Privacy Policy

Honoring a generation that sent us to the moon.

Effective Date: February 10, 2026

Section 1: Introduction and Who We Are

Sentinel Silver, LLC ("Sentinel Silver," "we," "us," or "our") is a Maryland limited liability company providing technology support services to older adults.

We operate out of the David W. Fletcher Incubator + Labs in Hagerstown, Maryland.

At Sentinel Silver, we believe that protecting your personal information is not merely a legal obligation; it is a matter of dignity and respect. The generation we serve built the institutions, industries, and values that shaped our world - safeguarding your privacy honors that legacy.

This Privacy Policy describes how we collect, use, share, and protect your personal information when you use our technology support services, visit our website at SentinelSilver.com, or interact with us in any way. It applies to all Sentinel Silver service tiers, including The Shield, The Companion, and The Life COO.

This policy does not cover third-party websites, applications, or services that you may access independently, even if we helped you set them up. Each of those services has its own privacy practices.

How to Contact Us About Privacy

Privacy questions, requests, or concerns: Hello@SentinelSilver.com or (855) 301-4220, Monday through Friday, 9:00 AM to 5:00 PM Eastern.

You may also write to:

Sentinel Silver LLC
Attn: Privacy
20140 Scholar Drive
Suite 214
Hagerstown, MD 21742.

Accessibility

This policy is available in large-print format and screen-reader-compatible HTML on our website. If you need this policy in another format, contact us, and we will accommodate your needs.

---

Section 2: Information We Collect

Information You Provide Directly

• Identity Data: Your name, mailing address, email address, phone number, and date of birth, collected during enrollment.
• Emergency Contact Data: Names, relationships, and contact information for people you designate as emergency contacts.
• Getting Acquainted Call Data: Information you voluntarily share during your introductory call, including your technology comfort level, goals, concerns, and life context. We value what you teach us as much as what we teach you.
• Service Request Data: Descriptions of technology issues, preferences, and instructions you provide during support interactions.
• Scam Incident Data: If you experience fraud or suspect fraud, provide the information, including evidence files and reporting records.

Information Collected Through Our Technology Tools

• Device Data: Device type, operating system, installed software, and system health information collected through a remote monitoring platform. We treat Device Data as personal information when we link it to your Identity Data. See Section 7 for detailed monitoring disclosures.
• Service Data: Support session logs, issue resolution records, and service history maintained in our customer relationship management system (Zoho CRM).
• Communication Data: Call logs, email records, and service notes generated through our communications platform (Twilio) and CRM.
• Device Access Data: Remote session connection logs, timestamps, duration, and actions performed during authorized support sessions (TeamViewer).

Information Collected for Billing

• Billing Data: Your subscription tier, transaction history, and payment status. Payment card details are processed and stored by our third-party payment processor, not by Sentinel Silver directly.

Information from Facility Partners (B2B2C Members Only)

If you receive Sentinel Silver services through a senior living community or similar facility, that facility may share limited information with us to coordinate your services, such as your name, unit or room number, contact information, and any accessibility needs relevant to technology support. (See Section 13 for details.)

Health-Adjacent Incidental Data

During remote support sessions, our technicians may inadvertently see information on your screen, including health-related information displayed in open applications.

We do not intentionally collect health or medical information.

See Section 7 for our policies on incidental data exposure.

---

Section 3: Information We Do Not Collect

Sentinel Silver does not collect, request, or store the following:

• Social Security numbers (consistent with data minimization principles and the Maryland Social Security Number Protection Act, Md. Code, Com. Law 14-3401 et seq.)
• Bank account numbers or credit card numbers (processed by our third-party provider)
• Medical records, diagnoses, or treatment information (intentionally)
• Insurance information
• Legal documents (wills, powers of attorney, or advance directives)
• The contents of your Bitwarden/DashLane password vault

About Password Management

Sentinel Silver uses a zero-knowledge architecture for deployed password management systems. Your device encrypts your master password and vault contents locally before transmitting the data.

Sentinel Silver cannot access, read, or recover your vault contents. We may assist you with password management setup, organization, and troubleshooting, but we cannot access your stored passwords.

