Consumer Health Data Privacy Policy 

Effective Date: May 12th, 2025

Last modified: May 12th, 2025

Oasis Senior Advisors (“OSA”, “We”) is committed to respecting your privacy. Our general Privacy Policy describes how we handle your personal data generally. This supplemental Consumer Health Data Privacy Policy (“Health Privacy Policy”) explains our practices for “Consumer Health Data” as such term is defined by applicable health privacy laws, as each are amended and as and when they become effective including any regulations thereunder (“U.S. Health Privacy Laws”).

“Consumer Health Data” is broadly defined to mean personal information that is linked or can be reasonably linked to a consumer and that identifies past, present or future physical or mental health status. Consumer Health Data does not include information pertaining to individuals with whom we have an employment relationship.

Please read this Health Privacy Policy carefully to understand our policies and practices regarding your Consumer Health Data and how we will treat it. If you do not agree with our policies and practices, you should not use our sites, products, applications, platforms, or services that are linked to this Health Privacy Policy (collectively, “Services”).

If we make any material updates to this Health Privacy Policy, we will notify you as required by U.S. Health Privacy Laws, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Health Privacy Policy earlier than required. We reserve the right to amend this Health Privacy Policy at our discretion and at any time. 

Please note that this Health Privacy Policy applies solely to OSA and its franchisees. It does not apply to any of OSA’s affiliates, such as ElderLife Financial or Aid and Attendance.com. To understand your privacy rights in relation to a specific OSA affiliate, please refer to their website and privacy policies.      

Categories of Consumer Health Data that We May Collect

We only collect, use and disclose your Consumer Health Data as needed to provide you with the Services that you request or with your consent.

We may collect Consumer Health Data related to the following categories of Consumer Health Data:

Individual Health Conditions, Treatments, Diseases, Diagnosis, or Diagnostic Testing. Information about your health history, symptoms and/or treatment, such as, for example, those health conditions relating to dementia, COPD, and diabetes.      

Social and Psychological Behaviors and Intervention.  Information about your mental health history, symptoms, and/ or treatment, such as, for example, dementia related conditions, capabilities to perform activities of daily living, and use of walker or wheelchair.     

Health Related Surgeries or Procedures.  Information about your health-related surgeries or procedures. 

Use of Prescription Medication.  Information about prescription medications that you are taking.

Bodily Function, Vital Signs and Measurements. Information about the operations of the systems of your body, such as digestion, metabolism, continence, or height and weight. 

Other Data. Other information that could identify your attempt to seek health care services or information, or any inferences of the above categories of health data derived or extrapolated from non-health information.

For any Consumer Health Data that constitutes “Sensitive Data” as defined under applicable U.S. Health Privacy Laws, we will first obtain your affirmative consent before collecting, using, or sharing that health data in compliance with those privacy laws.  

For all other Consumer Health Data, we will not collect, use, or share additional categories of Consumer Health Data disclosed in this Health Privacy Policy without first disclosing the additional categories and obtaining your affirmative consent prior to the collection, use, or sharing of that health data.

Please note that Consumer Health Data protected by this statute does not include data that cannot reasonably be used to infer information about, or otherwise be linked to, you (“deidentified data”). We take reasonable measures to protect deidentified data, and we only process such data in a deidentified fashion without attempting to reidentify such data. We will contractually obligate any recipients of deidentified data to also take reasonable measures and process such data in the same fashion we do.

Purposes for Collecting Consumer Health Data and How We Use It

We may use these categories of Consumer Health Data for the following purposes:

• Services, including providing you with services you request from us.

• Customer Service/ Communications, such as:

  • Providing you with the information or support that you request from us, including sending you information about our Services and resources that may be tailored to your specific health condition(s);

  • Providing you notices about your account; 

  • Responding to your questions or requests for information; 

  • Sending transactional messages (such as account statements or confirmations); and

  • Sending you marketing communications about our services, surveys, and invitations.

• Research & Development, such as our internal research, designing and developing new services, and improving our Services, customer relationships, and consumer experiences.      

• Quality and Safety, including performance analytics, identity verification and authorization, site and application optimization, and quality control.

• Security, including undertaking activities to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Consumer Health Data or that otherwise threaten to compromise the performance, security, or integrity of our business.

• Recordkeeping and auditing, including recordkeeping and auditing interactions with consumers, including logs and records maintained as part of transaction information.

• Legal/ Compliance: Complying with our legal obligations and risk management, audit, investigations and reporting, and other legal and compliance reasons.

• Administering customer accounts and preferences.     

