Last updated February 19, 2024
This privacy
notice for
Sleep Healthily
( 'we', 'us', or
'our' ), describes
how and why we might collect, store, use, and/or share (
'process' ) your information when you use our services ( 'Services' ), such as when
you:
- Visit our website
at https://sleep-healthily-12a12155ea31.herokuapp.com , or any website of ours that links to this privacy notice
- Engage with us in
other
related ways, including any sales, marketing, or events
Questions or
concerns? Reading this privacy
notice
will
help you understand your privacy rights and choices. If you do not agree with our policies and practices,
please do not use our Services. If you still have any questions or
concerns, please contact us at privacy@sleephealthily.com
.
SUMMARY
OF
KEY POINTS
This
summary provides key points from our privacy notice, but you can find out more details about any of
these
topics by clicking the link following each key point or by using our table of
contents below
to find the section you
are
looking for.
What
personal information do we process? When you visit, use, or navigate our Services, we may process
personal information depending on how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more about personal information you
disclose to us.
Do we
process any sensitive personal information?
We do not process sensitive personal information.
Do we
receive any information from third parties?
We do not receive any information from third parties.
How do
we
process your information? We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply with law. We may also
process
your information for other purposes with your consent. We process your information only when we have a valid
legal reason to do so. Learn more about how we process your
information.
In what
situations and with which parties do we share personal
information? We may share information in specific situations and with specific third parties. Learn more about when
and with whom we share your personal information.
How do
we
keep your information safe? We have organisational and technical processes and procedures in place to protect your personal
information. However, no electronic transmission over the internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to
defeat our security and improperly collect, access, steal, or modify your information. Learn more
about how we keep your
information safe.
What are
your rights? Depending on where you are located geographically, the applicable privacy law may
mean
you have certain rights regarding your personal information. Learn more about your privacy rights.
How do
you
exercise your rights? The easiest way to exercise your rights is by
visiting
https://sleep-healthily-12a12155ea31.herokuapp.com/privacy-policy
, or by contacting us. We will consider and act upon any request in accordance
with applicable data protection laws.
Want to learn
more
about what we do with any information we collect? Review
the privacy notice in full.
TABLE OF
CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
Personal information you disclose to
us
In
Short: We
collect personal information
that you provide to us.
We collect personal
information that you voluntarily provide to us when you
register on the Services,
express an interest in obtaining information about us
or
our products and Services, when you participate in activities on the Services, or otherwise when you
contact us.
Personal
Information Provided by You. The personal information that we collect depends on the context of
your interactions with us and the Services, the choices you make, and the products and features you use.
The
personal information we collect may include the following:
-
names
-
phone numbers
-
email addresses
-
usernames
-
passwords
-
contact or authentication data
Sensitive
Information.
We do not process sensitive information.
Payment
Data. We may collect data necessary to process your payment if you make purchases, such as your
payment instrument number, and the security code associated with your payment instrument. All payment data
is stored by
Stripe
.
You may find their privacy notice link(s) here:
https://stripe.com/privacy
.
All personal
information
that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such
personal information.
2. HOW DO WE PROCESS YOUR
INFORMATION?
In
Short: We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and to comply with law.
We
may also process your information for other purposes with your
consent.
We process your
personal information for a variety of reasons, depending on how you interact with our Services,
including:
- To facilitate
account creation and authentication and otherwise manage user accounts. We may process
your information so you can create and log in to your account, as well as keep your account in working
order.
- To save or protect an
individual's vital interest. We may process your
information when necessary to save or protect an individual’s
vital interest, such as to prevent harm.
3.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In
Short: We
only process your personal information when we believe it is
necessary and we have a valid legal reason (i.e. legal basis) to do so under
applicable law, like with your consent, to comply with laws,
to
provide you with services to enter into or fulfil
our contractual obligations, to protect your rights, or
to fulfil our legitimate business
interests.
If you are located in
the EU or UK, this section applies to
you.
