Privacy Policy

1. Introduction

Thanks for choosing Sleep Easy!

At Sleep Easy we want to give you the best possible experience to ensure that you enjoy our service. Your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.

That is our objective, and this Privacy Policy ("Policy") will explain exactly what we mean in further detail below.

2. About this Policy

This Policy sets out the essential details relating to your personal data relationship with Sleep Easy, LLC. The Policy applies to all Sleep Easy services and any associated services, including are App (our "Services"). The terms governing your use of the Service are defined in our Terms of Service (the "Terms of Service").

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

The aim of this Policy is to:

1. Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
2. Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Service; and
3. Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see Section 13 "How to contact us" below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Service.

3. Your rights and your preferences: Giving you choice and control

The General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

• Right of access - the right to be informed of, and request access to, the personal data we process about you;
• Right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to erasure - the right to request that we delete your personal data;
• Right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to object -
• the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
• the right to object to your personal data being processed for direct marketing purposes;
• Right to data portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service; and
• Right not to be subject to automated decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

If you have any questions about your privacy, your rights, or how to exercise them, please contact us - see Section 13 "How to contact us."

4. Personal data we collect from you

We have set out in the tables below the categories of personal data we collect and use about you and how we collect it:

The table below describes personal data collected when you sign up for the Service:

Categories of personal data	Description of category
User Data	This is personal data that is provided by you or collected by us to enable you to sign up for and use the Service. Depending on the type of Service plan you sign up for, this may include your username, email address, phone number, birth date, gender, street address, and country. Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with additional personal data in order to make your account more personalized. The exact personal data we will collect depends on the type of plan you sign up for, how you create an account, and whether you use third party services (such as Facebook) to sign up and use the Service. If you use a third party service to create an account, we will receive personal data via that third party service but only when you have consented to that third party service sharing your personal data with us. Please note that the available plans and sign-up options may differ by country.
Usage Data	This is personal data that is collected about you when you're accessing and/or using the Service, including: Information about your type of plan. Information about your interactions with the Service. Content you post to the Sleep Easy App. Certain technical data, which may include: URL information; Online identifiers including cookie data and IP addresses; Information about the types of devices you are using such as unique device IDs, network connection type, provider, network and device performance, browser type, language, information enabling digital rights management and operating system; Device attributes of devices on your Wi-Fi network that are available to connect to the Service (such as speakers); and Your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your devices, or payment currency).
Payment and Purchase Data	We may collect certain personal data if sign up for a trial or purchase any of our paid subscriptions or make other purchases through the Service. The exact personal data collected will vary depending on the payment method, but will include information such as: Name; Date of birth; Credit or debit card type, expiration date and certain digits of your card number; Postal code; Mobile phone number; and Details of your purchase and payment history.
Surveys and Research	When you complete any forms or respond to a survey or questionnaire, we collect the personal data you provide.
Authentication partners	If you register for or log into the Services using third party credentials (e.g., Facebook), we will import your information from such third party to help create your account with us.
Technical service partners	We work with technical service partners that provide us with certain data, such as mapping IP addresses to non-precise location data (e.g., city, state), to enable us to provide the Services, content and features.
Payment partners	If you choose to pay for a service or feature by invoice, we may receive data from our payment partners to enable us to send you invoices, process your payment and provide you with what you've purchased.
Advertisers and other advertising partners	We may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.

5. What we use your personal data for

When you use or interact with the Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 4 "Personal data we collect from you") used for these purposes:

Description of why Sleep Easy processes your personal data ("processing purpose")	Legal basis for the processing purpose	Categories of personal data used by Sleep Easy for the processing purpose
To provide and personalize the Service	Performance of a contract Legitimate interest Consent	User Data Usage Data Payment and purchase data
To understand, diagnose, troubleshoot, and fix issues with the Service	Performance of a contract Legitimate interest	User Data Usage Data
To evaluate and develop new features, technologies and improvements to the Services	Legitimate interest Consent	User Data Usage Data
For market, promotion, and advertising purposes	Legitimate interest Consent	User Data Usage Data
To comply with legal obligations and law enforcement requests	Compliance with legal obligations Legitimate interest	User Data Usage Data Payment and Purchase Data
To fulfill contractual obligations with third parties, for example licensing agreements and to take appropriate action with respect to reports of intellectual property infringement and inappropriate content	Legitimate interest	User Data Usage Data Payment and Purchase Data
To establish, exercise or defend legal claims	Legitimate interest	User Data Usage Data Payment and Purchase Data
To conduct business planning, reporting and forecasting	Legitimate interest	User Data Usage Data Payment and Purchase Data
To process your payment	Performance of a contract Compliance with legal obligations	User Data Payment and Purchase Data
To detect fraud, including fraudulent payments and fraudulent use of the Service	Performance of a contract Compliance with legal obligations Legitimate interest	User Data Usage Data Payment and Purchase Data
To conduct research and surveys	Performance of a contract Legitimate interest Consent	User Data Usage Data Surveys and Research

