Effective Date: October 19, 2026 | Last Updated: October 19, 2026
1. INTRODUCTION AND SCOPE
This Website Privacy Policy (the “Policy”) explains how CREF3-Oxford Living Fifth Avenue LLC, CREF3-Oxford Living Lodge and Cottages LLC, CREF3-Oxford Living Sherwood LLC (“Sherwood Communities,” “Company,” “we,” “us,” or “our”) handles personal information about visitors to our website at SherwoodCommunities.com (the “Site”). We are a Washington General Business LLC at all locations. This Policy covers how we collect, use, share, and store your information.
Sherwood Communities operates three senior living communities in Sequim, Washington: The Lodge at Sherwood Village, an independent living community that also offers cottage homes and bed & breakfast stays; The Fifth Avenue, an independent living community; and Sherwood Assisted Living & Memory Care, a licensed assisted living community that also offers memory care, respite stays, and adult day services. Sherwood Communities is managed by Oxford Living US, LLC.
This Policy covers personal information we collect through the Site. That includes information you enter into forms, share through chat or chatbot features, send by email, or that is picked up automatically as you use the Site. It also covers information about you that we receive from other sources in connection with the Site.
This Policy does not cover the following. Each of these is governed by its own notice, agreement, or law:
- Any privacy or confidentiality notice we give you when you or a family member sign up for care, are admitted, or begin services with us.
- Our Website Terms of Use. These are the rules that apply when you use the Site. You can find them at SherwoodCommunities.com/terms-of-use/.
2. INFORMATION WE COLLECT
We collect personal information in several ways when you use the Site. What we collect depends on how you use the Site and which forms and features you use.
2.1 Information You Provide to Us
We collect the personal information you choose to give us through the Site. For example, when you:
- Fill out a contact form or send us a question or request for information.
- Ask for a tour or schedule a visit.
- Send us an email.
- Send us feedback.
This information can include things like your name, mailing address, email address, phone number, other ways to reach you, and what you say in your messages to us.
2.2 Care-Related Inquiries
The contact form on the Site is not designed for sending health information, and we ask that you not include it. If you choose to tell us about the care needs of yourself or a loved one in a message, by email, or by phone, we may collect information such as the person’s name, age, medical conditions or care needs, and current living situation. We also collect the name and contact information of the person contacting us. That person may be the individual, a family member, a guardian, a personal representative, a discharge planner, a referral source, a health care professional, or someone else.
2.3 Sensitive Personal Information
Depending on how you use the Site, we may collect information that state privacy laws call “sensitive personal information” or “sensitive data.” This is information that gets extra protection under the law. It may include:
- Health information, such as details about medical conditions or care needs that you choose to include in a message to us.
Where the law requires it, we will ask for your permission before we collect or use sensitive personal information. We will also give you a way to limit how we use it, if the law requires that instead.
2.4 Information Collected Automatically
When you visit or use the Site, we and the companies that help us run it may automatically collect certain information about your device, how you browse, and how you use the Site, including:
- Your IP address and the general area you are in.
- The type and version of your browser, your operating system, and the type of device you use.
- The pages you view, the links you click, and how long you spend on the Site.
- The website or search terms that brought you to the Site.
- The date and time of your visit.
We collect this information using cookies, web beacons, pixels, and similar tracking tools. For more details, see Section 6 (Cookies and Tracking Tools).
2.5 Information from Third Parties
We may also receive personal information about you from others. This includes referral sources, health care providers, discharge planners, family members, advertising and social media platforms, and analytics companies. We may combine that information with what we collect directly through the Site.
3. HOW WE USE YOUR INFORMATION
We use the personal information we collect for these reasons:
- To answer your questions, requests, and messages.
- To respond to tour requests and questions about our communities, care options, and availability.
- To tell you about our services, programs, facilities, and events.
- To run, maintain, and improve the Site and our online services.
- To look at how people find and use the Site.
- To send you marketing messages and other information you have asked for or that may interest you, where the law allows.
