Home Instead Privacy Policy
(Effective June 28, 2024)
Who We Are
Home Instead, Inc.,is the franchisor of the Home Instead® network. The Home Instead franchise network is made up of independently owned and operated franchise and master franchise businesses. (each a “Franchise” and collectively, the “Network”).
Scope of Policy
This Privacy Policy explains how Home Instead, Inc. and its subsidiaries, ("Home Instead", "we," “our,” "us") collect, use, and share Your information, including through Our digital properties on which this Privacy Policy is linked (“Site”). This Privacy Policy applies generally to the information We collect about You as a consumer, employee or contractor, prospective employee, member of the Network, prospective member of the Network, or about another person for whom You have the legal authority to represent, such as Your family member, friend, or client. (“You,” “Your,” “Yourself”).
This policy is limited to data of US and Canadian residents only. Our international privacy policy may be accessed here.
This Privacy Policy generally does not apply to data collected, controlled, or processed by independently owned and operated Network franchise businesses, third-parties acting on behalf of Network franchises (rather than Home Instead), except to the extent Your specific data has been collected by Us. Inquiries regarding any Network marketing communications, franchise Network employment or application records, or client records, must be directed to the appropriate franchise office.
This Privacy Policy does not apply to any protected health information covered by the Health Insurance Portability and Privacy Act (“HIPAA”), and its implementing regulations. Members of the Network may maintain their own privacy notices. Where subject to HIPAA, and members of the Home Instead Network and Honor Technologies, Inc.(“Honor”) jointly provide care services, client health information is subject to the linked Notice of Privacy Practices.
If your data is collected, used, or shared in connection with your employment or contracting with Home Instead, Inc., your data is also subject to the terms of all applicable employment policies, handbooks, rules, and agreements, which will control in the event of any conflict.
If your data is collected, used, or shared in connection with your status as a member of the Network, your data is also subject to the terms of the applicable franchise agreement(s) and written requirements, which will control in the event of any conflict.
Notice of Collection of Personal Information
We may collect the following categories of personal information:
- Identifiers
- Customer personal information under California. Civ. Code § 1798.80(e)
- Voluntarily provided information on personal characteristics of protected classes,
- Commercial information & financial information,
- Professional or employment-related information,
- Sensitive personal information,
- Website/Application interaction or similar network activity,
- Biometric Information
- Sensory data
- Health & Physical Characteristics, and
- Inferences drawn from the above.
Categories of Sensitive Personal Information
Under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), we collect and use the following categories of sensitive personal information:
- Social Security Numbers
- Driver’s License Numbers
- State Identification Card Numbers
- Financial Account Information
- Precise Geolocation
- Health Information
- Biometric Information
- Contents of Mail, Email, and Text Messages
We collect this information so that we may:
- Communicate with you
- For administration of our business
- Anonymize Your data for further internal and external use in a manner that does not identify You
- Enhance security and preventing fraud or illegal activity
- Perform our contractual duties and obligations or enter into an agreement
- Verify and onboard home care partners on to the Honor care platform
- Ensure compliance with legal obligations
- Facilitate of online or platform interactions, (excluding use of web tracking technologies for targeted advertising)
- Care coordination & customer service,
- Provide educational resources/ learning management
- Identify and test business innovations
- Perform market research and analytics
- Advertise/market for employment, recruitment, products and Services
We may share identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, and Website/Application interaction or similar network activity for purposes of targeted advertising. We do not sell or share client health information.
A more detailed description with examples is provided below in the Data We Collect, Data We Use and Data Sharing sections.
Data Minimization and Purpose Limitation
We adhere to principles of data minimization and purpose limitation, which means we collect, use, retain, and share personal information only as reasonably necessary and proportionate to achieve the purposes for which the information was collected or processed, or for other disclosed purposes compatible with the context in which the personal information was collected.
Retention Periods
We retain personal information only for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. The specific retention periods for each category of personal information are as follows:
- Identifiers: Retained for the duration of your relationship with us and for a period thereafter as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Customer Personal Information: Retained for as long as needed to provide you with our services and for a period thereafter as required by law.
- Personal Characteristics of Protected Classes: Retained for as long as necessary to fulfill the purposes for which such information was collected and as required by law.
