1. Introduction

All Seniors Care Living Centres Inc. (“ASCL”) ("we", "us", "our") uses cookies and similar technologies on our website to improve website functionality, enhance user experience, understand how visitors use our website, and facilitate services such as our online AI-powered virtual assistant and visit booking tools.

This Chatbot and Cookies Policy explains:

• What cookies are;

• What cookies and similar technologies we use;

• How Grace uses cookies and related technologies;

• What personal information may be collected;

• How you can manage your cookie preferences; and

• Your privacy rights.

2. Cookies

During your visit to our website, which may include but is not limited to your interaction with Grace, we may collect information about how you are using our website, to help us improve the design and layout of our website to enhance your online experience. We do this through the use of “cookies” and other site-usage information technologies.

“Cookies” are small text files containing a unique identification number that is automatically stored on the visitor’s computer. The information collected helps us determine traffic patterns and site usage, including the total number of visitors, whether a visitor is a new or repeat visitor, the types of internet browsers and operating systems used by the visitor, and information provided or received by the visitor.

Cookies may be used to remember items in your shopping cart, to monitor and understand your preferences, and to improve site performance.

No additional personal information is stored in these “cookies”.

We do not link this information to any other personal information that you may voluntarily provide to us at our website. If you do not wish to accept “cookies”, you may set your browser to block or refuse them. However, some functions on the website may be impacted if “cookies” are not allowed.

We may also use similar technologies, including:

• Web beacons;

• Tracking pixels;

• Local storage technologies;

• Session identifiers;

• Analytics tags; and

• Chat session technologies.

For purposes of this Chatbot and Cookies Policy, all such technologies are referred to collectively as "cookies."

3. Our Commitment to Privacy

As an Ontario-based operator of private retirement living facilities, we recognize the importance of protecting privacy, particularly where seniors, family members, substitute decision-makers, caregivers, and prospective residents interact with our website.

We collect, use, and disclose personal information in accordance with applicable law, including PIPEDA, and seek meaningful consent where required. We limit the collection of personal information to what is reasonably necessary for identified purposes.

4. Canadian Privacy Legislation

1. Personal Information Protection and Electronic Documents Act

PIPEDA is a federal statute which applies to any organization that collects, uses, or discloses personal information in the course of commercial activities. On this, PIPEDA defines “commercial activities” as:

“…any particular transaction, act, or conduct or any regular course of conduct that is of a commercial character, including the selling, bartering, or leasing of donor, membership, or other fundraising lists”.

The PIPEDA definition of “personal information” is broad and includes any “information about an identifiable individual”, with “information” comprising a variety of identifiers: the employee’s home address and phone number, birth date, SIN, birth date, income, prior work record, ethnic/religious/racial background, and sexual orientation.

Under PIPEDA, Canadian residents have the right to access, update, and correct inaccuracies in your personal information that is in our custody and control, subject to certain exceptions as prescribed by applicable law.

You may request to access, update, and correct inaccuracies in your personal information that we have in our custody or control by emailing or writing to us at the contact information set out below. We may require that you provide sufficient identification information for the purposes of verifying the identity of any individual or organization seeking to access their personal information records. Any such identifying information will be used only for this purpose.

We expect you, from time to time, to supply us with updates to your personal information, when required. We will not routinely update your personal information, unless such a process is necessary.

At any time and for whatever reason, you may withdraw your consent for certain uses of information, subject to legal or contractual restrictions.

You also retain the right to file a complaint with the Office of the Privacy Commissioner of Canada if you believe your rights have been violated.

To exercise your rights under PIPEDA, please contact us at the coordinates set out below.

2. Canada’s Anti-Spam Legislation (CASL)

We comply with CASL in all commercial electronic communications. By providing your email address, you consent to receiving messages from ASCL related to products, services, and updates. You may unsubscribe at any time by clicking the unsubscribe link in our emails or by contacting us directly.

5. Categories of Cookies We Use

A. Strictly Necessary Cookies

These cookies are required for the operation of our website and cannot be disabled through our cookie preference centre.

Examples include:

• Website security cookies;

• Session management cookies;

• Load-balancing cookies;

• Authentication cookies (if applicable);

• Booking and form-submission functionality.

Without these cookies, certain portions of the website may not function properly.

B. Functional Cookies

These cookies enhance website functionality and help personalize your experience.

Examples include remembering:

• Language preferences;

• Accessibility settings;

• Previous website preferences;

• Chatbot interaction status.

If disabled, certain website features may function less effectively.