- To advertise our communities, including on search engines and social media sites, and to measure how well our ads work.
- To follow the law, including responding to subpoenas, court orders, and government requests.
- To protect the safety, rights, and property of our organization, our residents, our staff, and the public.
- To spot, prevent, and respond to fraud, security problems, and other harmful or unauthorized activity.
- For any other purpose we tell you about when we collect the information, or that you agree to.
4. HOW WE SHARE YOUR INFORMATION
We may share your personal information with these types of recipients:
- Service Providers. We share personal information with outside companies and contractors who do work for us. That includes website hosting, data analysis, sending emails, marketing and advertising, customer service, and IT support. These companies can only use your information to do the work we hire them to do. They also agree in writing to protect your information.
4.3 Affiliated Communities and Management Company. We may share personal information among The Lodge at Sherwood Village, The Fifth Avenue, and Sherwood Assisted Living & Memory Care, and with our management company, Oxford Living US, LLC, for the purposes covered by this Policy. For example, if you ask about one community, we may share your inquiry with another Sherwood community that may better fit your needs.
4.4 Referral Sources and Health Care Professionals. We may share personal information with referral sources, discharge planners, health care professionals, or others who help coordinate a current or future resident’s care or placement, if you or your representative started the referral or inquiry.
4.5 Legal Compliance and Safety. We may share personal information when we believe we need to in order to follow the law, a court order, subpoena, or other legal process. We may also share it to respond to government or law enforcement requests, to protect the safety, rights, or property of our organization, our residents, our staff, or others, or to investigate possible fraud, security incidents, or violations of our policies.
4.6 Business Transfers. If we go through a merger, purchase, reorganization, sale of assets, bankruptcy, or a similar deal, your personal information may transfer to the new owner as part of that deal.
4.7 With Your Consent. We may share your personal information for other reasons if you tell us to or agree to it.
5. SALE, SHARING, AND TARGETED ADVERTISING
We use Google Ads to advertise our communities and to measure how well our ads work, for example by seeing when someone who clicked one of our ads contacts us. We do not use remarketing or retargeting, which means we do not use information about your visit to the Site to show you ads on other sites and apps. Google may collect limited information about your visit through cookies and similar tools to provide this ad measurement. Some state privacy laws may call this activity a “sale” or “sharing” of personal information, or “targeted advertising,” even if no money changes hands. To opt out, see Section 7 (Your Privacy Choices and Opt-Out Rights).
6. COOKIES AND TRACKING TECHNOLOGIES
6.1 Tools We Use. The Site uses cookies and similar tracking tools to run, analyze, and improve the Site. These tools include:
- Cookies. Small data files your browser stores on your device. Some are needed for the Site to work. Others are used for analytics, advertising, or personalization. You can block cookies through your browser settings, but some parts of the Site may not work as well if you do.
- Web Beacons and Pixels. Small images or bits of code inside web pages or emails. They let us see when a page is viewed or an email is opened.
- Analytics Tools. We use Google Analytics to see how visitors use the Site.
- Advertising. We use Google Ads conversion tracking to measure how well our ads work. We do not use remarketing or retargeting. We also advertise on social media sites such as Facebook and Instagram, but we do not place Meta (Facebook) tracking pixels on the Site.
6.2 Your Cookie Choices. You can manage cookies in these ways:
- Browser Settings. Most browsers let you block or delete cookies in your settings. If you block cookies, some parts of the Site may not work as well.
- Ad Industry Opt-Outs. You can opt out of interest-based advertising through the Network Advertising Initiative at optout.networkadvertising.org, the Digital Advertising Alliance at optout.aboutads.info, or directly in your Google ad settings.
The Site uses essential cookies needed for the Site to work. We do not use non-essential cookies (including analytics and advertising cookies) without a separate consent mechanism where the law requires one. People who live in certain states may have the right to opt out of the sale or sharing of personal information or its use for targeted advertising. See Section 7, or contact us at info@sherwoodassistedliving.com.
