General data protection regulation (GDPR)
Your privacy is important to us. This privacy statement explains what personal data Comfort Life collects from you, through our interactions with you and through our products, and how we use that data.
References to Comfort Life products in this statement include Comfort Life services, websites, apps, software, servers and devices.
Please read the product-specific details in this privacy statement, which provide additional information about some of Comfort Life products. This statement applies to Comfort Life’s interactions with you and the Comfort Life products listed below, as well as other Comfort Life products that display this statement.
Personal Data We Collect
Comfort Life collects data to operate effectively and provide you the best experiences with our products. You provide some of this data directly, such as when you create a Comfort Life account, submit a search query, speak a voice command or contact us for support. We get some of it by recording how you interact with our products by, for example, using technologies like cookies, and receiving error reports or usage data from software running on your device. We also obtain data from third parties.
We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but have included:
- Data brokers from which we purchase demographic data to supplement the data we collect.
- Social networks when you grant permission to a Comfort Life product to access your data on one or more networks.
- Service providers that help us determine a location based on your IP address in order to customize certain products to your location.
- Partners with which we offer co-branded services or engage in joint marketing activities, and
- Publicly-available sources such as open government databases or other data in the public domain.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature.
The data we collect depends on the context of your interactions with Comfort Life, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include the following:
Name and contact data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Demographic data. We collect data about you such as your age, gender, country, and preferred language.
Payment data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
Device and Usage data. We collect data about your device and how you and your device interact with Comfort Life and our products. For example, we collect:
- Product use data. We collect data about the features you use, the items you purchase, and the web pages you visit. This data includes your voice and text search queries or commands to our chat bots. This also includes the settings you select and the software configurations you use most.
- Device, connectivity and configuration data. We collect data about your device and the network you use to connect to our products. It includes data about the operating systems and other software installed on your device, including product keys. It also includes IP address, device identifiers (such as the IMEI number for phones), regional and language settings.
- Error reports and performance data. We collect data about the performance of the products and any problems you experience with them. This data helps us to diagnose problems in the products you use, and to improve our products and provide solutions. Depending on your product and settings, error reports (sometimes called “crash dumps”) can include data such as the type or severity of the problem, details of the software or hardware related to an error, contents of files you were using when an error occurred, and data about other software on your device.
- Troubleshooting and Help Data. When you engage Comfort Life for troubleshooting and help, we collect data about you and your hardware, software, and other details related to the incident. Such data includes contact or authentication data, the content of your chats and other communications with Comfort Life, data about the condition of the machine and the application when the fault occurred and during diagnostics, and system and registry data about software installations and hardware configurations.
Interests and favorites. We collect data about your interests and favorites, such as the teams you follow in a sports app, the programming languages you prefer, the stocks you track in a finance app, or the favorite cities you add to a weather app. In addition to those you explicitly provide, your interests and favorites may also be inferred or derived from other data we collect.
Contacts and relationships. We collect data about your contacts and relationships if you use a Comfort Life product to manage contacts or to communicate or interact with other people or organizations.
Location data. For products with location-enhanced features, we collect data about your location, which can be either precise or imprecise. Precise location data can be Global Navigation Satellite System (GNSS) data (e.g., GPS), as well as data identifying nearby cell towers and Wi-Fi hotspots, we collect when you enable location-based products or features. Imprecise location data includes, for example, a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level.
Content. We collect content of your files and communications when necessary to provide you with the products you use :
- subject line and body of an email,
- text or other content of an instant message,
- audio and video recording of a video message, and
- audio recording and transcript of a voice message you receive or a text message you dictate.
We also collect information you provide to us and the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
Product-specific sections below describe data collection practices applicable to use of those products.
How We Use Personal Data
Comfort Life uses the data we collect to operate our business and provide you the products we offer, which includes using data to improve our products and personalize your experiences. We also may use the data to communicate with you, for example, informing you about your account, security updates and product information. And we use data to help show more relevant ads, whether in our own products supported by advertising, or in products offered by third parties. However, we do not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files to target ads to you.
In carrying out these purposes, we combine data we collect to give you a more seamless, consistent and personalized experience. However, to enhance privacy, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address or phone number.
Providing and improving our products. We use data to provide and improve the products we offer and perform essential business operations. This includes operating the products, maintaining and improving the performance of the products, developing new features, conducting research, and providing customer support. Examples of such uses include the following:
- Providing the Products. We use data to carry out your transactions with us and to provide our products to you. Often, those products include personalized features and recommendations that enhance your productivity and enjoyment, and automatically tailor your product experiences based on the data we have about your activities, interests and location.
