Sleepify Privacy Policy

Introduction

This Privacy Policy explains how GoodVyzn LLP, a Kazakhstan company BIN 220340025338 («Company» or «we» or «us») collects, stores, uses, transfers and discloses Personal Data from our users («you») in connection with the Sleepify mobile application and related services (collectively, the «App»).

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of this Privacy Policy for you to accept, if we, for example, add new processing activities or collect some additional Personal Data from you.

Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to Privacy Policy to continue using the App. We encourage you to periodically review our Website and the App for the latest information on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

1. Personal data and information we collect from you

Personal data you provide to us

When you sign up to use the App, we may collect Personal Data about you such as:

  • a. Email address or alias;
  • b. Your full name or nickname;
  • c. the states that you've experienced throughout a certain period of time up to the moment of the survey;
  • d. the feelings that you've experienced throughout a certain period of time up to the moment of the survey;
  • e. the thoughts that have been bothering you throughout a certain period of time up to the moment of the survey;
  • f. the difficulties that you've faced throughout a certain period of time up to the moment of the survey;
  • g. other information regarding your health, lifestyle and activities (collectively, "Personal data").

Information we collect automatically

  • a. Device Information: We collect information about the mobile device you use to access the App, including the hardware model, information about the operating system and its version.
  • b. Location Information: We collect your IP address, time zone, and information about your mobile service provider, which allows us to infer your general location.
  • c. Application usage information: We use various technologies to collect information about your use of the App, such as frequency of use, which areas and features of our App you visit and your use patterns generally, engagement tracking with particular features, etc.

We may use third-party tools like Appsflyer, Google Firebase, Amplitude and Facebook SDK that provide us some of your attribution data that we further utilize to customize and personalize the App for you. We may also use such data for statistical purposes and analytics.

If the information covered by this Section is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent information covered by this Section is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as «Personal Data».

YOUR CONSENT

I. WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED TO US.

II. PERSONAL DATA YOU PROVIDE TO US THROUGH THE ACCOUNT CREATION PROCESS INCLUDES PERSONAL DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA, AND YOUR MENTAL HEALTH DATA .

III. WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES UNLESS OTHERWISE IS PROVIDED BY THIS PRIVACY POLICY. PLEASE NOTE THAT WE WILL NEVER SHARE YOUR EXACT AGE OR ANY DATA RELATED TO YOUR HEALTH WITH ANY THIRD PARTIES.

2. How we use your personal data and information

We may use your information, including your Personal Data, for the following purposes and in accordance with the indicated legal bases (as defined in the GDPR):

  • a. to analyze, operate, maintain and improve the App, to add new features and services to the App (Company’s legitimate interest – art. 6.1 (f));
  • b. to customize content, insights and patterns you see when you use the App (Company’s legitimate interest – art. 6.1 (f);
  • c. to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders (Company’s contractual obligation – art. 6.1 (b);
  • d. to customize product and service offerings and recommendations to you, including third-party products and offerings (except data from Apple HealthKit) (Company’s contractual obligation – art. 6.1 (b);
  • e. to send you technical notices, updates, security alerts and support and administrative messages (Company’s contractual obligation – art. 6.1 (b);
  • f. for billing (invoicing), account management and other administrative purposes, if applies (Company’s contractual obligation – art. 6.1 (b);
  • g. to respond to your comments, questions and requests and provide customer service (Company’s contractual obligation – art. 6.1 (b);
  • h. to monitor and analyze trends, usage and activities in connection with our App (Company’s legitimate interest – art. 6.1 (f);
  • i. to link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service (to use in training of neural networks, artificial intelligence, as well as for any other automated decision-making processing) (Company’s legitimate interest – art. 6.1 (f);
  • j. for scientific and academic research purposes (Company’s legitimate interest – art. 6.1 (f); and
  • k. for any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.

No sale of Personal Data.

We will never sell, rent, or disclose your Personal Data. We may share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this Privacy Policy.

We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with Section 2 of this Privacy Policy or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the Privacy Policy.

3. Your rights

Modification, correction and erasure.

You are able to modify, correct, erase, and update your Personal Data by writing us at help@sleepify.club. Please be aware that erasing some Personal Data inserted by you may affect your possibility to utilize the App and its features. Erasure of some Personal Data may also take some time due to technical reasons.

Right to object to processing of your Personal Data.

You can object to the processing your Personal Data in case you believe that the processing is illegal or that the legitimate interest of the Company is invalid in some particular situation. In such a case you may simply write to us at help@sleepify.club. Please be aware that some objections to processing also imply erasure of your Personal Data, which may affect your possibility to use the App and its features. Please note that the Company still has the right to decline your request in case the legitimate interest of the Company for such processing remains valid.

