Privacy Policy

EFFECTIVE JULY 15, 2026

This privacy policy (the "Privacy Policy") explains the collection, use, and disclosure practices of the websites, mobile applications, artificial intelligence ("AI") agents (including our digital Toor Guide, "GiGi"), and other online and offline products and services, including, without limitation, our senior living referral, virtual tour, community, and care-professional connection services (collectively, the "Services") owned and operated by Senior Toor LLC and/or any of its affiliates ("Senior Toors," "we," "us," or "our"). For clarity, this Privacy Policy describes how we collect and use information when you access and use our websites, including but not limited to www.seniortoor.com and any subdomains (individually and collectively, the "Site" or "Sites"). For the purposes of this Privacy Policy, "you" and "your" mean you as the user of the Services, whether you are a Toorist, Toor Guide, Care Pro, community partner, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. Please be advised that the practices described in this Privacy Policy also apply to how we handle information that you submit to us offline.

CONSENT

Privacy Policy. By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not use or access the Services.

Phone Calls. By providing us with your telephone number through your use of our Services, you agree to be contacted by Senior Toors and contracted Toor Guides, community partners, and care professionals to explore options relating to our Services. You agree to be contacted by telephone call or text message at the telephone number you provided, even if you previously registered on a Do Not Call registry.

COLLECTION & USE OF YOUR INFORMATION

We collect information from four primary sources: directly from you, automatically from your use of our Services, from third parties, and by using information we collect to derive new information. The types of information we collect about you depend on your interactions with us and are described in more detail below.

Information We Collect Directly from You. We collect information directly from you in a variety of ways. Any information you provide to us is voluntary, but some information may be necessary for us to provide you with our Services. The categories of information we collect directly from you may include: • Identifiers, such as your first name, last name, phone number, email address, and mailing address; • Health information, such as whether you have health insurance, whether you receive Medicare or Medicaid, medical conditions and history, disability information, and care needs; • Characteristics such as age, sex/gender, marital status, veteran status, ethnicity, and religion; • Account information, such as your username and password; • Financial information, including your budget for senior care options and income; • Commercial information, including records of tours booked, inquiries sent, appointments scheduled, and move-in status; • Any information you choose to input into our AI-powered tools, including GiGi, our digital Toor Guide, which we use to generate and output new information or content as part of the Services; • Information you choose to include in communications with us, including in response to surveys or through our customer service channels; • User-generated content, such as reviews, community posts, and photos submitted by you through our Sites ("UGC"). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit your UGC to any public area of the Services (such as the Toor Community), your UGC will be considered "public" and accessible by anyone, including us; and • Geolocation data, when you use GPS-verified tour check-in features to confirm attendance at a scheduled Toor or professional appointment.

You may also provide information to us about another person for whom you may be seeking the Services ("Resident"): • Identifiers, such as their first name, last name, phone number, email address, and mailing address; • Health information, such as whether they have health insurance, whether they receive Medicare or Medicaid, medical conditions and history, disability information, and care needs; • Characteristics such as their age, sex/gender, marital status, veteran status, ethnicity, and religion; • Financial information, including their budget for senior care options and income; and • Commercial information, including tours booked on their behalf and records of their move-in status.

Information Automatically Collected from Your Use of the Sites. We automatically collect information about you from your use of our Services, including by using website analytics tools or other technologies, like cookies and web beacons (described in more detail below). The categories and types of information we collect automatically include: • Identifiers, such as your IP address and unique device identifiers; • Internet or other electronic network activity information, such as the type of browser you use, app version, access dates and times, pages viewed, and the page you visited before navigating to our Sites; • Approximate geolocation data, such as the country from which you access our Sites; and • Other information that relates to or is capable of being associated with you, such as information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, and mobile network information.

Cookies. Cookies are small text files stored on your computer when you visit certain online pages that record your preferences. We use cookies to track use of our Sites and other Services. We may also use cookies to monitor traffic, improve the Sites, make the Sites easier and/or more relevant for your use, and improve the performance of our advertising on other websites. You can opt out of accepting cookies by adjusting your browser settings. However, certain features may not work if you delete or disable cookies.

Web Beacons. Some pages of our Sites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email, and for other related website statistics.

