alton, our residents, visitors, or others
• Investigate and prevent fraud or security issues

6.3 Business Transfers

If The Alton is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. You will be notified of any such change in ownership or control.

7. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information under various privacy laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other state privacy laws.

7.1 GDPR Rights (European Union)

If you are located in the EU/EEA, you have the following rights:

• Right to Access: Request a copy of personal information we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete information
• Right to Erasure: Request deletion of your personal information
• Right to Restrict Processing: Request limitation on how we use your information
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

7.2 CCPA Rights (California)

If you are a California resident, you have the following rights under the CCPA:

• Right to Know: Request information about categories and specific pieces of personal information collected, sources, purposes, and third parties with whom we share information (up to twice per year)
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information for targeted advertising
• Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights
• Right to Limit Use of Sensitive Personal Information: Request limitation on the use of sensitive personal information

Note on "Sale" and "Sharing": While we do not sell personal information for monetary consideration, under California law, sharing data with advertising partners (like Google Ads) may be considered a "share" or "sale." You can opt out using the mechanisms described below.

7.3 Other State Privacy Rights

Residents of Virginia, Texas, Nebraska, and other states with comprehensive privacy laws have similar rights to those described above. Contact us to exercise your rights under applicable state law.

7.4 How to Exercise Your Rights

To exercise any of the rights described above, please contact us at:

• Email: [email protected]
• Phone: (651) 699-2480
• Mail: 1306 Alton Street, St. Paul, MN 55116

We will respond to your request within the timeframes required by applicable law (typically 30-45 days). We may need to verify your identity before processing your request.

7.5 Opt-Out Options

You can opt out of tracking and advertising through the following methods:

• Browser Settings: Adjust cookie preferences and enable "Do Not Track" signals
• Global Privacy Control (GPC): Enable GPC in your browser for automatic opt-out signals
• Google Analytics: Install the Google Analytics Opt-out Browser Add-on
• Google Ads: Adjust your ad preferences at Google Ads Settings
• NAI Opt-Out: Opt out of interest-based advertising at NAI Consumer Opt-Out

8. Healthcare Information Disclaimer

Important: This Privacy Policy governs information collected through our public-facing website only. It does not apply to protected health information (PHI) of residents receiving care at The Alton.

The Alton is subject to the Health Insurance Portability and Accountability Act (HIPAA) as it relates to resident medical records and protected health information. The privacy practices for protected health information are governed by our separate HIPAA Notice of Privacy Practices, which is provided to residents and their authorized representatives upon admission.

Information you submit through our website contact forms and general inquiries is not considered protected health information under HIPAA. Do not submit sensitive medical information through our website contact forms or general email. For confidential health inquiries regarding current residents, please contact our administrative office directly.

9. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using SSL/TLS protocols
• Secure data storage and access controls
• Regular security assessments and updates
• Employee training on data protection practices
• Spam and abuse protection through Google reCAPTCHA

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

10. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Retention periods vary based on:

• The nature and sensitivity of the information
• The purposes for which we collected it
• Legal, regulatory, accounting, or reporting requirements
• The need to resolve disputes or enforce agreements

When information is no longer needed, we will securely delete or anonymize it in accordance with applicable laws and our data retention policies.

11. International Data Transfers

Our Site is operated in the United States. If you access our Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our service providers operate.

By using our Site, you consent to the transfer of your information to the United States. The data protection laws in the United States may differ from those in your country of residence. We take steps to ensure that your information receives an adequate level of protection in accordance with applicable law.

12. Children's Privacy

Our Site is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information as soon as possible.

If you believe we have collected information from a child under 18, please contact us immediately.

13. Third-Party Websites

Our Site may contain links to third-party websites, including social media platforms and service provider sites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated policy on this page with a new "Last Updated" date
• Providing prominent notice on our Site
• Sending email notification if you have provided your email address

We encourage you to review this Privacy Policy periodically. Your continued use of the Site after changes are posted constitutes your acceptance of the updated Privacy Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For privacy-related inquiries, please include "Privacy Request" in the subject line. We will respond to your inquiry within a reasonable timeframe as required by applicable law.