Privacy Policy

Who We Are

Haven Senior Investments, LLC ("Haven," "we," "our," or "us") is a senior housing advisory and consulting firm and a subsidiary of HavenCo, LLC. We provide advisory, consulting, market analysis, capital introduction, and transaction support services to owners, operators, investors, buyers, developers, and other participants in the senior housing industry across all 50 states.

Haven Senior Investments, LLC operates havenseniorinvestments.com. HavenCo, LLC also operates affiliated subsidiaries including Haven Realty, LLC (our licensed brokerage arm) and SeniorCRE, LLC (operator of seniorcre.com, the SeniorCRE® platform). This Privacy Policy applies specifically to havenseniorinvestments.com and any other websites operated by Haven Senior Investments, LLC that link to this Policy. Separate privacy policies govern the websites and platforms operated by our affiliated subsidiaries.

This Privacy Policy describes how we collect, use, disclose, and protect personal information when you visit our website, submit an inquiry, register as a buyer or seller, subscribe to our communications, or engage with our advisory services.

Information We Collect

We collect information in three ways: information you provide directly to us, information collected automatically when you use our websites, and information we receive from third-party sources.

2.1 Information You Provide Directly

When you submit an inquiry form, register as a buyer or seller, request a consultation, subscribe to our email communications, or otherwise contact us, you may provide:

• Contact information: Name, email address, phone number, company name, and mailing address
• Professional information: Your role (owner, operator, buyer, investor, developer, broker), current portfolio size, states of interest, and acquisition or disposition criteria
• Transaction information: Property types of interest, price ranges, financing needs, number of units, and investment objectives
• Communications: The content of any messages, questions, or comments you send us through contact forms or email
• Account information: If you create an account on SeniorCRE®, your login credentials and profile information

We collect only the information necessary to respond to your inquiry, provide our advisory services, and communicate with you about senior housing opportunities relevant to your stated interests.

2.2 Information Collected Automatically

When you visit our websites, we and our third-party service providers automatically collect certain technical and behavioral information:

• Log data: IP address, browser type and version, operating system, referring URLs, pages visited, time and date of visit, and time spent on each page
• Device information: Device type, screen resolution, and other technical identifiers
• Cookie and tracking data: Information collected via cookies, web beacons, and similar tracking technologies (see Section 5 for details)
• Company identification: We use a B2B visitor identification service (LeadForensics) that may identify the company or organization associated with your IP address. This service identifies business visitors — it does not identify individuals by name from IP data alone. See Section 6 for more detail.

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources to supplement what you provide directly, including:

• Publicly available business directories and professional databases
• Industry data providers and market intelligence services
• Referrals from existing clients, partners, or advisory contacts
• Social platforms such as LinkedIn, where you have made information publicly available in a professional context

How We Use Your Information

We use personal information for the following purposes, always within the scope of your expectations when you provided it:

• Respond to inquiries and provide advisory services: To answer your questions, follow up on your stated interests, and provide the senior housing advisory and consulting services you request
• Match buyers and sellers: To connect qualified buyers with senior housing communities that meet their stated acquisition criteria, and to present seller opportunities to appropriately qualified prospects on a confidential basis
• Send relevant communications: To send market reports, research updates, property notifications, event announcements, and other senior housing content you have requested or that we reasonably believe is relevant to your professional interests
• Operate and improve our websites: To monitor website performance, diagnose technical issues, analyze usage patterns, and improve the functionality and content of our sites
• Comply with legal obligations: To meet applicable legal requirements, respond to lawful requests from government authorities, and enforce our terms and agreements
• Protect our business and users: To detect, investigate, and prevent fraud, unauthorized access, and other harmful or illegal activities
• Maintain our business records: For legitimate business administration purposes including record-keeping, invoicing, and audit purposes

We do not sell your personal information to third parties. We do not use your personal information for automated decision-making that produces legal or similarly significant effects without human review.

How We Share Your Information

We share personal information only in the limited circumstances described below. We do not sell, rent, or trade personal information to third parties for their own marketing purposes.

4.1 Service Providers

We engage trusted third-party service providers who process personal information on our behalf to support our operations. These providers are bound by contractual obligations to protect your data and use it only for the purposes for which it was disclosed. Our service providers include:

• Website hosting and content delivery providers
• Contact form and CRM platforms (including WPForms and associated data processors)
• Email marketing and communication platforms
• Website analytics providers
• B2B visitor intelligence services (LeadForensics — see Section 6)
• Document storage and collaboration tools

4.2 With Your Consent

When you register as a buyer or seller with Haven, you understand and consent that Haven may share relevant, non-public information about senior housing opportunities or qualified buyers with counterparties to a potential transaction, subject to appropriate confidentiality obligations. We disclose seller information only to registered, qualified buyers under confidentiality agreements, and we do not disclose buyer identities to sellers without prior consent.

