Zzoma and Sleep Specialists, LLC Website Privacy Policy

Sleep Specialists, LLC (the “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 https://zzomaosa.com/ (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • Over the phone, in writing, by fax, or through the mail.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Us on any other website operated by the Company or any third party (including our affiliates and subsidiaries);
  • Any third party (including our affiliates and subsidiaries, and social media platforms), including through any application or content (including advertising) that may link to or be accessible from or through the Website;
  • Us pertaining to employees, job applicants, or independent contractors located outside of California; or
  • Us about entities or individuals with whom we only have a business-to-business (“B2B”) relationship and who are located outside of California.

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, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • That personally identifies you in particular, or that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”), such as name, email address, telephone number, and/or any other identifier by which you may be contacted online or offline, as well as username and password;
  • That describes your past, present, or future physical or mental health condition, the treatment you have received, or the health products you purchase (“Protected Health Information” or “PHI”);
  • That is about you but individually does not identify you, such as company name; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us 

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of creating an account on or registering to use our Website, or requesting further services. We may also ask you for information when you report a problem with our Website.
  • PHI, when you provide a copy of your prescription to us or purchase products from us.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information (such as IP address), or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed in the storage of your computer or device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Advertising and marketing pixels. We use advertising and marketing pixels for remarketing and conversion tracking purposes.  The specific pixels and/or tags that we may use include but are not necessarily limited to, Google Tag Manager.

Categories of Personal Information Collected in the Past 12 Months

The tables below show the categories of personal information and sensitive personal information that we have collected in the past 12 months.  Please note that while examples are listed for each category, we do not necessarily collect each of those examples in all instances.

Personal Information Category

Examples

Collected

Retention Period

Identifiers

Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, and account name.

Yes

Up to account deletion

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Name, address, telephone number, credit card number, debit card number, or any other financial information, or medical information.

Some personal information in this category may overlap with other categories.

Yes

We do not retain payment information after your payment has been processed.  Other data in this category is retained up to account deletion

Protected classification characteristics under California or federal law

Age (40 years or older), medical condition, physical or mental disability, or sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).

Yes

Up to account deletion

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

Up to account deletion

Biometric Information

Physiological, behavioral, and biological characteristics, or other physical patterns, and sleep, health, or exercise data.

Yes

Up to account deletion

Internet or other similar network activity

Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement

Yes

3 years

Inferences drawn from other personal information

A profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

Up to account deletion

In the course of providing our products, services, or our Website to you, we may collect certain sensitive personal information about you.  In the past 12 months we have collected the categories of sensitive personal information shown in the table below.

Sensitive Personal Information Category

Collected

Retention Period

Complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password)

Yes

Up to account deletion

Health information

Yes

Up to account deletion

We will not retain your personal information or sensitive personal information for longer than is reasonably necessary for fulfillment of the purpose of each disclosed collection and use.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To send you reminders, including by SMS text message (if you have opted in to receiving text messages), about the products you have purchased and about your upcoming appointments.
  • 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 though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form/registration form).

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

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

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To third parties to help you obtain the services you seek from them.
  • 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 Sleep Specialists, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Sleep Specialists, LLC about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

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 or terms of sale and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sleep Specialists, LLC, our customers, or others.

Categories of Personal Information Shared or Sold in the Past 12 Months

We may share your personal information or sensitive personal information by disclosing it to a third party for a business purpose.  In some circumstances we may “sell” your personal information as that term is defined under certain state privacy laws, including the California Consumer Privacy Act or the California Privacy Rights Act.  In the past 12 months we have disclosed or sold the categories of personal information shown in the tables below.

Personal Information Category

Categories of Third-Party Recipients

Business Purpose Disclosures

Sales

Identifiers

Subsidiaries and Affiliates, Service Providers, Data Analytics Providers

None

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Subsidiaries and Affiliates, Service Providers

None

Protected classification characteristics under California or federal law

Subsidiaries and Affiliates, Service Providers

None

Commercial information

Subsidiaries and Affiliates, Service Providers

None

Biometric Information

Subsidiaries and Affiliates, Service Providers

None

Internet or other similar network activity

Subsidiaries and Affiliates, Service Providers, Data Analytics Providers, Advertising Networks

