Website Privacy Policy

Last Updated: June 2022

Your privacy is important to us. This Privacy Notice (“Notice“) describes how Consumer Sleep Solutions LLC dba SleepScore Labs (“SleepScore”, “we“, “us” or “our“) collects, uses and stores personal data about you when you visit our website www.sleepscore.com. SleepScore also operates an App available on the relevant app store, the privacy notice for our App can be found here https://www.sleepscore.com/privacy-policy/“.

For the purposes of this Privacy Notice, the controller of your personal data is Consumer Sleep Solutions LLC of 2175, Salk Avenue, Suite 200, Carlsbad CA 92007. USA. The contact details of our Data Protection Officer (“DPO“) are:  DPO@sleepscorelabs.com

  1. What Personal Data Do We Collect About You? Why and How Do We Process your Personal Data?

This section explains the categories of personal data that we may collect about you, why we process your personal data and how we process your personal data.

  • 1.1 Request for information
Why: When you visit our Website and you request information about our Services we may collect your name, address, phone number, and e-mail address and use it to communicate with you and to comply with your request;

Data We Collect: Basic contact details including your first and last name, email address.

How (Legal Basis): It is necessary to process this personal data to contact you and to provide you with the information you are requesting. The legal basis for this processing is Article 6(1)(b) of the General Data Protection Regulation (“GDPR“).

  • 1.2 Newsletters Subscription & Marketing communication
Why: When you visit our Website, we may ask for your details to contact you about our company, our services or you may subscribe to our newsletter or other marketing related information.

Data We Collect: Basic contact details including your first and last name, email address and phone number.

How (Legal Basis): where we process your data for the purpose of promoting our company or services to you, we rely on your consent to do so in accordance with Article 6(1)(a) of the GDPR. Important: you may withdraw your consent to our processing of such data at any time – please see below for more details.

  • 1.3 Testimonials & Social Media Comments
Why: If you submit comments or testimonials to us directly or via social media, we will use your data to provide information to other users to inform them about your experiences with our services.

Data We Collect: Testimonial, Videos or social media posts may contain your name, country/city and your experience with our service.

How (Legal Basis): where we process your data for promotional purposes and rely on your consent to do so in accordance with Article 6(1)(a) of the GDPR. Important: you may withdraw your consent to our processing of such data at any time – please see below for more details.

  • 1.4 Website browsing activity / Cookies
Why: We may process your website browsing activity to provide you with a more personalised experience, improve our website, maintain security of our users and address and remediate technical issues and bugs.

Data We Collect: We may collect personal data about your device and how you / your device interacts with our website

How (Legal Basis): where we process your usage data, we rely on your consent to do so in accordance with Article 6(1)(a) of the GDPR. Important: you may withdraw your consent to our processing of such data at any time – please see below for more details.

For further information also see our cookie notice https://www.sleepscore.com/cookie-policy/

  • 1.5 Recruitment / Careers

Why: You may contact us regarding open roles as advertised on our careers https://www.sleepscore.com/careers/ page. If you contact us directly, we will use the personal information you provide to us strictly in relation to the relevant job application.

Data We Collect: We may collect personal data about you including your name, contact details and job related information.

How (Legal Basis): We collect, use and process your Personal Data where: (i) this is necessary for the purposes of a legitimate interest pursued by us
(such as managing the workforce and the protection of our business); (ii) we are permitted or required to do so by applicable law; (iii) this is necessary in connection with your employment contract or (iv) you have consented to us processing your information for a specific reason.

  • 1.6 Customer Service

Why: If you contact us through this website for any customer support queries related to our SleepScore app based delivery service, we will process your information to provide our customer support service to you.

Data We Collect: we collect personal data about you, such as your email address and any other information you provide to us in your communication to us. When you contact us for customer support, any phone conversations, email correspondence with our representatives may be monitored and reviewed for training purposes.

How (Legal Basis): It is necessary to process this personal data to provide customer service and support to you. The legal basis for this processing is Article 6(1)(b) of the General Data Protection Regulation (“GDPR“).

  1. Retention of your Personal Data

We will store your personal data only for as long as necessary for the purpose(s) for which it was obtained. The criteria used to determine our retention periods include

  • (i) the length of time we have an ongoing relationship and/or provide our services;
  • (ii) whether there is a legal requirement to which we are subject; and
  • (iii) whether the retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

In case of marketing activities, we will keep your data as long as you consent to the use for the specified purpose.

For the storage period of cookies, the information can be found in the cookie notice.

Please contact us if you wish to obtain further information concerning our retention periods (see ‘Contact Us’ below).