4.3 Business Transfers

If Haven is involved in a merger, acquisition, asset sale, or other business transfer, personal information may be among the assets transferred. We will provide notice before your personal information becomes subject to a materially different privacy policy.

4.4 Legal Requirements

We may disclose personal information if required to do so by law, regulation, or valid legal process, or when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Haven, our clients, or the public.

Cookies & Tracking Technologies

Our websites use cookies and similar tracking technologies to operate properly, analyze usage, and improve your experience. A cookie is a small text file stored on your device when you visit a website. We use the following categories of cookies:

Managing Cookies

Most web browsers allow you to control cookies through their settings preferences. You can set your browser to refuse all cookies, accept only first-party cookies, or notify you when a cookie is set. Note that disabling certain cookies may affect the functionality of our website, including contact form submission.

To opt out of Google Analytics tracking across websites, you may install the Google Analytics Opt-out Browser Add-on.

WordPress Login Cookies

If you are an authorized user of the Haven website backend (WordPress CMS), logging in will set session cookies that persist for two days, and screen options cookies that last for one year. Selecting "Remember Me" at login extends session persistence to two weeks. Logging out removes all login cookies.

Third-Party Services

Our websites use the following third-party services that may collect or process data independently. We encourage you to review each provider's privacy policy.

6.1 LeadForensics (B2B Visitor Intelligence)

Our websites use LeadForensics, a B2B visitor intelligence service that identifies the company or organization associated with a visitor's IP address. LeadForensics works by matching IP addresses against a database of known company IP ranges. This service identifies business organizations — it does not identify individual visitors by name from IP address data alone.

This data helps Haven's advisory team understand which companies are researching senior housing opportunities and follow up with relevant information. If you are visiting on behalf of a company and prefer not to be identified, you may use a personal network connection or configure your browser to use a VPN.

LeadForensics privacy policy: leadforensics.com/privacy-policy

6.2 WPForms

We use WPForms to process contact, buyer registration, and seller inquiry forms on our websites. Form submissions are stored in our WordPress database and may be transmitted to our CRM or email platform. WPForms collects your IP address and browser user agent string alongside your form submission to assist with spam detection. Submission data is retained per our data retention policy in Section 7.

6.3 Website Analytics

We use web analytics services to understand how visitors interact with our websites. Analytics data is used in aggregate to improve our content and user experience. Where analytics providers offer data anonymization options, we enable them. You may opt out of analytics tracking using browser settings or opt-out tools provided by those services.

6.4 Email Communications (CAN-SPAM Compliance)

When we send commercial email communications, we comply with the CAN-SPAM Act. Every commercial email we send includes a clear identification of Haven as the sender, an honest subject line, our physical mailing address, and a simple, functioning mechanism to opt out of future emails. We honor all opt-out requests promptly, no later than 10 business days from receipt.

To unsubscribe from Haven email communications, click the "Unsubscribe" link at the bottom of any email you receive from us, or email us at privacy@havenseniorinvestments.com.

6.5 SeniorCRE® Platform

SeniorCRE® (seniorcre.com) is operated by SeniorCRE, LLC, a separate subsidiary of HavenCo, LLC. SeniorCRE® maintains its own terms of service and privacy policy. If you create an account on SeniorCRE®, your use of that platform is governed by the SeniorCRE® Privacy Policy available at seniorcre.com. Haven Senior Investments, LLC and SeniorCRE, LLC may share certain operational data to provide coordinated advisory services to mutual clients.

6.6 Embedded Content

Pages on our websites may include embedded content such as videos, maps, social media feeds, or podcast players sourced from third-party platforms. Embedded content from external websites behaves as if you had visited those websites directly — they may collect data about you, use cookies, embed additional tracking, and monitor your interaction with the embedded content. Please review the privacy policies of those third-party providers.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with our legal, contractual, and business obligations. Our general retention principles are:

• Inquiry and contact form submissions: Retained for up to 3 years from the date of submission, or longer if an ongoing advisory relationship develops. Active client and prospect records are retained for the duration of the relationship plus 5 years
• Transaction-related records: Retained for a minimum of 7 years following completion or termination of a transaction engagement, consistent with applicable legal and contractual obligations
• Email communications and marketing records: Subscriber records retained until you unsubscribe, plus 2 years thereafter for record-keeping. Unsubscribe records retained indefinitely to prevent re-subscription without consent
• Website analytics data: Aggregated analytics data retained for up to 26 months. IP-level log data purged after 90 days
• Spam detection data: Browser and IP data collected for spam prevention purposes retained for 30 days
• Legal holds: Data subject to a legal hold, investigation, or regulatory inquiry will be retained for the duration of that matter regardless of the above schedules

When personal information is no longer required, we securely delete or anonymize it in accordance with our data disposal procedures.