None

Geolocation data

Subsidiaries and Affiliates, Service Providers

None

Sensory data

Subsidiaries and Affiliates, Service Providers

None

Professional or employment-related information

Subsidiaries and Affiliates, Service Providers

None

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Subsidiaries and Affiliates, Service Providers

None

Inferences drawn from other personal information

Subsidiaries and Affiliates, Service Providers

None

Sensitive Personal Information Category

Categories of Third-Party Recipients

Business Purpose Disclosures

Sales

Government identifiers (social security number, driver’s license number, state identification card number, or passport number)

Subsidiaries and Affiliates, Service Providers

None

Complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password)

Service Providers

None

Precise geolocation

Subsidiaries and Affiliates, Service Providers

None

Racial or ethnic origin

Subsidiaries and Affiliates, Service Providers

None

Religious or philosophical beliefs

Subsidiaries and Affiliates, Service Providers

None

Union membership

Subsidiaries and Affiliates, Service Providers

None

Genetic data

Subsidiaries and Affiliates, Service Providers

None

Mail, email, or text messages contents not directed to us

Subsidiaries and Affiliates, Service Providers

None

Unique identifying biometric information

Subsidiaries and Affiliates, Service Providers

None

Health, sex life, or sexual orientation information

Subsidiaries and Affiliates, Service Providers

None

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own products or services, you can opt-out by checking or unchecking the relevant box located on the form on which we collect your data (the order/registration form) or at any other time by sending us an email stating your request to privacy@zzomaosa.com. If we have sent you a promotional email, you may click the “Unsubscribe” link to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

[Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.]

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page

You may also send us an email at privacy@zzomaosa.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.]

Your State Privacy Rights

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “California Privacy Law”), as well as other state consumer privacy laws, provide their residents with additional rights regarding our use of their personal information.  These rights are described below.

The Right to Know and to Confirm, and the Right to Data Portability

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 (the “right to know” and the “right to confirm”). Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of personal information that we collected about you.
  • 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.
  • 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.
  • The specific pieces of personal information we collected about you (also called a “data portability” request).
    • If you submit a data portability request, we will provide you with a copy of your personal information in a common and portable format that you may transfer to another organization of your choosing.

The Right to Delete

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 (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with specific laws, such as the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

The Right to Correct Inaccurate Information

You have the right to correct any inaccurate personal information about you that we have in our possession (the “right to correct”).  Once we receive your request and confirm your identity, we will disclose to you the specific pieces of personal information that we have collected about you.  You will then have the opportunity to direct us to correct the pieces of information which you believe are inaccurate.

We may deny your request to correct if we believe the updated information is incorrect or is being used for any fraudulent or deceptive purpose.

The Right to Restrict Sensitive Personal Information Processing

You have the right to restrict our processing of your sensitive personal information (the “right to restrict”).  Once we receive your request and verify your identity, we will cease the processing of your sensitive personal information for the purpose of inferring characteristics about you.  Please note that we may continue to process your sensitive personal information for other purposes consistent with this Privacy Policy.

The Right to Opt Out of the Processing and Sale of Personal Information

You have the right to direct us to not process your personal information for targeted advertising and to not sell your personal information at any time (the “right to opt-out”). Once we receive your request, we will no longer use or process your personal information for the purpose of providing targeted advertising to you based on your activity and interests.  We will also no longer sell (as that term is defined by relevant and applicable state law) your personal information to third parties for targeted advertising purposes.

The Right to Opt Out of the Sharing of Personal Information for Cross-Contextual Behavioral Advertising

You have the right to opt out of the sharing of your personal information with third parties for cross-contextual behavioral advertising.  Once we receive your request, we will no longer use or process your personal information for the purpose of advertising to you based on your individual activity.

The Right to Opt Out of Profiling

You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects to you.  Once we receive your request, we will no longer use or process your personal information for making decisions that produce a legal or similarly significant effect to you.

The Right to Be Free from Discrimination

We will not discriminate against you for exercising any of your rights under applicable state privacy law.  Unless permitted by applicable law, 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 with 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.

