The Sleep Code LLC (“The Sleep Code”, “Sleep Code”, “we”, “our”, “us”) is a Delaware corporation with principal offices at 18 West 21st Street, suite 902, New York, NY 10010. The Sleep Code operates the website located at the URL www.thesleepcode.com.
Effective date: April 7, 2020
We (and our service providers) use your Location Information to provide you with customized nearby services or value-added services (including marketing) that we think you’d like. Where possible, we may also use Location Information to enhance or localize content and services that you use. If you do not wish to share your GPS location with us, you can switch off GPS functionality on your mobile device. If you otherwise wish to withdraw your consent to us using cell ID data and GPS data, email us at firstname.lastname@example.org.
Certain portions of the Website require that you register for an Account before being able to access them. On those portions of the Website that require registration, we collect information to create your account, as well as to determine specific content, products and services that will be of particular interest to you. By collecting and maintaining accurate information, we learn more about your interests and needs and are better able to provide you with such content and with offers for such products and services.
We store or transfer your credit/debit card data in order to more easily provide services to you. If such credit/debit card and other billing information is collected and/or stored, such credit/debit card and other billing information will be collected and transferred over a secure connection in accordance with applicable regulatory requirements, and is used only for processing underlying transactions.
Where you have consented (or not opted out, as applicable), we add your information to our databases to contact you through future emails, postal mailings and SMS text-messaging regarding site updates, upcoming events, new products and services and/or the status of orders placed online. We do not currently use geolocation for purposes of tracking your location when you use the Website, but we reserve the right to do so in the future in order to better target product and service offerings and other information to you.
When you sign up for an account with us, we will send you a welcome email. We will also communicate with you in response to your inquiries, to provide any services you request, to provide newsletters or other updates that you request and to manage your account. In addition, when you register an Account with us, you can consent to our contacting you by email and to receiving our email subscriptions, editorial emails and advertorial emails (see below) from us. If, at any time, you no longer want us to contact you by email and/or receive our email subscriptions, editorial emails and advertorial emails, you can opt out of these functions by changing the preferences in your Account. You can contact customer service by email, telephone or postal mail at the contact information listed below to assist you with any such changes to your Account.
We reserve the right to rent or sell the information we collect from you to third parties.
We also share your information with certain third parties in other circumstances, including when complying with legal process, preventing fraud or imminent harm and/or ensuring the security of our network and services.
We will share certain of your information with third parties for the purposes of fulfilling orders for products or services placed by you. We will share your credit/debit card data only with those directly involved in the processing of the underlying transaction, and who maintain appropriate security measures designed to safeguard such information.
We will also share certain of your information with third parties for the purposes of providing you with newsletters or other communications.
We will provide you with direct access to functionality from other third parties, including Facebook, Twitter, Instagram, YouTube, Pinterest, Spotify, advertising networks and others. The placement of social media widgets, or advertising units on the Website can permit these third parties to see information about you and your activities via cookies, web beacons and other technologies they place and/or access on your browser or device, even if you do not interact with them.
In the event that we go through a business transition, such as a merger, acquisition or sale of our assets, your personal information will likely be among the assets transferred. You will be notified of any such change in ownership or control of your personal information. We transfer your information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control.
We reserve the right to release information to law enforcement or other governmental officials as we, in our sole discretion, deem necessary to comply with applicable law.
We employ a software technology called tracking pixels (a/k/a web beacons/web bugs/clear gifs) that enables us to better manage the content on the Website by informing us what content is effective. Tracking pixels are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of visitors to a website. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are embedded invisibly on website pages and are about the size of the period at the end of a sentence. We do not tie the information gathered by tracking pixels to your personally identifiable information.
As is true of most websites, we gather information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track the movements of users around the Website and to gather demographic information about our user base as a whole.
What types of cookies and other Web Technologies do we use and how do we use them?
