Proactive Life Privacy Policy

Contents

PART ONE: INTRODUCTION

WE AT PROACTIVE LIFE, INC. D/B/A SLEEPSPACE (“SleepSpace”, “We”, “Us”, “Company”) VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF PROVIDING YOU A PLATFORM TO MONITOR, TRACK, AND TRANSMIT YOUR HEART RATE, MOTION DATA, SOUND DATA, LOCATION DATA, EEG DATA, AND/OR OTHER PHYSIOLOGICAL DATA, IN ADDITION TO SUBJECTIVE DATA ABOUT SLEEP AND HABITS THAT MAY INCLUDE ALCOHOL AND MEDICATION USE, FOR THE PURPOSE OF DISPLAYING SLEEP STAGES, QUALITY, EFFICIENCY, CORTICAL AROUSALS, ESTIMATES OF HYPOPNEAS AND OTHER ANALYSES RELATED TO SLEEP HEALTH TO YOU AND/ OR YOUR SLEEPSPACE PROVIDER (THE “PROVIDER”) BY OFFERING YOU A CONVENIENT AND HIGH-QUALITY APPLICATION THAT WILL COLLECT SUCH DATA FROM YOUR DEVICE(S) AND SECURELY TRANSMIT THEM TO YOU AND/ OR YOUR PROVIDER FOR REVIEW AND CARE DECISIONS.

THIS PRIVACY POLICY APPLIES TO PERSONAL DATA SLEEPSPACE COLLECTS FROM USERS OF THE SLEEPSPACE APPLICATION (THE “APP”) AND RELATED DEVICES. “PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION IN COMBINATION TO IDENTIFY OR CONTACT ONE OF OUR USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL DATA IS OF UTMOST IMPORTANCE. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE YOUR PERSONAL DATA, HOW WE PROTECT PERSONAL DATA, AND YOUR RIGHTS REGARDING YOUR PERSONAL DATA.

Please read the following carefully to understand our views and practices regarding Your Personal Data.

BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS APP, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE APP AND DO NOT SUBMIT ANY PERSONAL DATA TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS ON OUR WEBSITE AND NOTIFY YOU VIA THE EMAIL ADDRESS YOU HAVE PROVIDED TO US. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL PERSONAL DATA WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE APP FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case You have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact us at dr.snooze@sleepspace.com. We appreciate Your feedback.

PART TWO: POLICY SUMMARY

For Your convenience, We have summarized the key takeaways from our Privacy Policy, below. You may access our full Privacy Policy HERE.

Responsible Entity

Proactive Life, Inc. d/b/a SleepSpace (“SleepSpace”, “We”, “Us”, “Company”) is the controller of Your Personal Data and may process this data in accordance with this Privacy Policy. If We are processing Personal Data on behalf of a third party, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about our Privacy Policy at dr.snooze@sleepspace.com.

What information do We collect and why?

We collect “Personal Data”, which includes any information that can be used on its own or with other information in combination to identify or contact You. For a description of the types of Personal Data We collect, review this section in the full Privacy Policy. In some cases, this Personal Data may be or may include healthcare information or “protected health information”.

We may use Personal Data to (1) provide You with the web and mobile App and all of its content and functionality (collectively, the “Services”); (2) communicate with You about and manage Your User Account; (3) store data; (4) comply with the law; (5) respond to requests from public and government authorities; (6) to enforce Our terms and conditions; (7) manage and improve Our operations and applications; (8) provide additional functionality; (9) protect Our rights, privacy, safety or property, and/or that of You or others; and (10) allow Us to pursue available remedies or limit the damages that We may sustain. Additional uses are described in this section of the full Privacy Policy.

We only use or disclose Your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described above (and in the full Privacy Policy). Where required by law, We will ask for Your prior consent before doing so.

Failure to Provide Data. Providing Your Personal Data is not statutorily or contractually mandated. However, if You choose not to provide this information, We cannot create a User Account, and You will be unable to use our Services.

Will We share Your Personal Data with anyone else?

Yes, with the Provider(s) with whom You choose to share Your Personal Data via the App (if applicable)
Yes, with third parties that help us power Our App
Yes, with third parties and the government when legal or enforcement issues arise
Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of SleepSpace’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).

For more details regarding the above, review this section in the full Privacy Policy.

Where is Your Personal Data stored, transmitted, and/or maintained?

Personal Data SleepSpace collects through the App will be stored on secure servers in the United States. Some Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer Your Personal Data outside of the United States. The App is “native” to Your device, meaning information You enter into the App is also stored directly on the device You use to access and enter information into the App.

How long will We maintain Your Personal Data?

