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Privacy Policy

Last updated: April 15, 2025.

Introduction

Sleep Doctor Holdings, LLC (“Company,” “We” or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website located at SleepDoctor.com, any of our social media sites, or any other online site or application hosted or managed by us such as SleepFoundation.org, community.SleepFoundation.org, SleepApnea.org, community.SleepDoctor.com, and shop.SleepDoctor.com (collectively, the “Sites”) and through any other means, as well as our practices for collecting, using, maintaining, protecting, and disclosing that information.  For example, Sleep Apnea.org, SleepDoctor.com, and SleepFoundation.org are content sites where we are more likely to be collecting data on the pages you visit and how our site is performing, while shop.SleepDoctor.com is a commerce site where more information will be collected in order to facilitate any purchases you make and where sleep tests that will collect Personal Health Information may be obtained.

This policy applies to information we collect on the Sites and in email, text, and other electronic messages between you and the Sites as well as from offline or any other sources. It does not apply to any website operated by any third party or by any third party that may link to or be accessible from or on the Sites. The policy covers your rights with respect to your personal information and your privacy choices.  California Residents should also review the California specific notices.   We also provide policies specific to Consumer Health Information and Protected Health Information that apply only when such data is collected.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use the Sites. By accessing or using the Sites, you agree to the terms of this privacy policy. This policy may change from time to time as we update or evolve our services. Your continued use of the Sites after we post that we have updated changes is deemed to be acceptance of those changes, so please check this privacy policy periodically for updates.

1. Information We Collect

Over the last 12 months, we have collected personal information in order to provide and improve our products and services for the Sites and consistent with “How We Use Your Personal Information” below.  The following are the types of personal information we may collect:

  • Identifiers/Contact information such as name, physical or shipping address, mobile or phone number, a cookie or other online identifier, Internet Protocol address, email address, account name, resettable mobile device ID (such as the ID for Advertising on iOS and Android ID on Android) or other similar identifier.
    • Internet or other similar network activity such as interaction with our Sites, browsing history (the referring URL that brought you to us), search history (the term you used to find our content and searches within our Sites), connectivity information and version and time zone settings. 
    • Geolocation information such as Internet protocol address, GPS information or similar information from a device or when you give us an address for shipping or billing. 
    • Commercial information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies on our Sites.  
  • Demographic information when you fill out a sleep quiz and share answers to many questions about your sleep habits and patterns, or a new patient form, which may include gender, birthdate, height, weight, medication allergies, indicators of your cardiovascular, neurological, psychiatric and other health indicators when a new sleep test is purchased.  
  • Health related data  – through quizzes, surveys or when you purchase and use a Home Sleep Test or further interact with an affiliated doctor or Sleep Care Advocate Team.  We will also have the diagnosis resulting from the test and appointments you may make related to the results through the Sites. Such data that constitutes Consumer Health information under the “My Health My Data Act” in Washington or “The Consumer Health Data Privacy Act” in Nevada shall be processed in accordance with those Acts. Please see our Consumer Health Data Privacy Policy.  Any data that constitutes Protected Health Information PHI) per the federal Health Insurance Privacy and Portability Act will be handled in accordance with that law.  Please see our Protected Health Information Privacy Policy. 
  • User Content when you post, comment, review, give feedback, upload photos or videos or make available content on the Sites.  This information is available to the public.
  • Communications you provide to us such as customer service interactions, emails, records, or copies of your correspondence.  This includes communities you may join on SleepFoundation.org or SleepDoctor.com, and social media likes or sharing of our posts.  It also includes intake forms, quizzes, and surveys in which you participate.  