---

Section 4: How We Collect Information

We collect information through four channels:

Directly From You

When you enroll in our services, participate in a Getting Acquainted Call, request support, communicate with us by phone, email, or in person, or provide feedback.

Through Our Technology Tools

Our remote monitoring platform may continuously collect device health data from enrolled devices. Our remote support tool (TeamViewer) records session metadata during active support sessions. Our communications platform (Twilio) generates call metadata. Our CRM (Zoho) records service interactions.

From Facility Partners

For members receiving services through a senior living community, the facility may provide enrollment and coordination information as described in Section 2.

From Our Website

When you visit SentinelSilver.com, we may collect standard website analytics data such as pages visited, time on site, and browser type.

(See Section 14 for our cookie and tracking practices.)

---

Section 5: How We Use Your Information

We use your information for the following purposes:

• Service Delivery: To provide, personalize, and improve your technology support experience across all service tiers.
• Device Security and Monitoring: To monitor your enrolled devices for health issues, security threats, and performance problems through Atera.
• Scam Prevention and Response: To help protect you from fraud, assist with scam documentation, and support reporting to appropriate authorities.
• Communication: To contact you about your service, respond to your requests, and provide appointment reminders.
• Billing and Account Management: To process payments, manage your subscription, and maintain accurate account records.
• Quality Assurance: To review and improve our service delivery, train our team, and develop better support processes.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and legal processes.
• Safety and Protection: To protect you, our team, and others from fraud, abuse, or threats to safety, including making good-faith reports of suspected elder exploitation to appropriate authorities (see Section 11).

We Do Not Use Your Information For

• Selling your personal information to anyone, for any reason, ever.
• Third-party advertising or marketing.
• Automated decision-making that produces legal or similarly significant effects without human review.
• Profiling you for purposes unrelated to your technology support services.
• Building marketing profiles to sell to data brokers.

---

Section 6: How We Share Your Information

We share your information only in the following circumstances:

With Your Designated Contacts

We share information with emergency contacts or family members only when you have provided written authorization specifying who may receive information, or in circumstances described in Section 11 (Cognitive Decline and Capacity Provisions).

With Technology Service Providers

We use the following service providers to deliver your services. Each processes only the data necessary for its function:

Provider

Purpose

Data Accessed

Location / Privacy Policy

Atera

Device monitoring and remote management

Device health, OS, software inventory, system alerts

Cloud-hosted (US/EU); atera.com/privacy-policy

TeamViewer

Remote desktop access for support sessions

Session logs, screen content during active sessions

Cloud-hosted; teamviewer.com/privacy

Zoho One

CRM, billing, service records

Identity, service history, billing, communications

US data centers; zoho.com/privacy.html

Twilio

Phone system, call routing, messaging

Call logs, call metadata, and recordings (if enabled)

US-hosted; twilio.com/legal/privacy

Bitwarden

Password management deployment

Account email only; vault contents are zero-knowledge encrypted

US-hosted; bitwarden.com/privacy

With Facility Partners (B2B2C Only)

If you receive services through a facility, we share limited service-coordination information as described in Section 13.

Unless you authorize it or the law compels us, we do not share details from your support sessions, Getting Acquainted Calls, or scam incidents with your facility.

With Payment Processors

Our payment processor receives your payment card information directly; Sentinel Silver does not store this data on its systems.

As Required by Law

We may disclose information when required by court order, subpoena, or other legal process; when we reasonably believe disclosure is necessary to protect the rights, property, or safety of any person; or when we make good-faith reports of suspected elder abuse, neglect, or exploitation to Adult Protective Services or law enforcement (see Section 11).

Absolute Commitments

We NEVER sell your personal information.

We NEVER share your information for third-party marketing purposes.

We NEVER provide your information to data brokers.

These commitments are unconditional and without exception.

---

Section 7: Remote Access and Device Monitoring

This section explains how our technology tools interact with your devices.

We designed these tools to keep you safe while respecting your privacy.

Understanding this section matters because these tools are central to how we serve you.

Continuous Device Monitoring (Atera)

Enrolling in Sentinel Silver and authorizing our monitoring software installs a small program on your device(s).