• For any other purpose as may be permitted by law or that we describe when you provide the information. 

Sources of Consumer Health Data 

We may collect your Consumer Health Data from the following sources:

• You, such as when you request certain health-related Services, or when you give us information about your Consumer Health Data by interacting with our website, or by communicating with us via email or contact us page.  This includes Consumer Health Data you voluntarily provide by emailing us about our website or Services, leaving feedback on our Contact Us form, or responding to our surveys. 

• Your device when you visit or interact with our sites, applications, or services, including through cookies, web beacons, and similar technologies that automatically send us information when you browse, use, visit, or otherwise interact with our sites, applications, or services.

• Authorized/legal representatives, family members, and caregivers.

• Health care providers.  

• Other third-party sources and referral partners, such as elder law attorneys or financial advisors, who provide us with information about consumers that may be interested in our Services.     

• We may also infer or derive Consumer Health Data by analyzing other non-health related data we have about you or other consumers.

Disclosure of Consumer Health Data 

We do not sell your Consumer Health Data. 

We may disclose categories of your Consumer Health Data described above in the following circumstances:

• We may disclose your Consumer Health Data to assisted living facilities such as senior living communities, skilled nursing facilities, and home care companies depending on your consent and whose services best address your needs.       

• We may disclose your Consumer Health Data with our data processors, service providers, and contractors who assist us in providing Services to you and to our affiliates, such as, for example, ElderLife Financial and AidandAttendance.com. These processors may only use the data as permitted by our contracts with them.  

• We may also disclose your Consumer Health Data as permitted by law, such as (i) with your consent, (ii) if needed to protect your vital interests, such as in the event of a medical emergency or natural disaster, (iii) to an acquiring organization if we are involved in a sale or a transfer of our business, (iv) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (v) as needed to preserve the integrity or security of our systems, or (iv) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.

Your Privacy Rights

You have specific rights with respect to your Consumer Health Data. 

You have the right to know if we are collecting, using or disclosing your Consumer Health Data, to access that consumer health data, including receiving a list of the entities and affiliates with whom we have shared or sold your information, though currently we do not sell  your Consumer Health Data with third parties or Affiliates.

You have the right to request that we delete your Consumer Health Data 

If you think some of the personal information we have about you is incorrect, you have the right to request that we correct the personal information in compliance with applicable U.S. Health Privacy Laws. 

If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent. For cookie-related Consumer Health Data, you can do this by visiting your “Cookie Preferences” in the bottom right corner of our health-related websites or in the Settings menu of our mobile applications. Withdrawing your consent for collection of non-cookie related Consumer Health Data will effectuate a deletion request.

We will not discriminate against you for exercising any of your rights. However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the Services.

To exercise these rights, you may submit a request by emailing us at  privacy@silverassist.com or via our Privacy Request form. We will respond to your request as required by applicable law. When you submit a request regarding your Consumer Health Data, we reserve the right to verify your identity in connection with any requests regarding Consumer Health Data to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals to exercise rights with respect to that information. 

To help us respond to your request, all communications to us should include the sender’s name and contact information (such as email address, phone number or mailing address), and a detailed explanation of the request. We will endeavor to respond to all reasonable requests in a timely manner, and in any case, within any time limits prescribed by applicable local law.

Any questions, concerns, complaints, or appeals regarding handling of Consumer Health Data, or related to revocation of consent to collect, process, transfer, or disclose your Consumer Health Data should be directed by email to privacy@silverassist.com.  If your appeal is unsuccessful, you can file a complaint with the relevant government body in your state, including:

• Connecticut State Attorney General at https://portal.ct.gov/ag/sections/privacy/ the-privacy-and-data-security-departmen

• Maryland State Attorney general at https://www.marylandattorneygeneral. gov/Pages/CPD/Complaint.aspx

• New York State Attorney General at https://formsnym.ag.ny.gov/OAGOnlineSubmissionForm/faces/OAGBITHome;jsessionid=nTa5_PBH7sqdmLWS5TgpF0e2xglVNgd8vqiflAYw1No0KqmyVUBp!548137084

• Washington State Attorney General at https://www.atg.wa.gov/file-complaint.

Please contact us directly with any questions or concerns you may have about your Consumer Health Data privacy or this Health Privacy Policy.  You can also contact us via our Contact Us page.  You may also contact us by telephone at 1-888-455-5838, email at privacy@silverassist.com, or by mail at the following address:  

Oasis Senior Advisors 

100 Bluegrass Commons Blvd

Building 1, Suite 120 

Nashville TN 37075