Privacy Policy

1. Scope of This Policy

This Privacy Policy describes the practices of Senioa Life Management, LLC and its affiliates (collectively, "Senioa Life," "we," "our," or "us") with respect to personal information collected through www.SenioaLife.com, the LP Portal, email communications, and in-person and telephone interactions. It applies to prospective and current limited partners, community residents and their families, business partners, job applicants, and website visitors.

2. Information We Collect

Information you provide

• Name, address, email address, phone number, and other contact details
• Investor-qualification information (accredited investor status, source of wealth, KYC/AML documentation, tax identification numbers)
• Account and subscription information for fund investments
• Family and resident information provided during community inquiries or admissions (subject to separate HIPAA notices where applicable)
• Employment information for job applicants
• Any information you voluntarily submit through forms or correspondence

Information collected automatically

• Device and browser information (IP address, browser type, operating system, language)
• Usage information (pages visited, time on page, referring URL)
• Cookies and similar technologies (see Section 5)

Information from third parties

• Publicly available business and background information
• Information from KYC/AML service providers
• References and referrals

3. How We Use Information

We use personal information to:

• Evaluate investor qualification and process subscription and redemption requests
• Provide fund reporting, tax documents, and investor communications
• Respond to inquiries and provide services
• Comply with legal, regulatory, and audit obligations, including anti-money-laundering, know-your-customer, and sanctions screening
• Improve the website, LP Portal, and our services
• Detect, prevent, and investigate fraud or security incidents
• Send administrative communications and, with consent where required, marketing communications

4. How We Share Information

Senioa Life does not sell personal information. We share it only with:

• Fund administrators, transfer agents, custodians, and auditors
• Legal, tax, and compliance advisors
• KYC/AML, background-check, and identity-verification providers
• IT, hosting, and cybersecurity providers under written contract
• Regulators, courts, and law enforcement, when required by law
• A successor entity in the event of a merger, acquisition, or restructuring

5. Cookies & Tracking

We use strictly necessary cookies to operate the website and LP Portal. We use analytics cookies to understand how the site is used, on an aggregated and de-identified basis. We do not use advertising or cross-site tracking cookies. You may control cookies through your browser settings; disabling strictly necessary cookies may impair site functionality.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, and thereafter as required by applicable law, tax rules, audit standards, or contract. Investor records are generally retained for the life of the fund plus seven (7) years.

7. Security

Senioa Life maintains administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, role-based access control, multi-factor authentication for the LP Portal, and periodic penetration testing. No system is perfectly secure, and we cannot guarantee absolute security.

8. Your Rights

California Residents (CCPA / CPRA)

California residents have the right to know what personal information we collect, to request deletion, to correct inaccurate information, to opt out of the sale or sharing of personal information (we do not sell or share for cross-context behavioral advertising), and to limit use of sensitive personal information. Requests may be submitted to [email protected]. We will not discriminate against you for exercising these rights.

European Economic Area / United Kingdom (GDPR / UK GDPR)

Individuals in the EEA and UK have the rights to access, correct, delete, restrict processing, port their data, and object to processing. Our lawful bases for processing include contract, legal obligation, legitimate interests, and consent. Complaints may be lodged with the applicable supervisory authority.

Other U.S. States

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Delaware, and other states with comprehensive privacy laws have similar rights. Please contact us to exercise them.

9. Children

This website is not directed to children under the age of thirteen (13). We do not knowingly collect personal information from children under 13. If we learn that we have inadvertently collected such information, we will delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted with a new "Last Updated" date and, where required by law, communicated directly to affected individuals.

11. Contact

To exercise your rights, ask questions, or submit a complaint:

Data Protection Officer
Senioa Life Management, LLC
1910 Pacific Avenue
Suite 2000
Dallas, TX 75201
[email protected]
972.945.5050