SENIORLY PRIVACY POLICY & NOTICE AT COLLECTION

Last Reviewed/Updated: March 31, 2026

This Privacy Policy and Notice at Collection ("Privacy Policy") describes the types of Personal Information that Seniorly, Inc. ("Seniorly," "we," "our," or "us") collects from and about you, how we may use and disclose such information, and your choices and legal rights with respect to such information. We ask that you carefully review this Privacy Policy, as it applies to the websites (each a "Site") and mobile applications (each an "App") as well as the services owned, operated, and/or provided by Seniorly that display or link to this Privacy Policy, including services provided via phone or offline (collectively, "Seniorly Services").

By using Seniorly Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not use Seniorly Services.

For purposes of this Privacy Policy, "Personal Information" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household, and includes "personal data" or similar terms as defined in applicable law.

For information on our collection and use of "Consumer Health Data" as defined by the Washington My Health My Data Act, please visit our Washington Privacy Policy.

NOTICE AT COLLECTION OF PERSONAL INFORMATION

We collect the categories of Personal Information identified in the following chart. We generally disclose these categories of Personal Information for business purposes to our service providers, including payment processors and account management providers to facilitate Seniorly Services and access to the Website. Some of these categories we "sell" or "share" for "targeted advertising" (as such terms are defined in U.S. law) with business partners and third parties, such as data analytics providers, advertising technology vendors, third-party advertising networks, and social media platforms.

We do not knowingly sell or share Personal Information about persons under the age of 18.

Please click here to opt out of the sale or sharing of your Personal Information, including for targeted advertising. You may also choose to enable online, where available, 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.

a. Categories of Personal Information We Collect

b. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information

• To provide you with Seniorly Services.
• To process payments.
• To create, maintain, customize, and secure your account with us.
• To communicate with you, such as through bots, including to respond to your inquiries/requests and request feedback from you, and to send you important updates and messages about changes to Seniorly Services, this Privacy Policy, and/or other applicable terms and conditions.
• To review the usage and maintain the operation of Seniorly Services.
• To conduct analysis and develop and/or improve our products and Seniorly Services.
• To monitor, protect, and maintain the security and integrity of Seniorly Services and our business, such as protecting against and preventing fraud, unauthorized transactions, claims and other liabilities.
• To comply with applicable laws and regulations and respond to lawful requests and communications from law enforcement and other government officials.
• To carry out sales and business transactions in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction.
• To protect our rights, privacy, safety, property and/or those of others.
• To fulfill any other purpose for which you provide your Personal Information or as explained to you at the point of information collection.
• To provide you with customized content or targeted offers.
• To engage in data driven targeted advertising.
• To send you information, newsletters, and marketing/promotional material from us and, or on behalf of, our marketing partners and affiliates.

c. Retention

We will retain your Personal Information for as long as reasonably necessary to provide you with the Seniorly Services that you request, for marketing purposes unless you opt out as described in our Privacy Policy, or otherwise where permitted or required in accordance with applicable law. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

PERSONAL INFORMATION WE COLLECT

There are several ways we may obtain Personal Information about you, including through (A) information you provide to us or others provide on your behalf; (B) information we automatically collect; (C) information we receive from third parties; and (D) combining information from different sources. This includes data that identifies you personally whether directly or indirectly.

a. Information You Provide

We collect Personal Information as listed in the above Notice at Collection from you as follows:

• When You Use Seniorly Services. We collect Personal Information from you when you inquire about or create an account to use Seniorly Services, or when a third party inquires about or uses Seniorly Services on your behalf.
• When You Make a Purchase. If you purchase services from us, we or our third-party payment processors collect a payment card number or other payment information.
• When You Provide Information About a Third Party. If you send someone else a communication from Seniorly Services, such as sending an article or community profile to a friend, the Personal Information you provide (e.g., name, contact information) may be used to facilitate communication with such person.

b. Information We Automatically Collect

We and our third-party partners and service providers use a variety of technologies to automatically collect certain information from you when engaging with our Site and Seniorly Services. We may collect your Personal Information using different data collection technologies, such as cookies, pixels, and tags on our Site, and in email messages and certain online advertisements. For information on the choices you may have with respect to these data collection technologies, see the "Your Privacy Choices" section below.

