Privacy Policy
SleepScore App Privacy Policy
Version: 1.2.0
Updated: 11th June 2024
Your privacy is important to us. This Privacy Policy describes how Consumer Sleep Solutions, LLC d/b/a SleepScore Labs (“SleepScore Labs”) collects data from you through our interactions with you, via our various products and services, and also describes how we use and store that data. This Privacy Policy identifies the choices you can make about the data we collect and store, and provides information on how we secure your data and the choices you have depending on where you are located.
Unless otherwise stated, Consumer Sleep Solutions LLC is a data controller for personal data we collect through products and services subject to this statement. Where we act as a data processor for some Clients, their Privacy Notice will explain how they process your data.
SleepScore offers a range of products and services focused on helping you understand and optimize your overall sleep through use of collected sleep data. They include SleepScore Max device and other SleepScore applications and related products. The Max and related Applications help you track your sleep data including sleep duration, sleep onset, sleep staging and other collected information to provide a SleepScore and other key metrics that allow you to take actionable steps to better sleep (all collectively “Services”). Your data is necessary for us to provide the Services.
The prime purpose of collecting and using your data is to allow us to properly measure and create a personalized path to achieve better sleep. The use of your collected personal sleep data is necessary for SleepScore to deliver Services that involve analyzing and evaluating Sleep conditions and solutions. We do not and will not sell your data to third parties.
Please carefully read this Privacy Policy and also our Terms and Conditions for your specific Services, product or solution to understand how SleepScore may collect, use and share your personal information. The terms “we”, “us” or “SleepScore” are each intended as reference to Consumer Sleep Solutions, LLC.
Depending on the context, “you” might be a Client, product or service End User, or website Visitor.
How and Why We Collect and Use Personal Data
SleepScore collects data to operate effectively and provide you with the appropriate sleep advice and recommendations to achieve better sleep. You have the option to decline when asked to provide personal data. But if you elect not to provide data that is necessary to a product or service feature, you may not be able to use all Services, products or features given the provided information is necessary for us to perform certain critical Services tasks and to support Services features.
We use the data gathered through our interactions with you to personalize sleep advice and insights along with recommendations of relevant sleep Services that may help your sleep condition based on analysis of your collected sleep data.
SleepScore does not sell your data to advertisers, nor does it use what you provide in your measured sleep data, sleep questionnaires, or other Service interactions to target external ads to you. We may carry out advertising based on your interactions with our website. For more information on this, please see our cookie policy.
The data we collect varies based on your interactions with SleepScore, and your selections regarding various Services product settings and the specific product and features you may utilize. We may collect your Data from various sources. For example, you may be referred to SleepScore by a service provider you use who offers our Services to you as a benefit and who may provide some information on you to us to enable us to set you up on our systems.
The table below sets out the different types of Data that we collect, why we process this and the legal basis for each:
| Category | Type of Data | Purpose of processing | Legal Basis of processing |
|---|---|---|---|
| Website Visitors | |||
| Contact Information | Name, email address and telephone number (if you have provided this information to us), the time, date and details of your visit to our website, and any other information that you may provide by filling in forms on our website | This information is processed to enable SleepScore to: (i) deal with and respond to your request, query, or complaint, (ii) address your B2B queries (iii) manage any customer service or DSAR requests you may send us | Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Email Address | Email address and contact information. | This information is processed to allow SleepScore to maintain its marketing database when you subscribe to our newsletter or other marketing materials | Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Cookie IDs | A cookie ID is the identifier that is included within most cookies when set on a user’s browser. It is a unique ID that allows our website to remember the individual user and your preferences and settings, when you return to our website. More information is available in our cookie banner and cookie policy here | This information is processed where it is necessary for the website to function
In the case of cookies used where you have consented to that process, that information is processed to provide the service you have consented to, in accordance with SleepScore Cookie policy. This may include to understand how you interacted with our site, your online shopping activities and to analyse each area of the website to understand how it works for our users |
Under the strictly necessary basis which does not required consent when the cookies are necessary for the website to function and cannot be switched off in our systems
They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms; and your consent for all other cookies Otherwise, these are dropped based on your consent |
| Website usage data | We collect information from your browser, computer, or mobile device when you access our sites, such as browsing history and search history within our sites
This information includes device and network information, cookies, log files and analytics information which we use to increase our ability to improve our services |