This program continuously monitors:

• Operating system version and update status
• Installed software and whether it is current
• System health indicators (storage space, memory usage, performance)
• Security alerts and potential threats

The program monitors your device continuously in the background whenever your device is on, even when you are not receiving support.

What monitoring does NOT see: The content of your emails, messages, documents, photos, browsing history, or passwords.

Monitoring collects system-level data about your device, not the personal content on it. Think of it like a check engine light in your car: it watches for warning signs, not where you drive.

Your Monitoring Choices

• You can request that we remove the monitoring software at any time. If you remove it, we may not be able to proactively identify and resolve issues.
• You may request a summary of monitoring data collected from your device(s) at any time.

Remote Desktop Access (TeamViewer)

When you need hands-on help, our technicians can use remote access software to view and interact with your screen.

What this means:

• A session begins only when you actively request or approve it.
• You must take an affirmative action (such as sharing a session code or clicking an approval prompt) before any technician can access your screen.
• You can see all screen activity during the session, though some background system maintenance tasks may run separately.
• You can terminate the session at any time, instantly, no questions asked, by closing the TeamViewer window or clicking the disconnect button.
• When the session ends, the technician no longer has access to your device via TeamViewer.

Incidental Data Exposure During Screen Sharing

During a remote session, our technician can see what is on your screen, including personal emails, financial information, health portal data, or other sensitive content you have open.

Our commitment: Before each session, we will remind you to close any applications or documents you do not want us to see.

Sentinel Silver trains its Personal Technology Guides to focus exclusively on the task at hand. Our Guides agree by contract not to record, copy, save, or share any sensitive information they may incidentally observe.

If a Personal Technology Guide requires a screenshot for troubleshooting, they will capture only the minimum necessary window (for example, the error message) and avoid including other open applications or tabs.

If a screenshot inadvertently includes sensitive personal content (including health-related content), we will (1) restrict access to the file, (2) promptly crop or redact it to remove the sensitive content when feasible, and (3) delete the unredacted version as soon as we no longer need it for the support issue. We log all such incidents internally.

Session Recording

Sentinel Silver may record support calls and remote sessions for quality assurance and training purposes. Because Maryland law requires the consent of all parties to a communication before recording (Md. Code, Cts. & Jud. Proc. 10-402):

• We will clearly notify you at the beginning of any recorded interaction.
• You will be asked for your explicit verbal consent before recording begins.
• If you decline recording, we will still provide your service. Declining recording will never affect your service quality.
• If a call or session includes additional participants (such as a family member or facility staff member), each participant will be notified and asked for consent.
• We retain recordings for 90 days, after which we permanently delete them unless a legal hold or active dispute requires preservation.
• You may request access to recordings of your own sessions.

Device Access Logs

We maintain logs of every remote access session and monitoring connection, including the date, time, duration, technician identity, and a general description of the work performed.

These logs are available to you upon request.

Prohibited Monitoring

Sentinel Silver does not use its monitoring tools to capture the contents of your communications, record audio or video, log keystrokes, read message or email content, or conduct covert surveillance.

We limit data collection to device health, security status, and support-related data. Tool configurations enforce these restrictions, which we verify through regular security reviews.

Separate Consent for Continuous Monitoring

Sentinel Silver enables continuous monitoring only when the member (or a legally authorized representative) provides clear, affirmative consent through a stand-alone step. This consent is separate from the general service enrollment.

We provide an easy way to pause or remove monitoring at any time by phone, email, or during a support session, and we reconfirm monitoring consent at least once per year and whenever our monitoring practices materially change.

Shared Devices

If multiple people use the same device, support sessions, device alerts, and related records may reflect activity from more than one user.

We recommend using separate device profiles or accounts where possible. Our systems may struggle to separate data by individual user on a shared device.

If you share a device, please be aware that our monitoring and support records will reflect all activity on that device.

Incidental Health-Related Information

We do not request or need medical records to provide our services.

If health-related information appears incidentally during a support session (for example, a visible medical portal, prescription notification, or health application), we treat it as sensitive and apply strict handling.

We do not record, use, analyze, or share incidentally observed health-related information for any purpose other than completing the immediate support task.

We do not use it for marketing, analytics, or training, and we do not share it with facility partners or other third parties unless required by law.

