WELLTOWER
Website Privacy Policy
Last modified: September 29, 2023
This Privacy Policy (this “Privacy Policy”) discloses the privacy practices of Welltower Inc. (“Welltower,” “our”, “us” or “we”) of 4500 Dorr Street, Toledo, OH 43615 with respect to our collection and use of United States residents’ Personal Information (defined below), including on our websites such as www.wtwebtest.welltower.com and medicaloffice.wtwebtest.welltower.com (collectively, the “Site”).
Please read this Privacy Policy as it provides important information regarding your use of the Site, our data and privacy practices, and explains your rights. You acknowledge that this Privacy Policy is part of the Terms of Use for the Site (the “Terms of Use”), and by accessing or using the Site, you accept and agree to be bound by the Terms of Use and this Privacy Policy. If you do not agree to the Terms of Use and this Privacy Policy, please do not access or use the Site.
We reserve the right to change, revise or modify this Privacy Policy at any time and from time to time without notice to you. Such changes, revisions or modifications shall be effective immediately when we post them. You acknowledge and agree that it is your responsibility to review the Site and this Privacy Policy periodically and to be aware of any changes, revisions or modifications. Your continued use of the Site after such changes, revisions or modifications will constitute your acceptance and acknowledgment of the changed, revised or modified privacy policy and agreement to abide and be bound by it as changed, revised or modified. The date of modification is located above.
In order to better provide you with services, we may collect, process and store Personal Information about you and as further described in this Privacy Policy.
Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device or household (“Personal Information”). It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
The following list describes the categories of Personal Information we may have collected about you in the past 12 months:
We may collect Personal Information directly from: you, from your employer, from an agent or third party acting on your behalf, our group companies, business partners, companies we provide services for, publicly available sources, one of our affiliated operating companies, a lead referral service, or a data provider who collected information from you directly or indirectly, from third party data brokers, or from the use of our CCTV cameras for certain premises where they are installed for security purposes.
When you engage in certain activities on the Site, such as asking for information or requesting services, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities; however, we may ask that you provide us Personal Information. Depending upon the activity, some of the information we ask you to provide are in mandatory fields and some are in voluntary fields. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
We also use Personal Information to monitor or improve our Site; for internal business analysis; to prevent fraud, activities that violate our Terms of Use or other contracts, or that are illegal; and to protect our rights and the rights and safety of our users or others.
For those who interact with us in a commercial capacity, we use your Personal Information to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent.
We may share information with:
We provide some of our services through contractual arrangements with affiliates, services providers, partners, and other third parties. We and our service providers may use your Personal Information to operate our Site and to deliver our services. Service Providers with whom we share your Personal Information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.
Occasionally, we may be required to share your Personal Information with third parties for legitimate business purposes, or to comply with legal obligations. For example, we may share Personal Information when we believe in good faith that an applicable law requires it; at the request of law enforcement, judicial authorities (i.e. upon receipt of a court order or subpoena), appropriate governmental authorities; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety or security of third parties, visitors to our Sites, our businesses, or the public. Additional disclosures of your Personal Information to third parties for legitimate business purposes or to comply with legal obligations may include us sharing:
We do not grant access to your Personal Information to any other third parties unless we say so in this Privacy Policy or unless the law requires it.
When we may engage in digital advertising, we may sell the following categories of Personal Information (according to the broad definition of “sell” under select state privacy laws) or we may share them for purposes of cross-context behavioral advertising: personal identifiers (IP address); and internet or other electronic activity information.
These categories of Personal Information are sold to or shared for cross-context behavioral advertising to advertising networks and other companies that facilitate digital advertising. We engage in such sales and sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the Site we provide. We do so by allowing third parties to place cookies or other tracking technologies on our website that may collect information about your online activities over time and across different websites or applications. For more information about the use of cookies and other tracking technologies, see the Section 12 below.
To opt out of such sales and sharing of Personal Information, click here: https://wtwebtest.welltower.com/opt-out.
We do not use or disclose sensitive Personal Information to create profiles about individuals or for any purposes other than providing our services.
