Effective Date of Current Policy: Last Updated: August 24, 2021
This Policy applies to all Sleep Reset's operating divisions, subsidiaries, affiliates, and branches and any additional subsidiary, affiliate, or branch of Sleep Reset that we may subsequently form.
3. TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It
The categories of Personal Information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with Sleep Reset and the requirements of applicable law. Some of the ways that Sleep Reset may collect Personal Information include:
- You may provide Personal Information directly to Sleep Reset through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
- We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and easily navigate our Services. Sleep Reset collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees, including:
- a. Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Sleep Reset, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
I. Account Information. If you create an Account, we'll collect certain Personal Information that can be used to identify you, such as your name, email address, postal address and phone number.
1. When you create an account, we may collect sensitive Personal Information, such as whether you are interested in meditation for help with anxiety, depression, or other medical or health issues.
2. If you create an account using your login credentials from your Facebook or Google account, we'll be able to access and collect your name, email address, profile photo and other Personal Information that the privacy settings on your Facebook or Google account permit us to access. If you create an Account through your Facebook or Google account, we may also collect your gender, age or date of birth, zip code and other information.
II. Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Sleep Reset's newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
III. Surveys. From time to time, we may contact you to participate in online, phone, or in-person surveys or interviews. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.
IV. Posting on the Site. Sleep Reset may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Sleep Reset's pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered "public" and will not be subject to the privacy protections set forth herein.
V. Registration for Sweepstakes or Contests. Occasionally, Sleep Reset may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
VI. Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as
- b. When you create an account, we may collect sensitive Personal Information, such as whether you are interested in improving sleep for help with anxiety, depression, or other medical or health issues.
- c. Information Submitted Via Services. You agree that Sleep Reset is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Sleep Reset will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
- d. Information from Other Sources. We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third party application, such as Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, "App Stores") and Social Networking Sites ("SNS") such as Facebook , we may collect information about you from that third party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Sleep Reset and to enhance our ability to provide you with information about our business, products, and Services.
3.2 How Sleep Reset Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- Fulfill our contract with you and provide you with our Services, such as:
- Manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Undertake activities to verify or maintain the quality or safety of a Service or device;
- Provide access to certain areas, functionalities, and features of Sleep Reset's Services;
- Contact you to answer requests for customer support or technical support;
- Allow you to register for events.
- Analyze and improve our Services pursuant to our legitimate interest, such as:
- Detect security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measure interest in Sleep Reset's Services and short-term, transient use, such as contextual customization of ads;
- Undertake research for technological development and demonstration;=
- Improve, upgrade or enhance our Services or device;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity and preventing fraud;
- Communicate about Individual accounts and activities on Sleep Reset's Services and systems, and, in Sleep Reset's discretion, changes to any Sleep Reset policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Debug to identify and repair errors that impair existing intended functionality;
- Process payment for products or services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities;
- Comply with our legal obligations, protecting your vital interest, or as may be required for the public good; and
- Enforce our Terms.
- Marketing Sleep Reset Products and Services. Sleep Reset may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Sleep Reset may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- - To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- To audit interactions, transactions and other compliance activities;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
- Research and Development. Sleep Reset may use Personal Information to create de-identified information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Sleep Reset may perform research (online and offline) via surveys. We may engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share de-identified Individual and aggregate data for research and analysis purposes.
- Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Sleep Reset's or our business partners' products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
- De-Identified and Aggregated Information Use. Sleep Reset may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Sleep Reset's Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, and Sleep Reset may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Sleep Reset and with Third Parties for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
- Sharing Content with Friends or Colleagues. You may provide Sleep Reset access to your contacts and provide information about your friends through our referral services, such as "Tell a Friend." Our referral services may allow you to forward or share certain content with a friend, such as an email inviting your friend to use our Services or view certain content on the Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Sleep Reset or any other Third Parties for any other purpose.