We apply strict minimization and deletion practices to any incidental capture of health-related content.

---

Section 8: Data Security

Technical Safeguards

• Encryption of data in transit (TLS/SSL) and at rest, where supported by our service providers.
• Multi-factor authentication is required for all Sentinel Silver team member accounts.
• Role-based access controls limit data access to team members who need it for their specific duties.
• Secure, authenticated connections for all remote access sessions.
• Regular security reviews of our technology tools and configurations.

Administrative Safeguards

• Background checks for all team members who access member data.
• Mandatory privacy and security training before any team member interacts with members.
• Written confidentiality agreements for all team members.
• Documented security policies and procedures.
• Regular review and update of security practices.

Vendor Security

We require our technology service providers (listed in Section 6) to maintain security practices appropriate to the data they process, and we evaluate the security practices before engagement and periodically thereafter.

Breach Notification

In the event of a security breach involving your personal information, we will:

• Promptly investigate the incident to determine whether personal information was compromised.
• Notify affected members as soon as reasonably practicable, but no later than 45 days after we discover or are notified of a breach of the security of a system involving personal information, as required by the Maryland Personal Information Protection Act (Md. Code, Com. Law 14-3504(b)(3)), unless law enforcement requests a delay.

What Our Breach Notice Will Include

When we provide breach notification, it will include: a description of what happened, the types of information involved, what we are doing to address the breach, steps you can take to protect yourself, and contact information for questions.

We will provide notice when legally required, and we may also provide voluntary notice for other high-risk exposures even when not legally required.

• Notify the Maryland Attorney General as required by law.
• Provide clear information about what happened, what information was involved, and what steps we are taking.
• Offer guidance on steps you can take to protect yourself.

No system is completely secure. While we implement and maintain reasonable safeguards, we cannot guarantee absolute security. We are committed to acting quickly and transparently if a security incident occurs.

---

Section 9: Data Retention and Deletion

We retain your information only as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, and resolve disputes.

The following schedule outlines our standard retention periods:

Data Category

Retention Period

Trigger for Deletion

Identity Data

Duration of membership + 2 years

Membership termination + retention period

Device Data (Atera)

Duration of monitoring + 1 year

Monitoring removal + retention period

Service Records

Duration of membership + 3 years

Membership termination + retention period

Communication Logs

Duration of membership + 1 year

Membership termination + retention period

Billing Data

Duration of membership + 7 years

Tax and accounting requirements

Session Recordings

90 days

Automatic deletion after period

Scam Incident Data

Duration of membership + 5 years

Extended for potential ongoing investigations

Getting Acquainted Data

Duration of membership + 1 year

Membership termination + retention period

Device Access Logs

3 years from the session date

Automatic deletion after period

Exceptions to Standard Retention

• Legal Holds: If Sentinel Silver is involved in litigation or a legal investigation, it preserves relevant data until the matter concludes.
• Mandatory Reporting Records: The law may require us to retain records related to elder abuse or exploitation reports.
• Active Disputes: We will retain data related to any unresolved complaints or disputes until they are resolved.

Your Right to Request Earlier Deletion

You may request deletion of your data before our standard retention period expires. We will honor such requests unless legal requirements, active disputes, or other legal obligations compel us to retain the data. (See Section 10 for how to exercise this right.)

Once data reaches its retention limit or we approve its deletion, we perform secure destruction to render the data unreadable and unrecoverable, in accordance with Maryland data disposal requirements (Md. Code, Com. Law 14-3502).

If a member is deceased and a scam matter, chargeback, or legal proceeding remains active, we may retain relevant records under a documented legal hold until we or the relevant authorities resolve the matter. Otherwise, we will follow our standard retention schedule and honor valid requests from the estate’s authorized representative.

---

Section 10: Your Privacy Rights

You have the following rights regarding your personal information.

While Sentinel Silver is not currently subject to the Maryland Online Data Privacy Act (MODPA, Md. Code, Com. Law 14-4701 et seq.) based on our current size, we voluntarily offer these rights because we believe you deserve control over your own information.

These voluntary commitments do not create statutory obligations under MODPA.