- Commercial Information: Retained for the duration of your relationship with us and for a period thereafter as necessary to comply with our legal obligations.
- Financial Information: Retained for as long as needed to provide you with our services and for a period thereafter as required by law
- Professional or Employment-Related Information: Retained for the duration of your employment or application process and for a period thereafter as required by law.
- Sensitive Personal Information: Retained for as long as necessary to provide the services or goods requested and for a period thereafter as required by law.
- Website/Application Interaction or Similar Network Activity: Retained for the duration of your use of our website and for a period thereafter as necessary to comply with our legal obligations.
- Biometric Information: Retained for as long as needed to fulfill the purposes for which such information was collected and for a period thereafter as required by law.
- Sensory Data: Retained for as long as necessary for quality assurance purposes and for a period thereafter as required by law.
- Health & Physical Characteristics: Retained for as long as necessary to fulfill the purposes for which such information was collected and as required by law.
General Retention Policy:
We will retain and use Your Personal Information for as long as necessary to satisfy the purpose(s) for which it was collected and to comply with our legal obligations, resolve disputes, and enforce our agreements. Once data is aggregated, de-identified, or anonymized, it may be retained for a longer period as permitted by law.
Communications Consent and Practices
By utilizing our Services or providing your information, You acknowledge and consent to the terms of this Privacy Policy. You agree not to provide us with information about any other person unless You have that person’s consent or other legal authority.
Telephone Communications
Your telephone communications with Us may be recorded or monitored for quality control purposes. By communicating with Us in this manner, You expressly consent to the recording for such purposes.
Contact Information and Communication
By providing Us with Your contact information, such as email or telephone number, You agree to be contacted by Us and by the providers we have contracted with to contact You on our behalf. This includes receiving communications by telephone call or text message at the telephone number You provided using automatic telephone dialing systems, even if You previously registered on a Do Not Call registry. We ensure that any provider we use for SMS services does not use your phone number or SMS consent for their own marketing purposes. Your consent is not a condition of purchase.
Text Messaging Consent and Communication
Home Instead, Inc. offers customers the option to receive updates and promotional messages via text. By subscribing through our designated sign-up forms, you consent to receive text messages from us and our franchisees. These messages may include promotional offers, service updates, and other relevant communications. We do not share your phone number or SMS consent with third parties for their marketing purposes.
Collection and Use of Information
When you opt into our text messaging service, we collect your mobile phone number and any other information you provide during the sign-up process. We may also collect data regarding your interaction with our messages, such as confirmation of receipt. This information is used solely for the purpose of sending you the text messages you have consented to receive. The information collected may be used to send you text messages according to your preferences and behaviors. We do not share your mobile phone number or SMS consent with third parties for their own use or marketing purposes under any circumstances.
Automated Technology
We use automated systems, including autodialers, to send text messages to the mobile number you provide. By consenting to receive our text messages, you acknowledge and agree that such automated technologies may be used.
Opt-Out Options
You may opt out of receiving text messages at any time by replying with the word "STOP" to any message you receive from us. Upon receiving your opt-out request, we will promptly discontinue sending you text messages. You may also choose to have your name removed from our registration list or cease marketing communications by using the opt-out option in any marketing emails or contacting us using the information provided at the bottom of this Privacy Policy. We will respond to your request in the timeline required by law.
We Do Not Sell Your SMS Data
At Home Instead, Inc., we are committed to protecting your privacy. To ensure transparency and trust, we want to make it clear that:
- No Sale of SMS Data: We do not sell any personal information collected through our SMS services, including phone numbers and SMS consents. This data is used solely for the purposes you consented to when providing it.
- Targeted Marketing Activities: While we engage in targeted marketing activities using other types of personal information, SMS data collected under consent is strictly excluded from these practices. We do not share or sell your SMS data for any marketing purposes.
Opting out of one form of communication does not automatically opt You out of other forms. For example, if You opt-out of receiving marketing emails, You may still receive marketing text messages if You have opted-in to receiving them. If You submit a general opt-out request on this Site, we will unsubscribe You based upon the information provided, such as Your name, email address, and phone number.