Data Security

We implement reasonable and appropriate technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for data transmitted between your browser and our websites
• Access controls limiting personal data access to authorized Haven personnel on a need-to-know basis
• Secure hosting infrastructure with routine security monitoring
• Password management and authentication requirements for system access
• Periodic review of our data handling practices and vendor security postures

Your Privacy Rights

Depending on your location and applicable law, you may have the following rights with respect to your personal information:

• Right to Know / Access: Request a copy of the personal information we hold about you and how it is being used and shared
• Right to Correction: Request that we correct inaccurate or incomplete personal information we hold about you
• Right to Deletion: Request that we delete your personal information, subject to certain exceptions for legal obligations, ongoing business relationships, and legitimate business purposes
• Right to Opt Out of Marketing: Opt out of receiving commercial email communications from Haven at any time using the unsubscribe mechanism in any email, or by contacting us directly
• Right to Data Portability: Where applicable under law, request that we provide your personal information in a portable, machine-readable format
• Right to Non-Discrimination: Exercise any of the above rights without receiving discriminatory treatment in the services or information we provide to you

To exercise any of these rights, submit a request to privacy@havenseniorinvestments.com with the subject line "Privacy Request." We will respond within 45 days of receipt. We may ask you to verify your identity before fulfilling your request.

California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with additional rights regarding your personal information.

Categories of Personal Information We Collect

In the preceding 12 months, Haven has collected the following categories of personal information as defined by the CCPA:

• Identifiers: Name, email address, phone number, company name, IP address
• Professional or employment-related information: Job title, role type, company size, portfolio information, and professional interests submitted through our forms
• Internet or electronic network activity: Browsing behavior on our websites, pages visited, and interaction data
• Geolocation data: General geographic location inferred from IP address (city / state level only; not precise GPS location)
• Communications: Content of inquiries, emails, and messages submitted to Haven

We Do Not Sell or Share Personal Information

Haven does not sell personal information as defined by the CCPA, and does not share personal information with third parties for cross-context behavioral advertising. We do not have actual knowledge of selling or sharing the personal information of consumers under 16 years of age.

California-Specific Rights

California residents have the right to: know what personal information is collected and how it is used; delete personal information subject to legal exceptions; correct inaccurate personal information; opt out of the sale or sharing of personal information (not applicable here, as we do not sell or share); limit the use of sensitive personal information (we do not collect sensitive personal information as defined by the CPRA); and non-discrimination for exercising your rights.

To submit a California privacy request, contact us at privacy@havenseniorinvestments.com. We will respond within 45 days and may extend by an additional 45 days with notice.

Colorado Residents

HavenCo, LLC and its subsidiaries, including Haven Senior Investments, LLC, operate in the United States. The Colorado Privacy Act (CPA), effective July 1, 2023, provides Colorado residents with rights similar to those described in Section 9 of this Policy.

Colorado residents have the right to access, correct, delete, and obtain a portable copy of their personal data. You also have the right to opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. Haven does not conduct targeted advertising, sell personal data, or engage in automated profiling for consequential decisions.

To submit a Colorado privacy rights request or appeal a decision regarding your personal data, contact privacy@havenseniorinvestments.com.

Children's Privacy

Our websites and services are directed exclusively to business and investment professionals in the senior housing industry. We do not knowingly collect, use, or disclose personal information from children under the age of 13. Our inquiry forms and registration processes are not designed for or intended to attract individuals under 13.

If we become aware that we have inadvertently collected personal information from a child under 13, we will delete it promptly. If you believe we have collected information from a child under 13, please contact us at privacy@havenseniorinvestments.com.

Third-Party Links

Our websites may contain links to third-party websites, including regulatory resources (HUD.gov, eCFR, Grants.gov), industry platforms (NIC MAP, JLL), and affiliated platforms (SeniorCRE®). Clicking a link to a third-party or affiliated site takes you away from havenseniorinvestments.com and into a site governed by that site's own privacy policy.

Haven is not responsible for the privacy practices, security, or content of third-party websites. We encourage you to review the privacy policy of every website you visit. The presence of a link on our site does not constitute an endorsement of that site's privacy practices.

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, applicable law, or for other operational, legal, or regulatory reasons. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify you by email or by posting a prominent notice on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. Your continued use of our websites after any changes constitutes your acknowledgment of the updated Policy.

For historical versions of this Privacy Policy, contact us at privacy@havenseniorinvestments.com.