Your browser settings may allow you to transmit a "do not track" signal, "opt-out preference" signal, or other mechanism for exercising your choice regarding the collection of your information. To learn more about "do not track" signals, visit http://www.allaboutdnt.com/. To learn more about Global Privacy Control, visit https://globalprivacycontrol.org/. To learn more about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, visit https://www.aboutads.info/choices.

INFORMATION WE COLLECT FROM OTHER SOURCES

We may collect information about you from other sources. For example, we may collect information from: • Community partners, Toor Guides, and care professionals with whom you interact; • Third-party social media services, such as Facebook, Instagram, TikTok, YouTube, and LinkedIn, that you use to interact with our Services or that allow you to share information; • Analytics data we receive from analytics providers; and • Advertising networks.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties.

INFORMATION WE INFER

We may derive information or draw inferences about you based on the other information we collect. For example, we may infer your location from our collection of your IP address.

In addition to the specific uses described above, we may use any of the above information to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services, providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, conducting internal research and development, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting the Services, our rights, and the rights of our employees, users, or other individuals. We may review chat, voice, and SMS interactions and related transcripts or summaries for quality assurance, safety, troubleshooting, and to improve the Services.

We may de-identify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be reasonably linked to you ("de-identified information"). We may use such de-identified information for any purpose, including sharing or selling to third parties for their own use.

USE OF YOUR INFORMATION

For each category of information we collect about you or a Resident, we use such category of information for the purposes set forth below: • To provide you with the Services; • Communicate with you, including by telephone, text, email, and chat, regarding the Services; • Send advertising or marketing communications about products, services, offers, promotions, rewards, Toor Points, and events offered by us and our partners and other third parties; • Offer and administer surveys, contests, prize draws, sweepstakes, and other promotions; • Conduct internal research and development; • Target or retarget advertisements to you on third-party platforms and websites; • Analyze your engagement with Senior Toors, community partners, Toor Guides, and care professionals, and your use of our Services to better understand your interests and behaviors and customize your experience; • Detect security incidents and protect against malicious, deceptive, or illegal activity, error, and negligence; • Debug, identify, and repair errors that impair the functionality of our Services; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with our business; • Improve our products and technology, including by training or fine-tuning the AI models that power such tools; • Comply with our legal obligations, including our tax obligations and those related to the prevention of fraud; and • With our legal, financial, insurance, and other advisors in connection with the management of all or part of Senior Toors' business or operations.

DISCLOSURE OF INFORMATION

We will disclose your information to third parties for legitimate purposes, subject to this Privacy Policy, including the following categories of third parties:

To Community Partners, Toor Guides, and Care Professionals. As your referral and connection service, we may disclose information about you as a Resident or as a person seeking Services on behalf of a Resident to community partners, Toor Guides, and care professionals to provide you with the Services. These parties may contact you directly via email, telephone, text, regular mail, or in-person visits.

To Partners. We may disclose your information to partners so they can provide services to you; however, we do not disclose this information without first confirming that you wish to receive their services. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes unless you request that we do so.

To People Acting On Your Behalf. We may disclose information to the person who referred you as a Resident or to another person acting on your behalf.

To Our Service Providers and Vendors. We may disclose information to our service providers and vendors who help us provide the Services, including system administration, cloud storage, security, customer relationship management, marketing communications, AI-powered tools, payment processing, and web analytics. We do not permit our service providers to use your personal information to train or improve their generalized AI models for their own purposes.

To Marketing Providers. We may disclose your information for marketing purposes.

To Affiliated Companies or Others Within Our Corporate Group. We may disclose your information to our parent company, subsidiaries, joint ventures, or other companies under common control with us.

For Legal and Other Compliance. We may disclose information when we believe it is appropriate for legal purposes, including to: (a) comply with the law; (b) enforce or apply this Privacy Policy or our other policies or agreements; (c) protect our or our users' rights, property, or safety; (d) protect our users from fraudulent, abusive, or unlawful use of our Sites; or (e) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury requires disclosure.

As Part of Business Transfers. We may disclose information as part of any merger, acquisition, debt financing, sale, or transfer of company assets.

As Aggregated, Anonymized Information. We may disclose aggregated, anonymous, or de-identified information to our advertisers, business partners, and other third parties.

At Your Request. We may otherwise disclose information with your consent or at your direction, such as through your use of social media widgets or login integration.