- Other Uses. Sleep Reset may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use Google Analytics, Segment and Mouseflow to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. You can opt out of Google's collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. For more information about Segment, please visit https://segment.com or contact us as provided below. To opt out of Mouseflow, please visit https://mouseflow.com/opt-out/.
- Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Cross-Device Tracking
Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
3.5 THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS, AND SOFTWARE DEVELOPMENT KITS
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Sleep Reset does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Sleep Reset's Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We use third party software development kits ("SDKs") or Application Programming Interfaces ("APIs"), as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Information to provide analytics services and content that is more relevant to you.
3.6 Third-Party Payment Processing
When you make purchases through the Services, we Process your payments through a third-party application, including App Stores and SNS. The third-party application may collect certain financial information from you to Process a payment on behalf of Sleep Reset, including your name, email address, address and other billing information.
4. Human Resources Data
Sleep Reset collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy ("Human Resources Data"). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver's license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
- * Workflow management, including assigning, managing and administering projects;
- * Human Resources administration and communication;
- * Payroll and the provision of benefits;
- * Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- * Job grading activities;
- * Performance and employee development management;
- * Organizational development and succession planning;
- * Benefits and personnel administration;
- * Absence management;
- * Helpdesk and IT support services;
- * Regulatory compliance;
- * Internal and/or external or governmental compliance investigations;
- * Internal or external audits;
- * Litigation evaluation, prosecution, and defense;
- * Diversity and inclusion initiatives;
- * Restructuring and relocation;
- * Emergency contacts and services;
- * Employee safety;
- * Compliance with statutory requirements;
- * Processing of Employee expenses and travel charges; and
- * Acquisitions, divestitures, and integrations.
5. Onward Transfer—Sleep Reset May Disclose Your Information
5.1 Information We Share
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Sleep Reset has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners. Sleep Reset may share Personal Information with our business partners, and affiliates for our and our affiliates' internal business purposes or to provide you with a product or service that you have requested. Sleep Reset may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner's name will appear, along with Sleep Reset. Sleep Reset requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Sleep Reset provided them.
- Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
- Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Sleep Reset may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Sleep Reset related websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising." We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours', ours' or others' rights, property, or safety; (iv) to enforce Sleep Reset policies or contracts; (v) to collect amounts owed to Sleep Reset; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
5.2 INTERNATIONAL Data Transfers
You agree that all Personal Information collected via or by Sleep Reset may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Sleep Reset, you explicitly consent to the storage of your Personal Information in these locations.
6. Your Privacy Choices
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Sleep Reset's Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting firstname.lastname@example.org. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
6.2 Email and Telephone Communications
6.3 Mobile devices
Sleep Reset may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Sleep Reset may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
6.4 Human Resources Data
With regard to Personal Information that Sleep Reset receives in connection with the employment relationship, Sleep Reset will use such Personal Information only for employment-related purposes as more fully described above. If Sleep Reset intends to use this Personal Information for any other purpose, Sleep Reset will notify the Individual and provide an opportunity to opt out of such uses.
6.5 "Do Not Track"
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6.6 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice.
7. Your Privacy Rights
In accordance with applicable law, you may have the right to:
- Access Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
- Request correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information or we may refer you to the controller of your Personal Information who is able to make the correction.
- Request deletion of your Personal Information, subject to certain exceptions prescribed by law.
- Request restriction of or object to Processing of your Personal Information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
- If you would like to exercise any of these rights, contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
8. Data Retention
9. Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
10. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
11. Children's Privacy
The Services are not directed to children under 16 years of age, and Sleep Reset does not knowingly collect Personally Identifiable Information from children under 16 years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 16 years old, we will promptly take steps to delete such information and terminate the child's Account.
12. Redress/Compliance and Accountability
The following capitalized terms shall have the meanings herein as set forth below.
- "Personal Information" is any information relating to an identified or identifiable natural person under applicable law ("Individual").
- "Process" or "Processing" means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction or as otherwise provided under applicable law.
15. Contact Us
Sleep Reset, Simple Habit, Inc,
2261 Market Street #4408 San Francisco CA, 94114