Privacy Policy

Effective Date: September 21, 2026 Last Revised: September 21, 2026

1. Who We Are

TopAhead Technology Solutions, Inc, a Florida profit corporation (Sunbiz Document Number P11000067250), doing business as FindRetireHome ("FindRetireHome," "FRH," "Company," "we," "us," or "our"), operates https://findretirehome.com, related pages (including partner / community pages), advisor workflows, forms, SMS/email outreach, and our CRM workspace at crm.findretirehome.com (Twenty CRM) (collectively, the "Services").

Contact: TopAhead Technology Solutions, Inc d/b/a FindRetireHome 10275 NW 46th St Sunrise, FL 33351 United States

Phone: +1 305-390-4707 Privacy requests: [email protected] General: [email protected] or via the Contact page on the Site Legal notices: [email protected]

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information, and the choices and rights available to you (including under the California Consumer Privacy Act as amended by the CPRA, "CCPA/CPRA").

2. Scope

This Policy applies to personal information we process about:

• Families, prospective residents, and decision-makers who browse or submit forms on the Services
• People who call, text, or email us, or who receive advisor outreach with consent
• Community / partner contacts who interact with partner pages, emails, or the partner portal
• Website visitors (device and usage data)

This Policy does not apply to:

• Third-party websites or communities we do not control (even if linked from our listings)
• Communities' own privacy practices after we introduce you (each community is a separate organization)
• Job applicants (if we post separate notices)

HIPAA: FindRetireHome is generally not a HIPAA "Covered Entity" and is not a medical provider. See HIPAA and your information and Section 14 below. This Privacy Policy is not a Notice of Privacy Practices under HIPAA.

3. Categories of Personal Information We Collect

Depending on how you interact with us, we may collect the following categories (aligned to CCPA-style categories). Not all categories are collected about every person.

3.1 Information you provide

• Contact / identifiers: name, email, phone, ZIP / city, preferred contact method
• Care and housing preferences: care level of interest (e.g., independent living, assisted living, memory care), budget range, timeline, location preferences, assessment or questionnaire answers, notes about needs or goals
• Communication content: messages, form free-text, emails, call notes
• Consent records: checkbox / TCPA consent timestamps, method, and related form version
• Partner contacts: name, title, community name, business email/phone, billing contacts

3.2 Information collected automatically

• Device and browser type, OS, language
• IP address and approximate location
• Referring/exit pages, URLs, clicks, time on page
• Cookies and similar technologies, including our first-party visitor identifier `frh_vid`
• CRM and analytics events tied to your session or lead record

3.3 Information from other sources

• Communities / partners (e.g., tour outcomes, move-in confirmation, payment-source category for partner billing. Typically partner-facing, not published about you)
• Public / government listing sources used to populate directory data (e.g., AHCA / CMS-style facility data may lag. See Terms)
• Service providers (hosting, analytics, SMS/email delivery, CRM) that return delivery or engagement status
• You, when you update preferences or correct information

We may combine information from these sources in our CRM (Twenty at crm.findretirehome.com) and related tools.

4. Sources of Personal Information

5. How We Use Personal Information (Purposes)

We use personal information to:

1. Provide the Services: show listings, run matching / shortlists, respond to inquiries
2. Advisor follow-up: contact you by phone, SMS, and/or email consistent with your consent and preferences (see the consent language on our forms and Section 8)
3. Referrals / introductions: after advisor follow-up (or as otherwise described at collection), share relevant contact and preference information with senior living communities you are matched with or ask to contact
4. Operate CRM and quality: maintain lead records, attribution, training, and service improvement
5. Partner operations: administer partner listings, portal access, subscriptions, and private-pay success-fee billing (partner data)
6. Security, fraud prevention, and debugging
7. Analytics and site performance: understand aggregate usage; improve UX
8. Advertising / measurement: where used, limited advertising or measurement technologies (see Sale/Share below)
9. Legal compliance: respond to lawful requests; enforce Terms; protect rights and safety
10. Communications: transactional messages; marketing only where permitted

Families do not pay FindRetireHome. Partner compensation is described in our Terms and Transparency materials and does not change how we use your data for matching based on fit.

6. How We Disclose Personal Information

We disclose personal information as follows:

6.1 Senior living communities (referrals)

When you request help finding communities (or equivalent), we may share your name, contact information, location/preferences, care-related preferences, and inquiry notes with one or more communities after advisor follow-up, consistent with our live practice and this Policy, so they can respond about availability, tours, and pricing. Communities are independent controllers of the data they receive and have their own privacy practices.

6.2 Service providers / processors

We use vendors that process data on our behalf under contractual restrictions, such as:

• Hosting / infrastructure
• CRM (Twenty, crm.findretirehome.com)
• Email and SMS delivery providers
• Analytics
• Customer support tooling
• Payment processors (partners only, for Track A/B fees. Families are not charged by FRH)

6.3 Corporate / legal

Affiliates under common control (if any, for internal operations); professional advisors; successors in a merger or asset sale; or when required by law, legal process, or to protect rights, safety, and security.

6.4 With your direction

If you ask us to share information with a specific community, family member, or advisor.

We do not sell your personal information as a standalone data product (we do not rent or sell lead lists as a primary business). See Section 7 regarding CCPA "sale" / "share."

7. Sale, Sharing, and Targeted Advertising (CCPA/CPRA)

Under CCPA/CPRA, "sale" and "share" are defined broadly and can include certain disclosures of personal information for cross-context behavioral advertising, even without money changing hands.