The specific types of Personal Information that we, our partners, and service providers may automatically collect when you visit our Site and interact with Seniorly Services include:

• Device and Browser Information. This includes your device's IP address and/or other unique identifiers, browser type, device type, internet service provider, operating system, and when you access Seniorly Services from a mobile device, your device's approximate location (derived from your device's IP address or other signals).
• Usage Information. When you interact with Seniorly Services, certain information may be collected by us or our third party vendors, including the date and time of your visit, the pages you view immediately before and after you access Seniorly Services, the areas or pages of Seniorly Services that you visit, the amount of time you spend viewing or using Seniorly Services, items placed or left in your shopping cart on the Site or App, keystrokes, mouse movements, form field entries, recordings of chat sessions or your use of and inputs to other AI-supported tools, and other use and overall engagement with Seniorly Services. We may also collect user experience recordings that reproduce your interactions with Seniorly Services, including mouse movements, page scrolling, and information you type (including Personal Information), screen taps, and other actions you take while using Seniorly Services. Recordings may include technical and usage data, as well as visual representations of actions you take while using Seniorly Services. We use these recordings to help us understand how users interact with Seniorly Services and to design a better user experience for you.
• Marketing Information. If you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to our Site).
• Third-party analytics technologies. We may use third-party analytics tools to better understand who is using Seniorly Services, how people are using them, and how to improve their effectiveness as well as the effectiveness of any related content.

Cookies and Other Similar Technologies: "Cookies" are text files that are placed on your browser by the websites that you visit. Cookies are used for various purposes, including to distinguish you from other users, make your site navigation more efficient, help remember your preferences, enhance your browsing experience, and improve the use and functionality of our Sites and related content. They can also enable the delivery of relevant and personalized advertisements to you across the Internet.

Please note that cookies and other similar technologies provided by third parties may be placed on our Sites. The providers of these technologies may create one or more identifiers associated with you or your device(s) both on and off our sites and in our apps, and combine this information with other sources and use the combined information for analytics and/or advertising purposes.

Our use of Google Analytics and Advertising technologies: Our website uses technology provided by Google to facilitate advertising and reporting. We implement Google Analytics cookies to collect Personal Information about you when you visit our Site for purposes of remarketing, impression reporting, and demographic and interest reporting. This information includes browsing and Site usage data and can be combined with other data related to you collected through Google's advertising cookie or other third-party technology. You can opt out of the use of this technology through the Google Analytics opt-out browser add-on, Google Ad Settings, and/or Ad Settings for mobile apps.

c. Information We Receive from Third Parties

We may receive Personal Information from other sources. Our third-party sources may include:

• Our Business Partners. Including companies that co-sponsor our promotions.
• Our Marketing/Advertising and Analytics Partners. Including online advertising networks and analytics providers that assist us in engaging in targeted advertising.
• Other Companies. Including data aggregators and other similar companies that help supplement the information we maintain about you. Certain third parties might link your name or email address to other information they have collected, such as your past online/offline purchases and your online usage information.

d. Combination of Information

We may combine Personal Information that we receive from various sources. For example, we may combine Personal Information that we collect from you offline with Personal Information we collect from you through Seniorly Services. Similarly, we may combine Personal Information that we receive from third parties with Personal Information we already have about you. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose each category of your Personal Information that we collect in a number of ways. We disclose your Personal Information for business purposes to the following categories of recipients:

• Service Providers. We disclose your Personal Information to our service providers that provide business, professional, or technical support services to us, help us operate our business and Seniorly Services, or administer activities on our behalf. We require our service providers to only use your Personal Information in connection with providing services to Seniorly.
• Research Companies. We may share your Personal Information with companies that administer surveys or conduct research projects in partnership with us or on our behalf.
• Providers and Communities. We may share your Personal Information with home care providers or senior living communities as part of providing Seniorly Services.
• Partners. For the purpose of providing Seniorly Services, we may disclose your Personal Information to a long-term care insurer, employer, affinity group, or other entity that has contracted with Seniorly to provide its policyholders, employees, affinity group members, or customers with access to Seniorly Services.
• Corporate Affiliates. We may disclose your Personal Information with our affiliated companies or brands for purposes consistent with this Policy and other business and operational purposes as permitted by applicable law.