C. Performance / Analytics Cookies

These cookies help us understand how visitors navigate and interact with our website.

Analytics information may include:

• Pages visited;

• Time spent on pages;

• Website navigation patterns;

• Referral sources;

• Device type;

• Browser information;

• General geographic region based on IP address.

We use this information to improve website performance, user experience, and content.

Where required by applicable privacy laws, these cookies will only be activated with your consent.

D. Advertising and Marketing Cookies

If enabled on our website, these cookies may be used to:

• Measure advertising effectiveness;

• Deliver relevant advertisements;

• Prevent repetitive advertisements;

• Understand interests and engagement with our services.

These cookies may be set up by us or by third-party service providers.

Such cookies are generally optional and may be activated only after obtaining your consent where required.

6. AI Chatbot – Grace

Purpose of the Chatbot

Grace is an AI assistant available for use on the ASCL website. Grace serves as a helpful resource and concierge for visitors. It is not a general purpose chatbot and not a sales bot.

What Grace does:

• Greets each visitor and identifies why they are there;

• Answers what she can, briefly, from a pre-determined and designated knowledge base;

• Capture lead details, including: name, email address, phone number, residence of interest, and tour interest; and

• Routes career-seekers and vendor and/or service solicitations to the appropriate webpage as opposed to capturing or collecting their details.

What Grace does not do:

• She does not quote, estimate, or range any price, as pricing is handled by the individual residences;

• She does not sell tours or recommend or compare one ASCL residence as against another; and

• She directs sensitive care topics, such as care provision particulars, government funding, and care task breakdowns, to the applicable ASCL Lifestyle Director; and

Grace is intended for informational purposes only and is not intended to provide medical, legal, financial, or clinical advice.

7. Information Collected Through the Chatbot

When you interact with Grace, we may collect:

• Messages and questions submitted by users;

• Responses generated by the chatbot;

• Date and time of interactions;

• Session identifiers;

• Device and browser information;

• IP address or related network information; and

• Information voluntarily provided by users.

If a user requests information about admissions or books a visit, Grace may also collect:

• Name;

• Email address;

• Telephone number;

• Preferred tour date;

• Relationship to a prospective resident; and

• Other information voluntarily provided.

Your use of our website does not generally require you to provide us with personal information. However, certain sections of our website may be restricted and may require registration prior to access. When you submit information to our website, you agree that we may collect, use, and disclose that information for the purpose(s) specified in those sections of the website and in accordance with the terms and conditions of the Privacy Policy. If you do not agree to these terms, please do not submit information to our website.

8. Chatbot Cookies and Session Tracking

To enable chatbot functionality, we may use cookies or similar technologies that:

• Maintain conversation continuity;

• Remember user preferences during a session;

• Enable appointment scheduling;

• Prevent duplicate submissions;

• Improve chatbot performance; and

• Detect misuse or security incidents.

These cookies may remain active only for the duration of the chat session or for a limited retention period as described in our Chatbot and Cookies Policy.

9. Use of AI and Automated Processing

The chatbot uses artificial intelligence technologies to generate responses based on user inputs.

Information provided to the chatbot may be processed by automated systems for purposes including:

• Generating responses;

• Improving chatbot functionality;

• Identifying frequently asked questions;

• Maintaining service quality; and

• Detecting fraud, abuse, or security threats.

Users should avoid providing sensitive personal information, health information, financial information, social insurance numbers, or other confidential information through the chatbot unless specifically requested through an authorized and secure process.

10. Third-Party Service Providers

Our website may provide links or references to other websites that are not owned or controlled by us. These links are provided only as a convenience to users. The availability of these links does not constitute our endorsement of the linked sites. Therefore, we cannot be responsible or liable for any damages or injuries arising from information provided at these sites or your use of these sites, including your submission of personal and/or organizational information through these sites and how these sites may use or disclose your personal and/or organizational information.

This Chatbot and Cookies Policy governs the collection, use, disclosure, and management of information obtained by us through this website, and through any transactions, services, platforms, or delivery channels offered by ASCL, now or in the future.

This Chatbot and Cookies Policy does not apply to the collection, use, and disclosure of personal and/or organizational information by third parties, where ASCL does not have any control over the collection of personal and/or organizational information or over their respective privacy practices.

We are not responsible for the privacy policies or content of the aforesaid third-party platforms and strongly encourage you to review the privacy policies of every third-party platform you visit that gathers personal and/or organizational information.

Similarly, we do not endorse, and are not responsible for, third party websites or platforms which may directly or indirectly link users to our website.

