At ComfiLife, we appreciate our customers and value your privacy. This Privacy Policy explains the information we collect, store, and use about you. ComfiLife sells top quality products for your comfort, operates a website (the “Website”) and delivers a newsletter (the “Newsletter”) to promote ComfiLife products. By accessing and using our Website, you explicitly accept, without limitation or qualification, the collection, use, and transfer of the personal information and non-personal information (defined below) in the manner described in this Privacy Policy.  Please read this Policy carefully, as it affects your rights and liabilities under the law.  If you disagree with the way we collect and process personal and non-personal information, please do not use this Website.

1. Types of Information We Collect.

We collect the following types of information about you.

1.1.  “Personal information” is information that can be used to identify a specific person.  For us, personal information means your first name, last name and e-mail address.

1.2.  “Non-personal information” is information that cannot be used to identify a specific person. It includes usage information about the Website such as: What product do users complete warranty registration for, how much time do they spend on the site, where did they come from, and where do they go once they leave. It includes demographic information about visitors to the website, such as information on age or income or interests. It also includes information about how often users read the Newsletter.

2. How We Collect Information.

2.1.  E-mail addresses are collected when you complete a product warranty registration or subscribe to our newsletter. 

2.2.  We obtain Website and Newsletter usage information from Google Analytics, as described below.

2.3.  We obtain information about the effectiveness of advertising campaigns on the Newsletter and the Website.

3. How We Use Information

3.1.  We use your e-mail address to deliver the Newsletter, offers, and webpage content that we believe you may find relevant, unless you have opted out. We may share your personal information with law enforcement and/or government agencies (a) if required by law or to comply with a subpoena or similar legal process, or (b) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.  Otherwise, except as expressly set forth in this policy, we do not share your e-mail address or other personal information with anyone.

3.2.  We use aggregated, anonymous non-personal information to operate and improve the website.

 

4. Third Party Information Collection

 4.1.  We utilize Google Analytics to collect Website and Newsletter usage information. Google collects usage information about the Website and Newsletter. Google Analytics utilizes the data collected through its cookies and Web beacons to track and examine the use of this Website, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-available at https://tools.google.com/dlpage/gaoptout/.

 

5. Opt-Out

5.1.  You can unsubscribe from receiving our e-mails at any time. You can unsubscribe by clicking on the “Unsubscribe” link in the footer of our emails and following the instructions. You can also unsubscribe by clicking here.

 

6. Storage

6.1.  We store and retain your personal information as long as you use the Site and/or remain subscribed to the Newsletter.

7. Information for EU Residents (General Data Protection Regulation)

If you are a EU resident, the following additional terms apply to your use of this Website from May 25, 2018 onward.

7.1. For purposes of the General Data Protection Regulation (“GDPR”), we are a data controller, as such term is defined by the GDPR, and therefore we are responsible for, and control, the processing of your personal information in accordance with the requirements of GDPR.

Under the GDPR, we may only process your personal information if we have a legal basis for doing so. For our Newsletter, our legal basis for processing is consent, which consent is obtained when you subscribe to our Newsletter and voluntarily provide your personal information to us.  For any other purposes, we otherwise rely on legitimate interest as the basis for processing your personal information.

7.2   For information regarding the types of information we collect from EU residents, how we collect that information, and how we use that information, please review Sections 1, 2, and 3 of this policy.

7.3   For information regarding our data retention practices, please review Section 6 of this policy.  You may unsubscribe from the Newsletter or request that we delete your personal information by following the instructions provided immediately below.

7.4   If you are a EU resident, your personal information is processed and stored by Amazon Web Services (AWS) Cloud in the United States on our behalf in accordance with the highest degree of security of AWS.  To the extent necessary under EU privacy laws and regulations, we enter into model contractual clauses to ensure an adequate level of protection is provided for personal information transferred outside of the EU.

7.5 If you have previously given consent by subscribing to our Newsletter, you may freely withdraw such consent at any time by either clicking on the “Unsubscribe” link in the footer of our emails and following the instructions, by clicking here.

7.6  Beginning May 25, 2018, the GDPR provides you, as an EU resident, with certain legal rights with respect to the personal information that we hold and/or process regarding you.  These legal rights are set forth below. If you wish to exercise any of these legal rights, you should put your request in writing and email it to us at the email address provided in this link with “GDPR Data Subject Rights Request” as the subject line.  Please provide enough information for us to identify you and to respond to your request.

Your rights as an individual based in the EU:

    • Access to your information: You have the right to request a copy of the personal information we hold about you.
    • Correcting your information: You have the right to have any inaccurate information we hold about you to be corrected and/or updated. We want to have accurate data. Please contact us if you think the data we hold is not up to date or correct.
    • Deletion of your information: You have the right to ask us to delete personal information about you if it no longer is required for the purpose it was collected, you have withdrawn your consent, you have a valid objection to us using your personal information, or our use of your personal information is contrary to law or our other legal obligations.
    • Objecting to how we may use your information: You have the right at any time to require us to stop using your personal information.  If so, we shall stop processing your personal information unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing, then we will let you know.
  • Restricting how we may use your information: You have the right in certain circumstances to request that we restrict the processing of your personal information, for example where the personal information Is inaccurate or where you have objected to the processing (see bullet point above).

7.7  If you have any questions or complaints or wish to contact us, please email us at the email address provided in this link .   

8. Information for California Residents (California Consumer Privacy Act) 

If you are a California resident, the additional terms set forth in our CCPA Privacy Statement apply to your use of this Website from January 1, 2020 onward.

9. Miscellaneous

9.1. We do not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database.

9.2. We do not collect information about your past, present or potential future medical conditions or treatments.