We store Your Personal Data for as long as You maintain a User Account and up to 5 years after the account is closed. For more information on Personal Data retention, review this section of the full Privacy Policy.

How do We protect Your Personal Data?

SleepSpace uses a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of Your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in Our possession or control that could result in substantial harm or inconvenience to You. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, We cannot ensure the security of information You transmit to Us. By using the App, You are assuming this risk. For more information on the safeguards that We have in place to protect Your Personal Data, review this section of the full Privacy Policy.

Your rights

You have certain rights relating to Your Personal Data, subject to local data protection laws. These rights may include:

to access Your Personal Data held by Us;
to erase/delete Your Personal Data, to the extent permitted by applicable data protection laws;
to receive communications related to the processing of Your personal data that are concise, transparent, intelligible, and easily accessible;
to restrict the processing of Your Personal Data to the extent permitted by law (while We verify or investigate Your concerns with this information, for example);
to object to the further processing of Your Personal Data, including the right to object to marketing;
to request that Your Personal Data be transferred to a third party, if possible;
to receive Your Personal Data in a structured, commonly used, and machine-readable format;
to lodge a complaint with a supervisory authority;
to rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); and
to the extent We base the collection, processing and sharing of Your Personal Data on Your consent, to withdraw Your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

For more details on Your rights and choices and how to exercise them, please review the full Privacy Policy.

How do You contact Us with questions or concerns?

If You have any questions about this Privacy Policy, please contact Us by email at dr.snooze@sleepspace.com or please write to: Proactive Life, Inc., 180 Bowery, NYC, NY 10012. Please note that email communications are not always secure; so please do not include sensitive information in Your emails to Us.

PART THREE: FULL PRIVACY POLICY

Version 1

Last Updated: July 8, 2021

WE AT PROACTIVE LIFE, INC. D/B/A SLEEPSPACE (“SleepSpace”, “We”, “Us”, “Company”) VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF PROVIDING YOU A PLATFORM TO MONITOR, TRACK, AND TRANSMIT YOUR HEART RATE, MOTION DATA, SOUND DATA, LOCATION DATA, EEG DATA, AND/OR OTHER PHYSIOLOGICAL DATA, IN ADDITION TO SUBJECTIVE DATA ABOUT SLEEP AND HABITS THAT MAY INCLUDE ALCOHOL AND MEDICATION USE, FOR THE PURPOSE OF DISPLAYING SLEEP STAGES, QUALITY, EFFICIENCY, CORTICAL AROUSALS, ESTIMATES OF HYPOPNEAS AND OTHER ANALYSES RELATED TO SLEEP HEALTH TO YOU AND/ OR YOUR PROVIDER BY OFFERING YOU A CONVENIENT AND HIGH-QUALITY APPLICATION THAT WILL COLLECT SUCH DATA FROM YOUR DEVICE(S) AND SECURELY TRANSMIT THEM TO YOU AND/ OR YOUR PROVIDER FOR REVIEW AND CARE DECISIONS.

THIS PRIVACY POLICY APPLIES TO PERSONAL DATA SLEEPSPACE COLLECTS FROM USERS OF THE SLEEPSPACE APPLICATION (THE “APP”) AND RELATED DEVICES. “PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION IN COMBINATION TO IDENTIFY OR CONTACT ONE OF OUR USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL INFORMATION IS OF UTMOST IMPORTANCE. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION.

SOME OF THE PERSONAL DATA WE COLLECT AND TRANSMIT WILL, IN SOME CIRCUMSTANCES, BE CONSIDERED “HEALTH DATA” (data related to a User’s physical or mental health) or “Protected Health Information” (information that relates to the past, present, or future physical or mental health or condition of a User; the provision of health care to a User; or the past, present, or future payment for the provision of health care to User). THEREFORE, OUR PRIVACY PRACTICES ARE INTENDED TO COMPLY WITH BOTH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA“) AND THE GENERAL DATA PROCESSING REGULATION (“GDPR”) PROVISIONS REGARDING SENSITIVE PERSONAL DATA. IN ADDITION, WE INTEND TO COMPLY WITH STATE LAW RELATED TO HEALTH DATA, WHERE APPLICABLE. FOR ADDITIONAL INFORMATION RELATED TO YOUR HEALTHCARE INFORMATION, PLEASE CONTACT OUR PRIVACY OFFICER AT DR.SNOOZE@SLEEPSPACE.COM.

BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS APP, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE APP AND DO NOT SUBMIT ANY PERSONAL DATA TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS ON OUR WEBSITE AND WILL ALSO NOTIFY YOU VIA EMAIL. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE APP FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case You have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact Us at dr.snooze@sleepspace.com. We appreciate Your feedback. If You do not agree or no longer agree to the processing of personal information as described in this Privacy Policy, You can delete Your account by notifying us by email at dr.snooze@sleepspace.com.

Responsible Entity

Proactive Life, Inc. d/b/a SleepSpace (“We”, “Us”, “the Company”, “SleepSpace”) is the controller of Your Personal Data and may process this data in accordance with the Privacy Policy. If We are processing Personal Data on behalf of a third party that is not an agent or affiliate of Company, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about Our Privacy Policy at dr.snooze@sleepspace.com.

Links to Other Sites

Our App may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that You provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We are not responsible for the content, privacy, or security practices and policies of any Third-party Service. To protect Your information, We recommend that You carefully review the privacy policies of all Third-party Services that You access.

What Personal Data do We collect?

We collect Personal Data, which includes the following types of data, and may include healthcare information or PHI. The types of Personal Data We collect are described below.

Google Fit Data

SleepSpace requires Google fitness API access in order to read sleep and health data and display your sleep health statistics. SleepSpace is a sleep tracking application for users to view historical sleep data that they use to gain insights into their habits and ways to improve sleep. To achieve this, the app requires access to the Google Fit datasource. Google Fit supports sleep and heart rate tracking (a relevant measure of sleep health). We use these data to display a sleep stage hypnogram and calculate sleep statistics like sleep onset latency, number of awakenings, and wake after sleep onset. We augment this data by displaying heart rate graphs, sound in room, and phone motion data, where variations in these data streams can be representative of sleep health.

Demographic Data

We collect demographic information, such as Your name, height, weight, phone number, email address, physical location address, and employer(s) (optional). Primarily, the collection of Your Personal Data assists us in creating Your User Account, which You can use to securely to receive the Services.

Payment Data

If You make payments via our App, We may require that You provide to Us Your financial and billing information, such as billing name and address, credit card number or bank account information.

Support Data

If You contact Us for support or to lodge a complaint, We may collect technical or other information from You through log files and other technologies, some of which may qualify as Personal Data. (e.g., “IP address”). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the App and related services in accordance with this Privacy Policy.

Device, Telephone, and ISP Data

We use common information-gathering tools, such as log files, cookies, Web beacons, and similar technologies to automatically collect information, which may contain Personal Data, from Your computer or mobile device as You navigate our App, or interact with emails We have sent You. The information We collect may include Your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files You viewed, Your searches, Your operating system and system configuration information, and date/time stamps associated with Your usage. This information is used to analyze overall trends, to help Us provide and improve Our Services and to guarantee their security and continued proper functioning.

Health and Device Data

In addition to demographic information, We will collect information regarding Your health conditions, age, gender, weight, height, medical history, symptoms, information from Your connected device, and communications between You and the Provider providing sleep coaching services to You via the App (if applicable). We collect this information to provide You with the Services and to provide the provider providing sleep coaching services through the App (if applicable) with the information required to provide medical treatment.

How will We use Your Personal Data?

We process Your Personal Data for purposes based on legitimate business interests, the fulfillment of our Services to You, compliance with Our legal obligations, and/or Your consent. We only use or disclose Your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described herein. Where required by law, We will ask for Your prior consent before doing so.

Specifically, We process Your Personal Data for the following legitimate business purposes:

To fulfill our obligations to You under the Terms of Use;
To communicate with You about and manage Your User Account;
To properly store and track Your data within Our system;
To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings or court orders;
To protect Our rights, privacy, safety, or property, and/or that of You or others by providing proper notices, pursuing available legal remedies, and acting to limit Our damages;
To handle technical support and other requests from You;
To enforce and ensure Your compliance with Our Terms of Use or the terms of any other applicable services agreement We have with You;
To manage and improve Our operations and the App, including the development of additional functionality;
To manage payment processing;
To evaluate the quality of service You receive, identify usage trends, and thereby improve Your User experience;
To keep Our App safe and secure for You and for Us;
To send You information about changes to Our terms, conditions, and policies;
To allow Us to pursue available remedies or limit the damages that We may sustain; and
To provide access to your Provider (with Your consent), to enable that individual to provide sleep coaching services and monitor Your progress and overall condition as they deem appropriate (if applicable).

Where is Your Personal Data processed?

Personal Data SleepSpace collects through the App will be stored on secure servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer Your Personal Data outside of the United States. The App is “native” to Your device, meaning information You enter into the App is also stored directly on the device You use to access and enter information into the App.

Will We share Your Personal Data with anyone else?