If you require further information about the balancing test that Sleep Easy has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 13 "How to contact us" for further details on how to contact us.

6. Sharing your personal data

We have set out the categories of recipients of the personal data collected or generated through your use of the Service.

Publicly available information

The following personal data will always be publicly available on the Service: your name and/or username.

Personal data you may choose to share

The following personal data will only be shared with the categories of recipients outlined in the table below if:

• you choose to make use of a specific Service feature where sharing of particular personal data is required for the proper use of the Service feature; or
• you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Service or authorizing through a presented consent mechanism.

Categories of Recipients	Reason for sharing
Third party applications and devices you connect to your Sleep Easy account	If you connect your Sleep Easy account to a third party application and/or device(s), such as, social media, audio, television, or automotive platforms and services, Sleep Easy shares technical data with the operator of that third party application and/or device in order to connect your Sleep Easy account. With respect to certain third parties which may request or require that we share your information with them, your permission will be requested before we provide your information to such third parties.
Support community

Learn more about how to manage notifications, your publicly available information, and what you share with others in Section 3 "Your rights and your preferences: Giving you choice and control" of this Policy.

Information we may share

Categories of Recipients	Reason for sharing
Service providers	We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we've hired to provide customer service support, operate the technical infrastructure that we need to provide the Service, assist in protecting and securing our systems and services, and help market Sleep Easy's own products and services as well as partner products, services, events, and co-branded promotions in which Sleep Easy is or may be involved.
Payment processors	We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.
Advertising partners	We work with advertising partners to enable us to customize the advertising content you may receive on the Service. These partners help us deliver more relevant ads and promotional messages to you, which may include interest based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the Service. We and our advertising partners may process certain personal data to help Sleep Easy understand your interests or preferences so that we can deliver advertisements that are more relevant to you.
Sleep Easy partners	Depending on how you sign up for the Service (e.g. through a third party service or a mobile provider), we share your Sleep Easy username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the Service, such as whether and to what extent you have used the offer, activated a Sleep Easy account, or actively used the Service.
Academic researchers	We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymized.
Law enforcement and data protection authorities	We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party's legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business	We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Sleep Easy will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.

7. Data retention and deletion

We keep your personal data only as long as necessary to provide you with the Service and for legitimate and essential business purposes, such as maintaining the performance of the Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Service. For example, we keep your account information.

If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

• If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
• Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
• Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

8. Transfer to other countries

Sleep Easy may subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country.

9. Links

We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties' privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

10. Keeping your personal data safe

We are committed to protecting our users' personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we encourage you to use a strong password that is unique to your Sleep Easy account, never share your password with anyone, limit access to your computer and browser, and log out after having used the Service.

11. Children

The Service is not directed to children under the age of 13 years. The Service is also not offered to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under the GDPR or other local law.

We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the "Age Limit"). If you are under the Age Limit, please do not use the Service, and do not provide any personal data to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Sleep Easy, please contact us and you may request exercise of your applicable rights detailed in Section 3 "Your rights and your preferences: Giving you choice and control" of this Policy.

If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Sleep Easy account for that child.

12. Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending you an email and/or a device notification. We may notify you in advance.

Please, therefore, make sure you read any such notice carefully.

13. How to contact us

Thank you for reading our Policy. If you have any questions about this Policy, please contact our Data Protection Officer by emailing info@sleepeasymethod.com, or by writing to us at the following address:

Sleep Easy, LLC
1077 Canyon Blvd 304
Boulder, CO 80302

We hope you enjoy Sleep Easy!