We use this data to develop aggregated analysis and business intelligence to enable us to operate, improve, make informed decisions, secure, and report on performance of the websites | Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Service Users/ End Users | |||
| Personal Contact Data, Login details and Sleep Data | Data We Collect: Basic account data that includes your first and last name, phone number, email, IP address, postal address, username and password. This may also include preferred language, date of birth, gender, products/ services used
Usage data (see below) Sleep data (see below) Personal data shared by our Clients about you as part of a benefit they may offer you (see below) |
We collect this information to authenticate, secure and provide you with access to our Services
We use this information to manage our marketing databases We also use this information to communicate with you in various ways about your account, sleep progress, news, to re-engage with you if you have not used the Services for a while and to communicate other information that may be pertinent to you which you may opt out of. This may include push communications or emails We also conduct marketing analytics to assist our acquisition and retention of users and understand how you chose our service, for example if you responded to a specific advertising campaign |
Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Sleep Data: | Through active use of the SleepScore products to quantify your sleep we collect measurements of your respiration, movement, noise disturbances, and other sleep measurement data. During onboarding we request personal information including height, weight, age, and gender. Where relevant to the Service, the SleepScore Max device record light level, temperature, audio events and radar data from your sleep environment. The radar data recorded is processed locally on your handset and turned into sleep stage data. Sleep stage, temperature, light level, audio events and processed signal data are collected. Audio events are classified as events above a certain threshold and stored as timestamps, no recognisable audio is collected or stored | Your collected sleep data is used to provide your daily SleepScore, and powering the engines based on your measured personal sleep condition, provides necessary insights, advice, and education to help you achieve greater understanding of your sleep condition. We may offer you personalized solution recommendations which may include general product or service categories or specific products or services, some of whom we may have a relationship with. Your height, weight, age and gender are critical to calculating your recommended sleep solutions. Access to your sleep data is required for your SleepScore products to work
We use collected data to continually improve our product and services including adding new features and enhancing accuracy of the platform. For example, we use sleep data and demographics to improve the relevancy of the sleep advice, insights and recommendations we provide by training sleep models and algorithms |
Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Sleep Environment Data: | Through questionnaires we may ask you questions relating to your specific sleep environment and products used to help you sleep. This information may include information regarding your mattress, curtains, sleep aids, and other related information pertaining to your sleep
For users of iOS Health app, to improve our ability to provide personalized sleep analysis and recommendations, SleepScore Labs requests permission to read and write health data from/to the Health app. Thereby allowing the importing of SleepScore sleep parameters into the Health app. SleepScore Labs does not use HealthKit data for advertising purposes and will not sell HealthKit data. For users of Google Health Connect, to improve our ability to provide personalized sleep analysis and recommendations, SleepScore Labs, via the Application, requests permission to read health data from Google Health Connect. SleepScore Labs does not use Health Connect data for advertising purposes and will not sell Health Connect data. Your Health Connect device will only allow SleepScore Labs, via the Application, to read such data if you grant permission via your device’s settings. The use of information received from Health Connect will adhere to the Health Connect Permissions Policy, including the Limited use requirements . |
We collect information regarding your sleep environment to supplement your sleep data to improve our ability to provide personalized sleep analysis and recommendations | Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Location Data: | For users accessing our sleep data services through our app or our other products with location-enhanced features, we request to collect data about your location. This information may include using GPS data, identifying nearby cell towers and Wi-Fi hotspots. Our sleep analysis products necessarily require your location data | Location-based data can include local weather, allergen, and related data available in the public domain to supplement our sleep data collected to help provide improved sleep recommendations. Location information helps render our sleep recommendations more data-driven and more accurate. If we lack location data, and the other data that location data confirms (like weather and allergen data), we may be unable to provide accurate sleep recommendations and guidance
We use location to assist our analysis in determining the impact of weather on sleep and to find trends with respect to sleep |
Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Contacts and Relationships: | You may choose to add your contacts information and information regarding relationships with others (who may also be consumers utilizing our platform) | Allowing participation in social or friends and family sharing capabilities hosted by SleepScore or its partners can greatly enhance your experience with our platform, and adds to the information we can utilize to guide our sleep recommendations | Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Usage Data: | Data about your device and how you and your device interacts with SleepScore and our products and services can be necessary to provide you a more personalized experience.
