SENIOR HOME EXCHANGE CORPORATION (hereinafter “Company”) is committed to protecting and respecting your privacy. This privacy policy (together with our Terms of Use Agreement and any other documents referred to thereof) sets out the basis on which any personal data the Company collects from you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how the Company will treat it. By visiting the Senior Home Exchange website located at www.seniorhomexchange.com or the downloadable Application designed for cellular, tablet and other devices (hereinafter “Website”) and service, you are accepting and consenting to the practices described in this privacy policy.

For the purposes of the Data Protection Act 1988 (the Act), the data controller is the Company. The Company is a South Dakota Corporation.

If this privacy policy appears in a language other than English (or if access to a function to translate this privacy policy into a language other than English is provided), you acknowledge that this is for convenience only and that, in the event of a conflict between the English language version and the non-English language version, the English language version will prevail.

1    INFORMATION THE COMPANY MAY COLLECT FROM YOU
The Company may collect and process the following data about you:
1.1    Information you give to us. You may give the Company information about you by filling in forms on the Website or by corresponding with the Company by phone, email or otherwise. This may include, without limitation, information you provide when you use the Website, register as a member, subscribe to and use our service, post material, search for a property on the Website, request further information or services from us, request information from other members, make use of any interactive features on the Website, enter a competition or promotion or complete a survey and/or when you report a problem with the Website. The information you give the Company may include, without limitation, your name, address, email address, phone number and electronic media (such as images, photographs, videos, or other electronic media), as well as financial and credit card information. If you contact the Company for any reason, the Company may keep a record of that correspondence.
1.2    Information the Company collects about you. Each time you visit the Website, the Company may automatically collect and process certain technical information (this is statistical data about our users' browsing actions and patterns and does not identify any individual), as well as certain information about your visit to the Website (including items you viewed or searched for, page response times, download errors, length of visits to certain pages and page interaction information).
1.3    Information the Company receives from other sources. The Company may receive information about you if you use any of the other websites the Company operates, or the other services the Company provides, from time to time. The Company may also receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Twitter, Instagram, Pinterest, etc.) and, if such functionality is available, you have chosen to link your profile on the Website with your profile on those websites or other social media platforms. The Company may also work closely with other third parties (including, for example and without limitation, business partners, subcontractors in technical and payment services, advertising networks, analytics providers, search information providers and credit reference agencies) and may receive information about you from them.

2    USE MADE OF THE INFORMATION
The Company reserves the right to sell or license any personal information about you to any third party. The Company uses information held about you in the following ways:
2.1    Information you give to us. The Company will use this information:
a)    to carry out our obligations arising from any contracts entered into between the Company and you and any relevant third parties and to provide you with the information and services that you request from us;
b)    to facilitate any transactions on the Website offered and/or administered by third parties in which you choose to participate;
c)    to pass any feedback and/or comments you provide via the Website to the third parties in respect of whom the feedback and/or comments were given;
d)    to provide you with information about the Company and to send you newsletters, blogs, simulcasts and other relevant information;
e)    to provide you with information about other services the Company offers that are similar to those that you have already made use of or enquired about;
f)    to provide you, or permit selected third parties to provide you, with information about products and/or services the Company feels may be of interest to you. If you do not want the Company to use your data in this way, or to pass your details on to third parties for marketing purposes, please contact the Company at info@seniorhomexchange.com;
g)    to notify you about changes to our service; and
h)    to ensure that content from the Website is presented in the most effective manner for you and for your computer.
2.2    Information the Company collects about you. The Company will use this information:
a)    to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
b)    to improve the Website and to ensure that content from the Website is presented in the most effective manner for you and for your computer;
c)    to allow you to participate in any interactive features on the Website, when you choose to do so;
d)    as part of our efforts to keep the Website safe and secure;
e)    to measure or understand the effectiveness of advertising the Company serves to you and others and to deliver relevant advertising to you; and
f)    to make suggestions and recommendations to you and other users of the Website about products and/or services that may interest you or them.
2.3    Information the Company receives from other sources. The Company may combine this information with information you give to the Company and information the Company collects about you. The Company may use this information and the combined information for the purposes set out above (depending on the types of information the Company receives).

3    DISCLOSURE OF YOUR INFORMATION
3.1    The Company may share your information with any member of our group from time to time and our subsidiaries.
3.2    The Company may also share your information with selected third parties, including:
a)    other members and users of our service;
b)    business partners, suppliers and subcontractors for the performance of any contract the Company enters into with them or you;
c)    advertisers, advertising networks and selected third parties that require the data to select and serve relevant advertisements to you and others (although the Company will not disclose information about identifiable individuals to our advertisers); and
d)    analytics and search engine providers that assist the Company in the improvement and optimization of the Website.
3.3    The Company may disclose your personal information to third parties:
a)    if the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users and members may be one of the transferred assets; and
b)    if the Company are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, or in order to enforce or apply our Terms of Use Agreement or any other agreements; or to protect the rights, property or safety of The Company, our members or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and with law enforcement agencies or court officials.

