Aging Solutions — Privacy Policy
Who We Are
Aging Solutions is a company based in Spokane, WA, providing senior care advisory, concierge, and safety services for older adults and their families, including the Trinity Suite (Trinity EMS Card, Trinity Connect, and Trinity Plan), Personalized Aging Advocacy, and Concierge Services.
Our website address is: https://agingsolutionsnw.com.
What Personal Data We Collect and Why We Collect It
Consultations, Advocacy, and Concierge Services
When you contact us for a consultation or engage our Personalized Aging Advocacy or Concierge Services, we collect the information you provide during that process, which may include your name, contact information, and details relevant to your aging and lifestyle plan (such as routines, preferences, goals, and safety considerations). This information is used solely to provide the services you’ve requested and is not sold or used for unrelated purposes.
Trinity EMS Card
To set up a Trinity EMS Card, we collect sensitive personal and health-related information necessary to make it useful in an emergency, including: personal treatment instructions, medication lists, allergy and condition information, and emergency contact details. This information is stored securely and is only made accessible to first responders and medical personnel via the card’s secure QR code, or to you when you log in to update your profile. We do not use this information for marketing or share it with advertisers.
Trinity Connect
To provide daily check-in service, we collect your (or your loved one’s) phone number, check-in response history, and emergency contact information. Trinity Connect uses this information to send daily check-in texts and/or calls, and — only if two consecutive check-ins are missed — to contact the designated emergency contact and, if necessary, coordinate a local welfare check. Check-in response data (i.e., whether and when you replied) is retained to operate and audit the safety-escalation feature described in your service plan.
Trinity Plan
When you purchase a Trinity Plan (Forms Only, Faux Leather Binder, or Genuine Leather), we collect the information necessary to process your order (name, shipping address if applicable, and payment details, the latter handled by our payment processor as described below). The legal, financial, medical, and personal information you record within your Trinity Plan document is filled in and kept by you; we do not collect, store, or have access to that content unless you separately share it with us as part of a consultation.
Purchases and Payment Processing
When you purchase any product or service from Aging Solutions, payment is processed through our third-party payment and checkout providers (Stripe and SureCart). We do not store your full credit card number on our own servers. Order details (product purchased, price, and billing name/contact information) are retained for order fulfillment, customer support, and legal/tax recordkeeping purposes.
Email Signup
If you submit your name and email address through a signup form or popup on our website, we collect your first name, last name, and email address to send you occasional updates, resources, and information about Aging Solutions products and services. You can unsubscribe at any time using the link included in any email we send.
Contact Forms
When you fill out a contact form on our website, the data submitted through that form — including your name, email address, phone number (if provided), and message — is collected and used to respond to your inquiry. Contact form submissions are retained as needed to respond to and document your inquiry.
Affiliate & Community Partners
If you are an affiliate or community partner, we collect the business and contact information necessary to establish and manage that relationship, including your organization’s name, contact person, contact details, and referral or commission records. If you refer a client or resident to Aging Solutions, we only collect that individual’s information with their own knowledge and consent as part of their enrollment.
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me,” your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Our checkout and shopping cart system (SureCart) also uses cookies necessary to maintain your cart contents and process your order securely.
Embedded Content from Other Websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor had visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
[Confirm and finalize: this section should list the specific analytics and advertising tools actually in use — for example, Google Analytics and/or the Meta (Facebook) Pixel, if either is active on the site.]
We may use website analytics tools to understand how visitors use our site, such as which pages are viewed and how long visitors stay. This helps us improve our website and services. If we run advertising campaigns (for example, on Meta/Facebook), an advertising pixel may be used on our site to measure the effectiveness of those campaigns; this may involve sharing limited, non-sensitive interaction data with the advertising platform. We do not use analytics or advertising tools to process Trinity EMS Card or Trinity Connect health-related data.
Who We Share Your Data With
We share personal data only as necessary to operate our business and provide our services, including with:
- Payment processors (Stripe and SureCart) to process purchases and subscriptions.
- SMS and voice communication providers (such as Twilio) to deliver Trinity Connect check-in texts and calls.
- Emergency contacts you’ve designated, and, when a safety escalation is triggered (e.g., two missed Trinity Connect check-ins, or use of a Trinity EMS Card), medical personnel, first responders, or local emergency services (EMS) as necessary to protect your or your loved one’s safety.
- Affiliate and community partners, only for clients they’ve referred to us and only to the extent necessary to coordinate that individual’s enrollment and services.
- Spam detection and security services (such as Akismet) to protect the site from spam and abuse.
- Analytics and advertising platforms, as described above, limited to non-sensitive website interaction data.
We do not sell personal data. We do not share Trinity EMS Card or Trinity Connect health-related information with advertisers or data brokers.
How Long We Retain Your Data
- Comments: the comment and its metadata are retained indefinitely, so we can recognize and approve follow-up comments automatically instead of holding them in a moderation queue.
- Trinity EMS Card, Trinity Connect, and Trinity Plan order data: retained for as long as your subscription or account is active, and for a limited period afterward as needed for customer support, safety-record purposes, and legal/tax recordkeeping, after which it is deleted or anonymized upon request, subject to any legal retention obligations.
