Applicable with effect from: 15/01/2020

 

Who we are

Arenar B.V. and its parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors – (collectively, “Arenar”, “we”, or “us”, “our”) is a high-tech company working on research and development of next-gen sleep engineering products. We are based in The Netherlands.

This privacy notice will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you when:

  1. you visit our website ibandplus.com (regardless of where you visit it from) (“Site”);
  2. you access our companion mobile app (“App”);
  3. you purchase our products (“Goods”); and
  4. we provide to you with our product applications and support services (“Services”).

The following are categories of individuals to whom this privacy policy applies to:

  • User: means any person accessing our Site or App.
  • Customer: means any individual who is purchasing the Goods or using the Services.
  • iBandPlus: means the website ibandplus.com

We reserve the right to change this privacy policy from time to time by changing it on the Site or App, or by emailing you.

 

How this Policy applies

This Privacy Policy explains how Arenar collects, uses, or otherwise processes information we collect about you and how you can control the collection, correction and/or deletion of such information when you use our Website: www.ibandplus.com, including on a mobile device and related services (the “Service“ or the “Services”) or any other service to which this policy is linked. Your use of our Website and the Services is also governed by our Terms of Use and Pre-Order Terms and Conditions which are to be read in conjunction with this policy.

 

What data do we collect?

We may collect the following types of data and information from our Users

  1. Personal Information: Registration information you provide when you create an account, enter a promotion, contest, or sweepstakes, or link your profile on a third-party site or platform with your registration account, or sign up for our newsletter or other publications, such as your first name and last name, address, e-mail address, date of birth and phone number.
  2. Transaction Information: means your shipping address, billing address, account information, other information you share during the purchasing process, such as details of the product purchased, the date and time of the order, the quantity and price of the order, whether payment was made, method of payment, purchase history, and whether you re-ordered.
  3. Internet or another network or device activity: The information such as browsing history, IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site and App.
  4. Sensor Data: data such as your brainwave patterns and behaviors.
  5. Other Information: We may collect additional information (collectively, the “Other Information”). Such Other Information may include:
  6. From You. Additional information about yourself that you voluntarily provide to us, such as product and service preferences; lifestyle details; your sex, age, height, weight, and other demographic and physical details; and other information that does not identify you personally.
  7. From Your Activity. Information that we automatically collect when you use the Services, including, without limitation:
  • IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on pages, sections of the website visited, etc.
  • Information about a mobile device, including universally unique ID (“UUID”), Platform type and version (e.g., iOS or Android), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G, 5G, etc.); and
  • Activity and usage information occurring via the Platform, including tagging data, favorites, survey responses, preferences, session lengths; and similar data.
  1. From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both, session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Platform. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Platform may not function properly.
  2. From Other Sources. Information that we collect or receive from Facebook, Twitter, and/or other third-party social media sites on which you have used the Services in accordance with their terms of use and privacy policies.

You may decline to provide us with your information. However, this will limit your ability to register for an account or use our Goods and Services. You may be able to purchase our Goods and Services without creating an account, but we will still need to collect required information for compliance purposes in order to process your purchase. If you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with the Goods and Services). In this case, we may have to cancel delivery of the Goods or Services you have with us, but we will notify you if this is the case at the time.

How do we collect your data?

You directly provide Our Company with most of the data we collect. We collect data and process data when you:

  1. We collect information you provide to us when you access, use, request or purchase our Goods and Services, request information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to User surveys, or otherwise interact with us online or offline.
  2. When you visit our Site and App, we may automatically collect Internet or another network or device activity data about your equipment, browsing actions and patterns. We collect information through a variety of technologies, such as cookies, Flash cookies, Web beacons and similar technologies.
  3. We collect information using analytics tools, such as Google Analytics, including when you visit our sites and applications or use our applications on third-party sites or platforms such as ad partners and analytics providers.
  4. If you access our Services through a third-party connection or log-in (like a social network), we may collect certain information from your social network profile. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. If you do not want to share information from your social network profile, do not access our Services through that third-party service.