The General Data Protection
Regulation (GDPR) and UK GDPR require us to explain the valid
legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases
to
process your personal information:
- Consent. We
may process your information if you have given us permission
(i.e.
consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Legal Obligations.
We may process your information where we believe it is
necessary for compliance with our legal obligations, such as
to cooperate with a law enforcement body or regulatory
agency,
exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are
involved.
- Vital Interests.
We
may process your information where we believe it is
necessary
to protect your vital interests or the vital interests of a
third party, such as situations involving potential threats
to
the safety of any person.
If you are located in
Canada, this section applies to you.
We
may process your information if you have given us specific
permission (i.e. express
consent) to use your personal information for a specific
purpose, or in situations where your permission can be
inferred
(i.e. implied consent). You
can withdraw
your
consent at any time.
In
some exceptional cases, we may be legally permitted under
applicable law to process your information without your
consent,
including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For
investigations and fraud detection and prevention
- For
business transactions provided certain conditions are
met
- If
it is contained in a witness statement and the collection is
necessary to assess, process, or settle an insurance
claim
- For
identifying injured, ill, or deceased persons and
communicating with next of kin
- If
we have reasonable grounds to believe an individual has
been,
is, or may be victim of financial abuse
- If
it is reasonable to expect collection and use with consent
would compromise the availability or the accuracy of the
information and the collection is reasonable for purposes
related to investigating a breach of an agreement or a
contravention of the laws of Canada or a province
- If
disclosure is required to comply with a subpoena, warrant,
court order, or rules of the court relating to the
production
of records
- If it was produced by an
individual in the course of their employment, business, or
profession and the collection is consistent with the
purposes
for which the information was produced
- If the collection is solely
for
journalistic, artistic, or literary purposes
- If the information is publicly
available and is specified by the regulations
In
Short: We may share information
in
specific situations described in this section and/or with
the following third
parties.
We
may need to share your personal information in the
following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW
LONG
DO WE KEEP YOUR
INFORMATION?
In
Short: We keep your
information for as long as necessary to fulfil the purposes
outlined in this privacy notice unless
otherwise
required by law.
We
will only keep
your personal information for as long as it is
necessary for the purposes set out in this
privacy
notice, unless a longer retention period is
required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in
this notice will require us keeping your
personal
information for longer than
the period of
time in which users have an account with us
.
When
we have no
ongoing legitimate business need to process your
personal information, we will either delete or
anonymise such information,
or,
if this is not possible (for example, because
your
personal information has been stored in backup
archives), then we will securely store your
personal information and isolate it from any
further processing until deletion is
possible.
6. HOW DO
WE
KEEP YOUR INFORMATION
SAFE?
In
Short: We aim to
protect your personal information through a
system of
organisational
and
technical security
measures.
We
have
implemented
appropriate and reasonable technical and organisational
security measures
designed to protect the security of any personal
information we process. However, despite our
safeguards and efforts to secure your
information,
no electronic transmission over the Internet or
information storage technology can be guaranteed
to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other
unauthorised
third parties
will
not be able to defeat our security and
improperly
collect, access, steal, or modify your
information. Although we will do our best to
protect your personal information, transmission
of
personal information to and from our Services is
at your own risk. You should only access the
Services within a secure environment.
7. DO WE
COLLECT INFORMATION FROM
MINORS?
In
Short: We do not
knowingly collect data from or market to children under
18 years of age
.
We
do not
knowingly
solicit data from or market to children under 18
years of age. By using the Services, you
represent
that you are at least 18 or that you are the
parent or guardian of such a minor and consent
to
such minor dependent’s use of the Services. If
we
learn that personal information from users less
than 18 years of age has been collected, we will
deactivate the account and take reasonable
measures to promptly delete such data from our
records. If you become aware of any data we may
have collected from children under age 18,
please
contact us at
hello@sleep-healthily.com
.
8. WHAT
ARE
YOUR PRIVACY
RIGHTS?
In
Short:
In some
regions,
such as the
European Economic Area (EEA), United Kingdom
(UK), Switzerland, and Canada , you have
rights that allow you greater access to and
control over your personal
information.