Technical Information: We collect information from your browser, computer, or mobile device when you access or use our Products and Services, such as browsing history and search history within our sites. This information includes device and network information, cookies, log files and analytics information which we use to increase our ability to improve our services. |
We use data to provide improve customer service and efficient troubleshooting of potential user issues
We use data to develop aggregated analysis and business intelligence to enable us to operate, improve, make informed decisions, secure, and report on performance of the business |
Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Sleep Research Content, Insights and Analytics | You may provide us with your sleep data for our sleep research programs or scientific studies on the subject of sleep. This data includes personal data that you provide through sleep measurement/analysis, external health data imported by you, user profile entries, feedback, reviews, questions, information, customer service. Your personal data will be aggregated when it is used for sleep research. This means that your personal data cannot be assigned to you. | We collect sleep research data in aggregate form (i.e. the personal data cannot be associated with you) in order to gain new insights about sleep that can help us advance sleep science. These findings may be published from time to time. This data is a valuable contribution to be able to provide better sleep tips, as we use the scientific knowledge gained from this data to continuously improve our products and services. | Your explicit consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Sleep Study or Beta Releases | Data you may share with us as part of occasional Sleep related Studies which you have consented to | To carry out specific Sleep related studies for partners based on your explicit consent | Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily |
| Personal data shared by and with Your existing service provider | You may have a service provider who provides access to our Services as a benefit to you. In order to provide access, they will provide a link to our services. We will then process the necessary information to set you up. This may include the referring service provider’s name, unique ID linking you to them, unique token for authorising your request to sign up, subscription type, your email address
Event types: a list of which SleepScore services you have used and when (dates/ times) |
This data is processed to enable us to set you up on our systems and provide you access to the Services | Consent, where the personal data relates to the person supplying it to SleepScore and has been supplied to SleepScore voluntarily Contract with our Clients |
| System security and development, fraud prevention | All system data which may include any personal data you share with us | This information is processed to enable network and information security throughout our Services and to prevent fraud | Legitimate business interest to manage the security of our business and Services |
Sleep Study or Beta Releases
From time to time, SleepScore may offer opportunities to participate in sleep studies or access to beta products and features. As a result, these may change the data collected and the user experience that employ different privacy and security measures from those typically present in our products. If you participate in such a study or beta release you may need to enter into a different agreement and consent to this processing.
Reasons We Share Personal Data
We only share your personal data with your consent or as necessary to complete any transaction or provide any product or service you have requested or authorized. For example, you may wish to share your sleep data with a connected third-party partner, which can occur only with your consent.
When you provide payment data to make a purchase, we or authorized agents of the company share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.
We may share your information with third parties with whom we partner and who offer our Services to you as a benefit. In these cases we limit the data shared only to what is necessary to meet our contractual obligations and as outlined in the table above.
We share personal data with subsidiaries, affiliates, vendors, partners or agents working on our behalf for the purposes described in this statement to provide our Service. These companies must follow our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.
We may share your information with third parties who provide services to SleepScore Labs such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. For example, we use 3rd parties for cloud hosting of data and customer service support. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage
service providers to collect information about your use of the Services over time on our behalf so that we or they may promote SleepScore Labs or display information that may be relevant to your interests on the Services or other websites or services. SleepScore Labs is not responsible for the terms or policies of third parties.
Subject to your privacy settings, your information and content may be publicly accessible should you authorize that, which is your choice.
If SleepScore Labs becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such a transaction.
We may preserve and share your information with other third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is reasonably necessary to comply with the law, including response to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that disclosure is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of SleepScore Labs or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation. We may share your information with third parties when we forward notifications under laws such as the Digital Millennium Copyright Act (DMCA) or similar, which will be forwarded as submitted to us without any deletions.