Yes, with the Provider(s) with whom You connect via the App (if applicable)

We will share information You enter into the App, information collected from the connected device, as well as any reports generated by the App based on the information You enter, with the Provider with whom connect via the Application. If, at any point, You want to deny access to one or more Providers, You can do so by emailing dr.snooze@sleepspace.com.

Yes, with third parties that help us power our App

SleepSpace has a limited number of service providers and other third parties (“Business Partners”) that help Us run various aspects of Our business. These Business Partners are contractually bound to protect Your Personal Data and to use it only for the limited purpose(s) for which it is shared with Us. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, customer service, and payment processing.

Yes, with third parties and the government when legal or enforcement issues arise

We may share Your Personal Data, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in

investigating acts in violation of this Agreement; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of SleepSpace or any third party, including other Users.

Yes, with third parties that provide advisory services

We may share Your Personal Data with Our lawyers, auditors, accountants, or banks, when We have a legitimate business interest in doing so.

Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of SleepSpace’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).

If We share Your Personal Data with a third party other than as provided above, You will be notiﬁed at the time of data collection or transfer, and You will have the option of not permitting the transfer.

How long do We retain Personal Data?

We will retain Your Personal Data for as long as You maintain a User Account and up to five (5) years after the account is closed. The exact period of retention will depend on the type of Personal Data, Our contractual obligation to You, and applicable law. We keep Your Personal Data for as long as necessary to fulfill the purpose for which it was collected, unless otherwise required or necessary pursuant to a legitimate business purpose outlined herein. At the end of the applicable retention period, We will remove Your Personal Data from Our databases and will request that Our Business Partners remove Your Personal Data from their databases. If there is any data that We are unable, for technical reasons, to delete entirely from our systems, We will put in place appropriate measures to prevent any further processing of such data. We retain anonymized data indeﬁnitely.

NOTE: Once We disclose Your Personal Data to third parties, We may not be able to access that Personal Data any longer and cannot force the deletion or modiﬁcation of any such information by the parties to whom We have made those disclosures. Written requests for deletion of Personal Data other than as described should be directed to dr.snooze@sleepspace.com.

What is Our Cookie Policy?

Cookies are small files that a web server sends to Your computer or device when You visit a web site that uses cookies to keep track of Your activity on that site. Cookies also exist within applications when a browser is needed to view certain content or display certain content within the application. Cookies hold a small amount of data specific to that web site, which can later be used to help remember information You enter into the site (like Your email or other contact info), preferences selected, and movement within the site. If You return to a previously visited web site or application (and Your browser has cookies enabled), the web browser sends the small file to the web server, which tells it what activity You engaged in the last time You used the web site or application, and the server can use the cookie to do things like expedite logging in and retrieving User data and keeping Your browser session secure.

We use cookies and other technologies to, among other things, better serve You with more tailored information, and to facilitate eﬃcient and secure access to the App. We only use essential cookies. Essential cookies are those necessary for Us to provide services to You. We have provided, below, a full list of our cookies, categorized as described above. We have described the purpose of each, whether they are SleepSpace or Third-Party cookies, and how to withdraw consent to their use. We have also indicated which cookies are “session cookies” (which last for as long as You keep Your browser open) and “persistent cookies” (which remain on Your hard drive until You delete them or they expire).

We may also collect information using pixel tags, web beacons, clear GIFs, or other similar technologies. These may be used in connection with some web site or application pages and HTML-formatted email messages to, among other things, track the actions of Users and email recipients, and compile statistics about usage and response rates.

Essential Cookies:

Cookie Name, Who Controls It, and Duration	Purpose	Information Collected	How to Withdraw Consent
AspNetCore.Antiforgery SleepSpace During active session	To help prevent cross-site request forgery attacks	A generated token that allows the server to identify You.	Do not use our Services if You do not want to receive this cookie.
Asp.Net_SessionID. SleepSpace During active session	To refresh Your authentication token when it expires.	A generated token that lets You log in.	Do not use our Services if You do not want to receive this cookie.
ASPXAUTH SleepSpace During active session	Identifies the user and allows authentication to the server	A generated token that lets You log in.	Do not use our Services and do not unsubscribe from automated emails if You do not want this cookie.

How can You “Opt Out” of Cookies?

If You prefer, You can usually choose to set Your browser to remove cookies and reject cookies. If You enable a do not track (“DNT”) signal or otherwise configure Your browser to prevent SleepSpace from collecting cookies, You will need to reenter Your username each time You visit the login page.

How do We protect Your Personal Data?

