GlenOak Senior Advisors Privacy Policy

Publication date: August 26, 2026
Current version effective: September 10, 2026

This Privacy Policy explains how GLENOAK SENIOR ADVISORS INC., doing business as GlenOak Senior Advisors (“GlenOak,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information in connection with our website, online forms, reports, senior-living information and placement-support services, referral coordination, business communications, and newsletter (collectively, the “Services”).

GlenOak operates in the United States. This Policy is written as a nationwide baseline. State law may provide additional rights or require a separate notice, consent, authorization, disclosure, or acknowledgment. When a state-specific notice or consent conflicts with this Policy, the state-specific document controls for the matter it addresses.

Notice at collection: The categories of personal information we collect are described in Section 2, the sources are described in Section 3, the purposes are described in Section 4, and the categories of recipients are described in Section 5. Our retention criteria are described in Section 9. We do not sell personal information to data brokers or disclose personal information for another business’s independent direct marketing. We do not use consumer health data for targeted advertising.

1. Who we are and how the Services work

GlenOak provides senior-living information, guidance, referral coordination, and placement support. A consumer or authorized representative may contact us directly. A senior living community or another referral source may also introduce a consumer after the consumer or an authorized representative requests or authorizes the introduction.

Depending on the request and location, GlenOak may:

• prepare or deliver senior-care guidance;
• answer questions about independent living, assisted living, memory care, and related options;
• connect a consumer with one independent local senior-living placement partner;
• help the consumer and placement partner evaluate potentially appropriate communities;
• assist with communications concerning pricing, availability, tours, assessments, applications, and placement-related next steps;
• coordinate an authorized introduction from a senior living community or other referral source;
• provide limited referral confirmations or status information; and
• communicate with senior-living business contacts and newsletter subscribers.

Independent placement partners, senior living communities, and other providers are separate organizations. They have their own privacy and information-handling practices. GlenOak is not a healthcare provider, medical practice, law firm, financial advisor, insurer, or senior living facility and does not provide medical, legal, financial, insurance, or emergency advice.

If you provide information about another person, you should do so only with that person’s permission or when you otherwise have legal authority to provide it.

2. Personal information we collect

2.1 Identifiers and contact information

We may collect a person’s name, email address, telephone number, mailing address, city, state, ZIP code, preferred location, preferred communication method, relationship to a prospective resident, and identifiers associated with an inquiry, referral, form, device, or account.

2.2 Senior-living inquiry and placement information

We may collect preferred community type and location; timing; current living situation; budget range and anticipated payment method; housing, lifestyle, accessibility, and accommodation preferences; communities considered; tour, application, and placement status; referral source; and notes or other information voluntarily provided.

We may also collect the city, ZIP code, state, distance, care type, budget, or other criteria used to request or generate community information; the communities displayed, viewed, selected, or contacted; and interactions with results or referral links. Community information may come from public records, mapping and review services, senior living communities, independent placement partners, and GlenOak’s records. Public community information is not treated as information about a consumer unless it is linked to that consumer’s inquiry or activity.

2.3 Consumer health and care-related information

When relevant to a requested Service, we may collect information about mobility, activities of daily living, memory or cognitive considerations, behavioral or supervision needs, medication-management needs, accessibility needs, current or anticipated level of care, and other physical or mental health or care-related information that a consumer or authorized representative chooses to provide.

This information may be “consumer health data” or “sensitive data” under certain state laws even when it is not protected by the Health Insurance Portability and Accountability Act (HIPAA). Our separate Consumer Health Data Privacy Notice provides additional information.

2.4 Referral, authorization, and source-attribution information

We may collect the identity of a referring organization and its authorized contact; the date, time, and method of a referral; confirmation that the consumer requested or authorized assistance; the referring page or link and referral identifier; information needed to prevent duplicate referrals and assign an advisor; disclosures and acknowledgments provided; and referral or placement status.

After a consumer or legally authorized representative requests or authorizes an introduction, a referral source may provide only the limited information needed for GlenOak to respond: name, telephone number, optional email address, preferred area, general timing, preferred contact method, source organization, and a record of the authorization. A referral source should not submit diagnoses, medications, assessments, resident or medical records, detailed activities-of-daily-living, cognition or behavioral narratives, or other sensitive records through the standard referral form, ordinary email, or SMS. GlenOak normally collects needed care information directly from the consumer or legally authorized representative after providing the required notice and obtaining any required consent.

