Genwin

Privacy Policy

Introduction — Who We Are

Welcome, and thank you for trusting Genwin, LLC ("Genwin," "we," "us," or "our") with your needs regarding assisted living. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, and what choices you have. If anything is unclear, please contact us.

Relationship to Other Agreements

Genwin’s relationship with its clients is governed by a separate Client Engagement Agreement. Genwin’s relationship with assisted living facilities and other community partners is governed by a separate Community Partner Agreement. The terms of those agreements supersede this Privacy Policy. In the event of any conflict between this Privacy Policy and a Client Engagement Agreement or Community Partner Agreement, the terms of the applicable Client Engagement Agreement or Community Partner Agreement shall control.

Information We Collect

To find the best assisted living option for you, we need to gather certain information. We only collect what is reasonably necessary to provide our services.

Health and Medical Data

Understanding your health helps us recommend facilities that can provide the level of care you need. We may collect the following health-related information:

  • Current medical conditions and diagnoses
  • Medications you are currently taking
  • Mobility status (for example, whether you use a wheelchair, walker, or cane)
  • Cognitive, physical, and behavioral status, including dementia or Alzheimer's assessments
  • The level of daily care you need (such as help with bathing, dressing, or meals)
  • Dietary restrictions related to medical conditions (such as low-sodium or diabetic diets)
  • Names and contact information for your physicians and specialists
  • Physician or specialist referrals

Financial Data

Assisted living costs vary depending on many factors. We collect financial information so we can recommend facilities that fit within your budget and help you explore all available payment options.

  • Income and retirement income (Social Security, pensions, annuities)
  • Budget relevant to assisted living affordability
  • Insurance coverage, including health insurance, supplemental insurance, and long-term care insurance
  • Medicaid and Medicare eligibility or enrollment status
  • Veterans Administration (VA) benefits eligibility
  • Monthly budget and spending capacity for assisted living expenses

Personal Preferences and Lifestyle Data

Your comfort and happiness matter. We collect information about your preferences so we can find a community where you will feel at home.

  • Geographic preferences (preferred city, neighborhood, or proximity to family)
  • Religious or cultural needs and preferences
  • Dietary preferences (vegetarian, kosher, halal, or other preferences)
  • Social and recreational interests (gardening, card games, arts, music, and similar activities)
  • Pet ownership (whether you have a pet and wish to bring it with you)
  • Language preferences

Family and Legal Representative Data

Many of our clients involve family members or legal representatives in the placement process. We may collect:

  • Names and contact information of family members involved in your care decisions
  • Emergency contact information
  • Names and contact information of Power of Attorney (POA) holders
  • Names and contact information of legal guardians or conservators
  • Documentation verifying a representative's legal authority to act on your behalf

Website Usage Data

When you visit our website at genwincares.com, we may automatically collect certain technical information to improve your experience and keep our site secure.

  • Your IP address
  • Browser type and version
  • Device information (desktop, tablet, or mobile phone)
  • Pages you visit on our website and how long you spend on each page
  • Cookies and similar tracking technologies (please see our separate Cookies Consent Notice for details)

How We Use Your Information

Everything we do with your information is aimed at one goal: helping you find the right assisted living community. Here is how we use the information we collect:

Primary Purpose

Our primary purpose for collecting your information is to evaluate your health needs, financial situation, and personal preferences to recommend suitable assisted living facilities.

Secondary Purposes

We also use your information to:

  • Communicate with assisted living facilities on your behalf to determine availability and suitability
  • Schedule tours and visits to facilities you are interested in
  • Coordinate your move and transition into your chosen facility
  • Maintain records of your placement process for follow-up purposes
  • Respond to your questions and provide ongoing support
  • Improve our services and better understand the needs of the seniors we serve

How We Share Your Information

We do not sell your personal information. We share your information only when necessary to help you find the right assisted living community or when required by law.

Third Parties Who May Receive Your Information

Assisted living facilities — We share relevant information with facilities so they can evaluate whether they can meet your needs and provide you with a quote.

Medical providers — With your consent, we may contact your doctors or specialists to obtain or verify health information needed for placement.

Insurance companies — We may share limited information with your insurance carriers to verify coverage and benefits that could help pay for assisted living.

Government benefit programs — We may share information with Medicaid, Medicare, or VA benefit programs to help determine your eligibility for assistance.

Data Minimization

When we share your information with any third party, we share only what is necessary for the specific purpose. For example, a facility evaluating whether it can accommodate your mobility needs does not need to see your full financial records.

Service Providers

We use a limited number of service providers to help us run our business, such as information technology companies, cloud storage providers, and analytics tools. These service providers are bound by contract to keep your information confidential and to use it only as we direct.