- Customer support. We use data to diagnose product problems, repair customers’ devices, and provide other customer care and support services.
- Product activation. We use data—such as device and application type, location, and unique device, application, network and subscription identifiers—to activate software and devices that require activation.
- Product Improvement. We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features, search queries and clicks to improve the relevancy of the search results, usage data to determine what new features to prioritize, and audio recordings from voice input features to improve speech recognition accuracy.
- Security, Safety and Dispute Resolution. We use data to protect the security and safety of our products and our customers, to detect and prevent fraud, to confirm the validity of software licenses, to resolve disputes and enforce our agreements. We may block delivery of a communication or remove content if it violates our terms.
- Business Operations. We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.
Communications. We use data we collect to communicate with you and personalize our communications with you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending, discuss your licensing account, let you know when security updates are available, remind you about items left in your online shopping cart, update you or inquire about a service or repair request, invite you to participate in a survey, or tell you that you need to take action to keep your account active. Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from Comfort Life by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions and promotional communications, please visit the Access and Controls section of this privacy statement.
Advertising. Comfort Life does not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files to target ads to you.
We use data we collect through our interactions with you, through some of our products and on third-party web properties, to show advertising. For example :
- We may share data we collect with third parties, so that they can select and deliver some of the ads you see in our products, their products, or other sites and apps serviced by these partners.
- Advertisers may choose to place our web beacons on their sites in order to allow Comfort Life to collect information on their sites such as activities, purchases and visits; we use this data on behalf of our advertising customers to help target their ads. We also share data directly with service providers, to permit them to provide services on our behalf or to partner with us in selecting and serving ads for our advertising partners.
The ads that you see may be selected based on data we process about you, such as your interests and favorites, your location, your transactions, how you use our products, your search queries, or the content you view.
The ads that you see may also be selected based on other information learned about you over time using demographic data, location data, search queries, interests and favorites, usage data from our products and sites, as well as the sites and apps of our advertisers and partners. We refer to these ads as “interest-based advertising” in this statement. To provide interest-based advertising, we combine cookies placed on your device using information that we collect (such as IP address) when your browser interacts with our websites. If you opt out of receiving interest-based advertising, data associated with these cookies will not be used.
Further details regarding our advertising-related uses of data include:
- Children and Advertising. We do not deliver interest-based advertising to children whose birthdate in their Comfort Life account identifies them as under 13 years of age.
- Data Retention. For interest-based advertising, we retain data for no more than 13 months, unless we obtain your consent to retain the data longer.
- Data Sharing. In some cases, we share with advertisers reports about the data we have collected on their sites or ads.
- Data Collected by Other Advertising Companies. Advertisers sometimes include their own web beacons (or those of their other advertising partners) within their advertisements that we display, enabling them to set and read their own cookie. Additionally, Comfort Life partners with third-party ad companies to help provide some of our advertising services, and we also allow other third-party ad companies to display advertisements on our sites. These third parties may place cookies on your computer and collect data about your online activities across websites or online services.
Reasons We Share Personal Data
We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. We also share data with Comfort Life-controlled affiliates and subsidiaries; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights or property of Comfort Life.
In addition, we share personal data among Comfort Life-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.
Finally, we will access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to:
- comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
- protect our customers, for example to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone;
- operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks; or
- protect the rights or property of Comfort Life, including enforcing the terms governing the use of the services – however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of Comfort Life, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.
Please note that some of our products include links to products of third parties whose privacy practices differ from Comfort Life’s. If you provide personal data to any of those products, your data is governed by their privacy statements.
How to Access & Control Your Personal Data
You can view, edit, or delete your personal data online for many Comfort Life products. You can also make choices about Comfort Life’s collection and use of your data. How you can access or control your personal data will depend on which products you use.
You can always choose whether you wish to receive promotional email, SMS messages, telephone calls and postal mail from Comfort Life.
You can view, edit, or delete your personal data online for many Comfort Life products. You can also make choices about Comfort Life’s collection and use of your data. How you can access or control your personal data will depend on which products you use.
If you cannot access certain personal data collected by Comfort Life via the links above or directly through the Comfort Life products you use, you can always contact Comfort Life by using our web form. We will respond to requests to access or delete your personal data within 30 days.