Your Rights

• Right to Know: You may ask us what personal information we have about you and how we use it.
• Right to Access: You may request a copy of your personal information in a readable format.
• Right to Correct: You may ask us to correct any inaccuracies in your personal information.
• Right to Delete: You may ask us to delete your personal information, subject to the exceptions in Section 9.
• Right to Data Portability: You may request your data in a commonly used, machine-readable format.
• Right to Withdraw Consent: You may withdraw consent for specific processing activities (such as recording or monitoring) at any time.

If you withdraw consent to monitoring, we can still provide support by appointment, but we will no longer receive proactive device alerts on your behalf. Withdrawing consent will never reduce the quality or availability of our support services.

• Right to Terminate Remote Access: You may end any remote access session immediately, at any time, for any reason, no questions asked.
• Right to Opt Out: You may opt out of non-essential communications at any time.

How to Exercise Your Rights

Contact us at Hello@SentinelSilver.com or (855) 301-4220.

To protect your information, we will verify your identity before processing your request.

You may also submit a written request by mail to our Hagerstown, Maryland, business address:

Sentinel Silver, LLC
20140 Scholar Drive
Suite 214
Hagerstown, MD 21742

Our Response Commitment

• We will acknowledge your request within 5 business days.
• We will fulfill your request within 30 calendar days, or we will notify you if additional time is needed and explain why.
• We will explain the specific reason if we cannot fulfill a request, such as when legal obligations prevent a deletion.
• Exercising your rights will never result in retaliation, reduced service quality, or any penalty.

---

Section 11: Cognitive Decline and Capacity Provisions

We recognize that cognitive abilities can change over time.

This section explains how we manage your privacy and account if your decision-making capacity changes. We prioritize your autonomy and dignity at every stage.

Your Advance Designations

At enrollment or any time during your membership, you may:

• Designate an Authorized Representative: Name a person (such as a family member or trusted friend) who may access your account information and make service decisions on your behalf if you become unable to do so.
• Provide a Power of Attorney: Submit a copy of a valid Maryland Power of Attorney (or equivalent from another state) that grants your agent authority over technology services and related financial matters.
• Specify Notification Preferences: Indicate whether and how you want family members or other contacts informed about your service or account changes.

How We Handle Power of Attorney Documents

When someone presents a Power of Attorney claiming authority over your account:

• We request a copy of the POA document and review it to confirm it grants relevant authority (per Md. Code, Est. & Trusts 17-203).
• We verify the agent's identity.
• We confirm no one has revoked the POA.
• We note the scope of authority granted. If the POA does not clearly cover technology services or account management, we may request clarification.
• We monitor for actions that appear to benefit the agent rather than you, consistent with fiduciary duty requirements (per Md. Code, Est. & Trusts 17-113, 17-114).

Graduated Autonomy

We believe in maintaining your maximum autonomy at every stage:

• If you can still communicate your preferences, your instructions take priority over those of any representative, unless a court has appointed a guardian.
• If you and your authorized representative disagree, we will attempt to resolve the disagreement respectfully and, if necessary, defer to the legally authorized party while documenting the situation.
• If a court-appointed guardian presents documentation, the guardian's authority supersedes a POA to the extent specified by the court.

Safety Disclosures

If our team members reasonably suspect that a member is experiencing abuse, neglect, or exploitation, we may disclose limited information to Adult Protective Services (APS) or law enforcement.

Under Maryland law (Md. Code, Fam. Law 14-302), certain categories of workers are mandatory reporters of suspected elder abuse.

Sentinel Silver is evaluating whether any service tiers, particularly comprehensive life management services, create mandatory reporting obligations. Regardless of legal classification, Sentinel Silver trains its team members to recognize and report suspected exploitation; we also reserve the right to make good-faith reports. Maryland law provides protections for good-faith reporters of suspected elder exploitation.

Our privacy commitments do not prevent us from taking action to protect your safety. We act to protect your safety to the fullest extent permitted by applicable law and emergency exceptions.

Conflicting Instructions

Requests From Family or Friends Without Authority on File

Regardless of legal classification, our team members learn to recognize and report suspected exploitation, and we reserve the right to make good-faith reports.