You may
review, change, or terminate your account at
any
time.
In
some regions
(like the
EEA,
UK, Switzerland, and Canada ), you have
certain rights under applicable data protection
laws. These may include the right (i) to request
access and obtain a copy of your personal
information, (ii) to request rectification or
erasure; (iii) to restrict the processing of
your
personal information; (iv) if applicable, to
data
portability; and (v) not to be subject to
automated decision-making. In certain
circumstances, you may also have the right to
object to the processing of your personal
information. You can make such a request by
contacting us by using the contact details
provided in the section '
HOW
CAN YOU
CONTACT US ABOUT THIS
NOTICE?
' below.
We
will consider
and
act upon any request in accordance with
applicable
data protection laws.
If
you are located
in the EEA or UK and you believe we are
unlawfully
processing your personal information, you also
have the right to complain to your Member
State data protection
authority
or UK
data
protection
authority.
If
you are located
in Switzerland, you may contact the Federal Data
Protection and Information
Commissioner.
Withdrawing
your consent: If we are relying
on your consent to process your personal
information,
which may be express and/or implied consent
depending on the applicable law, you
have the right to withdraw your consent at any
time. You can withdraw your consent at any time
by
contacting us by using the contact details
provided in the section '
HOW
CAN YOU
CONTACT US ABOUT THIS
NOTICE?
' below .
However, please note
that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable
law
allows,
will it affect the processing of your
personal information conducted in reliance on
lawful
processing grounds other than consent.
Opting
out
of marketing and promotional
communications: You
can unsubscribe from our marketing and promotional
communications at any time by clicking on the
unsubscribe link in the emails that we send,
or by
contacting
us using the details provided in the section '
HOW
CAN YOU
CONTACT
US ABOUT THIS NOTICE?
' below. You will then
be
removed from the marketing lists. However, we may
still communicate with you — for example, to send
you service-related messages that are necessary
for
the administration and use of your account, to
respond to service requests, or for other
non-marketing purposes.
Account
Information
If you would at any time
like to review or change the information in your
account or terminate your account, you can:
-
Log in to your account settings and update your user account.
Upon your request to
terminate your account, we will deactivate or
delete
your account and information from our active
databases. However, we may retain some information
in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce
our legal terms and/or comply with applicable
legal
requirements.
If you have questions or
comments about your privacy rights, you may email
us
at
privacy@sleephealthily.com
.
9.
CONTROLS
FOR DO-NOT-TRACK
FEATURES
Most
web browsers
and some mobile operating systems and mobile
applications include a Do-Not-Track ( 'DNT' ) feature or setting
you can activate to signal your privacy
preference
not to have data about your online browsing
activities monitored and collected. At this
stage
no uniform technology standard for recognising and implementing DNT
signals has been
finalised .
As
such, we do not currently respond to DNT browser
signals or any other mechanism that
automatically
communicates your choice not to be tracked
online.
If a standard for online tracking is adopted
that
we must follow in the future, we will inform you
about that practice in a revised version of this
privacy notice.
10. DO
UNITED STATES RESIDENTS HAVE SPECIFIC
PRIVACY
RIGHTS?
In
Short: If you are a
resident of
California
,
Colorado
, Connecticut
, Utah
or
Virginia
, you are
granted specific rights regarding access to
your
personal information.
What
categories of personal information do we
collect?
We
have collected
the following categories of personal information
in the past twelve (12)
months:
Category | Examples | Collected |
A.
Identifiers
|
Contact
details, such as real name, alias,
postal
address, telephone or mobile contact
number, unique personal identifier,
online
identifier, Internet Protocol address,
email address, and account
name
|
|
B.