Your Communications Preferences
You can choose whether you wish to receive promotional communications from Comfort Life by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt out, you can do so by following the directions in that message. You can also make choices about the receipt of promotional email, telephone calls, and postal mail by signing in with your Comfort Life account, and viewing your communication permissions where you can update contact information, manage Comfort Life-wide contact preferences, opt out of email subscriptions, and choose whether to share your contact information with Comfort Life partners. If you do not have a Comfort Life account, you can manage your Comfort Life email contact preferences by using this web form. These choices do not apply to mandatory service communications that are part of certain Comfort Life services, or to surveys or other informational communications that have their own unsubscribe method.
Your Advertising Choices
You may opt out of receiving interest-based advertising from Comfort Life. When you opt out, your selection will be stored in a cookie that is specific to the web browser you are using.
Because the data used for interest-based advertising is also used for other necessary purposes (including providing our products, analytics and fraud detection), opting out of interest-based advertising does not stop that data from being collected. Nor does it mean you will stop getting ads or see fewer ads. However, if you do opt out, the ads you receive will no longer be interest-based and may be less relevant to your interests.
You can opt out of receiving interest-based advertising from third parties we partner with by visiting their sites.
- Cookie Controls. Relevant browser-based cookie controls are described in the Cookies section of this privacy statement.
- Tracking Protection. Internet Explorer (versions 9 and up) has a feature called Tracking Protection that will block third-party content, including cookies, from any site that is listed in a Tracking Protection List you add. By limiting calls to these sites, the browser will limit the information these third-party sites can collect about you.
- Browser Controls for “Do Not Track.” Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, Comfort Life services do not currently respond to browser DNT signals. We continue to work with the online industry to define a common understanding of how to treat DNT signals.
Cookies & Similar Technologies
We also use web beacons to help deliver cookies and gather usage and performance data. Our websites may include web beacons and cookies from third-party service providers.
You have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. Your browser and other choices may impact your experiences with our products.
- Storing your Preferences and Settings. Settings that enable our products to operate correctly or that maintain your preferences over time may be stored on your device. For example, if you enter your city or postal code to get local news or weather information on a Comfort Life website, we may store that data in a cookie so that you will see the relevant local information when you return to the site. We also save preferences, such as language, browser and multimedia player settings, so those do not have to be reset each time you return to the site. If you opt out of interest-based advertising, we store your opt-out preference in a cookie on your device.
- Sign-in and Authentication. When you sign into a website using your Comfort Life account, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.
- Storing Information you Provide to a Website. When you provide information, or add products to a shopping cart when shopping on Comfort Life websites, we store the data in a cookie to remember the products and information you have added.
- Social Media. Some of our websites include social media cookies, including those that enable users who are logged in to the social media service to share content via that service.
Some of the cookies we commonly use are listed below. This list is not exhaustive, but it is intended to illustrate the main reasons we typically set cookies. If you visit one of our websites, the site may set some or all of the following cookies:
- MUID, MC1 and MSFPC – Identifies unique web browsers visiting Comfort Life sites. These cookies are used for advertising, site analytics and other operational purposes.
- ANON – Contains the ANID, a unique identifier derived from your Comfort Life account, which is used for advertising, personalization, and operational purposes. It is also used to preserve your choice to opt out of interest-based advertising from Comfort Life if you have chosen to associate the opt-out with your Comfort Life account.
- CC – Contains a country code as determined from your IP address.
- PPAuth, MSPAuth, MSNRPSAuth, KievRPSAuth – Helps to authenticate you when you sign in with your Comfort Life account.
- NAP – Contains an encrypted version of your country, postal code, age, gender, language and occupation, if known, based on your Comfort Life account profile.
- MH – Appears on co-branded sites where Comfort Life is partnering with an advertiser. This cookie identifies the advertiser, so the right ad is selected.
- MR – Used to collect information for analytics purposes.
- TOptOut – Records your decision not to receive interest-based advertising delivered by Comfort Life.
In addition to the cookies Comfort Life sets when you visit our websites, third parties may also set cookies when you visit Comfort Life sites. In some cases, that is because we have hired the third party to provide services on our behalf, such as site analytics. In other cases, it is because our web pages contain content or ads from third parties, such as videos, news content or ads delivered by other ad networks. Because your browser connects to those third parties’ web servers to retrieve that content, those third parties are able to set or read their own cookies on your device and may collect information about your online activities across websites or online services.
How to Control Cookies
Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. Instructions for blocking or deleting cookies in other browsers may be available in each browser’s privacy or help documentation.
Certain features of Comfort Life products depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.
Additional privacy controls that can impact cookies, including the Tracking Protection feature of Comfort Life browsers, are described in the Access and Control section of this privacy statement.