We retain the categories of Personal Information we collect for the length of time necessary to provide our Site and to comply with legal obligations or to protect our legal rights.
We summarize below the categories of Personal Information that we disclose to others.
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Category of Personal Information Collected |
Categories of Third Parties to Whom we have Disclosed Personal Information for a Business Purpose |
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Personal Identifiers |
Service providers such as IT providers, SaaS providers, banking providers who process payments or reimbursements, and other providers who help us operate our business, including our Sites and services; Consultants such as business consultants; and Advertising partners (please see the Categories of Personal Information We Sell or Share and Related Information section of this Privacy Policy). |
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Demographic Information |
HR service provides and other providers who help us operate our business. |
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Commercial Information |
Service providers such as IT providers, SaaS providers, banking providers who process payments or reimbursements, and other providers who help us operate our business, including our Sites and services; Consultants such as business consultants; Business teams that work with our clients and other entities that manage businesses for us (for example, building managers who engage with residents or potential residents); and Advertising partners (please see Categories of Personal Information We Sell or Share and Related Information section of this Privacy Policy). |
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Audio, electronic, visual, thermal, olfactory, or similar sensory information |
Service providers such as CCTV system providers or IT service providers who manage certain access controls systems located in certain facilities. |
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Internet and Other Electronic Activity Information |
Service providers such as IT SaaS providers, service providers who help us operate our business, marketing providers, and consultants such as business consultants or IT consultants. Advertising partners (please see the Categories of Personal Information We Sell or Share and Related Information section of this Privacy Policy). |
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Inferences, preferences, and other information |
Service providers such as IT SaaS providers, service providers who manage our systems, and consultants such as business consultants; and Business teams that work with our clients and other entities that manage businesses for us (for example, building managers who engage with residents or potential residents). Advertising partners (please see the Categories of Personal Information We Sell or Share and Related Information section of this Privacy Policy). |
We may also disclose the above categories of Personal Information (i) to our affiliates/group companies, (ii) to comply with federal, state, or local laws; (iii) to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (iv) to cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (v) when we sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction), or (vi) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
We believe you should have the ability to access and, where appropriate, edit the Personal Information that you have provided to us. You may access and correct your Personal Information and privacy preferences by writing us at:
Welltower Inc. 4500 Dorr Street Toledo, Ohio 43615-4040 Attn: Website Administrator
Please include your name, address, and/or e-mail address when you contact us. We encourage you to promptly update your Personal Information if it changes.
We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards.
While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security. As a result, while we strive to protect your Personal Information, you acknowledge that (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
We endeavor to adhere to self-regulatory advertising principles, such as the Digital Advertising Alliance’s Principles. If you are interested in learning more about and/or opting out of online behavioral advertising, sometimes called interest-based advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as www.youradchoices.com or aboutads.info. Please note that while we provide these links for your convenience, we do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.
We use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our Site. Tracking technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our Site. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as making it possible for you to save your preferences and help us understand how you interact with our Site.
We also allow third parties to use tracking technologies on our Site for analytics and advertising. They assist in helping display advertisements, tailor advertisements to your interests and to assist in determining if you require assistance or are having problems navigating on our Site. Some of these third parties are our service providers that may use certain technologies to record your interactions with the sites, including without limitation, your keystrokes and mouse clicks, and information about when, how and from where you accessed our sites. This information is used to help us manage our sites and provide a good user experience. The service providers we use in this regard agree not to sell or disclose any of the recorded information to third parties (other than subcontractors who assist in providing this service to us or for legal compliance purposes at our direction). Other third parties use the tracking technologies to collect information about how you interact with other website and advertisements across the Internet to provide advertising that is tailored to your interests and which may appear on our Site or on other website or platforms.
You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.
We use Google Analytics to evaluate the use of our Site. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a Site, what pages they visit when they do so, and what other websites they visited prior to visiting our Site. For information about Google’s privacy practices, please refer to the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US#infocollect.
Except as otherwise discussed in this Privacy Policy, this document only addresses our collection, use and disclosure of Personal Information. Other sites accessible through the Site have their own privacy policies and data collection, use, and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties.