We may also disclose your Personal Information to the following categories of third parties:

• Advertising Partners. We may disclose your Personal Information to third parties for targeted advertising, including social media platforms, third-party advertising networks, and other parties that assist us in serving and optimizing our advertisements.
• Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
• Competent Governmental, Regulatory, and Public Authorities. We may disclose your Personal Information to government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
• Other Third Parties. We may disclose your Personal Information to other parties at your direction or with your consent, where required by law, or as we believe necessary or appropriate either to: (i) comply with applicable law; (ii) protect our operations and those of any of our affiliates; (iii) investigate and prevent against fraud; (iv) protect our rights, privacy, safety, or property and/or those of others; or (v) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.

Please note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Privacy Policy. We will protect de-identified information in accordance with applicable law and will never attempt to "re-identify" the information.

Consumers Acting in a Professional Capacity

In addition to the information above, if you are a California resident acting in a professional capacity in your relationship with Seniorly, you also have rights under the California Consumer Privacy Act.

a. Seniorly Advisors, Premier Advisors, and other Independent Contractors

The categories of Personal Information we may collect about Advisors, Premier Advisors, or other independent contractors include the following:

1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, date of birth, driver's license number, passport number, or other similar identifiers that are capable of being associated with a particular individual.
2. Professional or employment-related information, such as your employment history.
3. Education information, such as your school records or degrees earned.
4. In certain circumstances, other personal information you may voluntarily provide such as your signature, insurance policy number(s), physical characteristics or description, telephone number, financial account information and your financial, medical or health insurance information.
5. Following contracting, we may collect characteristics of protected classifications under California or federal law provided voluntarily by employees, such as race or sex.
6. Internet or other electronic network activities, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.
7. Audio and/or visual data, such as call or meeting recordings.

The categories of sensitive Personal Information we may collect about Advisors, Premier Advisors, or other independent contractors might include the following:

1. Social security, driver's license, state identification card, or passport number.
2. Citizenship or immigration status.
3. Bank or financial account and routing numbers provided voluntarily by employees.
4. Following contracting, demographic information including racial or ethnic information.
5. The contents of your mail, email, and text messages accessed from, in connection with, our systems.
6. Certain voluntarily provided health information.

The purposes for which we collect the above categories of Personal Information and sensitive Personal Information include:

1. Reviewing and assessing your contract including background checks and consumer reports containing information on your character, general reputation, personal characteristics.
2. Reviewing and managing your role, conduct and performance.
3. Managing and administering your pay.
4. Supporting Seniorly's efforts in maintaining a safe and supportive work environment.
5. Researching, reviewing, analyzing and/or developing business or product plans or operations.
6. Preventing, detecting, and addressing security incidents and illegal activity.
7. Meeting any legal, regulatory, or court-ordered requirements associated with your contract.

We generally retain Personal Information and sensitive Personal Information that we collect about Advisors, Premier Advisors, or other independent contractors for as long as needed for regulatory or business purposes.

b. Other Consumers Acting in a Professional Capacity

Consumers acting in a professional capacity include, but are not limited to, individuals who are employed by our service providers, individuals who are employed with companies with whom we are contemplating a business relationship or have established a business relationship, individuals employed by companies or organizations where Seniorly provides services to those companies or organizations, and independent contractors. The categories of information we may collect about these types of consumers might include the following:

1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, professional number, social security number, driver's license number, passport number, or other similar identifiers that are capable of being associated with a particular individual.
2. Personal Information in addition to the identifiers listed above, such as your signature, insurance policy number(s), physical characteristics or description, telephone number, and business financial account information and your financial, medical or health insurance information.
3. Characteristics of protected classifications under California or federal law, such as your race or sex.
4. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.
6. Geolocation data, such as device location.
7. Audio, electronic, visual, thermal, olfactory, or similar information, such as call or meeting recordings.
8. Professional or employment-related information, such as your employment history.
9. Education information, such as your school records or degrees earned.