Our Use of Web Beacons and Analytics Services
Comfort Life web pages may contain electronic images known as web beacons (also called single-pixel gifs) that we use to help deliver cookies on our websites, count users who have visited those websites and deliver co-branded products. We also include web beacons in our promotional email messages or newsletters to determine whether you open and act on them.
In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us develop statistics on how often clicking on an advertisement on a Comfort Life website results in a purchase or other action on the advertiser’s website.
Finally, Comfort Life products often contain web beacons or similar technologies from third-party analytics providers, which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites or other products. However, we prohibit these analytics providers from using web beacons on our sites to collect or access information that directly identifies you (such as your name or email address).
Other Similar Technologies
In addition to standard cookies and web beacons, our products can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. But, like standard cookies, these technologies can also be used to store a unique identifier for your computer, which can then be used to track behavior. These technologies include Local Shared Objects (or “Flash cookies”).
Local Shared Objects or “Flash cookies.” Web sites that use Adobe Flash technologies can use Local Shared Objects or “Flash cookies” to store data on your computer. To manage or block Flash cookies, go to www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
Notice to End Users
Many Comfort Life products are intended for use by organizations and are administered to you by your organization. Your use of Comfort Life products may be subject to your organization’s policies, if any. If your organization is administering your use of the Comfort Life products, please direct your privacy inquiries to your administrator. When you use social features of such products, other users in your network may see some of your activity. To learn more about the social features and other functionality, please review documentation or help content specific to the Comfort Life product. Comfort Life is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.
If you use an email address provided by an organization you are affiliated with, such as an employer or school, to access Comfort Life online services, the owner of the domain (e.g., your employer) associated with your email address may: (i) control and administer your Comfort Life online services account and (ii) access and process your data, including the contents of your communications and files.
Comfort Life account
With a Comfort Life account, you can sign into Comfort Life products, as well as those of select Comfort Life Partners. Signing into your account enables improved personalization, provides seamless and consistent experiences across products and devices, permits you to access and use cloud data storage, allows you to make payments using payment instruments stored in your Comfort Life account, and enable other enhanced features and settings.
When you sign into your account to access a product, we create a record of that sign in. If you sign into a third-party service with your Comfort Life account, you will be asked to consent to share the account data required by that service.
Creating and using your Comfort Life account. When you create a Comfort Life account, you will be asked for certain personal data and we will assign a unique ID number to identify your account and associated information. While some products, such as those involving payment, require a real name, you can sign into and use some Comfort Life products without providing your real name. Some data you provide, such as your display name, email address and phone number, can be used to help others find and connect with you within Comfort Life products.
Signing in. When you sign into your Comfort Life account, we create a record of your sign-in, which includes the date and time, information about the product you signed into, your sign-in name, the unique number assigned to your account, a unique identifier assigned to your device, your IP address, and your operating system and browser version.
Signing into Comfort Life. Signing into your account enables improved personalization, provides seamless and consistent experiences across products and devices, permits you to access and use cloud data storage, allows you to make payments using payment instruments stored in your Comfort Life account, and enables other enhanced features and settings. When you sign into your account, you will stay signed in until you sign out.
Signing into third-party products. If you sign into a third-party product with your Comfort Life account, you will be asked to consent to share the account data required by that product. The third party will also receive the version number assigned to your account (a new version number is assigned each time you change your sign-in data); and whether your account has been deactivated. If you chose to make payments to third-party merchants using your Comfort Life account, Comfort Life will pass to the third party information stored in your Comfort Life account necessary to process your payment and fulfill your order (such as name, credit card number, billing and shipping addresses, and relevant contact information). The third party can use or share the data it receives when you sign in or make a purchase according to its own practices and policies. You should carefully review the privacy statement for each product you sign into and each merchant you purchase from to determine how it will use the data it collects.
Comfort Life accounts received from third parties. If you received your Comfort Life account from a third party, like an Internet service provider, that third party may have rights over your account, including the ability to access or delete your Comfort Life account. You should carefully review any additional terms the third party provided you to understand what it can do with your account.
Using work or school accounts. If required by your organization, you will also be asked to provide a phone number or an alternative email address for additional security verification. If you sign into Comfort Life products with a work or school account, the owner of the domain associated with your email address may control and administer your account, and access and process your data, including the contents of your communications and files. Your use of the products may be subject to your organization’s policies, if any. Comfort Life is not responsible for the privacy or security practices of these organizations, which may differ from those of Comfort Life. If your organization is administering your use of Comfort Life products, please direct your privacy inquiries to your administrator. See also, Notice to End Users.