How to exercise your privacy rights.

Сontact us at help@sleepify.club to exercise any of your privacy rights.

We will exercise them within 30 days after receipt. It may take us up to 60 days in some cases, for example for full erasure of your Personal Data stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.

4. Sharing your personal data and information

A. Personal Data we share with third parties.

We will not share your Personal Data with any third parties except as specified by the Section 4 and Section 11 of the Privacy Policy.

We may share some of your Personal Data with AppsFlyer, a mobile marketing platform. By using AppsFlyer and its integrated partners we are able to reach more people like you and spread the word about the App to help more people to stay in control with their mental health.

At the same time, AppsFlyer sends your data to some of its integrated partners (e.g. Pinterest, Google Ads, Apple Search Ads, Facebook/Meta marketing network, and a couple of others) to find people like you on different platforms, including social media websites. These integrated partners analyze your data (so-called "custom audience") and show relevant information about the App to people who might be potentially interested in it (so-called "lookalike audience").

We may also directly share your Personal data as defined by this Section of the Privacy Policy with the following third-party services:

  1. 1. Facebook/Meta Lookalike Audiences. We utilize Facebook advertising service called "lookalike audiences" to identify potential new Sleepify users on Facebook based on the information from the existing Sleepify users. We use the service to identify people on Facebook who might like Sleepify as much as our current users do.
  2. 2. Snapchat. Snapchat is a popular social network, and we utilize its targeting features to reach more people on Snapchat like our users.

You become a Sleepify App user and opt-in for sharing Personal data, strictly limited to the following set:

  1. a. Hashed technical identifiers: IP address (which may also provide general location information), user agent, IDFA (Identifier for Advertisers), Google Advertiser ID, Customer-issued user ID, and other similar unique technical identifiers;
  2. b. Your subscription status;
  3. c. The fact of application launch;
  4. d. Your actions in the app.

B. Aggregated Information.

We may share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you, including with our partners or research institutions.

C. Special Circumstances.

We will not share any of your Personal Data to any third party except as otherwise stated in this Privacy Policy and in the following circumstances: (i) in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements); (ii) when disclosure is required to maintain the security and integrity of the App, or to protect any user's security or the security of other persons, consistent with applicable laws; (iii) when disclosure is directed or consented to by the user who has input the Personal Data; (iv) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.

D. Processing to make the App run.

We engage processors that perform particular operations with your Personal Data for us.

Processors are companies that help us run the App, support our communication with you or perform other App-related activities. They may process certain Personal Data on our behalf to accomplish the goals related to the App functions and associated activities. Processors act only in accordance with our instructions and process only such amount of Personal Data as we instruct them to process.

5. Retention of your personal data

We will retain your Personal Data for as long as your account is active or needed to provide you services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can remove your Personal Data as specified in Section 3 of this Privacy Policy.

You should be aware that we may retain certain Personal Data and other information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We are not obligated to remove your posts or comments. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.

If you choose to delete the App, deactivate your account, we retain your Personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

6. Personal data you elect to share with third parties

You can direct us to share data from the App with other parties. For example, you can permit us to share data with other health apps and services like Apple HealthKit. Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time in your App account settings.

We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern processing of your Personal Data.

7. Security

We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:

  1. a. Encryption of your Personal Data in transit and in rest;
  2. b. Protection of data integrity;
  3. c. Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won't be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in this Privacy Policy.

8. Children's privacy

The App is not intended for children and we do not intentionally collect information about children under 18 years old.

9. Third party links

Although the App may contain links to third party websites or services, we are not responsible for the privacy policies and/or practices on those third-party websites or services. Please understand that this Privacy Policy applies only to information we collect from you. Where we have linked to a third-party website or service, you should read the privacy policy stated on that third-party website or service.

10. Privacy of payments

To process payments for particular features and functions of the App we may engage third-party payment providers.

For example, we use Apple for processing of payments in connection with our subscriptions offered on App Store. Please note that we never collect and we are not responsible for the collection or security of banking, financial, and payment information. Such information is processed and stored by Apple only. Apple can be contacted through their website: https://apple.com.

11. Email Communications

If the you consent to the email communications, we may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the "Unsubscribe" link contained in the email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App. If applicable laws prescribe so, certain exclusions may apply to the residents of some countries regarding an active opt-in for any email communications from us. We may ask such users to provide their consent for any such communications at the registration screen.

In order to provide communication services, we may engage third-party service providers to carry out such newsletter services, surveys or notifications campaigns.

12. Contact us

If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at help@sleepify.club.