The categories of sensitive Personal Information, a sub-category of Personal Information, we may collect about consumers acting in a professional capacity may include the following:

1. A consumer's social security, driver's license, state identification card, or passport number.
2. A consumer's ethnic origin for diversity reporting purposes.

The purposes we may collect the above categories of Personal Information and sensitive Personal Information may include one or more of the following:

1. Marketing our products and services to you, including responding to your requests for product or service information.
2. Understanding what products or services you or your company can offer to us.
3. Researching and analyzing our marketing efforts.
4. Responding to legal requests and complying with regulatory requirements.
5. Auditing our interactions and concurrent transactions with you.
6. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.
7. Debugging to identify and repair errors that impair existing intended functionality of our websites and other interactions with you.
8. Short-term, transient use, when your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction.
9. Maintaining or servicing accounts, contracts, or other relationships with you or your company, so that either party may provide: customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services.
10. Undertaking internal research for technological development and demonstration.
11. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

We may retain Personal Information and sensitive Personal Information that we collect about consumers acting in a professional capacity for as long as needed for business or regulatory purposes.

YOUR PRIVACY CHOICES AND RIGHTS

Seniorly provides you a number of choices with respect to how we collect and process your Personal Information.

a. State Privacy Rights

Residents of California, Connecticut, Maryland, New Hampshire, New Jersey, Texas, Virginia, or any other state with an applicable privacy law have certain rights relating to the collection, use, disclosure, and other processing of their Personal Information. The exact scope of these rights may vary by state and may vary depending on certain exceptions:

• Right to Know. You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, the categories of Personal Information disclosed to third parties, and the specific pieces of Personal Information we have collected about you. You may also have the right to access this Personal Information in a portable format.
• Right to Request Categories of Third Parties. You may have the right to request a list of the categories of third parties with which we disclose your Personal Information.
• Right to Request Specific List of Third Parties. You may have the right to request a list of the specific third parties to which we disclose your Personal Information.
• Right to Delete. You may have the right to request that we delete Personal Information that we have collected from or about you, subject to certain exceptions.
• Right to Correct. You may have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification. Where appropriate, we may comply with a right to correct by deleting your Personal Information.
• Right to Opt Out of Sale and Targeted Advertising. We use and disclose to third parties Personal Information for analytics and advertising purposes which may be considered a "sale" under applicable state laws. Accordingly, you may have the right to opt out of the sale or "sharing" of your Personal Information, or the use and disclosure of your Personal Information for "targeted advertising" (as these terms are defined in applicable law).

To exercise your right to opt out of sale and targeted advertising, please click here or click the “Do Not Sell or Share My Personal Information” link in the footer of the Site. Not Sell or Share My Personal Information” link in the footer of the Site.

In some jurisdictions, you may choose to enable a tool that automatically communicates your opt-out preferences to all businesses that you interact with online. If you enable a browser-based opt-out preference signal, such as the GPC, upon receipt or detection, we will treat the signal as a valid request to opt out of sale, sharing, or targeted advertising linked to that browser and, where we can do so, consumer profiles that we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each one that you use. We will never ask you to verify your identity to exercise your right to opt out of the sale of your Personal Information.

To exercise all other privacy rights, please contact us by phone at 800.571.1918 or email us at privacy@carescout.com. If you make a request through email, please include the following information and the statement "Your Privacy Rights" in the subject field of your email:

1. Your first and last name;
2. Whether you are a current or former customer, employee, Advisor, Premier Advisor, or business contact;
3. Your request type;
4. Your telephone number;
5. Your email address; and
6. Any other information you wish to provide.