  1. Sharing of Personal Data

We will share your personal data within our own business and customer teams for the purposes described in this Notice. We will also share your personal data with the following service providers:

  • Webhosting providers
  • Technological and analytical service providers to improve our website
  • Providers of customer support related services
  • Service providers and collaborators related to marketing and publicity, such as advertising agencies, advertising partners or social media

These service providers will only have access to the personal data necessary to perform these limited functions on our behalf and are required to protect and secure your personal data.

  1. Information transferred to 3rd party suppliers and Transfers

Access to your data is only allowed for company’s authorized employees involved in providing the website. Such employees keep strict confidentiality and prevent unauthorized third-party access to personal information.

SleepScore uses third party suppliers to provide the website and associated services to you who are outside the European Economic Area (“EEA”).

It is our policy that that such transfers to 3rd parties:

  1. do not occur without our prior written authority.
  2. an appropriate transfer agreement is put in place to protect your personal data (such as the Standard Contractual Clauses, as published by the European Commission);
  3. your data protection rights remain fully effective; and
  4. that your personal data are kept secure by way of technical, organizational and contractual measures, such as access controls, encryption (in transit and at rest), pseudonymization and staff training, to ensure that these recipients cannot identify you or process your personal data for any purposes other than those authorized by us to provide this website and associated services to you.

If you would like to find out more about any such transfers, please contact us by e-mailing DPO@sleepscorelabs.com.

  1. Your Rights in Relation to Your Personal Data

You have a number of rights in relation to your personal data – these rights are set out below. In particular, these rights include the right to withdraw your consent to our processing of your personal data (where we rely on your consent to do so). Note that in certain circumstances these rights might not be absolute.

You can exercise these rights by contacting us at support@sleepscorelabs.com.

SleepScore will respond to your request within thirty (30) days or less. In some instances, we may need to extend this response time by two further months. We will let you know if this need arises.

  • 5.1 Right to Withdraw Consent

Where you have provided your consent to allow us to process your personal data, you have the right to withdraw your consent to the processing of your personal data at any time. For example, you can withdraw your consent by updating your settings (e.g. opting out). In certain cases, we may continue to process your personal data after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities. Where you withdraw your consent, it does not affect the lawfulness of any processing we carried out in relation to your personal data before your withdrawal.

  • 5.2 Right of Access

You have the right to access and be provided with a copy of your personal data held by us. You can access much of your personal data by logging into your account.

  • 5.3 Right to Erasure

You may request that your account or any of your personal data held by us is deleted. Once deleted, your personal data, including your account data and related activities cannot be retrieved.

  • 5.4 Right to Rectification

You have the right to ask us to have any inaccurate personal data which we hold about you updated or corrected. You can also rectify your personal data by logging into your account.

  • 5.5 Right to Restriction

You have the right to ask us to restrict our processing your personal data in certain situations, including if you believe that the personal data we hold about you is inaccurate or our processing of your personal data is unlawful. If you validly exercise this right, we will store your personal data and will not carry out any other processing until the issue is resolved. You can also restrict your personal data by logging into your account.

  • 5.6 Right to Data Portability

You can request us to provide you with your personal data which you have provided to us in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another controller where this is technically feasible.

  • 5.7 Rights in Respect of Automated Decision Making (including Profiling)

You have the right to not be subject to solely automated decision-making, including profiling, which has legal effects or other similarly significant effects on you. To exercise this right, you can: (a) request that a person reviews any such decision; (b) express your point of view; and/or (c) contest the decision.

  • 5.8 Right to Lodge a Complaint with Data Protection Authority

If you wish to raise a concern about our processing of your personal data (and without prejudice to any other rights you may have), you have the right to do so by lodging a complaint with either the Data Protection Commission in Ireland (please see www.dataprotection.ie for further information) or your local data protection authority

  1. Collection of Personal Data from Children

SleepScore does not provide services to children, nor do we market to children. If you are under the age of 16, please do not submit any personal information through our website. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Privacy Notice by instructing their children never to provide personal information via our website without their guardian’s consent.

  1. Changes to the Notice

This Notice is subject to change from time to time. We encourage you to review this Notice occasionally.

We will identify changes, including material changes, to the Privacy Notice by updating the “Last Updated” date. Your use of the website after any update to this Privacy Notice will constitute your acceptance of the changes.

  1. How to Contact Us

If you have any technical or support questions, please contact us via email at support@sleepscorelabs.com.

If you have any privacy concerns, complaints or inquiries for the DPO of SleepScore, please contact us via email at DPO@sleepscorelabs.com.

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