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Consumer Health Data Privacy Policy

Distinctive Healthcare Family of Companies

Effective Date: June 2026

This Consumer Health Data Privacy Policy (“Policy”) supplements Distinctive’s Privacy Policy and applies to Consumer Health Data collected, used, disclosed, and otherwise processed by Distinctive Healthcare, LLC, Distinctive Living, LLC, DR Management Services, LLC, Distinctive Living Development, LLC, and their respective subsidiaries, affiliates, managed communities, development projects, business units, employees, agents, and representatives (collectively, “Distinctive,” “we,” “our,” or “us”).

This Policy is intended to comply with applicable consumer health data privacy laws, including the Washington My Health My Data Act (“MHMDA”), Nevada Consumer Health Data Privacy Law, and other similar laws that may be enacted from time to time.

This Policy applies when you visit our communities, interact with our websites, communicate with us, inquire about our services, become a resident, family member, employee, referral source, vendor, business partner, or otherwise interact with Distinctive.

Consumer Health Data

For purposes of this Policy, “Consumer Health Data” means personal information that is linked or reasonably linkable to an individual and identifies that individual’s past, present, or future physical or mental health status.

Consumer Health Data may include:

  • Individual health conditions, treatments, diseases, or diagnoses
  • Social, psychological, behavioral, and medical interventions
  • Health-related surgeries or procedures
  • Diagnostic testing and treatment information
  • Medication information
  • Vital signs, symptoms, bodily functions, and measurements
  • Reproductive or sexual health information
  • Gender-affirming care information where applicable
  • Biometric information
  • Genetic information
  • Information identifying an individual seeking healthcare or senior living services
  • Precise location information associated with seeking healthcare services
  • Information derived, inferred, or extrapolated from other information that may indicate health status

Consumer Health Data does not include information excluded by applicable law, including information protected under HIPAA, publicly available information, de-identified information, or aggregated information.

Consumer Health Data We Collect

Depending upon the services requested, provided, or discussed, Distinctive may collect the following categories of Consumer Health Data:

  • Health assessments
  • Wellness evaluations
  • Functional assessments
  • Care needs assessments
  • Health histories
  • Medical conditions
  • Diagnoses
  • Medication information
  • Mobility information
  • Nutritional information
  • Physician and provider information

  • Vital signs
  • Care plans
  • Therapy information
  • Hospital discharge information
  • Home health information
  • Hospice information
  • Wellness program participation
  • Safety and risk assessments

  • Inquiry information
  • Referral information
  • Tour information
  • Move-in assessments
  • Eligibility evaluations
  • Healthcare service needs

Distinctive may create inferences or operational insights from information provided to us to better understand resident needs, service preferences, care requirements, and operational improvements.

We may collect Consumer Health Data from:

  • Residents
  • Prospective residents
  • Family members
  • Guardians
  • Legal representatives
  • Healthcare providers
  • Physicians
  • Hospitals
  • Rehabilitation facilities
  • Home health agencies
  • Hospice providers
  • Referral agencies
  • Government agencies
  • Third-party service providers
  • Marketing and lead-generation providers
  • Social media platforms
  • Website interactions
  • Business partners
  • Other lawful sources

How We Use Consumer Health Data

Distinctive may collect, use, process, and disclose Consumer Health Data for purposes including:

  • Evaluating care needs
  • Coordinating resident services
  • Facilitating admissions and move-ins
  • Supporting resident wellness
  • Providing customer service
  • Communicating with residents and families

  • Quality assurance
  • Resident safety
  • Risk management
  • Operational planning
  • Training and education
  • Service delivery

  • Compliance with federal, state, and local laws
  • Licensing requirements
  • Regulatory reporting
  • Audits and investigations
  • Fraud prevention
  • Legal proceedings

  • Analytics and reporting
  • Operational improvements
  • Market research
  • Service enhancements
  • Technology and systems management

Where permitted by law:

  • Responding to inquiries
  • Providing information regarding services
  • Educational programming
  • Community events
  • Marketing communications

How We Share Consumer Health Data

Distinctive does not sell Consumer Health Data.