4    MANAGEMENT OF YOUR PROFILE AND PERSONAL INFORMATION
4.1    If you register as a member of our service, you will control your user profile. This means that you will be able to access your details by going to your profile page on the Website where you may review, correct and/or update the majority of your information at any time.
4.2    If you terminate or cancel your membership, the Company will remove your listings from the Website upon notification from you as soon as is reasonably possible. However, the Company reserves the right to retain certain information about your listings, communications and account in order to enforce our Terms of Use Agreement, analyze user experiences to improve our business and resolve disputes. Members should not expect that all their personal information will be removed from our databases after termination or cancellation of their membership.

5    YOUR USE OF OTHER MEMBERS' PERSONAL INFORMATION
5.1    The Company does not ordinarily share the identity, address or email address or other contact details of members with other members; instead, the Company facilitates communications between members through a messaging system on the Website. However, members may of course communicate their contact details to other members in connection with their use of our service.
5.2    Circumstances may also arise when one member may have an urgent need to contact another member and, in those circumstances, the Company may, at our sole and absolute discretion, provide a member's contact information to another member.
You agree that you will only use other member's personal information obtained through us:
a)    to make arrangements in connection with your use of our service; and
b)    for any other purpose to which the other member expressly agrees after complete disclosure of the purpose.
5.3    Under no circumstances will you disclose another member's personal information to any third party without the express consent of that member.

6    WHERE THE COMPANY STORES YOUR PERSONAL DATA AND DATA SECURITY
6.1    The data that the Company collects from you may be transferred to, and stored at, a cloud-based service provider with multiple data storage locations in the United States (USA) and other locations outside the USA. The data may also be processed by others operating outside the USA who work for the Company or for one of our partners. Such staff may be engaged in, among other things, the processing of payment details and/or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. The Company employs generally accepted industry standards to protect your personal information and the Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
6.2    All information you provide to the Company is stored on secure servers. Any payment transactions will be encrypted using secure technology. Where the Company has given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. The Company asks you not to share a password with anyone.
6.3    Unfortunately, the transmission of information via the internet is never completely private or secure. Although the Company will do our best to protect your personal data, the Company cannot guarantee the security of any of your data transmitted to the Website and any transmission is at your own risk. Once the Company has received your information, the Company will use strict procedures and security features to try to prevent unauthorized access, misuse or loss. Under no circumstance shall the Company be liable for any exposure of your personal information.

7    INFORMATION ABOUT OUR USE OF COOKIES
7.1    The Website uses cookies and other analytic technologies (together referred to herein as “Cookies”) to distinguish you from other users of the Website. This helps the Company provide you with a good experience when you browse the Website and also allows the Company to improve the Website.
A cookie is a small file of letters and numbers that the Company stores on your browser or the hard drive of your computer or device, if you agree. Cookies contain information that is transferred to your hard drive.
7.2    The Company may use the following cookies:
a)    Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website or make use of e-billing services.
b)    Analytical/performance cookies. They allow the Company recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps the Company improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily. All information collected by these cookies is aggregated and, therefore, anonymous.
c)    Functionality cookies. These are used to recognize you when you return to the Website. This enables the Company to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
d)    Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. The Company will use this information to make the Website and the advertising displayed on it more relevant to your interests. The Company may also share this information with third parties for this purpose. All information collected by these cookies is aggregated and, therefore, anonymous.
You can find more information about some of the individual cookies the Company currently uses and the purposes for which the Company uses them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which the Company has no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can block the download of all or some cookies or remove/disable them (including the cookies the Company uses) by altering the privacy settings on your web browser. Note, using your browser settings to block all or some cookies (including essential cookies) may prevent you from being able to access all or parts of the Website.
You can also prevent your data from being used by Google Analytics by downloading and installing the Google Analytics opt out browser add-on. Guidance on how to do this can be found at https://tools.google.com/dlpage/gaoptout/.

8    YOUR RIGHTS
8.1    You have the right to ask the Company not to process your personal data for marketing purposes. The Company will usually inform you (before collecting your data) if the Company intends to use your data for such purposes or if the Company intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing (i.e. to opt out of receiving any marketing communications) at any time by contacting the Company at info@seniorhomexchange.com. 
8.2    The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that the Company does not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

9    ACCESS TO INFORMATION
9.1    The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of $20 to meet our costs in providing you with details of the information the Company holds about you.

10    CHANGES TO THIS PRIVACY POLICY
10.1    The Company reserves the right to update or change this privacy policy from time to time. Any such updates or changes will be posted on this page (and will be effective immediately). If you do not agree to any updates or changes, please stop using the Website.

11    CONTACT DETAILS
11.1    If you have any questions or complaints regarding this privacy policy, please email the Company at info@seniorhomexchange.com.