However, we may offer you certain financial incentives permitted by applicable privacy law that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your personal information’s value and will contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Exercising Your Rights

To exercise your rights described in this Privacy Policy, you may submit a request to us by:

  • Contacting us online at https://zzomaosa.com/contact-us/
  • Emailing us at privacy@zzomaosa.com
  • Calling us at 1-877-799-9662
  • Mailing us at Sleep Specialists, LLC, Attn: Privacy Officer, 150 Monument Rd, Bala Cynwyd, PA 19004

Only you or someone legally authorized to act on your behalf may make a request related to your personal information.  You may also make a request on behalf of your child.  You may only submit a request twice within a 12-month period.

We may not require you to provide additional personal information to verify your identity for opt-out requests.  However, to process other requests, we may require you to:

  • 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:
    • Providing at least three (3) pieces of information that match the information we have about you.
    • Providing a signed declaration, under penalty of perjury, that you are the individual about whom you have submitted the request, or that you are legally authorized to submit the request on the individual’s behalf.
  • 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 that the personal information relates to you.

You do not need to create an account with us to submit a request.  We will only use the personal information provided in the request to verify the requestor’s identity or authority to make it.

You may appeal a decision concerning your privacy rights by emailing us at privacy@zzomaosa.com or by writing us at Sleep Specialists, LLC, Attn: Privacy Officer, 150 Monument Rd, Bala Cynwyd, PA 19004.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email privacy@zzomaosa.com or call 1-877-799-9662.

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

If you have an account with us, we may deliver our written response to that account. Alternatively, or if you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@zzomaosa.com or write us at: Sleep Specialists, LLC, Attn: Privacy Officer, 150 Monument Rd, Bala Cynwyd, PA 19004.

If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our Website. Please note that fulfilment of the request may not ensure complete or comprehensive removal (for example, copies may remain viewable in cached and archived pages or might have been copied and stored by other Website users). To request removal of content or information, send an email to privacy@zzomaosa.com.

Sleep Specialists, LLC as a Service Provider

Our Website also integrates with other third-party entities, including telehealth providers, to provide certain features and functions to you.  These features and functions may include, but are not necessarily limited to, appointment scheduling and payment collection/processing capabilities.

We may receive personal information about you, or you may provide personal information to us, when you use those features and functions.  In those instances, your personal information is being collected by or on behalf of a third party, and Sleep Specialists, LLC is acting only as a service provider to that third party.  If you have any questions or concerns about the third party’s use of your personal information, you must contact that third party directly.  Their privacy practices may differ from those of Sleep Specialists, LLC.  This privacy policy is not intended to supersede or govern the privacy policies and practices of any third party to whom we may provide services.

When acting as a service provider, Sleep Specialists, LLC, collects personal information under the direction of another entity and has no direct relationship with the individuals whose personal information may be processed as part of providing those services.  Any consumer privacy requests that we receive while acting as a service provider will be denied, and the consumer will be directed to submit the request directly to the third party.  We will follow the personal information processing instructions (including for correction and deletion) given to us by those third parties we serve, in accordance with applicable consumer data privacy laws.

Our Policy on “Do Not Track” Signals

You may be able to configure your device or browser to automatically communicate your preference to opt out of the sale and transfer of your personal information.  We will recognize signals communicated to us that are in a commonly used and recognized format, and we will apply your preferences to your browser or device.  If you have an account with us and are logged into your account when we receive your “do not track” signal, we will apply your preference to your account settings.

Transfer of Data

Your personal information may be transferred and maintained on computers located outside of your state, province, country, or other jurisdiction where the data protection laws may differ. If you are located outside of the United States and choose to provide information to us, note that we transfer the data, including, but not limited to, personal information, to the United States and process it there. Your use of the Website and submission of such information represents your consent to our Terms of Use, Privacy Policy, and transfer of personal information. We will take reasonable steps to ensure your personal data is treated securely and is not transferred to an organization or country unless there are reasonable security controls in place.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age without supervision by a parent or guardian. No one under age 18 may provide any personal information to or on the Website unless under the direct supervision of a parent or guardian. We do not knowingly collect personal information from children under 18 without parental or guardian supervision. If you are under 18, do not use or provide any information on this Website or [through any of its features, register on the Website, make any purchases through the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@zzomaosa.com.

California residences under 18 may have additional rights regarding the collection and sale of their personal information.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

privacy@zzomaosa.com,

Sleep Specialists, LLC, Attn: Privacy Officer, 150 Monument Rd, Bala Cynwyd, PA 19004

or via our toll-free number: 1-877-799-9662

877-799-9662