PRIVACY POLICY FOR LifeStory Connection^TM SOFTWARE

The developers of LifeStory Connection^TM software, and the memory care facilities using our LifeStory Connection^TM software to enhance resident experiences are committed to maintaining the accuracy, confidentiality, and security of your loved one's personally identifiable information ("Personal Information"). As part of this commitment, our privacy policy governs our actions as they relate to the collection, use and disclosure of Personal Information. Our privacy policy is based upon the following 10 principles for the protection of Personal Information

1. Accountability

The memory care facilities using our LifeStory Connection^TM software are responsible for personal information under their control and will designate an individual or individuals who are accountable for compliance with the following principles.

2. Identifying Purposes

Through the use of our LifeStory Connection^TM software, memory care facilities can collect, use and disclose Personal Information to provide memory care residents and adult daycare residents a particular software application (the "APP") designed and developed by our company intended to assist staff in a Memory Care environment through accessing individual resident life stories and preferences in a quick and simple manner. Our APP can be accessed on a PCs and/or APP loaded tablets or other smart mobile devices which can be beneficial in supporting memory care staff in their role by reducing resident events related to resistance to care and/or non-participation of activities. The purposes for which Personal Information will be collected will be identified before or at the time the information is collected. The purposes for which information is collected is clear, and consent may be implied if the information is provided.

3. Consent

Knowledge and consent are required for the collection, use or disclosure of Personal Information. Providing us with Personal Information is always your choice. However, your decision not to provide certain information may limit the memory care staff's ability to address resistance to care and/or non-participation of activities.

4. Limiting Collection

The Personal Information collected will be limited to those details necessary for the purposes identified above. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, or the Internet.

5. Limiting Use, Disclosure and Retention

Personal Information may only be used or disclosed for the purpose for which it was collected. Personal Information will only be retained for the period of time required to fulfill the purpose for which it was collected.by law; however, it may be shared with family members. You should be aware that residents or one or more family members may become hostile to, or upset with, some elements of life story and preference information revealed by one or the other, sometimes perhaps for the first time. The Health Insurance Portability and Accountability Act (“HIPAA”) regulations protect the privacy of health information. The APP includes reminders for both families and memory care staff users to avoid entering any health-related information. Additionally, the APP is not intended to store any resident health information – nor should it. Therefore, in the collection of information the memory care staff is instructed to be extremely cautious and careful in this regard to ensure only non-health related resident life story and non-health related preference information are entered into the App/database. Obviously, the exercise of caution, discretion, and good judgement in this regard to avoid HIPAA violations must also extend to educating the families and responsible parties of residents who are granted access to enter life story and preference information.

6. Accuracy

Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

7. Safeguarding Personal Information

Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information. We take all reasonable precautions to protect the Personal Information from any loss or unauthorized use, access or disclosure.

8. Openness

We will make information available to you about our policies and practices with respect to the management of your Personal Information.

9. Customer Access

Upon request, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to it. You may verify the accuracy and completeness of your Personal Information, and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or HIPAA restrictions.

10. Handling Complaints and Suggestions

You may direct any questions or enquiries with respect to our privacy policy or our practices by contacting [email protected]