CAN-SPAM Act Compliance
Commercial Email Communications
We comply with the requirements of the CAN-SPAM Act and are committed to ensuring that you receive only those emails that you request or consent to receive. The following outlines our email communication practices:
Opt-Out and Unsubscribe Optionns
- How to Opt-Out: If you wish to unsubscribe from receiving future commercial emails from us, you may follow the unsubscribe instructions included in each email or contact us using the information provided in the "Contact Us" section below. We will process your request promptly.
- Email Content: Our commercial emails will clearly state that they are advertisements and will include a valid physical address. Each email will also include an easy and clear method for you to unsubscribe from our email list.
- Processing Requests: We will honor your opt-out request within 10 business days and will ensure that your email address is removed from our mailing lists.
Prohibited Practices
- We do not use false or misleading header information.
- Our email subjects are not deceptive and accurately reflect the content of the message.
- We do not harvest email addresses from websites or use automated means to collect email addresses without consent.
Contact Information for CAN-SPAM Compliance
If you have any questions about our email practices or wish to opt-out of our commercial emails, please contact us using the information provided in the "Contact Us" section below.
Data Security
We are committed to protecting the security of your personal information. Measures are implemented to ensure the security and integrity of your data against unauthorized access and misuse.
Changes to Our Communications Practices
If we make changes to our communications practices, we will update this policy and notify you as required by law or contractual obligations.
Your Rights and Choices
You have the right to access, update, or request the deletion of your personal information that we hold. If you wish to exercise these rights, please complete the privacy request form linked in this policy.
Managing Web Tracking Technologies
Consent
When You first visit our site, a banner will appear and request consent to our use of online technologies that are not necessary for the function of our site. Our site only uses such optional online technologies when You consent.
If you accept the use of tracking technology, then a third party advertiser, search provider or ad network partner may collect information about Your activity on our website, on devices associated with You, and on third-party sites and applications to decide which ads You see both on our websites and applications and on third-party sites and applications.
You may opt-in or opt-out of the placement of optional technology going forwards, at any time, via our Cookie Preferences using this link:
Browser Settings
We generally use local storage ("LS") also referred to as HTML5 to store web content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon Your web browsing activity use local storage to collect and store information. Service providers that collect tracking data on our behalf may provide an opportunity for You to choose not to be tracked online. Various browsers may also offer their own management tools for removing HTML5 LS.
You may be able to adjust Your settings to limit ad tracking (e.g. “Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads'' or “Opt Out of Ads Personalization” on Android).
You may also be able to control receipt of targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers by visiting the Digital Advertising Alliance.
If You are seeing one of our advertisements on a third-party site, such as a social media site, You may also have the option to opt-out of such behavioral advertising through that site’s preference settings. Even if You opt out of personalized advertising, You may still see ads based on factors such as Your general location derived from Your IP address, Your browser type, and Your search terms.
Do Not Track
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting the user's activity that such activity will not be tracked. If You are using a “do not track” function on Your web browser, our cookie manager software will recognize this as an opt-out preference signal, such that we will not collect or share Personal Information we associate with your browser or device for purposes of targeted advertising.
Data We Collect
There are four main ways we collect personal information:
1. Data You Provide: Data You provide to Us;
2. Automated Data: Data collected through electronic/automated means;
3. Network Data: Data we are authorized to access and receive as from our affiliates, or as the franchisor at the Home Instead Network; and
4. Other Data Sources: Data from other sources (such as our service providers, Honor Technologies, Inc., or public sources).
We may combine data You provide to us with automated data and from other data sources. For example, we may receive automated data about those accessing our Site and combine that with data You provide or Network data to assess and improve the quality of our Site and services by and on behalf of the Home Instead Network.
Data You Provide
We collect data You provide to Us when You use the Site or Our services, including communicating with Us over the telephone, email, SMS or completing a website form. This includes personal information, which identifies (whether directly or indirectly) a particular individual.
Personal information You provide includes the types of data listed below (with examples).
1. Identifiers: name, postal address, phone number, or email address.
2. Customer Personal information under California. Civ. Code § 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
3. Personal characteristics of protected classes. Age, gender and other information voluntarily provided, such as marital status, medical diagnosis, physical or mental disability.
4. Commercial information. Records of Services obtained or considered, client payor sources, benefits, budgets or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
5. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments, invoices, and expenses relative to the Network or employees.
6. Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications, or through any chat functionality.
