Privacy Policy
The Sleep Cycle app privacy notice
We believe that transparency is the key to any healthy relationship. We appreciate that you trust us with information about you, and we want to be transparent about how we use it.
You own your personal data, and you are always in control. Therefore, we offer you several ways to control the privacy of your personal information and we are constantly striving to improve the functions and features needed in order for you to be in control.
Sleep Cycle AB (“we”, “us”, “our”) is the data controller for any personal data that you or the Sleep Cycle app forward to us and we will process your personal data only in accordance with applicable legislation, such as the GDPR.
This notice describes how we process your personal data. You will learn about the data we collect, how we use it, your rights, and the measures we take to keep it safe. We always make sure that your data is protected in accordance with applicable legislation.
If you have any questions, or feel you need any part of this notice explained, please contact us or our data protection officer.
General information about the Sleep Cycle app
When using the Sleep Cycle app, you will enter certain personal data into the app (such as your email address, your height and weight, when you go to bed and wake up, etc.), some personal data will be collected through your device’s accelerometer (such as your movements), microphone (such as snoring or other noises), camera (pulse), or device location (for weather and sleep location statistics), and some personal data will be derived (such as sleep efficiency and sleep quality).
Depending on what personal data you choose to provide, the data processed within the Sleep Cycle app may, alone or together with other data, indicate information about your health. Personal data, including health data, may also be collected from other sources, for example if you choose to connect the Sleep Cycle app with your Life Cycle app, or other (third party) apps – e.g. Google Fit or Apple Health. You have control over what data is stored and accessed between the different apps and you can modify these settings at any time. We do not collect information about you from any third party sources unless you tell us (or the app) to do so.
If you and another Sleep Cycle app user are connected to the same WiFi, and you have given Sleep Cycle access to the WiFi, your devices will automatically connect with each other via the Partner Link feature (available in the app’s privacy settings). This allows the app to separate your noise(s) and movement(s) from the other app user’s, which will ultimately give you better and more to the point insights about your sleep. You can deactivate the Partner Link feature at any time under Consent & Privacy in your profile settings.
Please note that this notice does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with, in or through Sleep Cycle, unless indicated otherwise. We will not be responsible or liable for: (i) the availability or accuracy of such third party apps or sites (ii) the content, products or services on or availability of such third party apps or sites; or (iii) your use of any such third party apps or sites.
How we process your personal data
To manage our relationship and provide the app and related services in a satisfactory and error free manner, we process your personal data. For example, we process your data when you create an account, when we provide the different functions of the app to you, if you contact our customer support team, for maintenance of the app, and for marketing purposes. Please find more detailed information on how we process your data below.
| Why we process this data | The personal data we process | Description | Where we got it from | Legal basis for doing so | How long will we keep your data? |
| Create and manage your user account | Name (if provided), email address, password or authentication credentials (stored in encrypted or hashed form), account identifiers, login and session information, security-related metadata (such as IP address and device information), and profile information associated with your account (such as language preferences or other account settings). If you use a social login, we may also process information provided by the selected authentication provider (such as Apple or Google), including your email address and provider-specific user identifier. | If you create a user account, we process the personal data you provide in order to create, maintain, and manage your account. To provide secure authentication and account management, we use an identity and authentication service provider (Ory). This means that certain account-related personal data is processed and hosted by Ory on our behalf to ensure secure logins and account protection. We remain the data controller responsible for your personal data, while Ory acts solely as our data processor and processes such data only in accordance with our documented instructions. | You (through the Sleep Cycle app) or from third-party authentication providers (e.g. Apple or Google) if you use social login. Authentication services are provided by Ory on our behalf. | Our agreement with you (GDPR art 6.1(b)). If you do not provide the data, you will not be able to create an account. | Three (3) years after your last activity. |
|---|---|---|---|---|---|
| Manage payments and returns (Android and iOS purchases) | Active subscription and returns. | Payments and returns are handled by App Store Connect and Google Play. If you have registered your email address in the app, we will receive information on your payments and returns. This data will also be kept for bookkeeping purposes. | App Store Connect or Google Play. | Our agreement with you (GDPR art 6.1(b)). It is also necessary to comply with the Swedish Bookkeeping Act, why we also process the data based on our legal requirement. | One (1) year after your last activity based on our agreement with you plus seven (7) years after your subscription has ended, in accordance with the Swedish Bookkeeping Act. |