A referral link or identifier may identify the referring organization or business contact. It should not contain a consumer’s name, diagnosis, or other sensitive information.

2.5 Business-contact and partner information

We may collect a business contact’s name, title, employer, business contact information, service area, community type, licensing or registration information, insurance and compliance records, communications, relationship and referral activity, facility profile, services, general availability, pricing or timing information, business-link interactions, and administrative, contractual, accounting, or payment information.

2.6 Newsletter and marketing information

For the GlenOak newsletter and similar business communications, we may collect name, email address, organization, newsletter edition or state, subscription topic, permission source and date, subscription status, opt-out status, delivery and bounce information, and interactions such as opens and link clicks. When reported by the email provider, this may include IP address, device information, and approximate location associated with an opening or click. A personalized business link in a newsletter may identify the recipient or the recipient’s organization when clicked.

Being listed in our customer-relationship-management system or having a business relationship with GlenOak does not, by itself, establish permission to receive a marketing newsletter.

2.7 Communications

We may retain communications sent or received through forms, email, telephone, voicemail, or SMS, together with related information such as the date, time, sender, recipient, message content, and communication preferences. We do not record calls unless we provide legally required notice and obtain any required consent.

2.8 Website, device, analytics, and interaction information

When someone visits our website or opens an electronic communication, we and our service providers may collect:

• IP address and approximate location inferred from IP address;
• device, browser, operating-system, and language information;
• cookie, tag, pixel, and similar identifiers;
• pages viewed, referring and exit pages, links clicked, and dates and times;
• email delivery, opening, and link-interaction information;
• website performance, error, security, and diagnostic information; and
• interaction information such as navigation, clicks, scrolling, cursor or tap movement, and masked session-replay information when an interaction-analytics tool is enabled.

We do not use session-replay technology on pages where a person enters or views contact, referral, personalized, care, or health-related information. If session replay is used on another public page, it is configured not to capture form-field values, personalized content, partner tokens, or URL or query information that could reveal a consumer or care request. Please do not place sensitive information in a page URL, ordinary email, or an SMS message.

2.9 Inferences

We may draw limited inferences from information a consumer provides, such as a potentially appropriate level of care, general service area, or type of placement partner. These inferences are used to provide the requested Services and are not used for targeted advertising or solely automated decisions that produce legal or similarly significant effects.

2.10 Information we ask you not to send through ordinary channels

Do not send medical records, detailed diagnoses, medication lists, Social Security numbers, Medicare or Medicaid identifiers, driver’s-license or passport numbers, bank-account information, payment-card information, account passwords, or similarly sensitive records through ordinary email or SMS. If additional sensitive information is reasonably necessary, use the secure form, telephone process, or other method GlenOak directs you to use.

3. Sources of personal information

We may obtain personal information from:

• the consumer or prospective resident;
• a family member, caregiver, agent, or other authorized representative;
• a senior living community or other referral source that confirms the consumer requested or authorized an introduction;
• an independent placement partner or advisor;
• a senior living community or provider being evaluated at the consumer’s request;
• GlenOak website forms, referral or business links, newsletter signup forms, email, telephone, SMS, and other communications;
• service providers that help us operate the Services, including customer-relationship-management, form, communications, hosting, security, and analytics providers; and
• public professional or business sources when we are identifying or communicating with senior-living business contacts.

We do not buy consumer lead lists, scrape personal social-media profiles to create consumer leads, or append third-party consumer demographic dossiers to an inquiry.

4. How we use personal information

We collect and process personal information only to the extent adequate, relevant, reasonably necessary, and proportionate to the purposes described below. Sensitive data is processed only as strictly necessary for a requested Service or with consent where required.