SleepSpace is committed to protecting the security and conﬁdentiality of Your Personal Data. We use a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of Your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in Our possession or control that could result in substantial harm or inconvenience to You. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, We cannot ensure the security of information You transmit to Us. By using the App, You are assuming this risk.

Safeguards

The information collected by SleepSpace and stored on secure servers, is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, encryption, backups, and access controls. If SleepSpace learns of a security concern, We may attempt to notify You and provide information on protective steps, if available, through the email address that You have provided to Us or via push notification sent through the App. Depending on where You live, You may have a legal right to receive such notices in writing.

You are solely responsible for protecting information entered or generated via the App that is stored on Your device and/or removable device storage. SleepSpace has no access to or control over Your device’s security settings, and it is up to You to implement any device level security features and protections You feel are appropriate (e.g., password protection, encryption, remote wipe capability, etc.). We recommend that You take any and all appropriate steps to secure any device that You use to access Our App.

NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED DESPITE THE IMPLEMENTATION OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US AND YOU TRANSMIT SUCH PERSONAL DATA AT YOUR OWN RISK.

How can You Protect Your Personal Data?

In addition to securing Your device, as discussed above, We will NEVER send You an email requesting conﬁdential information such as account numbers, usernames, passwords, or social security numbers, and You should NEVER respond to any email requesting such information. If You receive such an email purportedly from SleepSpace, DO NOT RESPOND to the email and DO NOT click on any links and/or open any attachments in the email, and notify SleepSpace support at dr.snooze@sleepspace.com.

You are responsible for taking reasonable precautions to protect Your User ID, password, and other User Account information from disclosure to third parties, and You are not permitted to circumvent the use of required encryption technologies. You should immediately notify SleepSpace at dr.snooze@sleepspace.com if You know of or suspect any unauthorized use or disclosure of Your User ID, password, and/or other User Account information, or any other security concern.

Your rights

You have certain rights relating to Your Personal Data, subject to local data protection laws. These rights may include:

to access Your Personal Data held by Us;
to erase/delete Your Personal Data, to the extent permitted by applicable data protection laws;
to receive communications related to the processing of Your personal data that are concise, transparent, intelligible, and easily accessible;
to restrict the processing of Your Personal Data to the extent permitted by law (while We verify or investigate Your concerns with this information, for example);
to object to the further processing of Your Personal Data, including the right to object to marketing;
to request that Your Personal Data be transferred to a third party, if possible;
to receive Your Personal Data in a structured, commonly used, and machine-readable format;
to lodge a complaint with a supervisory authority;
to rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete; and
to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making").

Where the processing of Your Personal Data by SleepSpace is based on consent, You have the right to withdraw that consent without detriment at any time or to exercise any of the rights listed above by emailing SleepSpace at dr.snooze@sleepspace.com.

How can You update, correct, or delete Personal Data?

You can change Your email address and other contact information by emailing SleepSpace at dr.snooze@sleepspace.com. If You need to make changes or corrections to other information, You may sign into your account to edit the information. Please note that in order to comply with certain requests to limit use of Your Personal Data, We may need to terminate Your account and Your ability to access and use the Services, and You agree that We will not be liable to You for such termination or for any refunds of prepaid fees paid by You. You can deactivate Your account by emailing SleepSpace at dr.snooze@sleepspace.com.

Although We will use reasonable efforts to do so, You understand that it may not be technologically possible to remove from Our systems every record of Your Personal Data. The need to back up Our systems to protect information from inadvertent loss means a copy of Your Personal Data may exist in a nonerasable form that will be diﬃcult or impossible for Us to locate or remove.

Can You “OPT OUT” of receiving communications from Us?

We pledge not to market third party services to You without Your consent. We may send emails to You regarding Your SleepSpace account and services. You can choose to ﬁlter these account and services emails using Your email client settings, but We do not provide an option for You to opt out of these emails.

Information submission by minors

We do not knowingly collect Personal Data from individuals under the age of 18 and the App is not directed to individuals under the age of 13. We request that these individuals not provide Personal Data to Us. If We learn that Personal Data 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 are aware of a User under the age of 13 using the App, please contact us at dr.snooze@sleepspace.com.

If You are a resident of California, under the age of 18 and have registered for an account with Us, You may ask Us to remove content or information that You have posted to App.

California Residents

California residents may request and obtain from Us, once a year, free of charge, a list of third parties, if any, to which We disclosed their Personal Data for direct marketing purposes during the preceding calendar year and the categories of Personal Data shared with those third parties. If You are a California resident and wish to obtain that information, please submit Your request by sending Us an email at info@getSleepSpace.com with “California Privacy Rights” in the subject line.

Contact Us