We will ask the caller to have the member contact us directly or provide legal authority (such as a power of attorney, a guardianship order, or a court appointment). Sentinel Silver may accept a member’s verbal authorization to share limited account information and schedule support if the member joins the call and we verify their identity.

We will document the authorization, including what was authorized, the date, and the participants. The member may withdraw that authorization at any time.

Capacity Concerns (Operational Standard)

Sentinel Silver is not a medical provider and does not determine legal capacity.

However, if we cannot reasonably confirm that a member understands a request to share account information, change services, or grant access, we may pause the request and require additional verification or legal documentation before we proceed.

If we reasonably suspect exploitation, coercion, or an imminent risk, we may take protective steps, such as placing a temporary restriction on account changes and, when appropriate, reporting to Adult Protective Services or law enforcement.

Deceased Members and Estate Requests

After we receive notice of a member’s death, we will suspend proactive monitoring and remote access for the member’s devices as soon as reasonably practicable.

We will not provide access to the deceased member’s personal information to family members or other third parties unless they provide legal authority to act for the estate (for example, letters testamentary, letters of administration, or a valid court order).

We may request a death certificate or other documentation to confirm death. Until legal authority is verified, we will not accept instructions from competing claimants.

Members may, in writing, designate a Legacy Contact to receive specified non-account information (such as scam documentation or service records) after death, subject to our verification procedures. We recommend discussing this option during your Getting Acquainted Call.

If we receive conflicting instructions about your account (for example, from you, a family member, a POA agent, and a facility), we follow this priority:

• Court-appointed guardian (highest authority)
• Your own instructions (if you retain capacity)
• Your designated POA agent (within the scope of POA authority)
• Your designated Authorized Representative (within the scope of your designation)
• Your Supported Decision-Making Supporter, if a Supported Decision-Making Agreement is in place (within the scope of the agreement)
• Facility staff (limited to service coordination matters only)

---

Section 12: Children's Privacy

We target our services toward adults, not children under thirteen (13).

We do not knowingly collect personal information from children under thirteen. If we learn that we have inadvertently collected information from a child under 13, we will promptly delete it.

If you believe a child has provided us with personal information, please contact us at Hello@SentinelSilver.com.

---

Section 13: Facility Partnership Data Provisions

Overview

Some members receive Sentinel Silver services through a senior living community, assisted living facility, or similar organization ("Facility Partner").

This section explains how data flows in those relationships.

Sentinel Silver's Role

Conservative approach (recommended): In most Facility Partner arrangements, Sentinel Silver acts as an independent service provider (data controller) with its own direct relationship with each member.

While the facility introduces us to residents, Sentinel Silver independently determines the reasons and methods for processing member data to provide technology support.

Alternative approach: In some arrangements, Sentinel Silver may act as a data processor on behalf of the facility, processing data only as directed by the facility. If this structure applies, a separate Data Processing Agreement will govern the arrangement.

Information Shared Between Sentinel Silver and Facility Partners

Facility to Sentinel Silver: Resident name, unit/room, contact information, accessibility needs relevant to technology support, and designated emergency contacts as authorized by the resident.

Sentinel Silver to Facility: Aggregate service utilization data (number of sessions, types of issues addressed) unless the member authorizes sharing of specific information. We do not share Getting Acquainted Call details, scam incident specifics, or personal support session content with facilities without member consent.

Facility Payment Does Not Control Member Privacy

When a facility arranges or pays for services, the member’s privacy rights and choices still apply in full. We do not grant facility partners the right to receive member-level information unless the member (or a legally authorized representative) provides explicit written authorization or legal requirements force our disclosure.

We will not create or provide behavioral, browsing, or application usage reports for facility monitoring. This commitment remains in effect regardless of the facility’s payment arrangement or contractual relationship with Sentinel Silver.

What Aggregate Utilization Means

Aggregate utilization reports provided to facility partners are limited to non-identifying counts and general metrics (for example, number of support visits, average response times, or overall satisfaction scores).

They do not include resident-level device inventories, installed application lists, website categories, session content, screenshots, recordings, or any data that could reveal a specific resident’s personal activities or preferences.

