Privacy Policy

Proxima Senior Advising · Effective: August 9, 2026 · Last updated: August 9, 2026

This Privacy Policy explains how Proxima Senior Advising ("Proxima," "we," "us," or "our") collects, uses, discloses, and protects information when you visit our website, contact us, use our placement referral services, or interact with a facility account on our portal. We take the privacy of seniors and their families seriously and have designed our systems around data minimization and on-device processing wherever possible

Short version We collect only what we need to match you with appropriate assisted living or memory care options. We don't sell your information. We don't share your phone number with facilities until you say it's okay. You can ask us to delete your data at any time. We process most data on equipment we control, not on third-party cloud servers.

1. Who we are

Proxima Senior Advising is a placement referral service for assisted living and memory care facilities. We help families identify and connect with licensed senior living options that fit their care needs, budget, and location preferences. We are paid by the facilities when a family we referred moves in — you do not pay us for our service

Operator Proxima Senior Advising
Contact [email protected]
Mailing address [Insert business mailing address before publishing

2. Information we collect

We collect information in three ways: (a) information you give us directly, (b) information collected automatically when you visit our website, and (c) information from facilities and public sources to operate our matching service

A. Information you give us

When you fill out a form, call us, use our AI voice or chat agent, request a callback, or create an account, you may provide

Contact information — name, phone number, email address, mailing address (or ZIP
Care recipient details — who needs care (often a parent or spouse), their age, mobility, cognitive status (e.g., memory care needs), and any medical or behavioral considerations relevant to placement
Search criteria — preferred location, budget range, desired move-in timeline, type of care (assisted living vs. memory care
Payer information — who is paying (private funds, long-term care insurance, Medicaid/Medicaid waiver, Veterans benefits) — we screen for eligibility, we do not collect account numbers
Account credentials — for the customer portal: your email and a one-time code sent to your phone (we use passwordless sign-in; we never store a password
Communications — call recordings and transcripts (with your consent, see §5), chat messages, emails, and SMS messages with us

B. Information collected automatically

When you visit our website we and our service providers automatically receive

IP address, approximate location (city/state level), browser type, device type, operating system
Pages visited, time on page, referring source, and click patterns (for analytics — see §6
Cookie data and similar tracking identifiers (see our cookie notice below

We do not require this data to browse the site, and we minimize what we collect

C. Information from facilities and public sources

To match you with appropriate options, we maintain a database of licensed assisted living and memory care facilities. Sources include

State regulatory agencies (e.g., Florida AHCA / FloridaHealthFinder.gov for license status, capacity, inspection results
Public reviews (Google Places — rating, geocode, and review excerpts; we use the official API, not scraping
CMS Care Compare and Medicaid waiver directories
Facility websites and publicly disclosed pricing
Court records and news sources — used internally only to flag litigation history; never disclosed to you verbally and never used to defame

Facility-side information about your account (if you are a facility partner) is described in §11

3. How we use your information

We use the information above only for the purposes listed below. We do not use it for automated profiling in a way that produces legal or similarly significant effects without human review

To provide placement referrals — match your stated criteria against our facility inventory and present you with ranked options
To operate our voice and chat agents — when you call or chat, our AI agent collects structured information during the conversation and answers questions about facility options. The AI runs on equipment we control; see §5
To communicate with you — appointment confirmations, follow-up check-ins (at 1 week, 30, 60, and 90 days post-move-in), SMS reminders, and the post-call packet email with your matched options
To verify and authenticate you — if you call back, we use caller ID only as a lookup hint (never as authentication). Account sign-in is by email magic link or SMS one-time code
To bill and operate the business — generate invoices, track commissions, reconcile facility-reported move-ins with family check-ins, prevent fraud, and meet legal record-keeping duties
To improve our service — aggregated, de-identified analytics about which facilities are most often matched, common search criteria, etc. We do not use your individual data to train third-party AI models
To comply with law — respond to lawful requests, defend claims, and meet record-keeping obligations (see §10

4. Legal bases for processing

If you are in a jurisdiction that recognizes specific legal bases for processing (such as the EU/UK under GDPR or California under CCPA/CPRA), we rely on