7. Professional or employment-related information. We may receive employment-related information from applicants and employees, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.
8. Sensitive Information. Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and the contents of a consumer’s mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.
9. Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications or through any chat functionality.
10. Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and health data that can be used to identify an individual.
11. Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
12. Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide.
Automated Data
As is true of most websites, we gather certain information about Your Site and web usage, patterns and location. We, our affiliates, and third-party vendors/service providers use technologies such as cookies, flash cookies, pixels, tags, scripts, software development kits, application program interfaces, and web beacons.
These technologies may be used for many purposes including, for example, to:
- Provide useful features to simplify Your experience when You return to or navigate our Site (for example, remembering the contact information You entered so You don’t need to re-enter it)
- Deliver relevant content and advertising based on Your preferences, usage patterns and location;
- Monitor, evaluate, and optimize the use and operation of our sites and applications; and
- Analyze traffic on our sites and on the sites of third parties.
We may receive reports from our third-party vendors/service providers based on the use of these technologies that contain personal information, aggregate information, or anonymous information.
Personal information we may automatically collect includes the types of data listed below (with examples).
1. Identifiers: online identifier, Internet Protocol (IP) address, or unique device identifiers.
2. Site interaction or similar network activity–interaction with the Site or advertisements including logs and session data, and browser, network, device and operating system information. We may also track the site You visited prior to our Site or what site You visit when You leave us.
3. Sensitive Personal Information-Geolocation data–Physical location, such as country or state from which You access the Site. This may include precise geolocation data.
Independently owned and operated Home Instead franchise businesses may also utilize such technologies on the Site dedicated to their specific franchise. The franchise business is the controller of any such data collection and Home Instead, Inc. does not collect or receive such data. Each franchise business is responsible for its data collection, use and disclosure; however, collection via the Site is subject to the terms and limitations of this privacy policy.
Network Data
As a franchisor of the Home Instead Network, we may require access to data of the Home Instead franchise Network for purposes such as maintaining brand standards and performing services on behalf of the Network. Personal information we may access from the Network includes the types of data listed below (with examples).
1. Identifiers. name, postal address, phone number, or email address.
2. Customer Personal information under California. Civ. Code § 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
3. Personal characteristics of protected classes. Age, gender and other information voluntarily provided, such as marital status, medical diagnosis, physical or mental disability.
4. Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
5. Professional or employment-related information. While Home Instead, Inc. is not the employer of those working, or seeking to work, for independently owned and operated Home Instead franchise businesses, We may have access to employment-related information of the Network, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.
6. Sensitive Personal Information. Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs,the contents of a consumer’s mail, email, and text messages, and information collected and analyzed concerning a consumer’s health.
7. Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide.
8. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.
Other Data Sources
We may also collect Personal Information from other sources (such as our service providers, including lead generation services, or public sources). Personal information we collect from other sources includes the types of data listed below (with examples).
1. Identifiers. name, postal address, phone number, or email address.
2. Customer Personal information under California. Civ. Code § 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
3. Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
4. Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
5. Professional or employment-related information. We may have access to employment-related information of Our employees or applicants, including: current and past employer name, positions held, physical demands of positions held, and wage information (where permitted); availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military (where applicable to the administration of benefits); and performance record.
6. Sensitive Personal Information. Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and the contents of a consumer’s mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.
7. Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and health data that can be used to identify an individual.
8. Site interaction or similar network activity. Information You provide for Us in any third-party contact form or chat functionality.
9. Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
10. Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information.
11. Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.
Data Use
For each type of data we collect, we use such Personal Information for the business purposes set forth below:
1. Communicating with You–For example, we may use client personal information to respond to an online or phone inquiry.
2. Verify and enhance quality of products and Services–For example, we may use data about caller inquiries, perform surveys or gather feedback to continuously improve the experience of those seeking Network services or employment.
3. Administration of our business–For example, we may use your personal information for customary business functions like obtaining legal and tax advice, obtaining payment, audits, or for HR functions like applicant reviews, provision of offer letters, onboarding, payroll, reports, complaints, compensation reviews, and performance management.
4. Anonymizing Your data for further internal and external use in a manner that does not identify You–For example, we may aggregate and de-identify data for analysis of survey results and related insights.