HIPAA and Health Data Safeguards

The Health Insurance Portability and Accountability Act ("HIPAA") is a federal law that protects health information held by healthcare providers, health plans, and healthcare clearinghouses. Genwin is not a HIPAA-covered entity because we are not a healthcare provider, health plan, or clearinghouse.

However, because we handle sensitive health information, we voluntarily adopt safeguards that we believe you deserve regarding protection of your health data.

Administrative Safeguards

  • We have appointed a Privacy Officer who is responsible for overseeing our privacy practices
  • All Genwin staff receive privacy and data-handling training before they begin work and at least annually thereafter
  • We follow relevant and applicable law concerning who, within Genwin, can view your health information. We conduct regular risk assessments to identify and address potential threats to your data

Physical Safeguards

  • Our office facilities have access controls to prevent unauthorized entry
  • Workstations are positioned and secured to prevent unauthorized viewing of client data
  • Portable devices (laptops, tablets, phones) that may contain client data are encrypted and password-protected

Technical Safeguards

  • AES-256 encryption protects your data at rest
  • TLS 1.2 or higher encryption protects your data in transit
  • Role-based access controls ensure that staff can only access the information they need for their job
  • Audit logging tracks who accesses your information and when
  • Multi-factor authentication (MFA) is required for all staff accessing client data systems

Your Right to Request Restrictions

You have the right to ask us to limit how we use or share your health information. For example, you may ask us not to share certain health details with a particular facility. We will do our best to honor your request, though please understand that some restrictions may limit our ability to find the best placement for you.

Your Rights and Choices

You have meaningful rights regarding your personal information, and we make it easy for you to exercise them.

Right to Access — You may request a copy of the personal information we have about you. We will provide it in a clear, understandable format.

Right to Correct — If any information we have about you is inaccurate or incomplete, you have the right to ask us to correct it. We will update our records promptly.

Right to Request Deletion — You may ask us to delete your personal information. We will do so unless we are required by law to keep certain records (for example, for tax or legal compliance).

Right to Restrict Use and Sharing — You may ask us to limit how we use or share your information. We will accommodate your request to the extent possible.

Right to Withdraw Consent — If you previously gave us consent to collect or share certain information, you may withdraw that consent at any time. We will process your withdrawal request within 15 business days.

Right to Data Portability — You may request that we provide your personal information in a commonly used, machine-readable format so that you can share it with another service provider.

Granular Consent — You do not have to agree to everything or nothing. You may consent to some types of data sharing while declining others. For example, you may allow us to share your health data with facilities but ask us not to share your financial data.

How to Exercise Your Rights

You may exercise any of these rights by contacting us at:

  • Email: info@genwincares.com
  • Phone: (678) 559-0810
  • Mail: Genwin, LLC, 10 Glenlake Parkway NE, North Tower, Suite 1050, Atlanta, GA 30328
  • We will respond to your request within 30 days. If we need more time, we will let you know and explain why.

Designated Representatives and Powers of Attorney

Many clients involve family members or legal representatives in the placement process. We welcome their involvement and have clear procedures for working with designated representatives.

Who May Act on Your Behalf

  • A person holding a valid Power of Attorney (POA) that covers healthcare or financial decisions
  • A court-appointed legal guardian or conservator
  • Any other person you have formally authorized in writing to act on your behalf

Verification Requirements

To protect you, we require anyone claiming to act on your behalf to provide documentation proving their authority. This may include:

  • A copy of the Power of Attorney document
  • A copy of a guardianship or conservatorship order issued by a court
  • A signed, written authorization from you (if you have capacity to provide one)
  • Government-issued photo identification of the representative

Capacity Considerations

If we have reason to believe that a client may lack the capacity to consent to the collection or sharing of personal information, we may require the involvement of a designated representative before proceeding. We handle these situations with care, sensitivity, and respect for the client's dignity.

Georgia Uniform Power of Attorney Act

Genwin complies with the Georgia Uniform Power of Attorney Act (O.C.G.A. § 10-6B-1 et seq.), which governs the creation, use, and scope of Powers of Attorney in the State of Georgia. If you have questions about whether a Power of Attorney document is sufficient for our purposes, please contact us and we will work with you to resolve any questions.

Data Security

We take the security of your personal information seriously and have implemented measures to protect your data from unauthorized access, loss, misuse, or alteration.

Data Breach Notification

In the unlikely event that your personal information is involved in a data breach, we will notify you and the appropriate authorities as required by law.