We may share Consumer Health Data when necessary to:

  • Physicians
  • Healthcare providers
  • Hospitals
  • Pharmacies
  • Therapy providers
  • Home health providers
  • Hospice providers
  • Other authorized care providers

  • Technology vendors
  • Software providers
  • Professional advisors
  • Insurance providers
  • Auditors
  • Consultants
  • Business service providers

  • Government agencies
  • Regulatory authorities
  • Courts
  • Law enforcement agencies
  • Parties involved in legal proceedings

Consumer Health Data may be transferred as part of:

  • Mergers
  • Acquisitions
  • Reorganizations
  • Financing transactions
  • Asset sales
  • Other corporate transactions

States Covered by This Policy

Distinctive operates communities, development projects, and business operations across multiple jurisdictions throughout the United States.

This Policy is intended to comply with applicable consumer health data privacy laws, including those enacted in:

  • New Jersey
  • Florida
  • Georgia
  • Tennessee
  • Louisiana
  • Ohio
  • Kentucky
  • Montana
  • Pennsylvania
  • Washington
  • Nevada

and any other jurisdiction where Distinctive operates or where applicable law requires consumer health data protections.

Where state-specific laws provide additional rights or protections, Distinctive will comply with those requirements.

Your Consumer Health Data Rights

Depending upon your state of residence and applicable law, you may have the right to:

  • Confirm whether we collect Consumer Health Data about you
  • Access Consumer Health Data we maintain about you
  • Receive a copy of your Consumer Health Data
  • Request correction of inaccurate information
  • Request deletion of Consumer Health Data, subject to legal and regulatory requirements
  • Withdraw consent where applicable
  • Request information regarding categories of third parties with whom data has been shared
  • Appeal certain privacy-related decisions
  • Be free from unlawful discrimination for exercising privacy rights

Washington Consumer Rights

If you are a Washington resident, you may have additional rights under the Washington My Health My Data Act, including:

  • Confirming whether Distinctive is collecting, sharing, or selling Consumer Health Data
  • Accessing Consumer Health Data maintained by Distinctive
  • Receiving a list of third parties with whom Consumer Health Data has been shared
  • Withdrawing consent where applicable
  • Requesting deletion of Consumer Health Data
  • Appealing privacy-related decisions

Nevada Consumer Rights

If you are a Nevada resident, you may have additional rights under Nevada Consumer Health Data Privacy laws, including rights related to access, deletion, correction, and consent withdrawal.

Exercising Your Rights

To submit a privacy request, please contact us using the information below.

To protect your privacy and security, Distinctive may require verification of your identity prior to processing requests.

Authorized representatives may be required to provide documentation demonstrating authority to act on behalf of another individual.

Data Security

Distinctive maintains administrative, technical, and physical safeguards designed to protect Consumer Health Data from unauthorized access, disclosure, alteration, misuse, or destruction.

While no security program can eliminate all risks, we continuously evaluate and improve our safeguards to protect information entrusted to us.

HIPAA

Certain health information maintained by Distinctive may be governed by the Health Insurance Portability and Accountability Act (“HIPAA”) and other healthcare privacy laws.

Where applicable, separate HIPAA notices and privacy practices may apply.

Nothing in this Policy is intended to limit Distinctive’s obligations under HIPAA or other applicable healthcare privacy laws.

Changes to this Policy

We may modify this Consumer Health Data Privacy Policy from time to time. Any updates will be posted on our website and become effective upon posting unless otherwise required by law.

Contact Us

If you have questions regarding this Consumer Health Data Privacy Policy, your privacy rights, or Distinctive’s information handling practices, please contact us:

Distinctive Healthcare Family of Companies

Attn: General Counsel

Distinctive Support Center

1 West Main Street

Freehold, New Jersey 07728

Email: [email protected]

Website: www.distinctive-liv.com

Covered Entities

This Policy applies to:

  • Distinctive Healthcare, LLC
  • Distinctive Living, LLC
  • DR Management Services, LLC
  • Distinctive Living Development, LLC
  • Any affiliated entities, subsidiaries, managed communities, ownership structures, development projects, home care operations, consulting operations, or business units operated, managed, controlled, or affiliated with the foregoing entities.

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