| Manage payments and returns (for web purchases) | Name, email address, home address, active subscription information, payment and return status. | If you make a purchase on our website (sleepcycle.com), payments and returns are handled by our payment service provider, FastSpring. We will process the personal data you provide in order to manage payments, subscriptions, and returns. This includes receiving and storing purchase-related information for accounting, customer support, and legal compliance purposes. This data is also processed to fulfil our bookkeeping obligations. | You (through purchases made on sleepcycle.com) and FastSpring. | Our agreement with you (GDPR art 6.1(b)). It is also necessary to comply with our legal obligations under applicable bookkeeping and accounting laws, including the Swedish Bookkeeping Act (GDPR art 6.1(c)). | One (1) year after your last activity based on our agreement with you, plus seven (7) years after your subscription has ended, in accordance with the Swedish Bookkeeping Act. |
| Respond to legal requests/requirements | All data in the Sleep Cycle app. | We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Sleep Cycle app or the physical safety of any person. | You/the Sleep Cycle app. | We process your personal data for the purpose of responding to legal requests/requirements based on our need to comply with applicable legal obligations (GDPR, art 6.1 (c)) as well as our legitimate interest to defend ourselves against legal claims and investigate violations and improper use that breach our terms. Furthermore, any health data covered by the request which is necessary to process in order to establish, exercise or defend legal claims or whenever a court is acting in its judicial capacity will also be processed (GDPR; art 9.2(f)). | As long as we have to establish, exercise or defend the claim or fulfil the legal requirement in question. |
| Provide the functionalities of the Sleep Cycle app. Improve the Sleep Cycle app and its features. Store your data on our servers (including recorded audio). Provide you with customer support. | All data in the Sleep Cycle app, including health data. Such categories of personal data processed for this purpose could be: name, contact information and technical data (e.g. IP addresses, timestamps, log files, device type and operating system). We also process your health data, to provide you with the functionalities of the app, to provide you with customer support, to improve the app and its features and to store the health data provided by you and generated through your usage of the app. Data within the following areas will be processed: Account and subscription information (e.g. account status). Sleep information (e.g. sleep session timing, sleep duration). Audio-based sleep insights (when enabled) (e.g. snoring, coughing). User-provided information and preferences (e.g. sleep notes and any other change of setting within the app). App interactions and feature usage (e.g. session start, did snooze). Device and technical information (e.g. device type, language setting). Approximate location and regional context (privacy-protected) (e.g. country). Weather and environmental context (when location is shared) (e.g. temperature, weather type). Consent and privacy preference information (e.g. marketing consent, microphone access). Experiment and analytics information (e.g. app version, participation in feature experiments). | All processing of personal data mentioned below is carried out to ensure your access to all app features and to make your user experience as seamless as possible. To be able to provide you with all the functionalities of the Sleep Cycle app, we process your personal data, including your health data. We also process your personal data to continuously improve the app and its features, to help you understand and improve your sleep patterns and sleep quality. We may use your data to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services. As part of this work, we may use tools such as Amplitude and Amplitude Experiment to track and analyse user behaviour and experiment with app functionality in order to evaluate and improve the app experience and its features. When you use the Sleep Cycle app, we process your personal data by storing it (including recorded audio). We store your data to protect it from loss and to ensure that your personal data is saved, even if something would happen to the app on your device. We will store all the data available in the app on our secure servers, hosted by Google Cloud. Learn more about Google Cloud under “How we share your personal data and who we share it with”. We also process your personal data to provide you with customer support if you have any questions or problems with the app. | You/the Sleep Cycle app. | Your personal data, including health data, is processed based on your consent (GDPR, art 6.1(a) as well as art 9.2(a)). | Until you withdraw your consent, or until you end your subscription. If you withdraw your consent, we will immediately delete or anonymize your health data. If you stop using our services, we will keep your data for up to one (1) year, in case you change your mind within this period of time and want to start a new subscription. We will thereafter delete or anonymize your data as soon as possible. |
| Improve and train our sound detection models and other models that use sound in its training — for example our sleep analysis. | Audio samples – random audio samples (max 30 seconds in length) and audio connected to your interactions in the app when you annotate that a sound should be of a different type. | If you consent, we will process audio samples to develop and improve our models, including improving detection of existing sound types and identifying new types of sounds. This may include random audio samples and audio related to sounds you interact with in the app (for example if you label or change the sound type in the user interface). Audio samples may be reviewed and annotated by Sleep Cycle employees or other parties acting on behalf of Sleep Cycle. | You (through your device when using the app). | Your consent (GDPR art 6.1(a)). You can withdraw your consent at any time in the app. | We will store audio samples and related annotations in pseudonymised form for as long as you have consented to this processing. If you withdraw your consent, we will stop collecting new audio samples. We may retain audio samples that have already been collected, but we will remove any link to you so that the data is fully anonymized and can no longer be associated with you as an individual. |
