What data we collect
We collect certain data directly from you, such as data you share with us, data about your content research and data from third-party platforms that you link to ComfortNest. We also collect some data automatically, such as information about your device and which of our Services you interact with or use. All data listed in this section is subject to the following processing activities: collection, recording, structuring, storage, modification, extraction, encryption, pseudonymization, deletion, merging and transfer.
We may collect different data about you depending on how you use the Services. Here are some examples to help you better understand what data we collect.
When you create an account and use the Services (including through a third-party platform), we collect any data you provide to us directly, including:
- Category of Personal Data
- Legal basis for processing
- Account information
- To use certain features (such as access to materials), you must create a user account, for which we need to collect and store your email address, password, and account settings.
- To create a faculty account, we collect and store information about your email address, name, password, and account settings.
- When using certain features of the website, you will be asked to provide additional information such as occupation, ID number, photo to verify, date of birth, race/ethnicity, special skills and interests, and phone number.
- Once your account is created, you will be assigned a unique identification number.
Publicly Available Materials
Some Services allow you to communicate with other users or share materials publicly, including by downloading courses and other educational materials, posting reviews of materials, posting questions or answers to questions, sending messages to students or faculty, or posting photos or other materials you have uploaded. Such publicly available materials may be available for others to view, depending on where they have been published.
- When you access materials, we collect certain data, including which courses, assignments, labs, workspaces, and tests you have started and completed;
- content and subscription purchases and credits; subscriptions; certificates of completion;
- Your interactions with instructors, teaching assistants, and other students;
- and essays, answers to questions, and other items provided to satisfy course requirements and related materials.
Student payment information
If you make purchases, we collect certain information about your purchase (such as your name, billing address, and zip code) necessary to process your order, which can be saved for future orders if you wish. You must provide certain payment and billing information directly to our payment service providers, including your name, credit card information, billing address and zip code. We may also receive some information from our payment service providers, such as when you have a new card and the last four digits of that card to facilitate payments. For security purposes, ComfortNest does not collect or store sensitive cardholder information, such as full credit card numbers or card authentication information.
Data about your accounts on other services
We may obtain certain information through your social media accounts or other online accounts if they are connected to your ComfortNest account. If you access ComfortNest through Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service, we may collect information about your name, profile picture, account identification number, login email address, location, physical location of your access devices, gender identity, date of birth and friend or contact list.
These platforms and services provide us with information through APIs. What information we receive depends on what information you (through your privacy settings) or the platform or service chooses to share with us.
If you use our Services through a third-party platform or service or click on any third-party link, the collection, use and distribution of your information will also be subject to the privacy policies and other agreements of such third parties.
Communications and Support
We store the above data and link it to your account.
Data We Collect By Automated Means
When you access the Services (including when you view our materials), we collect certain data through automated means, including:
- Legal basis for processing
- System data
- Technical data about your computer or device, such as your IP address, device type, operating system type and version, unique device identifier, browser, browser language, domain and other system data, and platform type.
Usage statistics for the Services section, including content studied, time spent on pages or Services, pages visited, features used, search terms, clickstream data, date and time, referrer, and other usage data for the Services section.
Legitimate interests (user interface improvements, fraud prevention and security, regulatory compliance)
The data listed above is collected through server logs and tracking technologies as described in the “Cookies and Data Collection Tools” section below. We store this data and link it to your account.
Third Party Data
If you are a current or potential corporate customer of ComfortNest, in addition to the data you provide, we may collect certain contact information about the company from third-party commercial sources.
How we collect data about you
We use tools such as cookies, web beacons and similar data collection tools listed above. Some of these tools allow you to opt out of data collection.
Cookies and Data Collection Tools
What we use the Data Collection Tools for
ComfortNest uses the following kinds of Data Collection Tools for the purposes described below:
- Strictly necessary: these Data Collection Tools allow you to access the site, provide a set of basic functions (such as logging in and accessing materials), provide site security and protection against fraudulent logins, and detect and prevent improper or unauthorized use of your account. These tools are essential to the proper operation of the Services section, so if you disable them, some parts of the site will stop working or become inaccessible.
- Functionality: These Data Collection Tools remember data about your browser and your preferences, enable additional site features, customize the display of content that best suits you, and remember settings that affect the appearance and behavior of the Services section (such as your preferred language or volume level when playing videos).
- Performance: These Data Collection Tools help you evaluate and improve the Services section by providing data on usage and performance, number of visits, traffic sources, or the resource from which the app was downloaded. These tools allow you to test different versions of ComfortNest to determine the features and content users prefer and the emails opened.
- Advertising: these Data Collection Tools are used to display relevant advertisements (on our site and/or other sites) according to the usage and system data collected and with information collected about you by advertising providers. The ads displayed may be tailored according to your recent or historical activity on other sites and services. To display targeted ads, we may provide service providers with a hashed, anonymized version of your email address (in human-readable form) and materials that you have shared through the Services.
- Social Media: These Data Collection Tools provide social media features, such as sharing content with friends or networks. These cookies may track a user’s or device’s activity on other sites in order to profile a user’s interests and display targeted advertisements.
How we use your information
We use your data to provide our Services, communicate with you, troubleshoot problems, protect against fraud and abuse, improve and update our Services, analyze use of our Services, provide personalized advertising, and for other purposes required by law or necessary to ensure security and integrity. We retain your data for as long as that data is necessary for the purposes for which it was collected.