We may use personal information to:

• respond to an inquiry and provide requested guidance or placement support;
• understand a consumer’s location, timing, budget, preferences, and care considerations;
• identify and introduce one independent local placement partner when requested or authorized;
• help evaluate communities, availability, pricing, tours, assessments, applications, and placement-related next steps;
• coordinate an authorized referral and communicate through an authorized method;
• confirm a consumer’s or representative’s permission, provide required disclosures, obtain acknowledgments, and document consent or withdrawal;
• administer an authorized referral, prevent duplicates, assign the appropriate advisor, provide limited status information, and maintain required records;
• administer relationships and contractual or payment obligations involving business organizations;
• send a requested newsletter, route the relevant edition, measure delivery and engagement, and honor opt-outs;
• operate, maintain, secure, debug, and improve the Services;
• conduct quality assurance, analytics, forecasting, and business planning, using de-identified or aggregated information when reasonably practicable;
• detect, investigate, and prevent fraud, misuse, security incidents, or unlawful activity;
• comply with law, licensing or registration obligations, record-retention duties, legal process, and enforceable agreements;
• establish, exercise, or defend legal claims; and
• create aggregated or de-identified information.

We do not use identifiable consumer health data, SMS consent information, or mobile information for targeted advertising, unrelated marketing, general audience analytics, or staff-training examples. We use de-identified or hypothetical information for general training and analytics whenever reasonably practicable.

5. How we disclose personal information

5.1 One independent placement partner

When a consumer requests or authorizes an introduction, and after obtaining any separate consent or authorization required by law, we may disclose relevant contact, senior-living, and care-related information to one independent local placement partner so the partner can respond and provide the requested assistance. The partner may accept or decline the handoff and is responsible for its own legal obligations. SMS consent provided to GlenOak does not transfer to the placement partner.

5.2 Senior living communities and providers

After obtaining any separate consent or authorization required by law, GlenOak or the placement partner may disclose information to communities or providers being evaluated at the consumer’s request to check potential fit, licensing, services, availability, pricing, or accommodations; arrange a discussion, tour, assessment, or application; or facilitate a placement. We limit care-related information to what is reasonably necessary and authorized for the requested purpose.

5.3 The referring organization

When an inquiry originates from a senior living community or other referral source, we may provide only the limited administrative status reasonably necessary and authorized to document and administer the introduction, such as whether it was received, accepted, declined, or closed. We do not disclose care details, private communications, communities considered, tours, or the consumer’s decision unless the consumer specifically directs the disclosure or applicable law otherwise permits it.

5.4 Service providers and processors

We may disclose information to providers that support website hosting, secure forms, customer-relationship management, email and newsletter delivery, telephone and SMS services, data storage and backup, analytics, security, accounting, contract administration, and legal or professional services. These providers may process information on GlenOak’s documented instructions only to perform contracted services for GlenOak, or as required by law.

5.5 Legal, safety, and business transactions

We may disclose information when reasonably necessary to comply with law or legal process; respond to a lawful government request; protect the rights, safety, property, or security of GlenOak or another person; investigate fraud or a security incident; or complete a merger, acquisition, financing, reorganization, bankruptcy, or transfer of business assets. A successor must handle transferred personal information subject to applicable law and the promises that continue to apply.

5.6 Compensation-related disclosures and “sale” or “sharing”

GlenOak does not operate a data-broker or lead-resale marketplace, sell consumer contact lists to data brokers or advertisers, or disclose personal information for cross-context behavioral advertising or a third party’s independent direct marketing. GlenOak’s referral, placement, and business relationships may involve compensation or other value, depending on the relationship and applicable law. Those arrangements do not create permission to use consumer information for unrelated purposes. We provide any compensation or relationship disclosure required by law before the relevant referral or authorization.

Some state laws define “sale” or “sharing” more broadly than ordinary usage. If a service-related disclosure or arrangement is treated as a sale or sharing under applicable law, GlenOak will provide the required notice and choice and will obtain any consent or authorization required before the covered disclosure. We do not sell consumer health data without a separate valid authorization that satisfies applicable law. If applicable law prohibits the sale, GlenOak will not make the disclosure.

5.7 No affiliate use for independent purposes

GlenOak currently does not share consumer health data with any affiliate. If that changes, we will update the applicable notice and obtain consent when required.

6. SMS and mobile-information privacy

Text messaging with GlenOak is optional. GlenOak uses SMS for low-volume, individual, conversational communications about authorized introductions, referral coordination, online-form links, service-status updates, and business support. We do not use this program for unsolicited, automated, bulk, or promotional text-message campaigns.