Personal
information as defined in the California
Customer Records
statute
|
Name,
contact information, education,
employment, employment history, and
financial
information
|
|
|
Gender
and
date of birth
|
|
|
Transaction
information, purchase history, financial
details, and payment
information
|
|
|
Fingerprints
and voiceprints
|
|
|
Browsing
history, search history, online
|
|
|
Device
location
|
|
|
Images
and
audio, video or call recordings created
in
connection with our business
activities
|
|
|
Business
contact details in order to provide you
our Services at a business level or job
title, work history, and professional
qualifications if you apply for a job
with
us
|
|
|
Student
records and directory
information
|
|
|
Inferences
drawn from any of the collected personal
information listed above to create a
profile or summary about, for example,
an
individual’s preferences and
characteristics
|
|
|
|
|
- Category B -
As long as the user has an account with us
We
may also collect other
personal information
outside
of these categories
through
instances where you
interact
with us in person, online,
or by phone or mail in the
context
of:
-
Receiving
help through our
customer
support
channels;
-
Participation
in customer surveys or
contests;
and
-
Facilitation
in the delivery of our
Services and to respond
to
your
inquiries.
How
do we use and share your
personal
information?
Learn
about how we use your personal
information in the section,
'
HOW
DO WE PROCESS YOUR
INFORMATION?
'
Will
your information be
shared
with anyone
else?
We
may disclose your personal
information with our
service
providers pursuant to a
written contract between
us
and each service provider.
Learn more about how we
disclose personal
information to in the
section,
'
WHEN
AND WITH WHOM DO WE SHARE
YOUR PERSONAL
INFORMATION?
'
We
may use your personal
information for our own
business purposes, such as
for undertaking internal
research for technological
development and
demonstration. This is not
considered to be
'selling'
of your personal
information.
We
have not disclosed, sold,
or
shared any personal
information to third
parties
for a business or
commercial
purpose in the preceding
twelve (12) months.
We will
not sell or share personal
information in the future
belonging to website
visitors, users, and other
consumers.
California
Residents
California
Civil Code Section 1798.83,
also
known as the
'Shine The Light'
law
permits our users who are
California residents to
request
and obtain from us, once a
year
and free of charge,
information
about categories of personal
information (if any) we
disclosed to third parties for
direct marketing purposes and
the names and addresses of all
third parties with which we
shared personal information in
the immediately preceding
calendar year. If you are a
California resident and would
like to make such a request,
please submit your request in
writing to us using the
contact
information provided
below.
If
you
are under 18 years of age,
reside in California, and have
a
registered account with the
Services, you have the right
to
request removal of unwanted
data
that you publicly post on the
Services. To request removal
of
such data, please contact us
using the contact information
provided below and include the
email address associated with
your account and a statement
that you reside in California.
We will make sure the data is
not publicly displayed on the
Services, but please be aware
that the data may not be
completely or comprehensively
removed from all our systems
(e.g.
backups, etc.).
CCPA
Privacy
Notice
This
section applies only to
California residents. Under
the California Consumer
Privacy Act (CCPA), you have
the rights listed
below.
The
California Code of
Regulations
defines a
'residents'
as:
(1)
every individual who is in
the
State of California for
other
than a temporary or
transitory
purpose and
(2)
every individual who is
domiciled in the State of
California who is outside
the
State of California for a
temporary or transitory
purpose
All
other individuals are
defined
as
'non-residents'.
If
this definition of
'resident'
applies to you, we must
adhere
to certain rights and
obligations regarding your
personal
information.
Your
rights with respect to
your personal
data
Right
to request deletion of
the
data — Request to
delete
You
can ask for the deletion
of
your personal information.
If you ask us to delete
your
personal information, we
will respect your request
and delete your personal
information, subject to
certain exceptions
provided
by law, such as (but not
limited to) the exercise
by
another consumer of his or
her right to free speech,
our compliance
requirements
resulting from a legal
obligation, or any
processing that may be
required to protect
against
illegal
activities.
