Privacy Policy


This Privacy Policy (the "Policy") describes the treatment of the information which is provided or collected in the Site on which this Policy is posted at comfortlabus.com. In this Privacy Policy, the terms "Company", “Site”, "we" and "us" refers to COMFORT LAB in USA. The term “your device" refers to any computer, tablet, smart phone or other device you use to access our Site or to operate our mobile applications. In addition the Policy also describes the information that is provided or collected in the course of using the mobile applications of the Company that exist in the Sites or platforms of any other company. 

Through this Policy, the Company considers important the personal information of the Site’s users as explains to them purpose and method of Company's using the personal information provided by the users and the measures the Company takes to protect that information. 

This Policy will be in effect from the 1 April 2018 and, in case of any modification to the Policy, the Company will make public notice of it through posting it on the Company Site or through individual notice by mail, fax, or e-mail.

The Site is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Site from other jurisdictions, please be advised that you are transmitting your personal information to us in the United States, and by using our Site, you consent to that transfer and use of your personal information in accordance with this Policy. You also agree to abide by the applicable laws of states of jurisdiction and U.S. federal law concerning your use of the Site and your agreements with us. Any persons accessing our Site from any jurisdiction with laws or regulations governing the use of the Internet, (including personal data collection, use and disclosure) different from those of the jurisdictions mentioned above may only use the Site in a manner lawful in their jurisdiction. If your use of the Site would be unlawful in your jurisdiction, please do not use the Site.

BY USING OR ACCESSING THE SITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED AND AGREEING TO THE PROVISIONS IN THIS PRIVACY POLICY.

1. Information to be collected and method of collection 


(1) Items of personal information to be collected 

     The Company will collect the following items of personal information:

• User-provided information 
The Company may collect and store any information directly provided by the users. 

[For Site membership services]
① Name
② E-mail address
③ ID/username
④ Home Phone number
⑤ Mobile Phone number
⑥ Home address
⑦ Zip/Postal Code
⑧ Encoded identification information (CI)
⑨ Identification information of overlapped membership (DI)
⑩ For minors, information of legal representatives, parent(s), guardian(s) (name, birth date, CI and DI of legal representatives)

 [Online payment services for any transactions on the Site]
① Name
② E-mail address
③ ID
④ Home Phone
⑤ Mobile Phone
⑥ Payment information, including account number, credit card number, billing address
⑦ Delivery information, including delivery address, name and recipient contact information
⑧ Information of purchase, sales and purchase history

[Social network services either on or connected with the Site]
① Name
② E-mail address
③ ID
④ Home Phone
⑤ Mobile Phone
⑥ Home address
⑦ Information of location of taking pictures and date of creation of files, and location of files 
⑧ Information of service use of members such as the type of contents watched or used by members, frequencies and period of member activity

• Information collected while users access the Site or services
Besides information directly provided user information, the Company may collect information during the time users access the Site or use the services provided by the Company.

[Equipment information]
① Equipment identifier
② Operation system
③ Hardware version
④ Equipment set-up

[Log information]
⑤ Log data 
⑥ Use time
⑦ User search word input
⑧ Internet protocol address
⑨ Cookie
⑩ Web beacon

[Location information]
Information of device location including specific geographical location detected through GPS, Bluetooth or Wi-Fi (limited to regions permissible under laws) 

[Other information]
① Preferences
② Advertisement environment
③ Visited pages regarding users service use

• Mobile Device Additional Terms 

[Mobile Device]
If you use a mobile device to access the Site or download any of our applications, we may collect and store device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address

[Geo-Location Information]
Excepting the case that have obtained your prior consent, we do not access or track any location-based information from your mobile device at any time while you download or use our mobile application or our services, except that it may be possible for the Company to determine the geographic location of your point of connectivity from an IP address, in which case we may collect and use the general location data.

[Push Notifications]
We may send you push notifications if you elect to receive them, notifying you when someone has sent you a message or for other service-related activities. If you wish to opt-out from receiving these notifications, you may turn them off in your device settings.

[Mobile Analytics]
We use mobile analytics software so we can better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and from where the application was downloaded. We do not link the information we store within the analytics software to any information that personally identifies you and that you may provide within the mobile application.