A senior living facility employee or other business contact may receive GlenOak’s SMS number in a one-to-one business communication and opt in by voluntarily sending the first message. By initiating that conversation, the sender agrees to receive conversational replies from GLENOAK SENIOR ADVISORS INC. at the number used to initiate the conversation. Message frequency varies. Message and data rates may apply. Reply STOP to opt out or HELP for assistance.

A business contact’s consent to receive replies does not constitute consent from the referred consumer. Receiving a consumer’s telephone number in a referral does not, by itself, authorize GlenOak to initiate SMS messages to that consumer. GlenOak obtains separate consumer permission when required. Consent to SMS is not a condition of receiving the Services.

Mobile information and SMS opt-in information will not be sold or disclosed to third parties or affiliates for their own marketing, promotional, or lead-generation purposes. SMS consent applies only to GlenOak and is not transferred to a placement partner, community, referral source, or other organization.

7. Newsletter and communication choices

We send the GlenOak newsletter only to contacts for whom we have a documented permission basis or another lawful basis. We do not infer newsletter permission solely from a contact’s presence in our records or an organization’s business relationship with GlenOak.

You may unsubscribe from a marketing email by using the unsubscribe link in that message or by contacting us. We maintain limited suppression records so that we can honor an opt-out. A topic-specific unsubscribe may stop only that newsletter, while a broader opt-out may stop all GlenOak marketing email.

You may ask us to stop non-SMS communications or change communication preferences by contacting us. Service or legal messages that are necessary to complete a request, protect the Services, or comply with law may continue where permitted.

8. Cookies, analytics, session replay, and privacy signals

We may use cookies, tags, pixels, local storage, and similar technologies to operate and secure the website, remember preferences, understand website use, measure performance, diagnose errors, prevent fraud, and evaluate outreach. Our providers may receive technical information such as IP address, device information, cookie identifiers, approximate location, pages viewed, referring information, and interactions with public pages.

We may use analytics and interaction tools supplied by providers such as Cloudflare, Google, and Zoho. When session-replay or interaction analytics is enabled on a nonsensitive public page, it may create a visual reconstruction of activity using information such as clicks, scrolling, navigation, and masked page elements. We exclude pages containing contact, referral, personalized, care, or health-related information and do not authorize analytics or advertising providers to use consumer health data, form-field content, mobile information, or SMS consent information for their independent purposes.

You may limit cookies through browser or device settings and through any cookie controls made available on our website. Some functions may not work properly if certain cookies are blocked. Some browsers offer a legacy “Do Not Track” signal, but there is no uniform industry standard for that signal and we do not respond to it as such. Where required by applicable law, we recognize qualifying universal opt-out preference signals, including Global Privacy Control, as a request to opt out of covered sale, sharing, or targeted advertising for the browser or device sending the signal. A universal opt-out signal does not withdraw a separate request for placement assistance or another service-specific consent; contact us to withdraw that request or consent.

We do not knowingly allow third parties to collect personal information through the Services over time and across unrelated websites for their own targeted advertising.

GlenOak does not use a geofence around an entity that provides in-person health care services to identify or track consumers seeking health care services, collect consumer health data, or send notifications, messages, or advertisements related to consumer health data.

9. Retention

We keep personal information only for as long as reasonably necessary for the disclosed purpose, taking into account the information’s sensitivity, the status of the relationship, applicable contracts, state referral-record requirements, tax and accounting requirements, limitation periods, dispute needs, and security considerations.

• Consumer inquiry and placement information: for the active assistance period and afterward only as needed to document the Service, comply with law or contract, resolve disputes, and protect legal rights.
• Consumer health data: for the shortest period reasonably necessary for the requested Service, consented purpose, legal obligation, or documented claim need, after which it is deleted or de-identified when reasonably feasible.
• Referral disclosures, acknowledgments, and authorizations: for the period required by applicable referral, privacy, contract, and recordkeeping laws and any longer period reasonably necessary to establish compliance.
• Business, accounting, and payment records: for the applicable relationship and the legally required tax, accounting, audit, and claim period.
• Newsletter records: while subscribed and afterward as necessary to maintain an opt-out, resolve delivery issues, and document permission.
• Website and analytics information: according to a limited business or security need and the settings of the applicable provider, after which the information is deleted, aggregated, or de-identified.