Please note some of our products and services include links to those of third parties whose privacy policies differ from SleepScore. Additionally, through affiliate product or service recommendations, you may elect to select links to partner sites whose privacy policies differ from SleepScore. Should you provide personal data to any of those products and services or partners, your data shall be governed by their respective privacy policies. We are not responsible for third-party practices or policy terms.
We may also have to disclose personal data necessary to:
- Protect our customers security, or to prevent the loss of life or severe injury;
- Operate and maintaining the security of our products which include internal and 3rd party computer systems and networks vital to the operation of our products;
- Protecting the rights or property of SleepScore, including enforcing the terms governing use of the services.
While SleepScore Labs continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and SleepScore Labs cannot ensure or warrant the security of any information you transmit to SleepScore Labs. Transmitting personal information is done at your own risk.
To learn more please also refer to the SleepScore Terms & Conditions.
Where We Store and Process Personal Data
Personal data collected by SleepScore stored and processed in the United States and accessed by authorized users for support in regions where SleepScore or its affiliates or service providers maintain facilities.
We take steps to ensure that the data we collect under this Privacy Policy is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.
International Transfers
As an international organisation, where legally permissible, SleepScore may collect, use, disclose, and otherwise process your personal information in countries outside of the country of your residence, which may have different data protection rules.
SleepScore will ensure appropriate safeguards are in place to protect your personal information wherever it is transferred. Where we share personal information of individuals in the E.E.A or the UK, we will make use of the EU approved standard contractual clauses or other approved mechanisms.
Security of Personal Data
SleepScore is committed to protecting the security of your collected personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide encrypted and on computer systems that have limited access and are in controlled facilities.
Retention of Information
We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted whichever comes first. For example, when you withdraw your consent for SleepScore Labs to process your health-related information, SleepScore Labs will delete all health-related information you uploaded. Following the deletion of your account, it may take up to 30 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.
- How long is personal data needed to operate our Products and Services? Apart from where the law stipulates a specific period, we retain your User Data for a period not exceeding the period required for the purposes for which it was collected and processed.
- What is the duration by which personal data is deleted? Upon confirmation personal data, not necessary for legal, contractual, or similar obligation will remain on our system for up to 30 days before final deletion. Aggregate sleep data with Personal Identifiable Information removed will still be retained in our database for use in product maintenance and improvements and sleep science analytics.
- Is SleepScore subject to a legal, contractual, or similar obligation to retain the data? Situations including mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation may result in varying retention periods.
Information about you that is no longer necessary and relevant to provide our Services may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to SleepScore Labs, such as statistics of the use of the Services. For example, we may retain publicly available segments or routes and other depersonalized geolocation information to continue to improve the Services. This information will be de-associated with your name and other identifiers.
Should you delete your SleepScore Account, aggregate de-identified sleep data may be retained in our database for use in Services product maintenance and improvements, and to otherwise advance sleep science analytics.
Collection of Data from Children
We do not intend to market to or interact with, or secure any User Data from, children sixteen (16) years old or younger. Our Service is not by design reasonably likely to attract children sixteen (16) years old or younger to purchase or otherwise use our Service.
You must be over the age of eighteen (18) to create an account and use our Service.
If you are a minor and wish to utilize our product or the Service, your parents or legal guardians (hereafter your “Parents”) must engage in purchasing the product or Service and additionally if you are over eighteen (18) years old give us their written consent by contacting our customer service department. Our teams will answer any questions that you or your Parents may have concerning the use of our products and services and the rules relating to the collection of personal data.
Data Subject Rights
Depending on your location and subject to applicable law, you may have choices regarding our collection, use, and disclosure of your Personal Data:
Access and Control of Your Personal Data
You can view and manage your data via the respective SleepScore app or website portal based on the product you are using to view and manage your data. For example, you can view and update your profile data, user settings, and view historical sleep data.
Depending on the product you use you may delete a specific night’s tracking session, and the session would be deleted from SleepScore however, other data and the basic measurement data captured by the device or product remain in the database.
Deleting Information and Accounts
You may request that your account is deleted by contacting the company at support@sleepscorelabs.com. Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated.