We collect this information:

Through information you give us 

  • When you call our telephone number to ask questions;
  • When you purchase, order, return, exchange or request information about our products and services while using the Sites;
  • When you participate in interactive features on the Sites, including such features as chat or with customer service;
  • When you sign up for our emails, mobile messages, or social media notifications or newsletters;
  • When you enter a contest or sweepstakes, respond to one of our surveys, or participate in a focus group;
  • When you provide us with comments, suggestions, or other input; 
  • When you meet with our Sleep Care Advocate team after taking a Home Sleep Test; and
  • Directly from you when you otherwise provide it to us.

Automatically 

  • When you interact with the Sites.
  • Through interactions with content served on behalf of our Sites on other websites. 

Information from other Sources

  • We may collect additional information about you to supplement information we collect (such as demographic, contact, and statistical information) from parties such as business partners, marketers, advertising networks, data providers, analysts, public databases, and other parties.

The types of personal information we collect depend on your level and method of engagement with the Sites. The higher the level, the more personal information we require to provide our services.

2. How We Use Your Personal Information

We also use information that we collect about you or that you provide to us for business or commercial purposes, including any personal information, to:

  • Provide the Sites and their services;
  • Conduct analysis of your sleep health, interests and needs in order to suggest relevant remedies, products, community support or other services;
  • Personalize the services to provide information more relevant to you and to remember your preferences;
  • For verification or authentication purposes, including to effectuate certain privacy choices;
  • Fulfill and manage requests for information, products or services;
  • Deliver newsletters, emails and mobile messages including, for example, by push notification or other mobile communications, subject to your privacy choices below;
  • Send marketing communications and other information regarding products, services and promotions, subject to your privacy choices below;
  • Improve the effectiveness of the Sites, website, stores, mobile experience and marketing efforts;
  • Conduct surveys, quizzes, research and analysis;
  • To provide security and anti-fraud techniques; and
  • For any other legal purpose with your consent.

3. Disclosure of Your Information

We may disclose personal information that we collect or you provide for business or commercial purposes as described in this privacy policy:

  • To our personnel in the normal course of business
  • To our affiliates, (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control) in which case we will require our affiliates to honor this privacy policy;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Sites’ users is among the assets transferred, in which case we will require the purchaser or successor to adhere to the privacy choices you have made;
  • To third parties for purposes of marketing our products or services that may be of interest to you, in which case we may combine the information that you give us and information about your site usage with other personally identifiable information (such as demographic information and past purchase history) available from our records and other sources and, when we disclose your information to these third parties, they are not allowed to use your information for any purpose other than supporting and promoting our Sites;
  • With certain business partners to provide requested services that we do not provide directly such as website hosting, data storage, analytics, research, payment processing, security, data enrichment, content, and contests;
  • To fulfill the legal purpose for which you provide it; and
  • With your consent for such legal purposes.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To enforce or apply our terms of use; and
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers or others.

We may also disclose aggregated information about our users, and information that does not, or is not reasonably likely to identify any individual, without restriction.

In the preceding twelve (12) months, we have not disclosed or sold personal information for purposes not enumerated above.

4. Our Use of Tracking Technology

The technologies we use for automatic data collection may include:

Cookies:  We put cookies on your computer to help us keep track of when you were last on our Sites, what you last searched on the Sites, and your interests. You can control cookies through your device or browser settings. 

Third-Party Cookies for Website Use Analysis:  We use third parties, such as Google and other 3rd party sites, to help us analyze how people are using the Sites, and those third parties are authorized to use cookies and other tracking technologies to access personal information of visitors to the Sites. We use the Google Analytics service to provide us with demographic data about our users on an anonymous basis, and that Google service uses a cookie that can be recognized by Google or its affiliates when you visit other websites.  Please visit relevant Google policies and choices with respect to this service here.

Third-Party Cookies for Advertising:  These Sites are affiliated with Freestar for the purposes of placing advertising on the Sites, and Freestar will collect and use certain data for advertising purposes. To learn more about Freestar's data usage, click here.  You may opt out of this service at any time by designating your privacy choices here.