When deletion from an active system is appropriate, residual copies may remain temporarily in restricted backups until overwritten or securely deleted. We do not use backup copies for ordinary business purposes.

10. Security and data incidents

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. These safeguards may include access controls, role-based permissions, vendor review, contractual protections, secure transmission methods, logging, backup controls, training, and incident-response procedures appropriate to the nature of the information.

No transmission or storage system is completely secure. Please use the secure method we provide and avoid sending sensitive information through ordinary email or SMS. If a data incident occurs, we will investigate and provide notices required by applicable law.

11. Nationwide privacy rights and choices

Subject to identity verification, legal exceptions, and limits permitted by law, GlenOak makes the following baseline privacy choices available to residents of the United States. These baseline choices include Maryland residents and do not reduce any broader right available under the law of another state:

• confirm whether we process personal information about you;
• access personal information we maintain about you;
• correct inaccurate personal information;
• request deletion of personal information;
• obtain a portable copy of information you provided where technically feasible;
• obtain information about the categories of personal information, purposes, sources, and recipient categories involved;
• request a list of specific third parties to which we disclosed personal information, where applicable law requires it;
• withdraw consent for future collection or disclosure of sensitive or consumer health data;
• opt out of a covered sale, targeted advertising, or profiling in furtherance of decisions producing legal or similarly significant effects;
• limit certain uses or disclosures of sensitive personal information where applicable;
• appeal a decision concerning a privacy request; and
• receive service without unlawful discrimination for exercising a privacy right.

To submit a request, email contact@glenoakadvisors.com with “Privacy Request” in the subject line or write to GLENOAK SENIOR ADVISORS INC., 4938 Hampden Lane, #552, Bethesda, Maryland 20814. Describe the right you wish to exercise and the information or Service involved.

We may request information reasonably necessary to verify your identity and authority. An authorized agent may submit a request where permitted by law; we may require proof of the agent’s authority and direct verification from the consumer. We will respond without undue delay and generally within 45 days, subject to any extension permitted by applicable law. Requests are free unless applicable law permits a reasonable fee for a manifestly unfounded, excessive, or repetitive request. If we deny a request, you may appeal by replying to our decision or emailing us with “Privacy Appeal” in the subject line. We generally respond to an appeal within 45 days. If an appeal is denied, we will provide information about any further complaint process required by applicable law.

A request to stop future disclosures does not necessarily require an independent placement partner or senior living community to delete information it already received. You may need to submit a request directly to that organization, although GlenOak will provide reasonable assistance and send deletion notices where applicable law requires it.

12. Consumer health data

This Privacy Policy is not a HIPAA Notice of Privacy Practices. GlenOak is not generally a healthcare provider or health plan, but whether HIPAA applies to particular information can depend on its source and GlenOak’s role. When GlenOak acts for a HIPAA-covered organization under a valid business-associate agreement, that agreement and applicable law govern the protected health information. Other care-related information may be protected by consumer-health-data, comprehensive privacy, security, breach-notification, and consumer-protection laws. Please read our separate Consumer Health Data Privacy Notice.

13. Children

The Services are intended for adults. We do not knowingly collect personal information directly from children under 18. If we learn that a child submitted personal information without appropriate authorization, we will take reasonable steps to delete it.

14. Third-party services

Our website and communications may link to or integrate with websites, forms, placement partners, senior living communities, communications platforms, or other services that GlenOak does not control. Their privacy policies govern their independent practices. Review those policies before providing information directly to a third party.

15. Changes to this Policy

We may update this Policy as our Services, information practices, vendors, or legal obligations change. We will revise the date above and provide additional notice or obtain consent when required. We will not use or disclose consumer health data for a materially different purpose without first providing the notice and obtaining the consent required by applicable law.

16. Contact us

GLENOAK SENIOR ADVISORS INC.
doing business as GlenOak Senior Advisors
4938 Hampden Lane, #552
Bethesda, Maryland 20814

Email: lucas  -at-  glenoakadvisors.com
Telephone: 240 414 7330

For general privacy requests, use the subject line “Privacy Request.” For consumer health data requests, use the subject line “Consumer Health Data Request.”