Do Not Sell or Share

Opt-out of sale/share / targeted advertising:

• Use any "Do Not Sell or Share My Personal Information" link we publish when required
• Send a request to [email protected] or call +1 305-390-4707
• We honor Global Privacy Control (GPC) signals as a valid opt-out of sale/share for that browser/device where required or as we elect under this Policy

Sensitive personal information (CPRA): Care-preference and assessment data you submit is used to provide matching and referrals, a purpose you should reasonably expect. We do not use sensitive PI to infer characteristics for unrelated cross-context ads. You may limit use of sensitive PI where CPRA provides that right by contacting us.

We do not have actual knowledge that we sell or share personal information of consumers under 16.

8. Cookies, Analytics, DNT, and GPC

We use:

• Essential / functional cookies and storage (including `frh_vid`) to remember sessions, attribute referrals, and operate forms
• Analytics to measure traffic and improve the Services
• Marketing / advertising technologies only if enabled on the Site (disclosed in a cookie notice or this Policy when live)

You can control cookies via browser settings; blocking some cookies may break features.

Do Not Track (DNT): There is no uniform industry standard for DNT. We instead honor GPC as described in Section 7 and provide the opt-out channels above.

9. SMS, Phone, and Email. Consent Cross-Reference

If you submit a lead form or otherwise provide a phone number or email and consent to contact, we (and our advisors operating for TopAhead / FindRetireHome) may contact you consistent with the contact consent language presented at collection and applicable law (TCPA, Florida telemarketing rules, and carrier requirements).

• Consent is logged (timestamp, form version, IP/user agent where collected)
• Message frequency varies; message and data rates may apply
• Text STOP to opt out of SMS; HELP for help
• Consent is not a condition of browsing the Site or receiving basic information
• Email unsubscribe links are honored for marketing email
• Community partners: if you ask us on a call, by email, or in the partner portal to text you a listing-claim link or account notices, we log that request as your consent and text only what you asked for. Reply STOP at any time.
• Program details: FindRetireHome texts (operated by TopAhead Technology Solutions, Inc) are listing-claim links, account notices, and advisor follow-ups you asked for. Message frequency may vary. Message and data rates may apply. Reply STOP to cancel (one confirmation, then no further messages). Reply HELP or contact [email protected] / +1 305-390-4707 for help. See the Terms of Service, Section 7A.
• No third-party sharing of SMS consent: We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages. All of the disclosure categories in Section 6 exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

The approved checkbox and long-form copy appear on our lead forms.

10. Retention

We retain personal information only as long as reasonably necessary for the purposes described above, unless a longer period is required or permitted by law. Criteria include:

We may retain de-identified or aggregated data that cannot reasonably identify you.

11. Security

We use commercially reasonable administrative, technical, and organizational measures designed to protect personal information (access controls, encryption in transit where standard, vendor diligence, least-privilege CRM access). No method of transmission or storage is 100% secure. Please use unique passwords for any portal accounts and notify us of suspected unauthorized access.

12. Your Privacy Rights (California and Other U.S. States)

Depending on your state of residence, you may have rights to:

• Know / access the categories and specific pieces of PI we collected
• Delete PI (subject to exceptions)
• Correct inaccurate PI
• Opt out of sale / share / targeted advertising
• Limit use/disclosure of sensitive PI (CPRA)
• Non-discrimination for exercising rights
• Appeal a denial (where state law provides)

How to exercise: Email [email protected], call +1 305-390-4707, or use the Contact page. Please describe the right you wish to exercise and enough information for us to verify your identity (we may ask for additional verification). Authorized agents may submit requests with proof of authority as required by law.

We will respond within the timeframes required by applicable law (generally 45 days under CCPA, extendable as permitted).

Nevada / other states: If you are a resident of a state with a comprehensive privacy law (e.g., Colorado, Virginia, Connecticut, etc.), we will honor applicable rights upon verified request through the same channels.

13. Children

The Services are directed to adults seeking senior living information (often adult children of seniors). We do not knowingly collect personal information from children under 13 (or under 16 where relevant for sale/share). If you believe we have collected such information, contact us and we will delete it.

14. Health-Related Information and HIPAA Posture (Brief)

FindRetireHome:

• Is not a hospital, physician practice, health plan, or other HIPAA Covered Entity in ordinary operation of the consumer referral Site
• Does not provide medical treatment, diagnosis, or care planning as a provider
• May receive health-related preferences and assessment answers from families to improve matching. We handle this information carefully under this Privacy Policy and limit sharing to referral / service purposes

Communities you contact may be Covered Entities or otherwise regulated and may provide their own HIPAA Notices of Privacy Practices. Do not treat this Policy as a substitute for a provider's NPP. See HIPAA and your information.

15. International Visitors

The Services are operated from the United States and intended primarily for a U.S. audience. If you access the Services from elsewhere, you understand your information may be processed in the United States, where laws may differ from those in your country.

16. Third-Party Links and Community Sites

Listings may link to community websites, AHCA/CMS resources, or other third parties. Their privacy practices are their own. Review their policies before submitting data to them.

17. Changes to This Policy

We may update this Policy from time to time. The Last Revised date will change when we do. Material changes will be posted on this page; where required, we will provide additional notice. Continued use of the Services after the effective date of changes constitutes acceptance of the updated Policy to the extent permitted by law.

18. Accessibility

We are committed to improving digital accessibility of the Services. See our Accessibility (ADA) Notice for our WCAG 2.1 AA target, how to request accommodations or report barriers, and contact channels (+1 305-390-4707, [email protected]).

19. Contact Us

TopAhead Technology Solutions, Inc d/b/a FindRetireHome 10275 NW 46th St, Sunrise, FL 33351

Phone: +1 305-390-4707 Privacy: [email protected] General: [email protected] / Contact form