| To collect and analyse sleep and health data for internal use and research purposes and to generate aggregated and anonymized insights that may be used in external research collaborations and statistical reporting | Health data either provided by you in the Sleep Cycle app, or generated by your interactions with the Sleep Cycle app. Sleep session information (e.g., start/end time, duration, time to fall asleep, wake-ups). Self-reported feedback (if provided) (e.g., mood on waking, sleep notes). Sleep-related sound and breathing insights (e.g., snoring, coughing, sleep talking, breathing patterns). Health and wellness signals (if provided) (e.g., heart rate, steps, wrist/body temperature). Location and regional context (privacy-protected) (e.g., approximate region/city and obfuscated coordinates). Weather and environmental context (if provided) (e.g., temperature and weather type). Device and app information (e.g., platform, app version). Basic profile information (if provided) (e.g., age, gender, height, weight) | We want to make the world a better place and contribute in the best way we can. If you consent, we may use your data (including health data to share publicly and to third parties, for example, in public reports about sleep and activity, to partners under agreement with us, to third parties conducting internal research studies, or as part of the community benchmarking information we provide to users of our subscription services. When insights are shared externally with universities, researchers, public authorities, or in scientific publications, the data will be aggregated and anonymized. This means that the shared information will not identify you as an individual and cannot reasonably be used to do so. When insights are shared with other users (for example as statistics in the app) this data is directly identifiable for us but never exposed towards others. Your data will be stored on our secure servers, hosted by Google Cloud. Learn more about Google Cloud under “How we share your personal data and who we share it with”. | You/The Sleep Cycle app. | Your personal data, including health data, is processed based on your consent (GDPR, art 6.1(a) as well as art 9.2(a)). | If you withdraw your consent, we will stop collecting data from you, in relation to given purposes, immediately. The withdrawal of your consent will not affect the lawfulness of the processing already conducted based on your previous consent. We will continue to store data that we have already collected based on your consent for statistical and scientific purposes. If so, your data will be stored only in anonymized form. |
| Generate personalized sleep insights for you and to improve the sleep coach experience for users with similar needs | Pseudonymised user data such as sleep data, demographic data, location, sleep notes, activity data, and other non-directly identifying data provided through your use of the app. | If you consent, we will process your data to generate personalized sleep insights for you in the app. We use your conversational data to understand what personalized communication is likely to be more relevant for you and for users with similar needs. We do this by processing data with the help of AI service providers (such as OpenAI/ChatGPT) and tools used to evaluate and improve AI performance (such as Braintrust). This involves sharing pseudonymised data with these service providers and analysing conversations you have had in the app in order to adjust and improve the instructions and logic we use for generating insights and conversational responses. This consent applies only to users of the iOS version of the Sleep Cycle app. If you use the Android version of the app, this processing does not apply to you. | You (through your use of the app). | Your consent (GDPR art 6.1(a)). You can withdraw your consent at any time in the app. If you do not provide consent, we will not generate these insights. | We will process and share data for this purpose for as long as you have consented to this processing. Data shared with OpenAI and Braintrust is retained for up to thirty (30) days before deletion, subject to longer data retention periods when required or authorized by applicable laws. |
| Read and write health data via Apple Health / Google Fit to improve sleep analysis and insights | Health and wellness data that you choose to share with us via Apple Health and/or Google Fit, including data types that you allow us to read from those services and/or write to them from the Sleep Cycle app (depending on your device settings and permissions). | If you choose to connect Sleep Cycle with Apple Health and/or Google Fit, we may read health data from these services and/or write certain data from Sleep Cycle to them. We use the data you allow us to access to improve your sleep analysis and generate sleep insights in the app. You can control and withdraw this permission at any time through your device settings (e.g. Apple Health / Google Fit permissions). | You / Apple Health / Google Fit (depending on your permissions and connected apps/devices). | Your consent (GDPR art 6.1(a) and, where applicable, GDPR art 9.2(a)). You can withdraw your consent at any time through your device settings. If you do not provide consent, you can still use the app, but some features may be limited. | We will process this data for as long as you have enabled the connection and granted permissions. If you withdraw your permission, we will stop reading and/or writing data through Apple Health and/or Google Fit, but we may continue to store and process health data that was previously collected. This data will be kept until you request deletion (for example by contacting our support) or one (1) year after your last use of the app. |
