Comfort Connect-Enabled Device Privacy Notice

by Adjustable Bed, a division of Leggett & Platt, Incorporated

Last Updated: March 31, 2020

Product Number 296-0016 EDR15671

When you use an adjustable base capable of being used in conjunction with the Comfort Connect Application (“Comfort Connect-Enabled Device”), we want you to understand what data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe. Accordingly, this Privacy Notice (“Notice”) describes the privacy practices of our devices, applications, software, websites, application programming interfaces (APIs), products, and services related to the Comfort Connect-Enabled Device (collectively, the “Services”). By downloading, registering with, or using the Services, you confirm that you have read, understand, and agree to these terms.

What Information Do We Collect?

When you use our Services, we collect information as part of our business operations and customer interactions.

You provide some of this data directly, such as when you download the Comfort Connect Application or contact us. When you download the Comfort Connect Application and create an account with us to link or use your Comfort Connect-Enabled Device with the Services, you will be asked for your name, email address, and password. This is the only information you must provide to create an account, but you may also wish to create third-party accounts in order to fully enable and use all the functionality of a Comfort Connect-Enabled Device. For example, you may wish to set up an account with Amazon’s Alexa to enable voice control. Such third parties will have their own collection practices and terms that will apply to your data. In addition, we may also receive data directly from you if you contact our Customer or Warranty Services Departments. When you contact us to register your adjustable base or to receive customer or warranty support, you may be asked to provide information such as your serial number, name, street address, phone number, and e-mail address, as well as your point of purchase information, and a description of the subject matter of your call. You may also desire to purchase accessories from us for your Comfort Connect-Enabled Device, in which case we will enter your credit card information into a third-party payment processing system. When you call us, phone calls may be recorded for training and quality assurance purposes. Such recordings are generally retained for no more than sixty (60) days.

We may receive other information automatically from the adjustable base, or from the Comfort Connect Application, regarding your interaction with the Services and the status of your adjustable base. For example, when connected, we will automatically receive and log the IP address and basic information about your adjustable base such as serial number, software version, software update status, and any failure codes. If you engage with the Services, we will log events or changes such as the request to move to “wake position,” “sleep position,” or “massage.”

If you choose to connect your account on our Services to your account on another service, such as Amazon Alexa, we may receive information from that other service, such as your email address and the number of voice commands issued. We do not receive audio recordings from third party voice control services, such as Amazon Alexa. You can stop sharing the information from another service with us by removing our access to that service.

If you are a California resident, the personal information that will be collected when you use our Services fits within the following categories: (1) identifiers; (2) personal information, as described in Section 1798.80 of the California Customer Records statute and Section 1798.140(o)(1-2) of the California Consumer Privacy Act (CCPA); (3) commercial information; (4) internet or other network activity; and (5) audio recordings. For purposes of clarification, the Comfort Connect Application does not collect browser or search histories or advertising information.

We will keep this information for as long as necessary to provide the Services, operate your account, and fulfill legitimate business purposes. Logging information that can be linked to an individual adjustable base is generally retained for no more than 30 days after the particular event is logged, after which the information may be retained in an aggregated or de-identified basis.

How Do We Use and Protect the Information?

When you use our Services, we use data to provide and improve the Services, authenticate customers, offer customer or warranty services, fulfill legal and contractual obligations, comply with applicable laws, protect our legal rights, and guard against fraud and abuse. The data collected may be used to operate the Comfort Connect-Enabled Device as directed by enabling voice commands, ensure the software is up-to-date to improve performance, troubleshoot and assist in warranty resolution, and provide customer care and warranty support. Aggregated data may be used in data analytics to develop new or improve existing Services and create a better customer experience.

We work hard to keep your data safe. We maintain technical, administrative, and physical controls designed to protect the security of your data, including using Transport Layer Security (“TLS”) to encrypt many of our Services. However, no method of transmitting or storing data is completely secure.

How Information is Shared

We do not sell your personal information associated with the use of the Services to third parties, nor do we share your personal information with third parties, except for a business purpose, such as when necessary to provide the Services, including to enable the connected device feature to operate or when a third party, service provider, partner or affiliate is assisting us in providing the Services. That is, we have not disclosed to other third parties any personal information for monetary or other valuable consideration within the 12 months preceding the effective date of this Notice. We will also share your information as directed by you and may share it in response to a lawful demand, to assert legal rights or defend against legal claims, or as part of a merger and acquisition.

Your Rights to Access and Control Your Personal Information

By logging into your account, you can access your account settings, change your password, or delete your account. You can also use the Comfort Connect Application to unpair your adjustable base from your account at any time or revoke the access of third-party applications you previously connected to your account.

If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data recorded by your Comfort Connect-Enabled Device and other data stored in our backup systems. This is due to the size and complexity of the systems we use to store data.

Notwithstanding anything in this Privacy Notice to the contrary, we may in certain circumstances be required to preserve data for legal reasons or to prevent harm.

If you are a California resident, you may have certain rights regarding access, portability, knowledge, and deletion of your personal information and a right not to be discriminated against because you exercise any of your rights under the CCPA. For more information about these rights, please visit https://privacy.leggett.com/california-consumer-privacy-notice/en. California residents may request the disclosures described above or the deletion of their personal information by calling us at 1-833-825-3660, visiting us at https://privacy.leggett.com/contact, or e-mailing us at privacy@leggett.com. Please note that we may take reasonable steps to verify your identity before implementing your request, including asking you to provide identification, if necessary.

Our Policies for Children

The Services are not intended for children under sixteen (16) years of age, and we do not knowingly collect personal information from children under sixteen (16). If we learn we have collected or received personal information from a child under sixteen (16) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under sixteen (16), please contact us at https://privacy.leggett.com.

Changes to This Notice

We may change or update this Notice from time to time. Any changes to this Notice will be posted with an updated revision date in the Comfort Connect Application and on https://privacy.leggett.com/privacy-notices, which may also contain other privacy notices that may apply.

Miscellaneous

This Notice does not cover the privacy practices of our websites, including but not limited to, https://lpadjustablebeds.com/. Please see our Privacy Statement at https://privacy.leggett.com/privacy-statement for more details.

Contact Information

If you have privacy-related questions, suggestions, or concerns about this Notice or about our use of your information, please contact us at https://privacy.leggett.com.