5. Your Rights and Privacy Choices 

Rights

Depending on your jurisdiction, you have specific privacy rights with respect to your personal information or personal data. As this is occurring in an increasing number of states, we display these as general rights (although there are specific “Notices for California Residents” enumerated further below).  These general rights include the ability to request any or all of the following:

  • To confirm whether or not we are processing your personal information/data.
  • To access such personal information/data.   
  • To correct inaccurate personal information/data we hold about you under certain circumstances.
  • To delete personal information/data. 
  • To obtain a portable copy of the personal information/data of the consumer under certain circumstances.  

To exercise any of the rights above, email [email protected].  We will adhere to the relevant requirements for the applicable state law.  

Privacy Choices

  • Opt-Out of Targeted Advertising/Sharing – collecting, using and sharing personal information/data about you to deliver targeted online advertising or sharing, which is advertising across separately-owned sites and services. To opt-out, click here.
  • No Sale of personal information/data – If we engaged in this practice, we would provide you with an opt-out feature, but we do not do so. 
  • No  profiling in the furtherance of decisions that produce legal or similarly significant effects, – If we engaged in this practice, we would provide you with an opt-out feature, but we do not do so. 
  • User Controls for Marketing emails – We use your personal information to provide you with marketing emails and other information we think may be of benefit to you, such as news related to our services, surveys or promotions. If you do not want to receive alerts or marketing email from us, please email [email protected] or click the unsubscribe link at the bottom of the unwanted email.

6. Our Retention of Your Information

We will only keep your personal information for as long as it is reasonably necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).  When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. Our Protection of Your Information

We store the information we collect from you in the United States. If you are located outside the United States and choose to use our Sites, we may store and process the information you provide to us in the United States. We take appropriate administrative, physical and electronic measures designed to protect the information that we collect from or about you from unauthorized access, use or disclosure. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will attempt to protect your personal information, transmission of personal information to and from the Sites is at your own risk. You should only access the Sites within a secure environment.

8. Children

The Sites are intended for use by adults. The Sites are not designed nor intended to collect personal information from children under the age of thirteen. Further, we do not knowingly use the data of users under 18 to send Targeted Advertising.  So that we may comply with the Children’s Online Privacy Protection Act, we ask that children under the age of thirteen not provide any personal information on the Site.  If a child under the age of thirteen has provided us with personal information, we ask that a parent or guardian contact us at [email protected]. Please mark your inquiries “COPPA Information Request.”  

9. Do Not Track Features

Most web browsers and some mobile operating systems and mobile applications include a DoNotTrack (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

10. Notices for California Residents

This Section 10 applies to all users who reside in the State of California and is adopted to comply with the CCPA. This Section does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This Section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:

  • The categories of personal information we collected about you, including any sensitive personal information;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting or selling that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific pieces of personal information we collected about you (also called a data portability request);
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us an email to [email protected].

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent please email us here and provide your name and phone number as well as the authorized agents’ name and contact information (phone number or email address) and let us know what the scope of the authorized agents’ rights are to act on your behalf. If your authorized agent requests sensitive information about you then we may ask you to provide us with a sworn declaration to further verify your identity.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your full name, email address, phone number and zip code.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing 

We attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unreasonable. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Privacy Choices

California residents have the same Privacy Choices listed above, but also have the ability to restrict the use of sensitive personal information as defined by the CCPA.  Unless otherwise permitted by the CCPA or with your consent, we will not use your sensitive personal information beyond what is necessary to perform the services or provide the goods reasonably expected by our users.  

12. Updates to This Policy

We may update this privacy policy at any time and from time to time. The updated version will be indicated by an updated “Last updated” date above and the updated version will be effective 30 days after such notice is given. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

13. Contacting Us

If you have questions regarding this privacy policy or wish to obtain additional information, please send an email to our Data Protection Officer at [email protected], or send mail to Sleep Doctor, LLC, 1414 NE 42nd St Suite 400, Seattle, WA 98105.