• Social Media
We may give you the option to link your Site account to your account on some social networking sites for the purpose of logging in, uploading information or enabling certain features on the Site. When you log in using your social network credentials, we may collect and store Personally-Identifying Information you have provided and made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list and any other information you have agreed to make public. Once linked, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By linking your account on the Site to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the linked social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you.

We may use hyperlinks on the Site which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly link to that provider’s servers. If you do not use these buttons none, of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Site, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Site. Settings regarding privacy protection can be found on the Sites of these social networks and are not within our control.

(2) Method of collection 

The Company collects the information of users in a way of the followings: 
- Webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information 
- Provided by partner companies

2. Use of collected information 

The Company gathers and uses user information for the following purposes: 
- Member management and identification 
- To detect and deter unauthorized or fraudulent use of or abuse of services on the Site 
- Execution of the contract and service fee settlement regarding the provision of the services demanded by the users 
- Improvement of existing services and development of new services 
- Notifying changes to the function of the Site, applications or matters on policy 
- To help connect you to other users you already know and, with your permission, allow other users to connect to you 
- To gather statistics on members’ service usage, to provide services and place advertisements based on statistical characteristics 
- To provide information on promotional events as well as give users the opportunity to participate 
- To comply with applicable laws or legal obligation 
- Use of information with the prior consent of the users (for example, utilization of marketing advertisement)
- Online Postings: certain Personally-Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Site. We may provide areas on the Site where you can post reviews and other information relating to your activities on the Site. Such postings are governed by our Terms of Use. In addition, such postings may appear on other Sites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

The Company agrees that it will obtain consent from the users if the Company desires to use information in any way other than those expressly stated in this Policy. 

3. Sharing collected information 

Except for the following cases, the Company will not share personal information with a third party: 

• when the Company shares information with its affiliates, partners and service providers 
When the Company's affiliates, partners and service providers carry out services such as bill payment, execution of orders, product delivery and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company

• when users consent to the sharing in advance 
- When the user consents to share personal information with the companies to receive information on the products and services of those companies
- When the user chooses to allow his or her personal information to be shared with the sites or platform of other companies, such as social networking sites
- Other cases where the user gives prior consent for sharing personal information
 
• when sharing is required by the laws 
- If required to be disclosed by applicable and relevant laws and regulations; or 
- If required to be disclosed by investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in relevant laws and regulations 

4. Cookies, Beacons and Similar Technologies 

The Company may gather collective and impersonal information through “cookies” or “web beacons.” 
Cookies are very small text files the server sends to user browsers for the purpose Site operation and will be stored in user computer hard drives. 
A web beacon is a small quantity of code that exists on the Sites and in e-mails. By using web beacons, we may know whether a user has interacted with certain parts of the site or the contents of an email. 
These functions are used for evaluating and improving services and for the Company to set up and improve user site operation.
 
The cookies used by the Site, the information those cookies collect, and the purpose of such collection are as follows: 

[Strictly necessary cookies]
This cookie indispensable for users to fully access Site functions. Unless users allow this cookie, services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information that may be used for marketing. Nor does it memorize other sites visited by the users. This cookie may
- Memorize the information entered in an order form while searching other pages during a web browsing session
- Memorize ordered services for product pages and checkout
- Check whether a user has logged onto the Site
- Check whether users are linked with correct services of the Site while the Company modifies Site operations
- Connect users with certain applications or services

[Performance cookies]
This cookie collects information on how users use the Site, such as information on which pages users visit most. This data helps the Company optimize its Site to improve User search and Site use experience. This cookie does not collect any personally identifying user information. Any and all the information collected by this cookie will be processed collectively and anonymity is guaranteed. This cookie may 
- Conduct web analysis: provide statistical data on how users use the Site
- Gauge advertisement response: check Company advertisement effects
- Trace affiliated companies: users provide anonymous feedback to the affiliated companies
- Manage error: measure an error which may occur for the purpose of improving Site experience
- Design testing: test other designs of the Site