| General marketing and communication | Name, email address, country, preferred language, subscription type, marketing consent status, and communication preferences. | To send you general marketing and communicate with you. We may send you service and marketing related notices and communication via different communication tools such as Braze. | You / The Sleep Cycle app. | Legitimate interest assessment (GDPR, art 6.1(f)). We assess that our legitimate interest to communicate with you outweighs the potential (but unlikely) impact this may have on your rights and freedoms. | Until you opt-out from communication via email or two (2) years after our relationship has ended. |
| Direct marketing about offers and promotions | Name, email address, country, preferred language, subscription type, app, usage data, marketing consent status, and communication preferences. | If you consent, we may send you marketing communications about offers, discounts, and promotions related to Sleep Cycle. We may contact you via e-mail (through communication tools like Braze) and other communication channels used for marketing purposes. To make our marketing more relevant, we may segment users based on non-health in-app data, such as feature usage and responses from onboarding surveys, so that different users receive different offers. You can withdraw your consent at any time. You can also unsubscribe from marketing e-mails at any time by using the unsubscribe link included in the e-mail you receive. | You / The Sleep Cycle app. | Your consent (GDPR art 6.1(a)). You can withdraw your consent at any time. If you do not provide consent, you will still be able to use the app. | Until you withdraw your consent or two (2) years after you stop using our services, whichever occurs first. |
| Provide personalized direct marketing through segmentation | Health data either provided by you in the Sleep Cycle app, or generated by your interactions with the Sleep Cycle app. Sleep session information (e.g., start/end time, duration, time to fall asleep, wake-ups). Self-reported feedback (if provided) (e.g., mood on waking, sleep notes). Sleep-related sound and breathing insights (e.g., snoring, coughing, sleep talking, breathing patterns). Health and wellness signals (if provided) (e.g., heart rate, steps, wrist/body temperature). | If you consent, we will process your personal data to provide you with personalized direct marketing measures tailored to your needs and interests. This includes analysing your data that is generated when you use the Sleep Cycle app and segmenting users in order to personalize offers and marketing content. For clarification, we will not use your health data in the marketing messages we send to you, but we may use health data to create segments and determine which offers or marketing content may be more relevant to you. | You / The Sleep Cycle app. | Your consent (GDPR art 6.1(a)). If health data is processed for segmentation, this is also based on your explicit consent (GDPR art 9.2(a)). You can withdraw your consent at any time. | Until you withdraw your consent or two (2) years after you stop using our services, whichever occurs first. |
| Targeting and retargeting outside of the Sleep Cycle app | Online identifiers and marketing-related data such as e-mail address (in hashed/pseudonymised form where applicable), device identifiers, advertising identifiers, IP address, and information about your interaction with our marketing campaigns. | If you consent, we will share certain personal data about you with third-party advertising platforms (such as TikTok and Instagram/Facebook) in order to show you personalized marketing campaigns outside of the Sleep Cycle app (retargeting). This may also allow us to reach users with similar characteristics (“lookalike audiences”) and measure the performance of our marketing campaigns. You can withdraw your consent at any time in the app. | You / The Sleep Cycle app. | Your consent (GDPR art 6.1(a)). You can withdraw your consent at any time. If you do not provide consent, you will still be able to use the app. | Until you withdraw your consent or two (2) years after you stop using our services, whichever occurs first. |
How we share your personal data and who we share it with
The data we store and otherwise process about you will be stored on secure servers hosted by Google Cloud. In addition, data that we process for product development purposes will be transferred to our product development environment (separate from the backup environment) hosted by Amplitude Inc. and their service provider Amazon Web Services.
We also use other service providers that may process your data on our behalf. When we communicate with you, for example via e-mail, your e-mail address may be transferred to Mailgun Technologies Inc. and Braze Inc., who provide e-mail and communication services. In order to provide the best possible customer support, we use the services of Zendesk Inc.
Your personal data may be processed within the EU/EEA as well as in countries outside the EU/EEA, including the United States. When personal data is transferred outside the EU/EEA, we use appropriate safeguards to ensure a level of protection consistent with EU data protection standards, for example by entering into the European Commission’s Standard Contractual Clauses (EU Model Clauses) with relevant service providers. We also apply technical and organizational security measures, including by encrypting your data both in transit and at rest, to the greatest extent possible.
Your rights
You can exercise many of your rights directly in the Sleep Cycle app or on your device. You are always welcome to contact us directly and we will help you with your request at [email protected].
Right to information and access
You have the right to know if we process personal data about you. If we do, you also have the right to receive information about the personal data we process and why we do it. You also have the right to receive a copy of all personal data we have about you.