PRIVACY RIGHTS

Depending on where you live, you may have some or all of the privacy rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Access, Correction, and Deletion. You may have the right to (1) request that we confirm whether we process information about you and give you access to that information in a portable and, to the extent technically feasible, readily usable format; (2) request deletion of your information; and (3) request correction of inaccurate information.

Opting Out of Targeted Advertising. You have the right to opt out of targeted advertising. You may need to renew your opt-out choice if you use a different browser or device, or if you clear your cookies.

Opting Out of Sharing and Sales. You have the right to direct us not to sell or share your personal information.

Nondiscrimination. We will not discriminate against you for exercising your privacy rights; however, we cannot provide you with some of our Services if you do not share certain information.

How to Exercise Your Rights. You may exercise any of these rights by contacting us via email at gigi@seniortoor.com or by visiting our privacy portal. We may verify your request by asking you to provide information related to your recent interactions with us. In some cases, we may need to collect additional information to verify your identity. If we deny your request, you may appeal by contacting us at gigi@seniortoor.com. We will not require you to pay a fee for verification of your request or appeal.

Authorized Agents. You may designate an authorized agent to exercise these rights on your behalf by providing your authorized agent with written permission to act on your behalf and by verifying your own identity with Senior Toors.

SOCIAL FEATURES

Certain features of the Services (such as the Toor Community, Toor Circle, and Guest Network) allow you to initiate interactions between the Services and third-party services or platforms ("Social Features"). Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, the information you post or make accessible may be publicly displayed by the third-party service.

LINKS TO THIRD PARTIES

We may provide links to third-party websites from our Sites, but we cannot control nor are we responsible for the privacy and data collection, use, and disclosure practices of third-party websites. When you click on links that take you to external websites, you will be subject to their privacy policies and not ours.

SECURITY

We use reasonable security measures to store and protect your information while it is under our control. Please note that no transmission of data over the internet is entirely secure. We recommend that you use secure channels to send us sensitive or confidential information.

RECORDED TELEPHONE COMMUNICATIONS

Telephone communications between you and Senior Toors may be recorded or monitored for quality control purposes or as required by state law. By participating in telephone communications with us, you expressly consent to the recording of these communications.

MINORS

Our Services are designed for adults, not persons under the age of 18. We do not intend to collect personal information from persons under the age of 18. If we become aware that we have unknowingly collected information from a person under 18, we will make commercially reasonable efforts to delete such information.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section supplements this Privacy Policy for California residents and describes our data practices today and in the preceding 12 months. For purposes of this section, references to "Personal Information" shall include "Sensitive Personal Information," as these terms are defined under the California Consumer Privacy Act ("CCPA").

We collect the categories of Personal Information indicated below, from the following categories of sources: directly from you, automatically using certain technologies, and from third parties.

• Identifiers (name, email, telephone, address, IP) — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: cloud storage, marketing vendors, analytics providers, ISPs, email providers, community partners, customer service. • California Customer Records categories — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above. • Protected Classifications (ethnicity*, religion*, sex/gender*, age, disability*, veteran status) — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above. • Commercial Information (tour records, inquiries, move-in status) — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above. • Internet/Electronic Activity — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above. • Geolocation (including GPS check-in data) — Providing Services; Communication; Analytics; Protection & Compliance. Recipients: cloud storage, analytics providers, community partners, customer service. • Audio (voice recordings) — Providing Services; Communication; Protection & Compliance. Recipients: cloud storage, customer service. • Financial Information (income, budget) — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above. • Inferences — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above. • Account Credentials* — Providing Services; Communication; Protection & Compliance. Recipients: cloud storage, customer service. • Ethnic origin and religious beliefs* — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above. • Contents of mail, email, and text messages* — Providing Services; Communication; Protection & Compliance. Recipients: cloud storage, email providers, customer service. • Health information* (medical conditions, history) — Providing Services; Communication; Marketing; Analytics; Protection & Compliance. Recipients: same as above.

Personal Information We "Sell" or "Share" (as defined by the CCPA): We do not have actual knowledge that we "sell" or "share" personal information of residents under 16 years of age. We do sell and share certain categories of Personal Information, and in the preceding 12 months we have sold and shared: Identifiers (Shared — marketing vendors); Commercial information about the Services you request (Shared — marketing vendors); Internet or other electronic activity information (Shared — marketing vendors).