If you make a request by phone, please provide your name, phone number, email address, whether you are a current or former customer, employee, Advisor, Premier Advisor, or business contact, your request type, and any other information you wish to provide. We will use the information provided to us to verify your identity.

To protect the confidentiality of yours and others' Personal Information, we will only complete your request when your identity has been verified (other than for requests to opt out). We will seek to match the information in your request to the Personal Information we maintain about you. As part of our verification process, we may ask you to: submit additional information, use identity verification services to assist, or, if you have set up an account on our website, to sign into your account as part of our identity verification process. Where permitted under applicable law, we may decline a request if we are unable to verify your identity (or an agent's authority to make the request) and confirm the Personal Information we maintain relates to you.

Authorized agents. In certain states, consumers may designate an authorized agent to exercise their privacy rights. You may designate an authorized agent to submit requests on your behalf using the methods described in this section. However, we may require written proof of the agent's permission to do so and verify your identity directly with you.

Right to appeal. Depending on your U.S. state residency, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a refusal to take action on your request, please contact privacy@carescout.com or 800.571.1918. If you are unsatisfied with the way that we have handled your appeal, you may have the right to complain to your state's attorney general.

Right to non-discrimination. You will not receive retaliatory or discriminatory treatment in connection with a request to exercise your privacy rights described in this section. However, the exercising of the rights described above may result in a different price, rate, or quality/level of product or service where that difference is reasonably related to the impact the right has on our relationship with you or is otherwise permitted by law.

You are not required to create an account to exercise your state privacy rights.

b. Interest-Based Advertising

Self-regulatory industry organizations such as the Digital Advertising Alliance (DAA) offer browser-based opt-out tools for the companies that participate in them. Please visit the DAA's AdChoices site for more information: https://youradchoices.com/control.

c. Marketing and Promotional Communications

From time to time, we may send you marketing and promotional communications, including special offers from us or our partners. If you no longer wish to receive promotional and marketing emails from us, you may opt out of such communications at any time by following the opt-out instructions included in any promotional or marketing email you receive from us.

TEXT MESSAGES

Messages may be sent by automatic telephone dialing system. You acknowledge that these messages are not otherwise secured when they are sent, and that there is a risk the message could be intercepted in its transmission to you. You acknowledge that these messages may be subject to fees from your cellular provider, message and data rates apply, and that we and your wireless carrier will not be held liable for any delayed or undelivered messages. To disable or update alert(s) or to update your mobile phone number, you can update your Notification Preferences in your account if applicable, or text HELP for assistance or STOP to cancel.

You are not required to opt in to receive marketing text message alerts (directly or indirectly) as a condition of transacting with us. Frequency of messages will vary.

EXTERNAL LINKS

Our Sites may have links to third-party services or websites, which may have privacy policies that differ from our own. We are not responsible for the information collection practices of such other services or websites, nor does the inclusion of a link on the Sites imply endorsement of the linked site or service by us or by our affiliates. We cannot guarantee how those services or websites use cookies, pixels or other data aggregating or analytics tools, or whether they use cookies or other tools that may be able to identify you personally. You should carefully review the privacy policies of each website you visit to understand how they collect, share, sell, use, and disclose Personal Information.

CHILDREN'S PRIVACY

Seniorly Services are intended for a general audience. We do not direct Seniorly Services to individuals under eighteen (18), nor do we knowingly solicit or collect any Personal Information from minors.

DATA SECURITY

We have implemented physical, administrative, and technical safeguards to maintain the security, confidentiality, and integrity of your information. However, as no transmission of information over the internet is absolutely secure, we cannot guarantee the safety of your information.

REVISIONS TO THIS PRIVACY POLICY

We reserve the right to update or modify this Policy at any time without prior notice by posting a revised version of the policy on the Site. Your use of the Site or any Seniorly Services following revision to this Policy constitutes your agreement that all information collected from or about you after the revised policy is posted will be subject to the terms and conditions of the revised policy. The date listed above indicates the most recent change or update to this Policy.

HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at privacy@carescout.com, by mail to 11011 West Broad Street, Glen Allen, VA 23060, or by phone at 800.571.1918.