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Effective Date: 2026-01-12

Welcome to SomnusLab (\"we,\" \"us,\" or \"our\"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (\"App\") and related services. By using the App, you agree to the collection and use of information in accordance with this policy.

This Privacy Policy also explains your rights under applicable data protection laws, including the General Data Protection Regulation (\"GDPR\") for users located in the European Economic Area (\"EEA\") and the United Kingdom.

1. Information We Collect

a. Personal Information

We may collect personally identifiable information (\"Personal Information\") that you voluntarily provide when you register an account, use our App, or contact us. This may include:

Contact Information: Name, email address.
Account Credentials: Username, password.
We collect sleep duration, heart rate, heart rate variability (HRV), respiration rate, sleep cycles, sleep patterns and snoring status. (Note: Snore detection is done locally on-device; raw audio is never recorded, stored, or uploaded to servers.) View full Privacy Policy.
Health Data (Optional): Menstrual cycle data (such as cycle start/end dates), activity/exercise data (such as duration and intensity), and sleep context data (such as screen time before bed). This data may be considered sensitive personal data under certain laws and is collected and processed only with your explicit consent, which you may withdraw at any time.
Partner Information: If you invite a partner to jointly control the device, we may collect their contact information.
Payment Information: If you purchase devices or services through the App, payment details are processed by secure third-party payment processors and are not stored by us.

b. Automatically Collected Information

When you use the App, we may automatically collect:

Device Information: Device model, operating system, unique device identifiers, IP address.
Usage Data: App features used, interaction times, preferences.
Location Data: Approximate location based on your IP address and, with your explicit consent, precise location data to provide local weather-based services for temperature adjustment.
Analytics and Tracking Technologies: We use limited third-party analytics and product improvement tools to understand how users interact with the App and to improve functionality, performance, and reliability. For the mobile App, we use analytics tools such as Google Analytics and Statsig in a limited manner, with appropriate safeguards (such as data minimization where applicable), and rely on our legitimate interests in operating, securing, and improving the App.

2. How We Use Your Information

We use the information we collect for the following purposes:

To Provide and Maintain Our Services: Enable App functionalities such as temperature control, sleep cycle settings, sleep quality analysis, and data visualization.
Personalization: Customize your experience by tailoring content and recommendations.
Customized Sleep Temperatures and Schedules: Generate personalized sleep temperatures and schedules aligned with your sleep patterns.
Analytics and Improvements: Understand usage trends and improve our App and services.
Communication: Send updates, notifications, newsletters, and respond to inquiries.
Partner Invitations: Enable joint device control with invited partners.
Marketing and Promotions: Inform you about offers, promotions, and events (where permitted by law).
Compliance and Enforcement: Comply with legal obligations and protect our rights.

Legal Bases for Processing (EEA and UK Users)

If you are located in the EEA or the UK, we process your Personal Information based on one or more of the following legal bases:

Performance of a contract (to provide core App and device functionality)
Your consent (for optional health data and marketing communications)
Legitimate interests (such as service security, fraud prevention, core service improvement, and limited analytics necessary to understand and improve App performance)
Compliance with legal obligations

3. Sharing Your Information

We do not sell or rent your Personal Information. We may share your information in the following circumstances:

a. Service Providers

We may engage third-party companies and individuals to facilitate our services, perform service-related tasks, or assist in analyzing how our services are used. These Service Providers include infrastructure providers, analytics and product improvement providers, customer support tools, and payment processors.

Analytics and product improvement providers may include companies such as Google Analytics and Statsig for the App, and Google Analytics and Hotjar for our website, among others used for similar purposes. These third parties are contractually obligated to protect your data and to use it only in accordance with our instructions and applicable data protection laws.

b. Legal Requirements

We may disclose your Personal Information if required to do so by law or in response to valid requests by public authorities.

c. Business Transfers

In the event of a merger, acquisition, or asset sale, your Personal Information may be transferred. We will provide notice before your information becomes subject to a different privacy policy.

d. Protection of Rights

We may disclose information to enforce our terms, protect our rights, privacy, safety, or property, or those of our users or the public.

4. Data Security

We take reasonable technical and organizational measures to protect your Personal Information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

5. Your Rights and Choices

a. Access and Correction

You may access, correct, or update your Personal Information through your account settings or by contacting us.

b. Deletion and Withdrawal of Consent

You may request deletion of your Personal Information or withdraw your consent at any time. This may affect our ability to provide certain services.

c. Opt-Out of Marketing Communications

You may opt out of promotional emails by following the unsubscribe instructions or contacting us.

d. Data Portability

You may request a copy of your Personal Information in a structured, commonly used, and machine-readable format.

e. Additional Rights for EEA and UK Users

If you are located in the EEA or the UK, you also have the right to:

Object to processing based on legitimate interests
Request restriction of processing
Lodge a complaint with your local data protection supervisory authority

6. Third-Party Services

The App may contain links to third-party websites or services not operated by us. We are not responsible for their content or privacy practices.

7. Children's Privacy

Our App is not intended for use by children under the age of 16 without adult supervision. We do not knowingly collect Personal Information from children under 16. If you believe a child has provided us with Personal Information without parental consent, please contact us so we can delete it.

8. International Data Transfers

Your information may be transferred to and processed on servers located outside your country of residence, including in the United States. Some of our service providers, including analytics and infrastructure providers, are located outside the European Economic Area.

Where required by law, we rely on appropriate safeguards for international data transfers, such as the EU–US Data Privacy Framework or Standard Contractual Clauses approved by the European Commission.

9. Data Retention

We retain Personal Information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When data is no longer needed, it is securely deleted or anonymized.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes to this Privacy Policy that affect how we process personal data, we will update this Privacy Policy and, where required by law, provide additional notice or seek renewed consent. Changes become effective upon posting.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:
Email: support@somnuslab.com

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