If you are interested in specific information, please indicate it in your request. For example, you can specify if you are interested in a certain type of information (e.g. what contact and identification information we have about you) or if you want information from a certain time period.
Right to have erroneous data corrected
If the data we hold about you are incorrect, you have the right to have it corrected. You also have the right to supplement incomplete information with additional information that may be needed for the information to be correct.
Once we have corrected your data, or it has been supplemented, we will inform those we have shared your data with about the update, provided that it is not impossible or too cumbersome. If you ask us, we will also tell you who we have shared your data with.
If you request to have data corrected, you also have the right to request that we limit our processing during the time we investigate the matter.
Right to have data deleted
In some cases, you have the right to have your data deleted. You have the right to have your data deleted if:
- The data is no longer needed for the purposes for which we collected it,
- You withdraw your consent, if applicable,
- The data is used for direct marketing and you unsubscribe from it,
- You oppose use that is based on our legitimate interest and we cannot show compelling grounds that outweigh your interests,
- The personal data has been used illegally, or
- Deletion is required to fulfill a legal obligation.
You can delete specific data points, for example sleep sessions or comments posted by yourself, directly in the app. If you are not using the online backup services you can simply just uninstall the Sleep Cycle app in order to remove any stored data. If you choose to delete your account (or if you withdraw your consent), please note that while most of your information will be deleted within a few days, it may take up to thirty (30) days to delete all of your information, like the data stored in our backup systems. We may preserve data for legal reasons or to prevent harm.
If we delete data following your request, we will also inform those we have shared your data with, provided that it is not impossible or too cumbersome. If you ask us, we will also tell you who we have shared your data with.
Data portability
You may export your personal data to a CSV file from inside the app.
Objecting to data use
You have the right to object to processing that is based on our legitimate interest. If you object to the use, we will, based on your particular situation, evaluate if our interests in using the data outweigh your interests in the data not being used for that purpose. If we are unable to provide compelling legitimate grounds that outweigh yours, we will stop using the data you object to – provided we do not have to use the data to establish, exercise or defend legal claims. If you object to the use, you also have the right to request that we restrict our use during the time we investigate the matter.
You always have the right to object to, and thus unsubscribe from, direct marketing.
Right to withdraw consent
You have the right to withdraw your consent for a specific processing at any time. You can withdraw your consent in the privacy settings in the app or by contacting us [email protected].
Your withdrawal will not affect processing that has already been carried out.
Right to request restriction
Restriction means that the data is marked so that it may only be used for certain limited purposes. The right to restriction applies:
- When you believe the data is incorrect and you have requested correction. If so, you can also request that we limit our use while we investigate if the data is correct or not.
- If the use is illegal but you do not want the data to be deleted.
- When we no longer need the data for the purposes for which we collected it, but you need it to be able to establish, assert or defend legal claims.
- If you object to the use. If so, you can request that we limit our use while we investigate if our interest in processing your data outweighs your interests.
Even if you have requested that we restrict our use of your data, we have the right to use it for storage, if we have obtained your consent to use it, to assert or defend legal claims or to protect someone’s rights. We may also use the information for reasons relating to an important public interest.
We will let you know when the restriction expires.
If we limit our use of your data, we will also inform those we have shared your data with, provided that it is not impossible or too cumbersome. If you ask us, we will also tell you who we have shared your data with.
Right to lodge a complaint to a supervisory authority
You may also submit complaints to a supervisory authority, in particular in the Member State of your habitual residence, place of work or where the alleged infringement of the GDPR took place. In Sweden, the supervisory authority is the Swedish Supervisory Authority for Privacy Protection.
Changes to privacy notice
We reserve the right to change this Privacy Notice from time to time. We will inform you of any changes by posting the updated notice in the app and on our website. If we make any material changes to our notice, we will push a notification through the Sleep Cycle app and/or by e-mail (if we have your e-mail address and you have not opted-out from such use). We encourage you to contact us if you have any questions about the notice or about how we process your personal data.
Contact information
Data controller
| Name: | Sleep Cycle AB |
|---|---|
| Registration number: | 556614-7368 |
| Postal address: | Drakesgatan 10 412 50 Gothenburg SWEDEN |
| E-mail address: | [email protected] |
Data Protection Officer
| Postal address: | Sleep Cycle AB Att. Data Protection Officer Drakegatan 10 412 50 Gothenburg SWEDEN |
|---|---|
| E-mail address: | [email protected] |
Versions in other languages than English
The original version of this Privacy Notice is written in English. To the extent a translated version of the Privacy Notice is in conflict with the English version, the English version shall prevail.
Cookies
You can view the cookies stored on your device and/or change your cookie settings here.