[Functionality cookies]
This cookie is to memorize set-ups so that the Company provides services and improves user experience. Any information collected by this cookie does not personally identify the users. This cookie may
- Memorize applied set-ups such as layout, text size, basic set-up and colors
- Memorize when a user responds to a Company-conducted survey

[Targeting cookies or advertising cookies]
This cookie is linked to the services provided by a third party such as “like” and “share” buttons. The third party provides these services by recognizing that the users access and use the Site. This cookie may
- Carry out PR to the users as targets in other Sites by connecting through social networks and these networks use user visit and access information
- Provide user visit and access information to third party ad agencies so that they can suggest and serve ads which may attract the users’ interests

[Analytics]
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve you ads based on your past activity on the Site, including Google Analytics for Display Advertising. The information collected may be used to, including but not limited to, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).
 
Users have the option for cookie installation. They may either allow all cookies by selecting that option in their web browser, making each cookie checked whenever it is saved, or refuse all cookies to be saved. Rejecting the installation of cookies may result in difficulty using part of the services provided by the Company. 

5. Users' right to access and options 

The users and/or their legal representatives, as main agents of the information, may practice the following options regarding the collection, use and sharing of personal information by the Company: 

• exercise right to access to personal information; 
• make corrections or deletions to said personal information; 
• temporarily suspend the of treatment of personal information; or 
• request the withdrawal of their prior consent 

If, in order to exercise the above options, you, as a user, use the Site options for modifying or deleting member information on the Site or contact the Company by using representative telephone or sending a document or e-mail, or making a telephone call to the responsible department (or to the person in charge of management of personal information), the Company will take measures without delay. However, the Company may reject your request only to the extent that there exists either proper cause as prescribed in the relevant and applicable laws, or equivalent cause.

6. Security 

The Company considers the personal information of users very important. The Company constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification of their personal information

• Encryption of personal information 
- Transmits users' personal information by using an encrypted communication zone 
- Stores important information, such as passwords, after encrypting it 

• Countermeasures against hacking 
- Installs a system in the zone of external access for the purpose of preventing leakage or damage of users' personal information by hacking, computer virus, or any other illegal cyber activity

• Establishes and executes an internal management plan 
• Installs and operates an access control system 
• Takes measures to prevent forging or alteration of access records

7. Protection of personal information of children 

The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under thirteen years of age. We do not knowingly collect or store Personally-Identifying Information from any individual under the age of thirteen, unless permitted or required by law. Any individual who provides Personally-Identifying Information through the Site represents to us that he or she is thirteen years of age or older. If we learn that Personally-Identifying Information has been collected from a user under thirteen years of age on or in connection with the Site, then we will take the appropriate steps to delete this information. If you are the parent or legal guardian of a child under thirteen who has become a member of the Site or has otherwise transferred Personally-Identifying Information to the Site, please contact he  Company using our contact information below to terminate the child’s account and delete their information.

8. Modification of Privacy Protection Policy 

The Company has the right to modify this Policy at any time, and, in such case, the Company will make a public notice of it by posting it on its Site or through individual notice through mail, fax, or e-mail. It will obtain consent from the users for such modifications if required by relevant and applicable laws. 

9. Others 

[Third party sites and services]
The Site, products and/or services of the Company may include links to the ones of third parties. The privacy protection policies of those third party sites may be different from ours. Thus, it is recommended that users also check the policy of third party sites linked to our Company and our Site. 

[California Privacy Rights]
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits California-resident users to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for the purposes of direct marketing in the preceding calendar year. If applicable, this information would also include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information (if any) in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy department as listed below.

[Do-Not- Track Policy]
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to indicate your preference to keep your data about your online browsing activities private and to not have said data monitored and collected. Due to the fact that as of yet no complete understanding of DNT processes exists, the Site currently does not respond to DNT mechanisms and/or browser signals.

10. Contact 

The Company designates the following department and individual in charge of personal information for the purpose of protecting customers’ personal information and dealing with customer complaints:
 
• Department responsible for privacy protection and customer services: 
- Address: 55 Kempton, Irvine, CA 92620, USA
- E-mail: comfortlabcs@gmail.com

Latest update date: 1 April 2018