Right
to be informed — Request
to
know
Depending
on the circumstances, you
have a right to
know:
-
whether
we collect and use your
personal
information;
-
the
categories of personal
information that we
collect;
-
the
purposes for which the
collected personal
information is
used;
-
whether
we sell or share
personal
information to third
parties;
-
the
categories of personal
information that we
sold,
shared, or disclosed for
a
business
purpose;
-
the
categories of third
parties to whom the
personal information was
sold, shared, or
disclosed
for a business
purpose;
-
the
business or commercial
purpose for collecting,
selling, or sharing
personal information;
and
-
the
specific pieces of personal
information we collected
about
you.
In
accordance with applicable
law, we are not obligated
to
provide or delete consumer
information that is
de-identified in response
to
a consumer request or to
re-identify individual
data
to verify a consumer
request.
Right
to Non-Discrimination
for
the Exercise of a
Consumer’s Privacy
Rights
We
will not discriminate
against you if you
exercise
your privacy
rights.
Right
to Limit Use and
Disclosure
of Sensitive Personal
Information
We
do not process consumer's
sensitive personal
information.
Verification
process
Upon
receiving your request, we
will need to verify your
identity to determine you
are the same person about
whom we have the
information
in our system. These
verification efforts
require
us to ask you to provide
information so that we can
match it with information
you have previously
provided
us. For instance,
depending
on the type of request you
submit, we may ask you to
provide certain
information
so that we can match the
information you provide
with
the information we already
have on file, or we may
contact you through a
communication method (e.g.
phone or email)
that
you have previously
provided
to us. We may also use
other
verification methods as
the
circumstances
dictate.
We
will only use personal
information provided in
your
request to verify your
identity or authority to
make the request. To the
extent possible, we will
avoid requesting
additional
information from you for
the
purposes of verification.
However, if we cannot
verify
your identity from the
information already
maintained by us, we may
request that you provide
additional information for
the purposes of verifying
your identity and for
security or
fraud-prevention
purposes. We will delete
such additionally provided
information as soon as we
finish verifying
you.
Other
privacy
rights
-
You
may object to the
processing of your
personal
information.
-
You
may request correction
of
your personal data if it
is incorrect or no
longer
relevant, or ask to
restrict the processing
of
the
information.
-
You
can designate an
-
You
may request to opt out
from future selling or
sharing of your personal
information to third
parties. Upon receiving
an
opt-out request, we will
act upon the request as
soon as feasibly
possible,
but no later than
fifteen
(15) days from the date
of
the request
submission.
To
exercise these rights, you
can contact us
by visiting
https://sleep-healthily-12a12155ea31.herokuapp.com/privacy-policy
,
by email at
hello@sleep-healthily.com
,
or
by referring to the contact
details at the bottom of this
document. If you have a
complaint about how we handle
your data, we would like to
hear
from you.
Colorado
Residents
This
section applies only to
Colorado residents. Under
the
Colorado Privacy Act (CPA),
you have the rights listed
below. However, these rights
are not absolute, and in
certain cases, we may
decline
your request as permitted by
law.
-
Right
to be informed whether or
not we are processing your
personal data
-
Right
to access your personal
data
-
Right
to correct inaccuracies in
your personal
data
-
Right
to request deletion of
your
personal
data
-
Right
to obtain a copy of the
personal data you
previously
shared with us
-
Right
to opt out of the
processing
of your personal data if
it
is used for targeted
advertising, the sale of
personal data, or
profiling
in furtherance of
decisions
that produce legal or
similarly significant
effects (
If
we decline to take action
regarding your request and
you
wish to appeal our decision,
please email us at
privacy@sleephealthily.com
. Within forty-five (45)
days
of receipt of an appeal, we
will inform you in writing
of
any action taken or not
taken
in response to the appeal,
including a written
explanation of the reasons
for
the decisions.
Connecticut
Residents
This
section applies only to
Connecticut residents. Under
the Connecticut Data Privacy
Act (CTDPA), you have the
rights listed below.
However,
these rights are not
absolute,
and in certain cases, we may
decline your request as
permitted by law.