5. Enhancing security and preventing fraud or illegal activity–For example, we may use personal information to verify your identity when you submit a data request.
6. Performing our contractual duties and obligations or entering into an agreement–For example, we may use personal information to enter into and administer a franchise agreement.
7. Ensuring compliance with legal obligations–For example, employment laws may require us to collect and maintain employee payroll records or other documentation.
8. Facilitation of online interactions–For example, we may use web tracking technologies to improve your user experience on our websites.
9. Franchise Client Lead Management, Engagement & Customer Service–For example, we may collect inquiries on behalf of the Network via our website.
10. Providing educational resources/ learning management–For example, we may document employee orientations and training for the purposes of confirming compliance with our requirements, payroll or compliance with regulatory requirements.
11. Identifying and testing business innovations–For example, we may receive data from franchisees that pilot business innovations.
12. Market research and analytics–For example, we may use Personal Information about employees to determine where we should focus future recruitment and advertising efforts.
13. Advertising/marketing for brand promotion, employment, recruitment, products and services–For example, if you accept cookies on our website, we may use Personal Information to determine the effectiveness of our advertising.
14. Qualification of prospective franchise owners or master franchise principals
15. Network event planning and coordination–For example, we may host training events for the franchise Network and require information in order to coordinate and communicate about the event.
16. Franchisor Brand Management, Standards, and Network Support–For example, we may require information to assess Network franchisee’s compliance with our brand standards.
We may use the information we collect about You in other ways, which we will tell You about at the time we collect it or before we begin using it for those other purposes. In certain instances You will have an opportunity to limit our uses at the time Your Personal Information is collected. You may also have the right to request deletion of Your data, depending upon Your state of residence, as provided below.
Public Sharing
You may post public testimonials, comments, feedback, or reviews on our Site, through a third-party site or one of our service providers. When You post, or authorize posting, such information publicly You understand that such information is no longer subject to this Privacy Policy and consent to Us posting Your testimonial along with Your name.
Data Sharing
We may disclose Personal Information to third-parties for business purposes as follows. However, we do not share phone numbers or SMS consent with third parties for their marketing purposes without your consent. We ensure that any sharing of personal information is in compliance with applicable privacy laws and regulations.
1. Network & Affiliates.
We may share the following categories of Personal Information with our Network and affiliates: identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, financial information, professional or employment-related information, Website/Application interaction or similar network activity, and Health & Physical Characteristics.
We may disclose such Personal Information for the purposes of: communicating with You, to verify and enhance quality of products and Services, administration of our business, anonymizing Your data for further internal and external use in a manner that does not identify You, enhancing security and preventing fraud or illegal activity, performing our contractual duties and obligations or entering into an agreement, ensuring compliance with legal obligations, facilitation of online interactions, franchise client lead management, engagement & customer service, providing educational resources/ learning management, identifying and testing business innovations, franchisor brand management, standards, and network support, and administration of our social purpose mission.
We may also share sensitive personal information concerning a consumer’s health, to the extent reasonably necessary for our Network or Affiliates to coordinate care, provide services, and verify and enhance the quality of Network services.
2. Third-Party Service Providers
We may share all categories Personal Information collected with service providers, who have entered into an agreement to only process data on our behalf and not sell or share the data.
We may disclose such Personal Information for the purposes of: communicating with You, to verify and enhance quality of products and Services, administration of our business, anonymizing Your data for further internal and external use in a manner that does not identify You, enhancing security and preventing fraud or illegal activity, performing our contractual duties and obligations or entering into an agreement, ensuring compliance with legal obligations, facilitation of online or platform interactions, franchise client lead management, engagement & customer service, providing educational resources/ learning management, identifying and testing business innovations, market research and analytics, qualification of prospective franchise owners or master franchise principals, network event planning and coordination, franchisor brand management, standards, and network support, and administration of our social purpose mission.
3. Legal and Administrative Authorities, Officials and Courts
We may disclose all categories of Personal Information where we believe it is necessary to comply with the law in special cases when we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may have breached our Terms of Use or who may be causing (whether intentionally or unintentionally) injury to or interference with our rights or property, other website users, or anyone else who could be harmed by such activities. We may also disclose Personal Information to law-enforcement personnel and agencies when requested to do so, as required by law, such as to comply with a subpoena. We may also disclose Personal Information to public health authorities as required by law.