HIPAA Business Associate Provisions

Sentinel Silver does not provide healthcare services and does not intentionally access, create, or manage protected health information (PHI). Sentinel Silver will not access facility-managed medical portals, electronic health record systems, or telehealth platforms without a specific Business Associate Agreement in place.

However, if a Facility Partner is a HIPAA-covered entity and the scope of services expands to include managing devices containing PHI (such as electronic health record systems or telehealth equipment), Sentinel Silver will:

• Enter into a Business Associate Agreement (BAA) as required by 45 C.F.R. 164.502(e) and 164.504(e).
• Implement HIPAA-grade security controls for any PHI in its custody.
• Ensure equivalent agreements bind downstream sub-processors handling PHI.
• Maintain incidental-exposure safeguards consistent with 45 C.F.R. 164.502(a)(1)(iii).

Member Rights in Facility Arrangements

If you receive services through a Facility Partner, you retain every privacy right described in Section 10.

Your facility arrangement does not diminish your individual rights.

If facility instructions conflict with your personal privacy preferences, your preferences prevail unless overridden by legal authority (such as a court order or guardianship).

---

Section 14: Cookies and Website Tracking

This section applies to visitors of SentinelSilver.com.

Cookies We Use

• Necessary Cookies: Required for the website to function (session management, security). Cannot be disabled.
• Functional Cookies: Remember your preferences (such as language or accessibility settings).
• Analytics Cookies: Help us understand how visitors use our website so we can improve it. We use Google Analytics for this purpose.

We do not use advertising or tracking cookies.

We do not serve targeted advertisements on our website.

Do Not Track

Our website respects Do Not Track (DNT) signals from your browser. When we detect a DNT signal, we turn off analytics cookies for your session.

Managing Cookies

You can control cookies through your browser settings.

Turning off necessary cookies may prevent parts of the website from functioning properly. For assistance managing browser cookie settings, contact us, and we will walk you through it.

---

Section 15: Changes to This Privacy Policy

Material Changes

If we make changes that significantly affect how we collect, use, or share your personal information, we will:

• Provide at least 30 days' advance notice before the changes take effect.
• Notify you by email at the address on file for your account.
• Post the updated policy on our website with a prominent notice of changes.
• For Companion and Life COO members, provide notice during your next scheduled interaction.
• Allow you to review the changes and contact us with questions before they take effect.

A "material change" includes: adding new categories of data collected; sharing data with categories of third parties not previously disclosed; significant changes to data retention periods; changes to your rights; or changes to how we handle remote monitoring or access.

Preferred Notice Method

You may choose your preferred method of receiving important notices from us: email, postal mail, or telephone.

We will honor your preference.

If we do not have an email address on file, we will use postal mail or telephone when advance notice is required. For breach notifications, we will use postal mail by default if no email address is on file, to ensure you receive the notice.

Non-Material Changes

Sentinel Silver posts minor changes, such as typographical corrections or contact updates, with an updated effective date; these changes do not require advance notice.

Version History

We maintain a version history of this policy, accessible upon request. Each version includes the effective date and a summary of changes.

---

Section 16: Contact Us and Complaints

Privacy Questions and Requests

Email: Hello@SentinelSilver.com

Phone: (855) 301-4220

Official Sentinel Silver, LLC, business address:

Sentinel Silver LLC
Attn: Privacy
20140 Scholar Drive
Suite 214
Hagerstown, MD 21742

Formal Complaint Process

• Submit your complaint in writing (email or mail) describing your concern.
• We will acknowledge receipt within 5 business days.
• We will investigate and provide a written response within 30 calendar days.
• If you are unsatisfied with our response, you may escalate as described below.

External Complaint Options

You have the right to file a complaint with:

• Maryland Attorney General, Consumer Protection Division: 200 St. Paul Place, Baltimore, MD 21202; (410) 528-8662; oag.state.md.us
• Federal Trade Commission: ReportFraud.ftc.gov; 1-877-FTC-HELP (1-877-382-4357)

Filing a complaint will never affect your membership, service quality, or how we treat you. We take every concern seriously and view complaints as opportunities to improve.

---

Effective Date: February 10, 2026

Sentinel Silver, LLC
20140 Scholar Drive
Suite 214
Hagerstown, MD 21742

SentinelSilver.com