11. Appointment and Visit Scheduling

If Grace allows users to schedule facility tours or visits, cookies may be used to:

• Authenticate scheduling sessions;

• Maintain booking information;

• Prevent booking errors;

• Facilitate calendar integrations;

• Improve user experience.

Booking-related information may be linked to information voluntarily provided by the user.

12. Consent

By selecting “Accept All Cookies”, enabling optional categories, or continuing with certain cookie-enabled features after being provided appropriate notice and choice, or otherwise providing and/or allowing your personal and/or organizational information to be provided to ASCL, you consent to the collection, use, and disclosure of information as described in this Policy.

Your consent to the collection, use, and disclosure of personal information may be express (that is, where you were asked specifically for your consent, whether verbally or in writing) or implied (where your consent is necessary in order for us to provide the information or service requested), depending on the circumstances.

Consent may also be provided in circumstances where notice has been given to you about how we would like to use your personal information and you have not withdrawn your consent, for example, by indicating that you would like to “opt out” of allowing us to use or disclose the personal information for the purpose we had specified.

Where an individual or organisation is not capable of consenting to the collection, use, or disclosure of their personal information but you wish to provide us with that information, please ensure that consent is obtained from the person or organisation who is legally entitled to consent on behalf of that individual if such person is not you.

Consent may be withdrawn at any time, subject to contractual or legal restrictions and provision of reasonable notice. Please be aware that if you withdraw your consent to certain uses of your personal information, it may no longer be possible for use to provide you with certain information or services.

Also, under certain circumstances, you will not be permitted to withdraw consent to certain necessary uses and disclosures of personal information that you have originally consented to. For example, we may be required by law to collect, use, or disclose (and store) personal information without your consent, to comply with other laws, an order of the court or other legal or administrative tribunal or body, or an authorized inquiry of a governmental agency.

13. How to Manage Cookies

You may manage your preferences at any time by:

• Using our cookie preference centre;

• Adjusting browser settings;

• Deleting cookies stored on your device; or

• Disabling specific categories of cookies.

Please note that disabling certain cookies may affect:

• Website functionality;

• Chatbot performance;

• Accessibility features;

• Online booking capabilities.

14. Retention of Cookie and Chatbot Information

Cookie-derived information and chatbot interaction records are retained only as long as reasonably necessary for:

• Operational purposes;

• Security monitoring;

• Service improvement;

• Legal and regulatory compliance; and

• Records management requirements.

Retention periods may vary depending on the nature of the information and applicable legal requirements.

15. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect information collected through cookies and chatbot interactions from unauthorized access, use, disclosure, alteration, or destruction.

We have taken steps to ensure that the only personnel who are granted access to your personal information are those whose duties reasonably require such information. More specifically, your personal information is stored on secure networks accessible only by a select group of individuals with specialized rights of access.

Unfortunately, no collection or transmission of information over the internet or information storage is “100%” secure or error free, and therefore, we cannot guarantee absolute security of any such information.

ASCL takes privacy complaints very seriously and has a procedure in place for escalating and managing privacy-related concerns to ensure that they are responded to in a timely and efficient manner. Any suspected privacy breach is escalated internally to trained members of the organization and/or third-party service providers who oversee the containment, investigation, and corrective actions for the breach situation.

16. Children's Use and Privacy

Our services are not intended to address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13.

If you are a parent or guardian and you are aware that your child has provided us with personal data and/or information, please contact us.

If we become aware that we have collected personal information from anyone under the age of 13 without verification or parental consent, we will take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

17. Your Privacy Rights

Subject to applicable law, you may request:

• Access to personal information;

• Correction of inaccurate information;

• Information about how your personal information has been used or disclosed;

• Withdrawal of consent, where applicable.

To submit a privacy-related request, please contact our Privacy Officer using the contact information below.

18. Contact Us

Privacy Officer
Elaine Spinner
175 Bloor Street East – South Tower

Unit 601

Toronto, Ontario M4W 3R8

Tel: 416-323-3773 ext 731

Tel: 416-929-8695

Email: spinner@allseniorscare.com

If you have concerns regarding our privacy practices, cookies, or the use of our AI chatbot, please contact us.

19. Changes and Updates

ASCL reserves the right to change this Chatbot and Cookies Policy from time to time, and at any time. If we change this Chatbot and Cookies Policy, we will post the date of the change at the top of this Chatbot and Cookies Policy.

You are advised to review this Chatbot and Cookies Policy regularly for any changes and to ensure that you are aware of our current Chatbot and Cookies Policy.

Where required by law, we will obtain additional consent before implementing material changes.