The types of cookies and similar technologies used by us and our partners in connection with the Website can be classified into one of five categories, namely ‘essential Website cookies’, ‘functionality cookies’, ‘analytics and performance cookies’, ‘advertising cookies’, and ‘ social media cookies’. Cookies do a lot of different tasks to ensure you enjoy your visit to our Website, for example, they are used to remember your preferences on our Website, to help you navigate between pages more efficiently, to enable you to log into your account more easily and to make sure the adverts you see on our Website are relevant to you and your interests. We have set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.
You can block these cookies and similar technologies by changing your browser setting. However, in relation to those that are essential for the operation or improve the functionality of the Website, this may impact your use of the Website.
These cookies are essential to provide you with the Website and any services available through this Website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
Functionality cookies record information about choices you’ve made and allow us to tailor the Website to you. These cookies mean that when you continue to use or come back to the Website, we can provide you with our services as you have asked for them to be provided.
We use performance/analytics cookies to analyze how the Website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Website.
We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here. You can opt out of Google Analytics without affecting how you visit our site—for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
As you use our Website, you will notice that it features advertising. We allow third party companies, including advertising companies, to place cookies on our Website.
These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet.
Cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.
We can use information from one device to help personalize your experience on another device.
On some pages of our Website, third parties that provide applications through our Website will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. [Some pages of our Website will also contain embedded content, such as video content from YouTube, and these sites will set their own cookies.]
These cookies are used when you share an article using a social media sharing button on our Website (e.g., Facebook, Twitter, or Google Plus) as the social network that has created the button will record that you have done this. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via cookies.
When you use the Website, you may have set your browser or other means used to access the Website to send “do not track” requests to us. At this time, we do not respond to such “do not track” requests, although we may choose to do so in the future.
We take reasonable precautions to protect the confidentiality and security of your personally identifiable information by using industry recognized security safeguards. Unfortunately, no method of transmission over the Internet is completely secure. Therefore, while we strive to protect your personally identifiable information within industry standards, we cannot guarantee its absolute security.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personally identifiable information. Our security procedures mean that we will occasionally request proof of identity before we disclose personal information to you. You are responsible for protecting against unauthorized access to your password and to your computer/mobile device. We ask you not to share your password with anyone.
Our employees are trained and required to safeguard your information. Our internal controls limit access to personally identifiable information based on job functionality.
The content and services provided by us or our affiliates, sponsors and advertisers, including without limitation the Website, are not intended for anyone under the age of 18 and you should not access such content or services if you are under the age of 18. No information is knowingly collected or retained from children under the age of 13, nor is any such information knowingly used for any marketing or promotional purposes whatsoever, either inside or outside the Website. No part of the Website is designed to attract anyone under the age of 13. Children are not eligible to use any services provided by us and we ask that children under the age of 13 not submit any personal information to us or visit the Website.
To opt out of third-party tracking on our Website use the following tools
You can opt out of the Ad Tech Network by clicking http://www.youronlinechoices.com/opt-out-interface.
If you would like to opt out of having interest-based information collected during your visits to our Website or other sites, both the National Advertising Initiative (the “NAI”) and the Digital Advertising Alliance (the “DAA”) offer opt out tools to assist you in managing your choices. Click http://www.networkadvertising.org/choices/ to visit the NAI opt out page and click http://www.aboutads.info/choices/ for the DAA opt out page.
You can visit http://www.networkadvertising.org/understanding-online-advertising/ to learn more about interest-based advertising and your choices regarding having this information used by third parties and your “opt out” choices. Opting out through the DAA or the NAI only means that those DAA or NAI members will no longer be able to deliver targeted content and/or ads to you, which will affect our Website as well as other unaffiliated websites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit these opt out pages, or you subsequently erase your cookies, use a different computer or change web browsers, your opt out choices could not (or could no longer) be effective.
If you want to be removed from our marketing list and do not want us to send you email, postal mail, or other messages about our products and services, you can opt out. To do so, please send an email to email@example.com, with the word “REMOVE” in the subject line.
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of such resident's personal information to third parties for such third parties direct marketing purposes. To make such a request, please email us at firstname.lastname@example.org.
