Navien OptiSleep Virginia Privacy Notice (VCDPA)

VIRGINIA PRIVACY NOTICE (VCDPA) – NAVIEN OptiSleep
Last Updated: April 10, 2026

This Virginia Privacy Notice supplements Navien OptiSleep’s Privacy Policy and applies solely to residents of the Commonwealth of Virginia. Navien OptiSleep (“we,” “us,” or “our”) complies with the Virginia Consumer Data Protection Act (“VCDPA”).

I. PERSONAL DATA WE COLLECT

Depending on how you interact with Navien OptiSleep, we may collect the following categories of personal data:

  • Identifiers (such as device ID)
  • Commercial information (including bed warmer purchases and order history)
  • Internet and application activity (including app usage and interactions)
  • Precise geolocation data (GPS latitude and longitude)
  • Sensitive personal data collected through optional application features, including sleep-related information and breathing sound data, when expressly enabled by the user

Sensitive personal data is collected only with the consumer’s affirmative consent.

II. SOURCES OF PERSONAL DATA

We collect personal data from the following sources:

  • Directly from you (e.g., checkout forms and application inputs)
  • Indirectly through cookies and similar technologies
  • Third-party vendors (such as payment processors)
  • Navien Sphere for Sleep and Navien Mate iOS and Android applications (e.g., device ID, push notification tokens)
  • Optional application features expressly enabled by the user, including Navien Sphere for Sleep and Navien Mate

III. BUSINESS PURPOSES FOR PROCESSING

We process personal data for the following business purposes:

  • E-commerce processing and payment fulfillment
  • Shipping and delivery of products
  • Customer service, returns, and warranty support
  • Marketing and promotional communications (where permitted by law)
  • Fraud prevention and security monitoring
  • Providing optional sleep-related analysis and automated comfort features through application functionality
  • Operating, maintaining, and improving application features, including Navien Sphere for Sleep and Navien Mate
  • Internal analytics and product development based on aggregated usage data
  • Legal and regulatory compliance

IV. THIRD PARTIES WITH WHOM WE SHARE PERSONAL DATA

We may share personal data with the following categories of third parties:

  • Payment processors
  • Shipping and logistics providers
  • Marketing and analytics service providers
  • Service providers supporting optional application features (including sleep data analytics providers), acting solely on Navien OptiSleep’s behalf

Navien OptiSleep does not sell personal data.

V. SENSITIVE DATA PROCESSING

Navien OptiSleep processes sensitive personal data, including precise geolocation and sleep-related information, only with the consumer’s affirmative consent.

  • Precise geolocation data is used to determine time zone and enable scheduled application operations.
  • Sleep-related information and breathing sound data are used solely to provide optional sleep analysis and automated comfort features through Navien Sphere for Sleep.

Consumers may withdraw consent at any time through application settings or by contacting optisleep@navien.com. Withdrawal of consent will not affect core product functionality.

VI. DATA SHARING & OPT-OUT RIGHTS

Navien OptiSleep does not sell personal data. Virginia residents have the right to opt out of:

  • Targeted advertising
  • The sale of personal data
  • Profiling in furtherance of decisions that produce legal or similarly significant effects

Opt-out requests may be submitted via:

VII. DATA RETENTION

We retain personal data only for as long as reasonably necessary for the purposes described in this Notice, including:

  • Order records, as required for warranty, accounting, and tax compliance
  • Customer service inquiries, retained for a limited period following resolution
  • Information subject to legal holds or dispute resolution

Personal data collected through optional application features such as Navien Sphere for Sleep and Navien Mate is retained until service termination or withdrawal of consent, unless a longer retention period is required or permitted by law.

VIII. YOUR RIGHTS UNDER THE VCDPA

Virginia residents have the right to:

  • Confirm whether we process personal data about you
  • Access personal data
  • Correct inaccuracies in personal data
  • Delete personal data
  • Obtain a copy of personal data in a portable format
  • Opt out of targeted advertising, the sale of personal data, or certain profiling
  • Non-discrimination for exercising privacy rights
  • Appeal our decision regarding a privacy request

IX. SUBMITTING A REQUEST OR APPEAL

Submit Requests:

Verification: Name, email address, physical address, and Virginia residency
Response Time: 45 days (with one 45-day extension where permitted by law)

Appeals: