Privacy Policy

Effective Date. September 11, 2026

Introduction

Spring Oak Management, LLC d/b/a Spring Oak Senior Living, together with its parent company, subsidiaries, affiliated entities, and communities operating under the Spring Oak name or any other associated brand name (collectively, "Spring Oak," the "Company," "we," "us," or "our"), respects the privacy of the individuals who interact with us. This Privacy Policy describes the personal information we collect, how we use and disclose it, the choices and rights that may be available to you, and how to contact us regarding our privacy practices.

Scope of This Policy

This Privacy Policy applies to our websites and online services and to information we collect in connection with prospective and current residents and their families, job applicants and candidates, volunteers, business contacts, and other visitors and users. Certain information may be governed by additional notices or agreements. This Privacy Policy does not replace or modify any Notice of Privacy Practices provided in connection with health information governed by the Health Insurance Portability and Accountability Act ("HIPAA"). Where HIPAA applies, the applicable Notice of Privacy Practices governs that protected health information.

Information We Collect

Depending on how you interact with us, we may collect personal information such as your name, telephone number, postal address, email address, ZIP code, and other contact information; information concerning the services or communities in which you are interested; information you provide in inquiries, forms, applications, surveys, or other communications; and records of communications with us.

Care and Residency Information

If you inquire about residency or services, we may collect information concerning the individual for whom services are being sought, the individual's relationship to you, desired services, care needs, level of assistance, medical history, diagnoses, and other information provided through a care questionnaire, residency inquiry, assessment, or related process. We may also collect emergency contact information, residency information, financial information, billing information, and other information necessary to evaluate or administer a residency relationship.

Employment and Applicant Information

If you apply for employment or communicate with us regarding employment opportunities, we may collect information contained in your resume, application, cover letter, transcripts, references, and other employment materials; employment history; education and qualifications; licenses or certifications; work authorization; availability; compensation information; responses to screening questions; interview information; background-check information where permitted by law; and other information relevant to your candidacy. We may also review professional or employment information you have made publicly available, such as information on LinkedIn or similar professional platforms. Where offered, demographic information may be voluntary and may be used as permitted by applicable law.

Payment and Financial Information

When necessary for billing, payment, residency, or other business purposes, we or our payment service providers may collect payment, banking, insurance, financial, or transaction-related information. Payment card information may be processed directly by third-party payment processors.

Communications Information

We may maintain records of telephone calls, emails, text messages, correspondence, inquiries, consent records, opt-in and opt-out records, and other communications between you and the Company.

Information Collected Automatically

When you visit our websites, we and our service providers may automatically collect information about your device and use of the website. This may include your IP address, browser type, device identifiers, operating system, language preferences, referring and exit pages, pages viewed, links clicked, approximate location derived from an IP address, and the dates and times of website activity.

Cookies and Similar Technologies

We may use cookies, pixels, web beacons, server logs, and similar technologies to operate our websites, remember preferences, understand website usage, improve our services, measure advertising effectiveness, and, where applicable, support advertising activities. You may be able to restrict certain cookies through your browser settings or through privacy or cookie controls made available on our websites. Disabling certain technologies may affect the operation of some website features.

Sources of Information

We collect information directly from you when you submit forms, applications, inquiries, or other information; automatically when you use our websites; from family members or other individuals communicating with us on your behalf; from service providers and business partners; from recruiting and professional platforms; and from other sources permitted by law.

How We Use Personal Information

We may use personal information to respond to inquiries; provide information regarding our communities and services; assist individuals in locating an appropriate Spring Oak community; schedule tours, appointments, interviews, or other activities; evaluate and process residency inquiries and applications; administer resident, account, or billing matters; evaluate employment applications and communicate with candidates; consider candidates for current or future opportunities; process volunteer or partnership inquiries; provide customer support; and otherwise provide services requested from us.