The Sleep Code is based in the United States, with our servers and offices headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Website, an Account, or any services provided by us will be processed and transferred to, and be subject to the laws of, the United States. The privacy and data protection laws in the United States will be different from similar laws in your country of residence. By using the Website or an Account, or by providing us with your information, you consent to the collection, transfer, storage and processing of information to and within the United States. If our cookies or other software detects IP addresses located in a country outside the United States, we reserve the right to deny access to any and all of our services.
If you are in the EU, you have certain additional rights and protections under the law regarding the collection and processing of your personal data.
Legal Basis for Processing
If you are in the EU, we will collect and process your personal data:
We share your information with selected recipients. These categories of recipients include:
If you are a user in the EU, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You also have the right to data portability, and to restrict certain processing of your data in certain circumstances. You also have the right to complain to your data protection authority if you have any complaints about how we process your personal information.
You have the right to object to our processing of your personal data at any time, and you can withdraw your consent to marketing at any time.
To make any of these requests please email email@example.com. We will respond as soon as practicable and no later than one month after receipt of your request. We will request proof of identification to verify your identity.
We reserve the right to deny or restrict fulfillment of your request in certain cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing or your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.
In the event that you have a concern about our collection and processing of your data, please contact us first at firstname.lastname@example.org and we will do our best to fix it. You also have the right to lodge a complaint directly with your local supervisory authority.
We will retain your information as long as needed to enable you to access the Website or otherwise interact with you, and for as long as you or we can bring a legal claim.
After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.
The table below explains the categories of information that we have collected in the past 12 months, the sources of that information, the purpose for that collection and the categories of third parties with whom we share that information.
User provided information (e.g. identifiers, such as, first name and last name, email address, phone number)
Location Information (geolocation information and commercial information)
Website and Account usage information (e.g. order history, wait lists, pages viewed, and customer service inquiries)
Device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information)
Inferred Data (e.g. inferred user information, preferences or tastes)
Audio and Visual Information (the public spaces in our physical locations are protected by CCTV.)
The CCPA has defined a “sale” to include any transfer of personal information by us to another entity for anything of value. For these purposes, in the past 12 months, we have “sold” (for the purposes of the CCPA) the following categories of personal information:
As applicable under the CCPA, from January 1, 2020, if you are a California resident, you may make requests to us as set out below. We will review all requests received and determine the extent to which and how to respond. We will not discriminate against any California resident who makes such requests.
You may request from us a list of: (i) the personal information that we have collected about you; (ii) the categories of third parties to whom we have disclosed your personal information; and (iii) the categories of third parties to whom we have sold your personal information. You have the right to up to two (2) access requests each twelve (12) months.
You may request to delete your account and your personal information.
RIGHT TO OPT-OUT FROM THE SALE OF YOUR PERSONAL INFORMATION
You may request, at any time, to direct us to stop “selling” (for the purposes of the CCPA) your personal information.
You may contact us to make the requests described above by completing this form or by contacting us at our toll-free number 212-729-0233 or as otherwise indicated below in the Contact Us section. We will not use the information you provide as part of your request for any other purpose other than to fulfill your request.
To ensure the privacy and protection of individuals, we are required to verify or otherwise authenticate your request(s). To verify your request for access or deletion of your personal information, we may request that you log into your account and make a request here.
If you do not have an account with us, please submit your request by completing this form. We will use the information you submit to verify your request prior to completing your request.
You may also submit such requests through an authorized agent. To designate an authorized agent, please send us a notarized power of attorney / notarized letter authorizing said agent. Requests from agents that do not submit such proof that they have been authorized by you to act on their behalf will be denied.
If you are a user of this service and a California resident under the age of 18, you may request to have your posted content or information removed from the publicly-viewable portion of this web site by logging into your account and removing your posted content or information from the webpage where it is posted, or contacting us directly. Content or information may not be removed from our systems or databases. In certain situations, content or information cannot be removed.
As a California resident, you may contact us with any questions or to request a list of third parties to whom we may disclose your information for such third parties’ marketing purposes and the categories of Information we may disclose.
See the Contact Us section below to make such requests.
The Sleep Code LLC
Attn: Customer Service
18 West 21st Street, Suite 902
New York, NY 10010
By email: email@example.com