- Payment and order records: retained as required for accounting, tax, and legal purposes (generally consistent with standard financial recordkeeping requirements).
- Contact form and email signup data: retained until you unsubscribe or request deletion, or until it is no longer needed for the purpose it was collected.
- Registered users (if applicable): we store the personal information users provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What Rights You Have Over Your Data
If you have an account on this site, have left comments, or have purchased a product or service, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we correct or erase any personal data we hold about you. This does not include data we are obliged to keep for administrative, legal, safety, or security purposes (for example, records needed to resolve a billing dispute or comply with tax law).
If you are a Washington resident, you may also have additional rights under Washington’s My Health My Data Act with respect to “consumer health data” (which may include information collected through the Trinity EMS Card and Trinity Connect), including the right to confirm whether we hold your consumer health data, request its deletion, and withdraw consent for its collection or sharing. See “Industry Regulatory Disclosure Requirements” below.
To exercise any of these rights, contact us using the information in “Your Contact Information” below.
Where We Send Your Data
Visitor comments may be checked through an automated spam detection service. Payment and order information is sent to our payment processors (Stripe and SureCart), which may process data in the United States. Trinity Connect check-in messages are sent through our SMS/voice provider (such as Twilio). In a safety escalation, information is shared with the designated emergency contact and, if necessary, local emergency services.
Your Contact Information
Aging Solutions 1722 E. Sprague Ave., Suite 210 Spokane, WA 99202
Phone: 844-888-5309
Email: info@AgingSolutionsNW.com
Website: www.AgingSolutionsNW.com
To ask a question about this policy, or to request access to, correction of, or deletion of your personal data, please contact us using the information above.
Additional Information
How We Protect Your Data
We use reasonable administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, or destruction. Payment card information is handled by our PCI-compliant payment processors (Stripe and SureCart); we do not store full payment card numbers on our own systems. Access to sensitive information, such as Trinity EMS Card medical details, is limited to what is necessary to provide the service.
[Confirm with your technical team/developer: specifics such as encryption in transit (HTTPS/TLS), access controls, and any additional safeguards specific to your hosting environment should be added here.]
What Data Breach Procedures We Have in Place
In the event of a data breach involving personal data, we will take reasonable steps to investigate and contain the breach, and will notify affected individuals and any relevant regulatory authorities as required by Washington state law and other applicable law, without unreasonable delay.
[This section should be finalized with your attorney to ensure it accurately reflects your actual incident response plan and legal notification obligations, including timelines required under Washington’s breach notification statute and, if applicable, the My Health My Data Act.]
What Third Parties We Receive Data From
We may receive limited personal data from affiliate and community partners who refer a client or resident to us (with that individual’s knowledge, for the purpose of enrolling them in our services), and from services such as Gravatar as described above.
What Automated Decision-Making and/or Profiling We Do with User Data
Aging Solutions does not use automated decision-making or profiling that produces legal or similarly significant effects on individuals. Trinity Connect’s check-in escalation process is rules-based, not automated profiling: if a check-in is missed, a second check-in is sent; if that is also missed, your designated emergency contact is notified; if the emergency contact cannot be reached, local emergency services are asked to perform a welfare check. This process does not use data about you to make predictions or automated judgments about you — it follows the same fixed steps for every client, based only on whether a check-in was received.
Industry Regulatory Disclosure Requirements
Washington My Health My Data Act (MHMDA): Aging Solutions is based in Washington State and, through the Trinity EMS Card and Trinity Connect, collects information that may qualify as “consumer health data” under Washington’s My Health My Data Act — a state law that imposes specific requirements around consent, a dedicated consumer health data privacy policy, restrictions on geofencing near health facilities, and a consumer right to withdraw consent and request deletion. This privacy policy should be reviewed by legal counsel to confirm compliance with MHMDA, including whether a separate, dedicated consumer health data policy and a distinct consent/opt-in mechanism are required, before this site collects any Trinity EMS Card or Trinity Connect data from Washington residents (or, depending on final legal advice, from residents of other states, since MHMDA’s protections can extend beyond Washington residents in some circumstances).
HIPAA: Aging Solutions is not a healthcare provider, health plan, or healthcare clearinghouse, and we do not believe we are a “covered entity” or “business associate” under HIPAA. However, because our services involve health-adjacent information (such as medications and allergies on the Trinity EMS Card), this determination should be confirmed with legal counsel.
TCPA / Telephone Consumer Protection Act: Because Trinity Connect involves automated or scheduled text messages and phone calls, our practices should be reviewed for compliance with the federal Telephone Consumer Protection Act and related consent requirements for automated communications.
Other state privacy laws: If Aging Solutions serves or advertises to residents of other states with comprehensive privacy laws (such as California’s CCPA/CPRA), additional disclosures and consumer rights may apply and should be evaluated by counsel.
This policy may be updated from time to time. We encourage you to review it periodically. Continued use of our website and services after changes are posted constitutes acceptance of the updated policy.
