California Privacy Policy Notice

Last updated: April 23, 2020

ComfortSoul (“ComfortSoul,” “we,” or “us”) understands the importance of your privacy and takes our responsibility to protect your information seriously. To that end, this privacy notice (the “Notice”) provides information regarding the categories of information we collect from California residents, how we use and share that information, and certain rights and obligations relating to that information, as required by the California Consumer Privacy Act of 2018 (the “CCPA”). This Notice applies to the personal information we collect from California residents that use our websites https://www.comfortsoul.com/, including applicants for job openings with ComfortSoul.

Please note that this Notice is a supplement to our Privacy Policy, which can be viewed here. We encourage you to review our Privacy Policy.

Personal Information We Collect and How We Collect It

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device. Personal Information does not include HIPAA-protected health information that ComfortSoul may receive as a business associate, as that information is excluded from the requirements of the CCPA. It does not include publicly available information from government records or information that has been de-identified or aggregated.

In the past 12 months, we have collected the following categories of personal information from California residents through our websites and from job applicants.

Category	Examples	Do We Collect?
Legally protected classification characteristics	Race, color, national origin, citizenship, religion, marital status, sex, sexual orientation, age (40 years or older), gender, military status, genetic information, medical condition, pregnancy, physical or mental disability	Yes
Personal information categories in California’s Consumer Records statute	Name, physical characteristics, address, telephone number, state identification number, education, employment, employment history, bank account numbers, credit or debit card numbers, medical information, health insurance information, signature	Yes
Identifiers	Name, alias, postal address, unique personal identifiers, IP address, other online identifier, email address, driver’s license or government identification number	Yes
Internet or similar network activity	Information relating to your interaction with our website or applications, browsing history, search history	Yes
Commercial information	Purchasing or consuming histories, records of personal property, products and services purchased	Yes
Geolocation information	Information regarding physical location, movement, and movement patterns	Yes
Biometric information	Physiological, biological, or behavioral characteristics, such as DNA sequence, finger prints, iris or retina scans, voice recordings, keystroke rhythm or gait, face or palm patterns, vein patterns, and sleep, health, or exercise data that contain identifying information	No
Sensory information	Audio, electronic, visual, thermal, or similar information	No
Professional or employment-related information	Prior employment history, performance information, resume or similar information	Yes
Non-public education information	Education records directly related to a student that are maintained by an educational institution pursuant to the Family Educational Rights and Privacy Act, such as grades, disciplinary records, student schedules, and financial aid information	No
Inferences from other personal information	Inferences drawn from the categories listed above to create a profile about an individual that reflects the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes	Yes

We collect this information directly from you when you choose to provide it to us by applying for a job, filling out forms on our website, registering to receive emails or information from us, creating an online account, communicating with us using chat features, and surveys. We also collect certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly when you visit, use, and navigate across our website. We do so by using cookies and passive tracking technologies, as described in our Privacy Policy.

How We Use Your Personal Information

We use the personal information that you provide us, or that we collect about you, for the following business and commercial purposes:

To present our website and its contents to you.
To consider you for current or future employment opportunities and to process your employment application.
To provide you with information, products or services that you request from us or that we are contracted to provide to you.
To fulfill any other purpose for which you provide it, such as subscribing you to an e-mail newsletter.
To provide you with notices about your account and status.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our website or any products or services we offer or provide through it.
To allow you to participate in interactive features on our website, if any.
To contact you regarding any of our services you have accessed, whether through our website or otherwise.
To comply with applicable laws, regulations, and legal process.
In any other way we may describe when you provide the information.
To keep a record of our transactions and communications.
As otherwise necessary or useful for us to conduct our business, provided the use is permitted by law. For example, analyzing audience and use patterns from the websites; storing information about your preferences and allowing us to direct or customize specific content to you; recognizing you when you return to our websites.
For the protection of our operations or those of any of our affiliates, or to protect our rights, privacy, safety or property, or that of our affiliates, you, or other parties.
For any other purposes with your consent.

Disclosure and Sale of Personal Information

ComfortSoul only shares your personal information as set forth in this Notice or our Privacy Policy. Third parties with whom we may share your information include:

Service providers, but only as necessary for us to conduct business and provide the agreed-upon services to you or related services.
Governmental agencies, as may be required by law.

During the past 12 months, ComfortSoul has disclosed the following categories of personal information for a business purpose:

Category of Personal Information	Category of Third Party / Business Purpose of Disclosure
Identifiers, Geolocation Information	With service providers that assist us with event management, marketing, communications with users / potential users of the services and those who inquire about our business, the security of our website and IT systems, customer relationship management, service and product support, contract fulfilment, and other functions necessary for our business.
Internet Activity	With service providers that assist us with the security of our website and IT systems, marketing, and communications with users.
Commercial Information	With service providers that assist us with communications with users / potential users of our services and those who inquire about our business, contract fulfilment, and service and product support.

ComfortSoul has not sold any categories of personal information to third parties in the past 12 months.

Please note that we may also use, disclose, or transfer your information in connection with the sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets. We may also disclose your personal information in response to a court order, subpoena, search warrant, law, or regulation.

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

Right to Request Access Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past 12 months. Specifically, you may request that we disclose:

The categories of personal information we collected about you;
The categories of sources for the personal information we collected about you;
The business and commercial purposes for collecting your personal information;
The categories of third parties with whom we shared your personal information;
The specific pieces of personal information we collected about you; and
If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.

Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible.

Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by calling us at 877-266-7685,submitting a request online, or sending us a letter at 1300 John Reed Ct, Ste D, City of Industry, CA 91745. Your request must allow us to reasonably verify that you are the individual regarding whom we collected the personal information and must describe the request with enough detail that we can understand and respond to it. You may only submit requests for access or data portability twice within any 12-month period. As indicated above, please be aware that the CCPA provides certain limitations and exception to the foregoing rights, which may result in us denying or limiting our response to your request.

The CCPA requires us to respond to a verifiable consumer request within 45 days, but permits us to extend that period by an additional 45 days, provided we notify you of the reason for the extension in writing. We will notify you that we have received your request within 10 days of its receipt. In general, we will not charge a fee to respond to a verifiable request, unless it is excessive, repetitive, or unfounded.

Our Commitment Not to Discriminate

If a California resident exercises the rights discussed above, consistent with the CCPA, we will not discriminate against that resident by denying goods or services, charging different prices or rates for goods or services, providing different levels or quality of goods or services, or suggesting that the resident will receive a different price, rate, or quality of goods or services.

Changes to this Notice

Please note that we may change this Notice from time to time. We will post change here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this Notice periodically for updates.

Our Contact Information

To contact us regarding this Notice, your rights under the CCPA, or to exercise those rights, please contact us using the information below.

ComfortSoul

Attn: California Privacy Notice

1300 John Reed Ct, Ste D

City of Industry, CA 91745

Phone: 877-266-7685

Email: sales@comfortsoul.com

Website: https://www.comfortsoul.com/pages/contact-us

California Privacy Policy Notice

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