While our Site may respect Global Privacy Control signals where required, our Sites do not respond to or honor other Do Not Track instructions, which are preferences that users can set in certain web browsers. If you do not leverage the Global Privacy Control signal, you can, however, adjust your web browser’s privacy preferences regarding the use of most cookies, through your browser’s privacy settings. Unless you choose to block cookies, some of our Sites may issue cookies when you visit them or click on an e-mail link that we send to you, even if you have previously deleted our cookies. Deleting or blocking cookies may impact your experience while interacting with the Site, and some features may not work without cookies.
Our Site is not designed for, and we do not knowingly collect personally identifiable information from, users under the age of 13 (or in some jurisdictions, under the age of 16). If you are a parent or guardian and you are aware that your child has provided us with Personal Information via our Site(s), please contact us via email at: legalnotice@wtwebtest.welltower.com. If we become aware that we have collected Personal Information from anyone under the age of 13 (or in some jurisdictions, 16) without verification of parental consent, we will take steps to remove it from our systems.
If you are a resident of the U.S. state of California, you have certain rights granted by the California Consumer Privacy Act and the amendments thereto under the California Privacy Rights Act (collectively, “CCPA”), which are described in this section of the Privacy Policy. This portion of the Privacy Policy describes the rights of California residents. Terms not defined in this Section 16, shall have the meanings set forth to them in the CCPA.
Please note, this portion of the Privacy Policy does not include Personal Information that is exempted from the CCPA.
As a California Resident you have certain rights in relation to your Personal Information.
Your Right to Request Disclosure of Information We Collect and Share About You. We are committed to ensuring that you know what Personal Information we collect. To that end, you can ask us for any or all of following types of information regarding the Personal Information we have collected about you on or after January 1, 2022:
Your Right to Correct Inaccurate Personal Information. You have the right to request that we correct Personal Information we hold that you believe is not accurate. We will take steps to determine the accuracy of the Personal Information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the Personal Information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating the request.
Your Right to Request Deletion of Personal Information We Collected About You. Upon your request, we will delete the Personal Information we have collected about you, subject to certain legal exceptions.
Your Right to Ask Us Not to Sell or Share Personal Information We Have Collected About You. With respect to those categories of Personal Information that we sell to third parties or share with third parties for the purpose of cross-context behavioral advertising, you have the right to opt out of such sales and sharing.
With respect to those categories of Personal Information that we sell to third parties or share with third parties for the purpose of cross-context behavioral advertising, you have the right to opt out of such sales and sharing.
Opt-out Preference Signals
An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.
We recognize the Global Privacy Control signal and do so at the browser level. This means that if the signal is sent through a specific browser, we will recognize it for that browser only. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).
To make a request, please call us at 877-670-0070 or legalnotice@wtwebtest.welltower.com. For requests for access or deletion, we will first acknowledge receipt of your request within 10 days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfil, we’ll let you know. We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
You can direct us not to sell your Personal Information or share it for purposes of cross-context behavioral advertising at https://wtwebtest.welltower.com/opt-out. For such requests, we will comply no later than 15 business days after receipt of your request.
Individual Requests. We will ask California residents for two pieces of identifying information and attempt to match it to information that we maintain about them in order to verify their request. Additionally, depending on the nature of your request, we may require that you provide a declaration attesting to your identity, signed under penalty of perjury. If we are unable to verify your identity with a degree of certainty required, we will not be able to fulfil to the request. We will notify you to explain the basis of the denial. Additionally, we will treat the request as one seeking disclosure of the categories of Personal Information we have collected about you and endeavor to verify your identity using the less-stringent standards applicable to such requests.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.
Authorized Agents – Additional Verification Required. You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process to verify your identity and provide us with proof of the agency relationship.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Household Requests — There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above. If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.
If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year.
If you have questions on the processing of your Personal Information, please contact us here: legalnotice@wtwebtest.welltower.com or call us toll free at 877-670-0070, or write us at:
Welltower Inc.
4500 Dorr Street
Toledo, Ohio 43615-4040
Attn: Data Privacy Officer
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 877-670-0070 or contact legalnotice@wtwebtest.welltower.com.