7. YOUR PRIVACY CHOICES AND OPT-OUT RIGHTS
Depending on where you live and what we do with your data, you may have the right to opt out of certain uses of your personal information, including:
- The “sale” of your personal information, as state law defines that term.
- The “sharing” of your personal information to help other companies show you ads on other sites based on your online activity (called “cross-context behavioral advertising”).
- Targeted advertising based on how you browse or on your personal information.
- “Profiling” when it is used to make decisions that have legal or similarly important effects on you (for example, decisions about credit, housing, insurance, or employment).
To opt out, you may contact us using the information in Section 19. You can also use your browser settings and the ad industry opt-out tools described in Section 6.2, or adjust your Google ad settings.
7.1 Universal Opt-Out Signals. Some browsers and browser add-ons support Global Privacy Control (GPC) or similar signals. These signals tell websites that you want to opt out of the sale or sharing of your personal information. Where the law requires it, we will treat these signals as a valid opt-out request. We do not currently respond to other browser Do-Not-Track signals, because there is no agreed technical standard for them.
8. YOUR PRIVACY RIGHTS
Depending on where you live, state consumer privacy laws may give you certain rights about your personal information. These may include:
- Right to Know / Access. The right to see what personal information we have about you and to ask for a copy.
- Right to Delete. The right to ask us to delete personal information we collected from you. This right is subject to exceptions in applicable law, including where we need to keep the information to complete a transaction you asked for, to detect or prevent security incidents or fraud, to comply with a legal obligation, to exercise or defend legal claims, or for other internal uses that are compatible with the reasons we collected it.
- Right to Correct. The right to ask us to fix inaccurate personal information about you.
- Right to Opt Out. The right to opt out of certain uses of your personal information, such as the sale of your personal information or its use for targeted advertising. Additional opt-out rights, including opt-outs from “sharing” and from certain profiling, may apply depending on your state. See Section 7 for details.
- Right to Data Portability. The right to receive your personal information in a form you can save and reuse.
- Right to Non-Discrimination. The right not to be treated differently because you used your privacy rights.
Not all of these rights are available in every state, and each right may work a little differently. To find out which rights apply to you, contact us using the information in Section 19.
8.1 How to Use Your Rights. To send a privacy request, contact us using the information in Section 19.
8.2 Authorized Agents and Personal Representatives. You can name someone else (an “authorized agent”) to send a privacy request for you. We may ask that person to prove you gave them permission in writing. We may also ask you to prove who you are. In some states, an authorized agent can also send a request using a universal opt-out signal. If you are a personal representative, guardian, conservator, or someone else the law allows to act for a resident, patient, or someone who cannot act for themselves, you may send a privacy request on that person’s behalf. You will need to provide papers showing your legal authority.
8.3 Verifying Privacy Requests. To protect your privacy and security, we will take reasonable steps to confirm who you are before we act on a privacy request. We may ask you to give us information that matches what we have on file. If we cannot confirm who you are, we may deny your request or ask you for more information.
8.4 Appeals. If we deny your privacy request in full or in part, state law may let you appeal. To appeal, contact us using the information in Section 19 and tell us why you disagree with our decision. We will respond within the time the law allows. If we deny your appeal, we will tell you how to contact the state attorney general or other regulator, if that is required.
9. RELATIONSHIP TO HIPAA
Sherwood Assisted Living is a HIPAA covered entity. Even so, we handle all personal information, including health information, according to this Policy and the law. We do not request or solicit any medical information on the website. Please do not submit HIPAA related information via the website, if you choose to do so please reach out to the site directly. Fifth Ave and The Lodge and Cottages are not HIPPAA covered entities.
10. INFORMATION SUBMITTED BY OR ABOUT OTHER INDIVIDUALS
The Site lets family members, guardians, personal representatives, discharge planners, referral sources, health care professionals, and other people send us information about a current or future resident, patient, or client.