We will not collect any Personal and Health Information from you or related to you without your explicit approval, which is obtained, inter-alia, through your active acceptance of the T&C and this Privacy Policy. PLEASE NOTE – If you give us personal information about someone else, you must do so only with that person’s express authorization. You should inform them how we collect, use, disclose, and retain their personal information according to this Privacy Policy before you provide us with their personal information.

 

How will we use your data?

Consistent with applicable law and choices and controls that may be available to you, we may use information collected (including the categories set forth above) from you, or from devices associated with you:

  1. To enable us to provide you with our Goods & Services, and to improve and promote our Goods & Services, such as process your order and manage your account.
  2. To communicate with you about your account or transactions on our Site and send you information or request feedback about features on our sites and applications or changes to our policies.
  3. For our marketing and third-party marketing purposes: to send you offers and promotions for our products and services or third-party products and services.
  4. Personalize the Services, content and experiences.
  5. Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications.
  6. Operate, understand, optimize, develop, or improve the Services, our sites, applications, products, services and operations, including by performing User market research and using analytics tools.
  7. Audit consumer interactions on the Services including to measure the placement, frequency, efficacy and compliance of advertising and ad impressions.
  8. Security, Fraud, and Legal Compliance, including to detect, investigate and prevent activities that may violate our policies or be illegal.
  9. Manage payments, fees and charges. Collect and recover money owed to us.
  10. For processing your order, we may send your data to our logistics partners to enable the delivery of Goods.

Your controls and choices

The laws in some jurisdictions require us to provide you with the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. Information for residents of certain jurisdictions is below. To the extent that those laws apply to you, your controls and choices may include any of the following:

  1. Updating or deactivating your iBandPlus account.
  2. Choosing or changing your choices for subscriptions, newsletters, and alerts.
  3. Choosing whether to receive offers and promotions for our products and services from us or offers for products and services that we think may be of interest to you.
  4. Choosing whether we share your personal information with other companies that would like to send you offers and promotions about their products and services.
  5. Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers (by visiting the Digital Advertising Alliance).
  6. Controlling whether you want us to access location information, such as by controlling or disabling location services on your mobile device’s settings menu.
  7. Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest-based ads.

You may exercise these controls and choices in various ways, such as following instructions provided in communications sent to you, or by using your device or other available settings (for example, by resetting your device’s advertising identifier and/or opting out of interest-based ads).

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our Services may not be able to take account of your interests and preferences. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact us.

 

General Data Protection Regulation (“GDPR”)

The following sections on GDPR applies to individuals in the European Economic Area (“EEA”). If you are not sure whether the GDPR section applies to you, please refer to the text of the regulation here or consult with an attorney as Arenar is not able to give you legal advice.

 

Who is the Data Controller?

Arenar B.V. is the “data controller” of personal data collected, and we are responsible for deciding how personal data is collected, used, and disclosed.

You should be aware that when you provide information to us using a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by the Arenar Privacy Policy only, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third party’s site or platform will not apply to our use of the information we have collected directly through our Site or Services.

 

Legal bases for use of your information & controls and choices

The laws in the European Economic Area (“EEA”) and some other jurisdictions require us to provide Users, to the extent those laws apply to such Users, with the following information:

Legal grounds for use and disclosure of personal information

The legal grounds for use and disclosure of personal information include any of the below reasons:

  1. As necessary to perform our obligations under any contract with you, including to register you as a new Customer or User, to provide the Goods and Services to you including, manage payments, fees and charges.
  2. On the basis of consent, such as to send you certain information, including marketing communications, to share your information with partners when you have requested, we do that, or to collect and process your information for research purposes.
  3. For our legitimate interests or the legitimate interests of others such as to ensure the security of our Sites, operate and improve our business and our Sites, respond to your questions, engage in certain marketing, make and receive payments, comply with our legal obligations, prevent fraud, conduct analysis, enforce our Terms, engage in a business change (e.g., sale, merger), to know the User to whom we are providing the Service, and to create anonymous data.

Controls and choices

  1. In addition, Users in the European Economic Area and some other jurisdictions outside the United States have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways (for example, if you opt out of the use of your telephone number for direct marketing, we might still decide to contact you by phone regarding potential fraud on your account).
  2. Users in the European Economic Area have the right to opt-out of all our processing of their personal data for direct marketing purposes. To exercise this right, you may contact us.
  3. The rights and options described above are subject to limitations and exceptions under applicable law. In situations in which we process personal data on behalf of our User, we may refer the request to the relevant User and cooperate with their handling of the request, subject to any special contractual arrangement with that User.