-
Right
to be informed whether or
not we are processing your
personal data
-
Right
to access your personal
data
-
Right
to correct inaccuracies in
your personal data
-
Right
to request deletion of
your
personal
data
-
Right
to obtain a copy of the
personal data you
previously
shared with us
-
Right
to opt out of the
processing
of your personal data if
it
is used for targeted
advertising, the sale of
personal data, or
profiling
in furtherance of
decisions
that produce legal or
similarly significant
effects (
If
we decline to take action
regarding your request and
you
wish to appeal our decision,
please email us at
privacy@sleephealthily.com
. Within sixty (60) days of
receipt of an appeal, we
will
inform you in writing of any
action taken or not taken in
response to the appeal,
including a written
explanation of the reasons
for
the decisions.
Utah
Residents
This
section applies only to Utah
residents. Under the Utah
Consumer Privacy Act (UCPA),
you have the rights listed
below. However, these rights
are not absolute, and in
certain cases, we may
decline
your request as permitted by
law.
-
Right
to be informed whether or
not we are processing your
personal data
-
Right
to access your personal
data
-
Right
to request deletion of
your
personal data
-
Right
to obtain a copy of the
personal data you
previously
shared with us
-
Right
to opt out of the
processing
of your personal data if
it
is used for targeted
advertising or the sale of
personal data
Virginia
Residents
Under
the Virginia Consumer Data
Protection Act
(VCDPA):
If
this definition of
'consumer'
applies to you, we must
adhere
to certain rights and
obligations regarding your
personal data.
Your
rights with respect to
your
personal
data
-
Right
to be informed whether or
not we are processing your
personal data
-
Right
to access your personal
data
-
Right
to correct inaccuracies in
your personal data
-
Right
to request deletion of
your
personal data
-
Right
to obtain a copy of the
personal data you
previously
shared with us
-
Right
to opt out of the
processing
of your personal data if
it
is used for targeted
advertising, the sale of
personal data, or
profiling
in furtherance of
decisions
that produce legal or
similarly significant
effects (
Exercise
your rights provided under
the Virginia
VCDPA
If
you are using an
authorised
agent to exercise your
rights,
we may deny a request if the
authorised
agent does not submit proof
that they have been validly
authorised
to
act on your
behalf.
Verification
process
We
may request that you provide
additional information
reasonably necessary to
verify
you and your consumer's
request. If you submit the
request through an
authorised
agent, we may need to
collect
additional information to
verify your identity before
processing your
request.
Upon
receiving your request, we
will respond without undue
delay, but in all cases,
within forty-five (45) days
of
receipt. The response period
may be extended once by
forty-five (45) additional
days when reasonably
necessary. We will inform
you
of any such extension within
the initial 45-day response
period, together with the
reason for the
extension.
Right
to
appeal
If
we decline to take action
regarding your request, we
will inform you of our
decision and reasoning
behind
it. If you wish to appeal
our
decision, please email us at
privacy@sleephealthily.com
. Within sixty (60) days of
receipt of an appeal, we
will
inform you in writing of any
action taken or not taken in
response to the appeal,
including a written
explanation of the reasons
for
the decisions. If your
appeal
is denied, you may contact
the
Attorney
General to submit a
complaint.
11.
DO WE MAKE UPDATES
TO THIS
NOTICE?
In
Short: Yes,
we will update this
notice
as necessary to stay
compliant with relevant
laws.
We
may update this privacy
notice from time to time.
The updated version will
be
indicated by an updated
'Revised'
date and the updated
version
will be effective as soon
as
it is accessible. If we
make
material changes to this
privacy notice, we may
notify you either by
prominently posting a
notice
of such changes or by
directly sending you a
notification. We encourage
you to review this privacy
notice frequently to be
informed of how we are
protecting your
information.
12.
HOW CAN YOU
CONTACT
US ABOUT THIS
NOTICE?
If
you have questions or
comments about this
notice,
you may
email us at
hello@sleep-healthily.com
or
contact
us by post
at:
13.
HOW CAN YOU
REVIEW,
UPDATE, OR DELETE
THE DATA WE
COLLECT
FROM
YOU?
This privacy policy was created
using Termly's Privacy
Policy Generator.