Consent — for placing or receiving calls and texts, for call recording, and for any optional analytics or marketing
Contract — to provide the placement service you have asked for
Legitimate interests — for internal matching logic, fraud prevention, business analytics, and maintaining accurate facility data, balanced against your privacy rights
Legal obligation — to retain consent records (5 years) and tax/transaction records as required

5. AI voice and chat — what to expect

Our intake line and website chat use an AI agent. The voice agent speaks to you using synthesized speech, listens using speech-to-text, and reasons using a language model. Here's what that means for you

Disclosure at the start of every call Before any substantive conversation begins, you will hear: "This call may be recorded for quality and training purposes. I'm an AI assistant…" If you do not consent, you can hang up at any time and we will not call you back without fresh express written consent
Recording and retention With your implied consent (continuing after disclosure), calls are recorded. Audio is retained for 30 days, then deleted. Transcripts are retained for 24 months. Consent records are retained for 5 years (TCPA statute of limitations is 4 years; we keep a one-year buffer
On-device processing The voice and chat models run on equipment we control, not on third-party servers that retain your data. The model provider does not receive your audio or transcript content
Structured data capture During the call, the AI extracts details like name, care needs, and budget into structured fields stored in our database. You can ask the AI to repeat or correct anything captured
No medical diagnosis The AI never provides medical advice, diagnosis, or prognosis. It helps you find facilities, period
Web chat limits Anonymous web chat is capped at roughly 20 messages. After that we ask you to leave a number so we can call you back (TCPA-consented callback). Web chat input is treated as untrusted — prompt-injection-style content is filtered at the tool layer

6. Cookies and analytics

We use a minimal set of cookies and similar technologies

Strictly necessary — Cloudflare Turnstile (bot/abuse protection) and basic session state. These cannot be disabled
Analytics (optional — privacy-respecting, IP-anonymized analytics to understand which pages are useful. We do not use Google Analytics or Facebook Pixel. You can opt out by using your browser's Do Not Track or by blocking cookies

For chat and callback requests, we rate-limit submissions and validate that the request is from a human, not a bot

7. Who we share information with

We do not sell your personal information. We do not share it with facilities until you are ready

We require all processors to protect your information with appropriate safeguards and to use it only for the services they provide to us

8. Your choices and rights

You can do the following at any time

Access — request a copy of the personal data we hold about you
Correct — ask us to fix anything wrong
Delete — ask us to delete your data (see §9
Stop communications — reply STOP to any SMS, or tell us on a call, and we will remove you from outbound contact. We will still retain the consent record itself
Withdraw consent — withdraw any consent you previously gave, without affecting prior lawful processing
Restrict or object — ask us to restrict processing in certain circumstances (e.g., while we investigate a correction request
Portability — receive your data in a structured, commonly used format
Non-discrimination — we will not penalize you for exercising any of the above

To exercise any of these rights, email [email protected]. We respond within 30 days. If we need more time, we'll tell you why and when to expect a response

9. Deleting your data

You can request deletion of your personal data at any time by emailing [email protected] from the address on file, or by submitting the form on our "Delete My Data" page. When we receive a verified request, we will

Delete or anonymize your name, contact details, address, captured care criteria, budget figures, and any other directly identifying fields
Delete call recordings (or, if past the 30-day window, confirm they were already deleted
Anonymize transcripts — replace your name with a random ID, so the conversation can no longer be tied to you
Keep what we must We retain the consent record itself (the fact that you consented, the timestamp, and the disclosure text) for 5 years as required by TCPA. We retain anonymized aggregate analytics. We retain tax and transactional records as required by law
Confirm completion by emailing you back when the deletion is finished

If you have a move-in in progress, we may need to keep referral and attribution records until the commission reconciliation is complete, after which they too are deleted or anonymized