Sensitive Personal Information: To the extent we collect Sensitive Personal Information, we use and disclose such information only as reasonably necessary to provide the Services.

Data Retention: We store Personal Information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.

ADDITIONAL INFORMATION FOR CANADIAN CONSUMERS

You have the right to submit a complaint or to object to the collection and use of your Personal Information by Senior Toors at any time. Upon written request, you may access or request deletion of your Personal Information, or request a correction or update.

You can exercise these rights by contacting Senior Toors at: • Email: gigi@seniortoor.com • Toll Free: (678) 446-6277 • Canadian Mailing Address: Forward to US Address (1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110)

ADDITIONAL INFORMATION FOR UK-BASED WEBSITE VISITORS

This section applies to website visitors based in the UK ("UK Website Visitors"). We, Senior Toor LLC, are the controller of personal data obtained via our website.

The "CONSENT" and "RECORDED TELEPHONE COMMUNICATIONS" sections shall not apply to UK Website Visitors. Telephone communications between UK Website Visitors and Senior Toors may be recorded or monitored for quality control purposes.

Legal bases of processing. Where we process your personal information to provide services, complete transactions and referrals, perform contractual obligations, communicate with you, send marketing communications, conduct research and development, analyze engagement, detect security incidents, and comply with legal obligations, the legal basis is our legitimate interests in the proper administration of our website, services, and business.

Retaining and deleting personal information. We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it. Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws.

UK Website Visitor rights. You have the right to access, rectification, erasure, restrict processing, object to processing, data portability, complain to a supervisory authority, and withdraw consent. You may exercise these rights by written notice to gigi@seniortoor.com.

WASHINGTON AND NEVADA CONSUMER HEALTH DATA PRIVACY POLICY

Effective date: July 15, 2026. This section applies solely to Washington and Nevada "Consumers," as this term is defined pursuant to Washington's My Health My Data Act and Nevada's Consumer Health Data Privacy Law (collectively, the "Consumer Health Privacy Laws").

Categories of Consumer Health Data ("CHD") we Collect: individual health conditions, treatments, diseases, or diagnoses; social, psychological, behavioral, and/or medical interventions; health-related surgeries or procedures; use or purchase of prescribed medication; bodily functions, vital signs, symptoms, or measurements; diagnoses or diagnostic testing, treatment, or medication; reproductive or sexual health information; and data that identifies a consumer seeking health care services. We do not collect gender-affirming care information, biometric data, genetic data, or precise location information indicating acquisition of health services.

Purpose for Collection: To provide our services; for advertising and marketing to you; to improve our services.

Categories of Sources: Customers and prospective customers; customers' representatives; Site users; our service providers; social media services that allow you to interact with us.

Shared: Yes. Categories of Third Parties and Affiliates with whom we Share CHD: Our Affiliates; our service providers; third parties, including referral sources and potential future service providers to you (e.g., senior living communities and care professionals we refer you to).

As a Washington or Nevada Consumer, you have certain rights with respect to your CHD, including the rights to: request confirmation of whether we are Collecting, Selling, or Sharing your CHD, and to access such data; request deletion of any CHD that we hold about you; request to review and request changes to any CHD that we hold about you; and withdraw your Consent to our Processing, Selling, or Sharing of your CHD.

To exercise your rights pursuant to the Consumer Health Privacy Laws, please email us at gigi@seniortoor.com, or call (678) 446-6277. In your email or call, please specify the nature of your request and provide the first and last name, email address, and phone number that you think we have on file for you. If we deny your request and you would like to appeal, you may email us at gigi@seniortoor.com or call to request that we reconsider your request.

OPT OUT OF SENIOR TOORS COMMUNICATIONS

At any time, you may adjust your communication preferences. Promotional Communications: You may opt out of newsletters and promotional communications by following the unsubscribe link. Mobile Push Notifications: You can deactivate these by changing notification settings on your mobile device. If you wish to opt out of communications with community partners, Toor Guides, or care professionals, you must contact them directly.

CHANGES IN THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top and, in some cases, provide additional notice. If you do not agree to any updates, please do not continue using the Services.

QUESTIONS AND CONCERNS

If you have any questions about this Privacy Policy or our privacy practices, please contact us at gigi@seniortoor.com.