Georgia Personal Identity Protection Act

We comply with the Georgia Personal Identity Protection Act (O.C.G.A. § 10-1-912), which requires businesses to notify Georgia residents of certain data breaches.

Our Notification Commitments

  • We will notify affected individuals in the most expedient time possible and without unreasonable delay after we discover a breach
  • If more than 10,000 individuals are affected, we will also notify the Georgia Attorney General
  • If more than 10,000 individuals are affected, we will notify consumer reporting agencies (credit bureaus)
  • Our notification will describe the breach, the types of information involved, the steps we are taking, and what you can do to protect yourself
  • When appropriate, we will offer credit monitoring and identity theft protection services at no cost to you

Data Retention and Destruction

We keep your personal information only for as long as it is needed to fulfill the purposes described in this policy or as required by law.

Retention Periods

Active client data — We retain your information during the time we are actively working with you, plus two (2) years after your placement is complete.

Inactive client data — If you begin working with us but do not complete a placement, we retain your information for two (2) years after your last interaction with us.

Financial records — We retain financial records in accordance with IRS requirements and Georgia state retention requirements.

Data Destruction

When your information is no longer needed and no legal obligation requires us to keep it, we will securely destroy it. Our destruction methods comply with NIST Special Publication 800-88 (Guidelines for Media Sanitization). This means:

  • Electronic records are permanently and irreversibly erased
  • Paper records are cross-cut shredded
  • Storage media that can no longer be sanitized are physically destroyed

Applicable Laws

Genwin's privacy practices are designed to comply with the following laws and regulations. Depending on your state of residence and the nature of our services to you, some or all of the following may apply:

  • Georgia Personal Identity Protection Act (O.C.G.A. § 10-1-910 et seq.) — Georgia's primary data breach notification law
  • Federal Trade Commission Act, Section 5 — Prohibits unfair or deceptive business practices, including deceptive privacy practices
  • Gramm-Leach-Bliley Act (GLBA) — To the extent applicable, protects the privacy of financial information we collect
  • Georgia Computer Security Act (O.C.G.A. § 16-9-90 et seq.) — Governs computer security and unauthorized access in Georgia
  • California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA) — If we serve California residents, we will comply with these additional privacy requirements
  • Other state privacy laws — As privacy laws continue to evolve across the United States, we will comply with applicable state laws as they apply to our services

Elder Financial Exploitation Safeguards

Protecting our clients from financial exploitation is a responsibility we take seriously. Senior citizens are unfortunately frequent targets of financial abuse, and we have safeguards in place to help protect you.

What We Do

  • We train all staff to recognize the warning signs of financial exploitation, abuse, and neglect
  • We monitor our interactions and transactions for signs that a client may be the victim of financial exploitation
  • If we suspect that a client is being financially exploited, abused, or neglected, we are required by Georgia law to report it to Georgia Adult Protective Services in accordance with O.C.G.A. § 30-5-4
  • We maintain clear protocols for how staff should respond when they suspect exploitation
  • We cooperate fully with law enforcement and protective services in any investigation of elder abuse or exploitation

If you believe that you or someone you know is a victim of elder financial exploitation, please contact Georgia Adult Protective Services at 1-866-552-4464 or contact local law enforcement.

Accessibility

We are committed to making this Privacy Policy accessible to all clients, regardless of ability.

  • This policy is written in plain, everyday language throughout
  • A large-print version is available upon request
  • An audio recording of this policy is available upon request
  • A simplified, one-page summary of this policy is available upon request
  • The digital version of this policy on our website is designed to be compatible with screen readers
  • If you need this policy in a different format, please contact Matt Kress at (678) 559-0810 or info@genwincares.com

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, changes in the law, or other reasons. When we make changes, here is how we will let you know:

  • If we make material changes (significant changes that affect your rights or how we handle your information), we will notify you by email or postal mail and by posting a notice on our website
  • The updated policy will be posted on our website at genwincares.com with a new "Last Updated" date at the top
  • Your continued use of our services after we post changes means that you accept the updated policy
  • Prior versions of this policy are available upon request — simply contact us and we will provide the version you need

Contact Information

If you have any questions about this Privacy Policy, your personal information, or how to exercise your rights, please contact us:

  • Company: Genwin, LLC
  • Address: 10 Glenlake Parkway NE, North Tower, Suite 1050
  • Phone: (678) 559-0810
  • Email: info@genwincares.com
  • Website: genwincares.com
  • Privacy Officer: Holly Mallory
  • If you have a concern about how we handle your information, please reach out to us first so we can try to resolve it.
  • By using Genwin's services or website, you acknowledge that you have read and understood this Privacy Policy.