Business Operations

We may also use personal information to operate, administer, evaluate, and improve our business and websites; conduct accounting, auditing, analytics, reporting, quality assurance, and other internal functions; maintain records; manage our workforce and recruiting processes; protect our systems and information; prevent fraud, misuse, or unauthorized transactions; enforce our agreements and policies; and comply with legal, regulatory, licensing, and other obligations.

Marketing and Personalization

Where permitted by applicable law, we may use information to provide information about Spring Oak communities, services, events, or opportunities that may be relevant to you; personalize website content; conduct marketing or promotional activities; and measure the effectiveness of advertising or outreach.

Text Messaging

If you provide a mobile number and opt in to text messaging, or where text messaging is otherwise permitted by applicable law, you may receive messages from us or on our behalf regarding matters such as inquiries, applications, interviews, scheduling, tours, appointments, residency, billing, account matters, surveys, or other communications related to your interaction with Spring Oak. Where required by law, we will obtain the applicable consent before sending automated or marketing text messages.

Consent to receive marketing or automated text messages is not a condition of employment, residency, purchasing goods or services, or otherwise doing business with us. Message frequency may vary. Message and data rates may apply. You may opt out of text messages at any time by replying "STOP" to a message and may reply "HELP" for assistance.

Email

We may use third-party service providers to send informational, transactional, employment-related, residency-related, and, where applicable, promotional emails on our behalf. You may unsubscribe from marketing or promotional emails by using the unsubscribe link included in those messages. Unsubscribing from marketing emails will not prevent us from sending transactional, account-related, employment-related, residency-related, or legally required communications.

Phone Calls

We may contact you by telephone at a number you provide in connection with your inquiry, application, employment, residency, account, or other interaction with us. Where applicable law requires consent to use automated dialing, artificial or prerecorded voice technology, or similar technology, we will obtain the required consent.

Analytics

We may use third-party analytics services, including Google Analytics, to help us understand how visitors use our websites and to improve website functionality and performance. These services may use cookies, pixels, web beacons, and similar technologies to collect information about website activity, including information such as IP addresses, device information, browser information, pages visited, and interactions with our websites. Information collected through these technologies may be transmitted to or processed by the applicable analytics provider in accordance with its privacy practices and our agreements with that provider.

For more information about Google's privacy practices, please review the Google Privacy Policy. You may also learn about Google's browser-based analytics opt-out option through the Google Analytics Opt-out Browser Add-on.

Advertising and Online Tracking

We and certain third parties may use cookies, pixels, and similar technologies to understand activity on our websites, measure advertising effectiveness, and, where applicable, provide advertisements based on interests or activity over time. Some disclosures of personal information to advertising or analytics providers may be considered "targeted advertising," "sharing," or a "sale" under certain state privacy laws even when no money is exchanged for the information.

Sale of Personal Information

We do not sell personal information in exchange for monetary payment. To the extent our use of advertising or analytics technologies is considered a "sale," "sharing," or targeted advertising under applicable state law, individuals may have the right to opt out as described below.

Browser and Universal Opt-Out Signals

Some browsers provide "Do Not Track" settings, and there is not a single uniform standard governing all such signals. Where applicable law requires us to recognize a qualifying universal opt-out mechanism or browser-based privacy signal, we will process qualifying signals in accordance with applicable law.

Information We Disclose

We may disclose personal information among Spring Oak affiliated entities where reasonably necessary for the purposes described in this Privacy Policy. We may also disclose information to vendors and service providers that perform functions on our behalf, including applicant tracking, recruiting, background checks, payroll, payment processing, billing, communications, website hosting, information technology, data storage, analytics, advertising, professional services, and other business functions.

Service Providers

Service providers that process information on our behalf are expected to use the information for the services they perform for us and as otherwise permitted or required by applicable law and their agreements with us.