Data Security and Data Retention

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented security measures that are designed to protect User information from unauthorized access, disclosure, use, and modification. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.

We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

 

Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at contact@ibandplus.com or using our contact form. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

The California Consumer Protection Act (“CCPA”)

The following section on CCPA, Cal. Civ. Code § 1798.100 which is effective January 1, 2020, applies to California residents who have certain rights regarding the personal information (as defined in the CCPA) collected by iBandPlus. It does not cover personal information not subject to the CCPA rights identified below, such as personal information we collect from our employees or job applicants. Likewise, the CCPA does not extend all the rights identified below to personal information collected from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

Definitions

 

  1. “Personal information” or “PI” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
  2. “Consumer” is a California resident, a natural person who is a California resident for other than a temporary or transitory purpose, or someone who is domiciled in California but is currently outside the State for a temporary or transitory purpose.
  3. “Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by iBandPlus to another business or a third party for monetary or other valuable consideration.

California residents have the following rights under CCPA

  1. Right to Opt Out. You have the right, at any time, to direct us to not sell your PI. You can do this by emailing us at contact@ibandplus.com or using our contact form.
  2. Sale of PI: Under the CCPA, sale is also broadly defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services.
  3. Categories of PI We Provide and Purposes of the Sale: We provide the following categories of information to third parties for these purposes: including identifiers, geolocation information, professional or employment related data, and physical characteristics or descriptions.
  4. Purpose of the Sale: We may provide the following categories of personal information to third parties for these purposes:
  5. For online targeted advertising purposes: device identifiers (such as browsing history; geolocation information; social media information), and
  6. For sharing with third parties to send you relevant offers and promotions and opportunities, such as when you sign up for an event or to receive more information and provide categories of information to us: identifiers, professional or employment related data (such as your job title or current company), and physical characteristics or descriptions (such as if you provide a picture of yourself).
  1. Right to Know or Right to be Informed. Subject to certain exceptions, you have the right to know what specific pieces of PI Arenar has collected about you in the 12 months preceding your request, along with the categories of sources of that PI, our business or commercial purpose for disclosing your PI, and the categories of third parties with whom we share your PI. You may make this request no more than twice per 12-month period.
  1. Right to Request Deletion. You have the right to request deletion of the PI Arenar has collected from you, subject to certain exceptions under the CCPA including, without limitation:
  2. Making sure you can receive your purchased order.
  3. Complying with Arenar’s legal or compliance obligations.
  4. Detecting fraudulent behavior or security incidents, and
  5. Other reasons that are in connection with our lawful internal uses that are consistent with your relationship with us and the context in which the information was collected.

Exercising Your Rights under CCPA

You can exercise any of your rights under CCPA by emailing us at contact@ibandplus.com or using our contact form.

We will take reasonable steps to verify your identity before responding to a request, which may include the following:

  1. If you are exercising your Right to Delete or a similar right that does not require the disclosure of specific pieces of information about you:
  2. If you are writing to us from the email address associated with your iBandPlus account or transactions that iBandPlus has on file for you, then to complete the verification process, we will ask you to confirm the action you wish us to take before we proceed (such as confirming you would like us to delete your information).
  3. If you are not writing to us from the email address associated with your iBandPlus account, then to complete the verification process, we will ask you to provide 3 specific pieces of data that we have on file for you, such as email address you used when making a purchase or billing information such as the last 4 digits of the credit card used or the billing address for an order.
  4. If you are exercising your Right to Know or a similar right that does require disclosure of specific pieces of information about you:
  5. If you are writing to us from the email address associated with your iBandPlus account or transactions that iBandPlus has on file for you, then to complete the verification process, we will ask you to both: 1) confirm the action you wish us to take before we proceed and 2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made”.
  6. If you are not writing to us from the email address associated with your iBandPlus account, then to complete the verification process, we will ask you to both: 1) provide 3 specific pieces of data that we have on file for you, such as email address you used when making a purchase or billing information such as the last 4 digits of the credit card used or the billing address for an order and 2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made”.
  7. You are also permitted to designate an authorized agent to submit certain requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above methods before processing the authorized agent’s request.
  8. If we are not able to successfully verify you according to the above methods, then we will not be able to comply with your request.

iBandPlus will not discriminate against you if you exercise your rights under CCPA. However, if your request requires us to delete, restrict or not share information, please be advised that this will inhibit some functionality of the Site. Any subsequent interaction with the Site after deletion will require new requests for action on your data.