We use data collected through your use of the Services for the following purposes:
- Providing and administering the Services, including facilitating the completion of educational material, issuing certificates of completion, personalized display of content, and facilitating interactions with other users (Account Data, Publicly Available Materials, Learning Data, System Data, Usage Data, Approximate Geographic Location);
- Processing payments to instructors and other third parties (Student Payment Data, Instructor Payment Data);
- Processing your requests and orders for educational materials, goods, certain services, information, or features (Account Data, Learning Data, Student Payment Data, System Data, Messages, and Support).
To whom we share your data
We share certain data about you with faculty, other students, companies that provide services to us, affiliated ComfortNest partners, our business partners, analytics and data enrichment service providers, your social media providers, companies that help us run promotions and surveys, and advertising companies that help us advertise our Services. We may also transfer your data as necessary for security, compliance or corporate restructuring purposes. Finally, we may transfer data in other ways if it is presented in aggregate or anonymous form or if we obtain your consent to the transfer.
- Transmission of data to your instructors: We share the data we have about you (other than your email address) with instructors or teaching assistants of educational materials to which you have access or about which you have requested information so that they can improve their materials for you and other students. This information may include your country, browser language, operating system, device settings, the site from which you accessed ComfortNest and your particular activities on ComfortNest, such as registering for courses and checking courses. We will not share your email address with instructors or teaching assistants. (Account Data, System Data, Usage Data, Approximate Geographic Location)
- Transmission of data to other students and faculty: Depending on your settings, your published materials and profile data may be available for viewing by others, including other students and faculty.
- Data Transfers to Service Providers, Contractors and Agents: We share your data with third-party companies that provide services on our behalf, such as payment processing, anti-fraud and violence, data analysis, marketing and advertising services (including redirected advertising), email and hosting services, and customer service and support. These service providers may have access to your personal data and are required to use it, at our direction, solely to provide the services we have requested. (All Data Categories).
- With respect to ComfortNest affiliate partners: We may transfer your data within our corporate group of companies that are bound by a joint ownership and management relationship necessary to implement and support the Services we provide. (All Data Categories).
- Data transfers to business partners: We have agreements with other websites and platforms to distribute our Services and to attract users to the ComfortNest website. Depending on your location, we may share your data with such trusted partners. (Account Data, Training Data, Messaging and Support, System Data)
- With organizations that provide additional education credits. If you have selected a course for additional vocational training, We may provide this information upon request from the additional training loan organization. (Account information, Learning data)
- Data transfer for promotions and surveys: We may transfer your data needed to run, market or sponsor promotions and surveys in which you wish to participate, in accordance with applicable law (e.g. to provide lists of winners and fill out applications) or in accordance with the rules of the promotion or survey. (Account Data, Sweepstakes, Promotions and Surveys) Transmission of data for security and compliance purposes: We have the right to disclose your data (all categories of data) to third parties at our discretion if we believe in good faith that the disclosure
- is requested in connection with a judicial, governmental or legal inquiry, order or proceeding;
- is reasonably necessary pursuant to the effect of a subpoena, order or other valid request;
- is required to detect, suppress or respond to fraud, abuse, misuse, possible violations of law (or rules and regulations), security or technical issues;
- in our discretion is required or reasonably necessary to protect against the imminent threat of infringement, damage to the property or safety of ComfortNest, our users, employees, members of the public or our Services;
- required or permitted by law.
We use appropriate security measures depending on the type and vulnerability of the stored data. As with any system with access to the Internet, there is always the risk of unauthorized access, which is why it is so important to protect your password and contact us if you suspect that someone has gained unauthorized access to your account.
ComfortNest takes appropriate security measures to protect against unauthorized access, alteration, and disclosure or destruction of your personal data that we collect and store. These measures depend on the type and vulnerability of the data. That said, unfortunately, no system can be 100% secure, and we cannot guarantee that unauthorized third parties will not have full access to the communications between you and ComfortNest, the Services section or any information provided to us in connection with the data we collect through the Services section. Your password is an important part of our security and you are responsible for protecting it. You must not share your password with any third party, and if you believe that your password or account has been compromised, you must immediately change your password and report your suspicions to our support team.
You have certain rights regarding the use of your data, including the ability to opt out of receiving promotional emails, cookies and the collection of your data by certain third parties. You may renew or terminate your account through our Services platform, and you may contact us to exercise your personal rights regarding your personal data. Parents who believe that we have inadvertently collected personally identifiable information about their minor child should contact us to have that information deleted.
Your choice about how we use your information
You may choose not to provide us with some data, but then you will not be able to use certain features of the Services.
- To opt out of receiving promotional emails from us, you can unsubscribe to promotions by using the instructions in the email you receive or by changing your email settings in your account (in English). Please note, regardless of your email settings, we will send you transactional and/or relationship messages in the Services, including, administrative notices, order confirmations, important changes to the Services, and notices regarding our policies.
- If you are located in the European Economic Area, you may opt-out of certain Data Collection Tools by clicking on the “Cookie Options” link at the bottom of any page.
- The device or browser you use may have cookie management features that store other types of local data.
Our Children’s Policy
We respect children’s right to privacy and encourage parents and guardians to take an active role in their children’s online activities and interests. Those who are under 18 but of sufficient age to use the Internet services in their country of residence (e.g. 13 in the US and 16 in Ireland) cannot create an account, but can ask their parent or guardian to create an account to gain access to the relevant materials. Individuals who are not of sufficient age to use the Internet Services are not eligible to use the Services. If we discover that the personal information of a child who is under age has been collected, we will take appropriate action to delete it.
Parents who believe that ComfortNest may have obtained the personal data of their underage child may send a request for deletion of such data to [email protected].