Privacy Policy (Canada)

 

Effective Date: April 10, 2026

 

Navien Mate (“Navien Mate,” “we,” “us,” or “our”) is committed to protecting the privacy of individuals and safeguarding personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial private‑sector privacy laws, including those of Alberta, British Columbia, and Québec (as amended by Law 25).

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with our Canadian website, products, and services.

 

1. What Is Personal Information

“Personal information” means information about an identifiable individual. This may include, for example, your name, mailing address, email address, telephone number, payment information, IP address, order details, and information relating to your interactions with our website or purchases.

Personal information does not include business contact information used solely to communicate with an individual in a business capacity.

 

2. Accountability

Navien Mate is responsible for personal information under its control and has designated a Privacy Officer who is accountable for our compliance with this Privacy Policy and applicable privacy laws.

Contact details for the Privacy Officer are provided in Section 14 below.

 

3. How We Collect Personal Information

We collect personal information in the following ways:

• When you place an order, create an account, or register a product
• When you contact us for customer service, warranty support, or inquiries
• When you subscribe to marketing communications (where permitted by law)
• When you participate in promotions, surveys, or product research
• When you browse or interact with our website, including through cookies and similar technologies
• When you enable optional application features, such as the Navien OptiSleep feature

 

4. Purposes for Collection and Use

We collect and use personal information only for purposes that a reasonable person would consider appropriate in the circumstances, including:

• Processing purchases, payments, shipping, returns, and warranties
• Providing customer service and responding to inquiries
• Communicating with you regarding orders, products, services, or updates
• Improving our website, products, and customer experience
• Sending marketing or promotional communications, where you have consented or where permitted by law
• Providing optional sleep‑related services and automated comfort features through the Navien OptiSleep application
• Detecting and preventing fraud or security incidents
• Meeting legal, accounting, and regulatory obligations

If we intend to use personal information for a new purpose, we will identify that purpose and obtain consent where required by law.

 

We comply with Canada’s anti‑spam legislation (CASL) with respect to electronic marketing communications.

 

5. Consent

Certain features, including Navien OptiSleep, require express consent due to the sensitivity of the information involved. You may withdraw consent for such features at any time through the application settings or by contacting us, subject to legal or contractual restrictions.

 

6. Disclosure of Personal Information

We disclose personal information only as necessary and for legitimate business purposes, including to:

• Payment processors and financial institutions
• Shipping, logistics, and fulfillment providers
• IT service providers, hosting providers, and analytics providers
• Marketing and communications service providers
• Professional advisors (such as legal or accounting)
• Government authorities or law enforcement, where required or permitted by law

Service providers are authorized to use personal information only as necessary to perform services on our behalf and are required to protect it through appropriate safeguards.

We do not sell personal information.

 

In addition to the disclosures described above, personal information may be shared with service providers that support optional application features, including sleep data analytics providers acting on our behalf.

 

7. Cross‑Border Transfers

Personal information, including OptiSleep data, may be processed or stored outside your province, including outside Québec, or outside Canada, depending on the location of our service providers. Appropriate contractual and organizational safeguards are implemented as required by applicable law.

 

8. Navien OptiSleep Feature

Navien OptiSleep is an optional application feature designed to enhance sleep comfort and provide sleep‑related insights. OptiSleep is disabled by default and requires your express opt‑in consent.

 

a. Categories of Personal Information Collected

When OptiSleep is enabled, we may collect the following personal information:

 

Device Installation Location

·       GPS latitude and longitude

·       Used solely to determine time zone and enable time‑based scheduled operations

Precise location data is not retained once the applicable time zone has been determined.

 

Sleep‑Related Information

·       Sleep time and wake‑up time

·       Total sleep duration

·       Sleep stages, sleep efficiency, and sleep regularity

·       Breathing sound data collected through the application

 

Sleep‑related information is treated as sensitive personal information and is subject to enhanced safeguards.

 

b. Purposes of OptiSleep Data Processing

OptiSleep personal information is used to:

·       Provide sleep analysis and personalized sleep‑related services

·       Enable automated temperature control based on sleep stages

·       Analyze feature usage and improve OptiSleep functionality

·       Support development of new sleep‑related features

 

OptiSleep data is not used to provide medical diagnoses or clinical health advice. Some OptiSleep features may involve automated processing to adjust product settings based on inferred sleep stages. Breathing sound data is analyzed solely to infer sleep patterns and is not used for identity verification or biometric identification purposes.

 

c. Outsourced Processing

We engage a third‑party service provider to support OptiSleep functionality:

·       Service Provider: A‑Sleep Co., Ltd.

·       Scope of Processing:

o   Analysis of sleep data based on breathing sound

o   Provision and improvement of OptiSleep‑related services

 

A‑Sleep Co., Ltd. acts solely as a data processor on our behalf and is contractually required to protect personal information and use it only in accordance with our instructions.

 

d. Retention of OptiSleep Data

OptiSleep data is retained:

·       Until service termination or withdrawal of consent; or

·       For longer periods as required or permitted by law

 

Afterwards, the data is securely deleted or anonymized.

 

e. Withdrawal of Consent

You may disable OptiSleep at any time through the application. Withdrawal of consent will stop further collection and processing of OptiSleep data and does not affect your ability to use non‑OptiSleep product features.

 

9. Cookies and Similar Technologies

We use cookies, pixel tags, web beacons, and similar technologies to:

• Enable core website functionality
• Remember user preferences
• Measure website performance and usage
• Support marketing and remarketing activities

Some of these technologies may allow us or third parties to recognize you, profile your interactions with our website, or re‑engage with you through advertising.

You can adjust your browser settings to manage or disable cookies. Please note that disabling cookies may affect website functionality.

 

10. Safeguards

We apply safeguards appropriate to the sensitivity of personal information. Sensitive information such as sleep‑related data is subject to enhanced technical, administrative, and organizational protections. Access to personal information is restricted to employees and service providers who require the information to perform their duties.

 

11. Retention of Personal Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to meet legal, accounting, warranty, or regulatory requirements.

When personal information is no longer required, it is securely destroyed, erased, or anonymized in accordance with our retention practices.

 

12. Access and Correction Rights

You have the right to request access to your personal information held by us and to request correction of any inaccurate or incomplete information, subject to limited exceptions permitted by law.

Requests must be made in writing using the contact information below. We may require verification of your identity before responding.

 

13. Children’s Privacy

Our website and products are intended for individuals who are at least the age of majority in their province or territory of residence. We do not knowingly collect personal information from minors.

 

14. Third‑Party Websites

Our website may contain links to third‑party websites. We are not responsible for the privacy practices or content of those websites, and this Privacy Policy does not apply to them. We encourage you to review their privacy policies.

 

15. Contact Information and Privacy Officer

If you have questions about this Privacy Policy, wish to withdraw consent, or want to request access to or correction of your personal information, please contact:

Navien Mate – Privacy Officer
Email: info@navienmate.com

Mailing Address:
Navien Mate
Attn: Privacy Officer
20 Goodyear
Irvine, CA 92618
United States

 

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be effective when the updated version is posted on our website, with the revised effective date indicated above.

 

A French version of this Privacy Policy is available upon request.