Such disclosures may include sensitive personal information to the extent reasonably necessary and proportionate to accomplish the legally permitted purpose of disclosure.
4. Business Transfers.
We may disclose any category of Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction,or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use Your Personal Information only for the purposes disclosed in this Privacy Policy. Disclosures will only include Personal Information to the extent reasonably necessary and proportionate to accomplish the legally permitted purpose of disclosure.
We may disclose or share Personal Information to third-parties for commercial purposes as follows:
1. Third-party Vendors
We may share the following categories of Personal Information with third-party vendors who do not process data solely on our behalf or utilize the data for targeted advertising: identifiers, customer personal information under California. Civ. Code § 1798.80(e), commercial information, and Website/Application interaction or similar network activity.
We may disclose Personal Information to such vendors for the purposes of: communicating with You and advertising/marketing for brand promotion, employment, recruitment, products and services.
You have the ability to opt-out of such sharing, as outlined in the Communications Consent and Practices section.
Disclosure to such third-party vendors may be considered a “sale” or “sharing” of personal information under state law. We do not provide Your data to third parties in exchange for financial gain. However, California law defines the “sale” or “sharing” of information as including any disclosure for use in targeted marketing.
We may otherwise disclose Your Personal Information to third-parties with Your consent or at Your direction, where permitted or required by law.
We do not use or disclose sensitive personal information of California residents for purposes other than those specified in regulation as not requiring the ability of consumers to limit use.
Links to Other Websites and Social Media
Our Site may offer links to websites that are not run by us but by third parties. If You visit one of these linked websites, Any information You give to those organizations is subject to their privacy policy, terms and conditions, and other policies. We are not responsible for the policies and practices of third parties. You understand and agree that by clicking on a link to a third party site You have left the Site, and this Privacy Policy is no longer in effect.
We may maintain profiles or accounts with various third-party social media providers, which may include Facebook, Twitter, Instagram, LinkedIn, YouTube, and Google+. While our collection, use, and disclosure of information obtained through the Social Media Properties and/or the Features is governed by this Privacy Policy to the same extent as information gathered through the Site, the information third-party social media providers collect or access through Your use of the Social Media Properties is governed by such third-party’s privacy policy. We encourage You to review the social media provider’s privacy policy before interacting with a Social Media Property and/or Feature.
The Site may offer publicly accessible blogs. You should be aware that any information You provide in these areas may be read, collected, and used by others who access them. You may contact Us to request removal of Your Personal Information from any blog we maintain. In some cases, we may not be able to remove Your Personal Information, in which case we will let You know if we are unable to do so and why.
Security
In order to prevent unauthorized access or disclosure we have put in place reasonable security measures, including physical, electronic and managerial procedures to safeguard and secure Your Personal Information.
We use standard Transport Layer Security (TLS) certificates to secure pages used for inputting users' Personal Information. However, unless we expressly advise You otherwise, the functionality on our Site does not provide a means for completely secure and private communications between us. Due to the open communication nature of the Internet, we cannot guarantee that communications between us will be free from unauthorized access by third parties.
If You believe that the Personal Information You have provided us has been compromised, or if You become aware of a potential security vulnerability in our Platform, please contact us as indicated below in the "Contact Us" section.
International Visitors
This Site is hosted in the United States and is intended only for United States and Canadian visitors. This website is not intended for users located in other countries, including those within the European Economic Area. Please be aware that Your personal information may be transferred to and maintained on servers or databases located outside Your state, province or country and that such information is processed and stored in the United States. By providing Your personal information, You confirm Your consent to having such personal data hosted and accessed in the United States.
Guidelines for Children
We do not specifically collect information about children nor market our and our Network's products or services to children. We have no reason to believe that the Site will attract children, or that children will access the Site or provide Personal Information.
U.S. State-Specific Data Privacy Rights
Certain states provide residents with privacy rights. These rights are not absolute and in certain cases are subject to conditions or limitations as specified in your state’s privacy law. We will not unlawfully discriminate against You because You exercised any of Your rights under applicable state privacy law.
General Privacy Rights for U.S. Residents
Residents of California, Virginia, Colorado, Connecticut, Utah, and other applicable states have the following rights regarding their personal information:
- Right to Know: You have the right to request access to the categories and specific pieces of personal information we collect, use, disclose, sell, and share about you.
- Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal data and the purposes of the processing.
- Right to Delete: You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
- Right to Portability: You have the right to obtain a portable copy of the personal data that you provided to us.
- Right to Opt-Out of Sale or Sharing of Personal Information: You have the right to opt out of the sale or sharing of your personal information to or with third parties for purposes of targeted advertising (as defined by applicable law). We do not knowingly sell any personal information of children under age 16.
California Residents: Additional Privacy Rights
In addition to the general privacy rights, residents of California have the following specific rights regarding their personal information:
- Right to Limit Use of Sensitive Personal Information: You have the right to request that we limit the use of your sensitive personal information to only those uses that are necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, as well as for certain other business purposes as permitted by law.
- Right to Access Information about Automated Decision-Making: You have the right to request meaningful information about the logic involved in our automated decision-making processes and a description of the likely outcome of those processes.
Opt-Out Preference Signals
We recognize and respond to opt-out preference signals, such as the Global Privacy Control (GPC). These signals allow consumers to communicate their preferences regarding the sale or sharing of their personal information. If Your browser or device is set to send a GPC signal, we will honor that signal as a valid opt-out request.
How to Enable Opt-Out Preference Signals
To enable an opt-out preference signal, you can configure your browser or use a tool that supports the Global Privacy Control (GPC). Once the signal is detected, we will apply your opt-out preference across all applicable online interactions without requiring further action from You.
Impact of Opt-Out Preference Signals
When we receive an opt-out preference signal from your browser or device, we will:
- Automatically apply Your request to opt out of the sale or sharing of Your personal information.
- Cease processing Your personal information for purposes of targeted advertising and other activities classified as "selling" or "sharing" under applicable laws.
Additional Opt-Out Options
In addition to using opt-out preference signals, you may also submit an opt-out request through the following methods:
- Privacy Request Form
- Contact Information: Reach out to us directly using the contact details provided below.
Contract Requirements with Third Parties
Our contracts with third parties, service providers, and contractors include terms that specify the purposes for which the personal information is collected and ensure that these parties provide comparable levels of privacy protection. These contracts stipulate that:
- Personal information can only be processed for specified purposes.
- The third party must maintain the confidentiality and security of the personal information.
- The third party must notify us if they can no longer meet these standards.
- Personal information cannot be further disclosed without our permission, except as required by law.
Exercising Privacy Rights
Request Form
To exercise your privacy rights, you may submit an online Privacy Request Form or call us as indicated below in the “Contact Us” section.
You may use the same form to appeal our decision regarding a request related to your rights under applicable state law.
To submit a request to opt out of the sale or sharing of your personal information, you may click on the link “Do Not Sell or Share My Personal Information” on the footer of our websites. Alternatively, you may enable online a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out as outlined in the Consumer Consent and Choices section above.
Verification Process
To protect Your privacy, we will verify Your identity prior to responding to a request for data. The request form will require some initial contact information that we will compare against our records.
Upon submission of the form You will be required to confirm Your request via email. You may receive an email from “On Behalf of Our Privacy Team” to which You must respond in order to verify Your identity and access our response(s).
If You request disclosure of specific pieces of personal information, we may take additional steps as permitted or required by law. For example, we may call You to verify Your request, in addition to matching at least three pieces of personal information You provide with information we maintain, and require a signed declaration, under penalty of perjury, that You are requesting Your own personal information.
Please note that state law may prohibit us from disclosing highly sensitive information in response to a request, including Your: social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. We will, however, inform You if we have collected such information and identify the type of information with sufficient particularity.
If an authorized agent is submitting on Your behalf, we will require submission of either 1) a written authorization, signed by You, that authorizes that agent to make the specific request on Your behalf; or 2) other valid legal authorization.
Any personal information collected from You in connection with verification of Your request will be used solely for the purposes of verification.
Canadian Residents: Your Privacy Rights
Canadian visitors may request: (a) the name or title and the address of the Privacy Officer to whom complaints or inquiries can be forwarded; (b) access to Your Personal Information in our possession or control; (c) a description of the type of Personal Information we hold about You, including a general account of its use; and (d) what Personal Information is made available to related organizations, i.e.: affiliated companies.