If you send us information about someone else through the Site, you are telling us that you have the right to share that information and to let us use it as this Policy explains. You are also responsible for making sure the information is accurate.
We will use information you send about someone else for the reasons this Policy explains, including to answer questions, handle referrals, and evaluate care needs. If the person you told us about later contacts us to use their privacy rights about that information, we will handle that request under the law.
11. EMERGENCY OR URGENT INFORMATION
This Site is not made for medical emergencies or for sending urgent medical information. If you or someone you know is having a medical emergency, call 911 right away or go to the nearest emergency room. Do not use this Site or its forms instead of getting emergency care.
If you send us information through the Site about an urgent health or safety concern, we will do our best to send it to the right people. But we do not watch the Site in real time for urgent or emergency messages, so we cannot promise a quick reply. For sensitive care questions, please call the community directly: Sherwood Assisted Living & Memory Care at 360-683-3348, The Lodge at Sherwood Village at 360-681-3100, or The Fifth Avenue at 360-683-3345.
12. DATA RETENTION
We keep personal information for as long as we reasonably need it for the reasons we collected it (as explained in this Policy), unless the law says we must keep it longer or lets us keep it longer. To decide how long to keep information, we look at things like how sensitive it is, why we collected it, what the law and regulators require, how long we could face a legal claim about it, and what we need to run our business.
When we no longer need personal information for any of these reasons, we will delete it or remove details so it can no longer identify you, following our retention practices and the law.
13. INFORMATION SECURITY
We use reasonable administrative, technical, and physical safeguards to help protect personal information from unauthorized access, sharing, changes, and destruction. These may include access controls, encryption while data is being sent, firewalls, and staff training.
No way of sending information over the internet or storing it electronically is 100% secure. We work hard to protect your personal information, but we cannot promise it is completely safe.
14. CHILDREN’S AND MINORS’ INFORMATION
The Site is not aimed at children under 13, and we do not knowingly collect personal information from children under 13. If we find out we have collected personal information from a child under 13 without a parent’s verifiable consent, we will delete it as soon as we can. If you think we have collected information from a child under 13, please contact us using the information in Section 19.
15. THIRD-PARTY WEBSITES AND SERVICES
The Site may link to websites, apps, or services we do not own or control. These may include:
- Social media sites.
- Outside review or rating sites.
- Government, regulator, or program eligibility sites.
We are not responsible for the privacy practices, content, or security of other websites or services. A link to another site is not an endorsement. We suggest you read the privacy policy and terms of use of any outside site you visit.
16. EMAIL, TELEPHONE, AND TEXT-MESSAGE COMMUNICATIONS
If you give us your email address, phone number, or mobile number through the Site, we may use it to reply to your question or request. Where the law allows, we may also use it to tell you about our services, programs, and events.
Agreeing to this Privacy Policy is not the same as agreeing to receive marketing emails, phone calls, or text messages. If we send you marketing messages, we will give you a clear way to opt out of future ones, such as an “unsubscribe” link in emails or reply instructions for texts.
17. POLICY UPDATES
We may update this Policy from time to time to keep up with changes in what we do, changes in the law, or for other business, legal, or regulatory reasons. When we make changes, we will update the “Last Updated” date at the top of this Policy. We suggest you check this Policy from time to time.
18. ACCESSIBILITY AND LANGUAGE
We want this Policy to be easy for everyone to read, including older adults and people who use assistive technology. If you have trouble accessing this Policy or need it in another format, please contact us using the information in Section 19. We will make reasonable efforts to share it in a format that works for you.
19. PRIVACY CONTACT INFORMATION
If you have questions about this Policy, want to use your privacy rights, or need to send a privacy request or complaint, please contact us:
Sherwood Communities
Attn: Privacy Contact – Greg Fortier – National Director of Operations
350 W. Hubbard, Suite 440, Chicago, IL 60654
Email: gfortier@oxford-capital.com
Phone: 289-668-4761