Legal and Safety Disclosures

We may disclose personal information if we reasonably believe disclosure is necessary to comply with applicable law, regulation, legal process, subpoena, court order, governmental request, licensing requirement, or other legal obligation; to investigate or prevent fraud or illegal activity; to protect the rights, safety, property, or security of Spring Oak or others; or to establish, exercise, or defend legal claims.

Business Transactions

Personal information may be disclosed or transferred as part of an actual or proposed merger, acquisition, financing, reorganization, sale of assets, change in ownership, bankruptcy, or other corporate transaction, subject to applicable law.

Sensitive Information

Certain information we collect, including information concerning health conditions, treatment or diagnoses and certain financial information, may be considered sensitive personal information under applicable law. Where applicable law requires consent or other protections before sensitive personal information may be processed, we will process such information in accordance with those requirements. Certain health information may instead be governed by HIPAA and the applicable Notice of Privacy Practices.

Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, acquisition, use, alteration, or disclosure. The safeguards we use are designed to be appropriate to the nature and sensitivity of the information involved. No system or method of transmission or storage can be guaranteed to be completely secure, and we cannot guarantee the absolute security of personal information.

Data Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and for legitimate business purposes, including complying with legal, regulatory, licensing, recordkeeping, and contractual obligations; administering employment and residency relationships; resolving disputes; protecting against fraud or misuse; and enforcing agreements. Retention periods may vary depending on the nature of the information and the purpose for which it was collected.

Your Privacy Rights

Depending on where you reside, the nature of your relationship with us, and applicable law, you may have rights regarding certain personal information we maintain about you. These may include the right to confirm whether we process your personal information; access certain information; correct inaccuracies; request deletion; obtain a copy of certain information in a portable format; and opt out of certain processing, including targeted advertising, the sale of personal information, or certain types of profiling. These rights are subject to applicable exceptions and may not apply to all individuals or all information we maintain.

Employment and Other Exceptions

Some state consumer privacy laws do not apply to information collected or processed in an employment, applicant, business-to-business, healthcare, or other exempt context. Nothing in this Privacy Policy is intended to provide a legal right that does not otherwise apply under applicable law.

Exercising Your Privacy Rights

To submit an applicable privacy request, contact us at concerns@springoakliving.com or using the contact information below. We may need to verify your identity before completing a request. We will respond within the time required by applicable law. Authorized agents may submit requests where permitted by law and subject to reasonable verification requirements.

Appeals

If we deny a privacy request and applicable law provides a right to appeal, you may appeal our decision by emailing concerns@springoakliving.com and stating that you are appealing a privacy rights decision. We will review and respond to the appeal in accordance with applicable law.

Opting Out of Targeted Advertising or Certain Data Disclosures

Where applicable law provides a right to opt out of targeted advertising or processing considered a sale or sharing of personal information, you may submit a request to concerns@springoakliving.com or use any privacy preference mechanism we make available on our website. Where required by applicable law, we will also recognize qualifying universal opt-out mechanisms.

No Discrimination

We will not unlawfully discriminate against you for exercising a privacy right provided to you under applicable law.

Children's Privacy

Our websites and online services are intended for individuals 18 years of age or older and are not directed to children. We do not knowingly collect personal information online from children under 13 in circumstances in which parental consent is required. If we learn that we have collected personal information online from a child under 13 in violation of applicable law, we will take appropriate steps to delete the information or otherwise comply with applicable legal requirements.

Third-Party Websites and Services

Our websites may contain links to websites, applications, or services operated by third parties. Those third parties maintain their own privacy practices and policies. We encourage you to review their privacy notices before providing information to them. We are not responsible for the privacy practices of independently operated third-party websites or services.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, services, or legal requirements. The updated Privacy Policy will be posted with a revised effective date. Where required by applicable law, we will provide additional notice regarding material changes.

Contact Us

If you have questions about this Privacy Policy, our privacy practices, or a privacy rights request, please contact Spring Oak Management, LLC, 1514 Route 138, Wall, New Jersey 07719; concerns@springoakliving.com; or 732-719-8688.