Children’s privacy

People under 18 (or the legal age in your jurisdiction) are not permitted to use iBandPlus on their own. iBandPlus does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services. If you believe that a child has provided us with personal information, please contact us at contact@ibandplus.com or using our contact form. If we become aware that a child under age 13 has provided us with personally identifiable information, we will delete it.

We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as quickly as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

 

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

  1. Strictly Necessary cookies let you move around the Site and use essential features like secure areas and shopping baskets. Without these cookies, we cannot provide the requested services.

We use Strictly Necessary Cookies to:

  1. Identify you as being logged in to our Site and to authenticate you
  2. Make sure you connect to the right service on our Site when we make any changes to the way the Site works
  3. To add purchases to your shopping cart and remembering the product you have added within a browsing session when you get the checkout page
  4. Identify that added items to the cart when you return to our Site
  5. For security purposes
  6. Make sure you connect to the right service on our Site when we make any changes to the way the Site works

Accepting these cookies is a condition of using the Site, so if you prevent these cookies, we can’t guarantee how Site or the security on our Site will perform during your visit.

  1. Performance cookies collect information about how you use our Site e.g. which pages you visit, and if you experience any errors. These cookies do not collect any information that could identify you and are only used to help us improve how our Site works, understand what interests our users and measure the effectiveness of our advertising.

We use Performance cookies to:

  1. Carry out web analytics: Provide statistics on how our Site is used
  2. Perform affiliate tracking: Provide feedback to affiliated entities that one of our visitors also visited their Site
  3. Obtain data on the number of users of the Site that have viewed a product
  4. Help us improve the Site by measuring any errors that occur
  5. Test different designs for the Site

Some of our performance cookies are managed for us by third parties. We do not allow the third party to use the cookies for any purpose other than those listed above.

By using our Site or expressing your consent as otherwise required by applicable law, you accept the use of ‘Performance’ cookies. Accepting these cookies is a condition of using the Site, so if you prevent them, we cannot guarantee how our Site will perform for you.

  1. Functionality cookies are used to provide services or to remember settings to improve your visit.

We use Functionality cookies for such purposes as:

  1. Remember settings you’ve applied such as layout, text size, preferences and colors
  2. Remember if we’ve already asked you if you want to fill in a survey
  3. Remember if you have engaged with a component or product list on the Site so that don’t show it again
  4. Show you when you’re logged in to the Site
  5. To provide and show embedded video content

Some of these cookies are managed for us by third parties. We do not allow the third party to use the cookies for any purpose other than those listed above.

  1. Targeting cookies are used to track your visit to our Site and other websites, including the pages you have visited and the links you have followed, which allows third parties to display targeted ads to you on the websites you visit.

We and our third-party service providers use Targeting cookies to:

  1. Link to social networks, like Facebook, that may subsequently use information about your visit to our website in order to provide advertising or other offers that may be of interest to you when you visit other websites
  2. Provide third parties with information on your visit so that they can present you with advertisements or other offers that may be of interest to you

If you are in the EU, you may opt-out of certain third-party cookies that we and other websites may use for targeting through www.youronlinechoices.eu or www.aboutads.info. Opting out of one or more ad networks only means that those particular members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our websites or other third-party websites. If your browser is configured to reject cookies when you visit one of the above referenced opt-out pages, and you later erase your cookies, use a different computer or change Web browsers, your preference may no longer be active. Since all these cookies are managed by third parties, you should refer to the third parties’ own website privacy notifications and policies for further information.

 

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

 

Changes to this Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

 

Contact us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us on:

E-Mail Address: contact@ibandplus.com or via the contact form on this website