10. How long we keep your data

Recipient	What we share	Why
Assisted living / memory care facilities	Your name, phone number, and care needs — only after you explicitly agree to be referred to that specific facility. Your budget figures and medical details are not shared by default	To set up tours, evaluate fit, and follow up
Twilio (SMS / voice telephony	Phone number, message bodies, call audio	To deliver SMS and place/receive calls. Twilio acts as our processor under a Data Processing Agreement
Cloudflare (hosting, bot protection, email	IP address, request contents, email messages	To serve the website, protect against abuse, and deliver email
Stripe (payment processor for facility invoices	None of your personal data; only the facility's billing details when we invoice a facility for a successful move-in	To collect commission. Your card or bank information never touches our systems
Email delivery (Amazon SES or Postmark	Your email address and message contents	To deliver the post-call packet and other emails to you
Authorities, courts, or counsel	Only what is legally required or necessary to defend a claim	To comply with law or protect our rights

Data	Retention	Why
Call audio	30 days	Quality, dispute resolution
Call transcripts	24 months	Service improvement, dispute resolution
TCPA consent records	5 years	TCPA statute of limitations (4y) + 1y buffer
Customer account record (email, phone	Until you delete your account + 30 days	Account operation
Referral and commission records	7 years	Tax, audit, statute of limitations on contracts
Aggregated, de-identified analytics	Indefinitely	No longer personal data

11. Facility partners (B2B portal

If you are a facility account holder using our partner portal, you have a separate account relationship with us. The data we collect from you in that role includes

Your name, work email, work phone, and job title
Your facility's name, address, license number, and operational details
Login activity and audit logs of who accessed which lead
Communications with us and with families we refer to you (only after you accept the lead

We use this data to operate the portal, deliver leads, invoice commissions, and meet our contractual obligations. The same rights in §8 apply. Facility account data is retained for the life of the partnership plus 7 years for tax/audit. The terms in this Privacy Policy apply to facility account data as well; any separate Master Referral Agreement controls where it conflicts

What you see in the portal Facility accounts see sanitized lead profiles (name, care needs, location) before accepting a referral. Full phone numbers are revealed only after lead acceptance. Facility accounts never see budget figures, payment method, or medical history unless a family explicitly authorizes it

12. Children

Our services are designed for adults arranging care for other adults. We do not knowingly collect personal information from anyone under 18. If you believe we have collected information from a minor, contact us and we will delete it

13. Security

We protect your information with administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including

Encryption in transit (HTTPS/TLS) and at rest (full-disk encryption on our servers
Database access limited by role (most staff cannot see full PII; the AI and admin tools are the only paths to it
Row-level security policies in our database — every query is restricted to the rows the caller has a right to see
Bot and rate-limit protection on every public endpoint
Secrets stored outside of source control; never pasted into prompts given to local AI models
Default-deny inbound network rules; no service exposed to the public internet except through Cloudflare
Monthly dependency and code audits; prompt-injection guardrails on the web chat

No system is perfectly secure. If we discover a breach affecting your information, we will notify you as required by applicable law

14. International visitors

We are based in the United States and process data in the US. If you visit from outside the US, you understand that your information will be transferred to and processed in the US, where data protection laws may differ from those in your country. We rely on your consent, contract performance, and our legitimate interests as the legal bases for any such transfer

15. Third-party links

Our website may link to facility websites, government resources, or other third-party sites we do not control. This Privacy Policy does not apply to those sites. Please read their privacy policies

16. Changes to this Policy

We may update this Policy as our service evolves or as laws change. When we do, we'll update the "Last updated" date at the top and, if the changes are material, notify you by email or by a clear notice on the website before the changes take effect

17. Contact us

For any privacy question, request, or complaint

Proxima Senior Advising
Email: [email protected]
Phone: [Insert intake phone number]
Mailing address: [Insert business mailing address before publishing

If we cannot resolve your concern, you have the right to lodge a complaint with your local data protection authority. In the United States, you may contact the FTC; in the EU/UK, your national supervisory authority; in California, the California Privacy Protection Agency

This Privacy Policy is provided for general informational purposes and does not create a contractual relationship beyond what is required by applicable law. Specific terms in any Master Referral Agreement, Family Service Agreement, or other signed contract control where they conflict with this Policy. © 2026 Proxima Senior Advising