Upon request, subject to certain exceptions under applicable Canadian privacy legislation, we will inform You of the existence, use, and disclosure of Your Personal Information and will give You access to that information. You may wish to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.
Under applicable law, we may not be able to provide access to all of Your Personal Information. The reasons for denying access will be provided to You upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. We may charge a reasonable administration fee for accessing Personal Information.
PIPEDA Compliance
Commitment to Privacy
We are committed to protecting the personal information of our Canadian customers and ensuring compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA). This section outlines our practices concerning the collection, use, disclosure, and management of personal information in accordance with PIPEDA.
Collection and Use of Personal Information
We collect personal information solely for the purposes identified in this Privacy Policy and only with your consent. The personal information we collect may include:
- Identifiers: Name, postal address, phone number, email address.
- Customer Personal Information: Physical characteristics, address, telephone number, medical information, or health insurance information.
- Personal Characteristics of Protected Classes: Age, gender, marital status, medical diagnosis, physical or mental disability.
- Commercial Information: Records of products or services purchased, obtained, or considered, payment sources, and benefits information (e.g., Medicaid, Veteran’s Benefits).
- Financial Information: Banking information, account numbers, routing numbers, revenue, royalties, payments, invoices, and expenses.
- Professional or Employment-Related Information: Employment history, job titles, work history, performance records, availability of reliable transportation, recruitment information, qualifications, references, resume/CV, cover letter, employment data (e.g., dates of service, promotions, leaves), licensure and certification, professional memberships.
- Sensitive Personal Information: Social security numbers, driver's license numbers, state identification card numbers, financial account information, precise geolocation, health information, biometric information, contents of mail, email, and text messages.
- Website/Application Interaction or Similar Network Activity: Information provided in website contact forms, applications, or chat functionality.
- Biometric Information: Fingerprints, faceprints, voiceprints, iris or retina scans, keystroke patterns, gait, health data.
- Sensory Data: Audio recordings or similar information, such as phone call recordings for quality assurance.
- Health & Physical Characteristics: Medical conditions, diagnoses, care needs, and other similar information.
Consent
We obtain your consent for the collection, use, and disclosure of your personal information, except where otherwise permitted by law. Consent may be express, implied, or given through an authorized representative. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
Access and Correction
You have the right to request access to the personal information we hold about you and to request corrections if necessary. To exercise these rights, please contact us using the information provided below.
Retention and Security
We retain personal information only as long as necessary for the fulfillment of the identified purposes or as required by law. We implement reasonable security measures to protect personal information against unauthorized access, disclosure, alteration, and destruction.
Cross-Border Data Transfers
Your personal information may be transferred to, stored, and processed in the United States or other jurisdictions outside of Canada. These jurisdictions may have different data protection laws than Canada. By providing your personal information, you consent to such transfers, storage, and processing. We take appropriate steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy, regardless of where it is processed.
Contact Information
If You have any questions about this Privacy Policy, the practices of the Site, or Your dealings with the Site, please contact us via the following methods:
Home Instead, Inc.
Attn: Privacy Team
13323 California Street
Omaha, NE 68154
1.855.969.6345
We will not retaliate against any person for filing a privacy complaint. Your privacy and confidence in our abilities is of utmost importance to us.
If You have any questions regarding a Home Instead franchise business’ privacy practices or wish to opt-out of its communications, please contact the franchise office directly.
Each Home Instead franchise business is independently owned and operated.
Policy Updates
This Privacy Policy may change from time to time. This Privacy Statement is in effect as of the date above. If we change this policy, we will post the revised version here and change the “effective date” to show the date from which the new policy will apply. We may also contact You directly where we deem appropriate to do so under applicable law. If you object to any changes, you must cease using the Services immediately. We encourage You to check here regularly for the most up-to-date version.
Accountability
Responsibility for our privacy management program and this Privacy Policy rests with designated individuals and an appointed privacy officer. Under Canadian law, we remain responsible for Personal Information that We have transferred to a third party for processing and must use contractual or other means to provide a comparable level of protection while data of Canadian residents is being processed by the third party. We also have systems in place to respond to requests from individuals with respect to their Personal Information.
Each Home Instead franchise business is independently owned and operated.