Note that content you have shared with others or that others have copied may also remain visible after you have deleted your account or deleted the information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.
Access and Porting
You can access much of your information by logging into your account. If you require additional access or if you are not a SleepScore Labs member, contact us at support@sleepscorelabs.com. To download a copy of your data, visit https://portal.sleepscore.com/.
Rectify, Restrict, Limit, Delete Requests
You can also rectify, restrict, limit or delete much of your information by logging into your account. If you are unable to do this, please contact us at support@sleepscorelabs.com. SleepScore Labs will generally respond to your request within thirty (30) days or less.
Objection Rights
Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
Revoking consent
Where you have previously provided your consent, such as to permit us to process health-related data about you, you have the right to revoke or withdraw your consent to the processing of your information at any time. For example, you can revoke or withdraw your consent by updating your settings. In certain cases, we may continue to
process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
Right to Opt Out
When you submit personally identifiable information to us through the Registration Pages as part of the Service, you may be given an opportunity to opt in to receiving additional information from or on behalf of SleepScore Labs entities as part of the Service and otherwise, including notifications and “advice nuggets” forwarded by parties providing the Service App, and/or selected third parties at the time of submitting your personally identifiable information to us. By using our product, you have opted in to be added to our list of users who will receive promotional and marketing communications from us, our partners and/or other third parties. You can opt out of sharing information with us by contacting us at support@sleepscorelabs.com.
You can opt out of receiving products and services recommendations by discontinuing use of our product and/or Service or communicating a request to opt-out of receiving that information from us. If you discontinue your use of our product and/or the Service for a period of ninety days or more, we may require you to re-register or otherwise stop communicating with you electronically.
If you cannot access, edit or delete your personal data collected by SleepScore using the mechanisms above or directly using the products, apps, website, or related interfaces you can always contact SleepScore Customer Support via support@sleepscorelabs.com. You can cancel your account at any time as well by contacting Customer Support. We will work to respond to requests to access, edit or delete your personal data within 30 days.
Country Specific Provisions
Brazil
You may exercise your rights by contacting our DPO at dpo@sleepscorelabs.com. Brazilian residents, for whom the Lei Geral de Proteção de Dados Pessoais (“LGPD”) applies, have rights set forth in Article 18 of the LGPD.
USA
Under the CCPA, Californians have the following rights; we extend these rights to all US users:
Right to Know:
You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
Right to Request Deletion:
You have the right to request that we delete your Personal Information that we have collected from you;
Right to Non-Discrimination:
We will not discriminate against you for exercising any of these rights.
To exercise your “right to know” or your “right to request deletion,” contact us by email on dpo@sleepscorelabs.com
Complaint Rights
If you have any privacy concerns, complaints or inquiries for the Data Protection Officer of SleepScore, please contact us via email at dpo@sleepscorelabs.com and we will endeavour to assist you.
For EU individuals, you can lodge a complaint with either the Data Protection Commission in Ireland (please see www.dataprotection.ie for further information) or your local data protection authority.
Cookies and Similar Technologies
See our Cookie Policy
Personal Data Breach Response
Should a data breach occur the company shall announce a breach response for affected users if the breach results in a risk to any user and will do so in a timely manner.
Changes to the Privacy Policy
This Privacy Policy is subject to change from time to time when necessary based on customer feedback and changes to our products and services. As such you are advised to review this Privacy Policy occasionally as SleepScore shall endeavor to notify you of any material changes to the Policy.
Your continued use of any aspect of the Service after SleepScore modification of this Privacy Policy constitutes your acceptance of the modified Privacy Policy. If any term or provision of this Privacy Policy is be found to be invalid, illegal or otherwise unenforceable, such finding will not affect the other terms or provisions of this Privacy Policy, or the whole of this Privacy Policy, but such term or provision will be deemed modified to the extent necessary to render such term or provision enforceable, and the rights and obligations of you and SleepScore will be construed and enforced accordingly, preserving to the fullest permissible extent the intent and agreements set forth in this Privacy Policy.
If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account immediately.
How to Contact Us
If you have any technical or support questions, please contact us at: support@sleepscorelabs.com.
Please find contact details for our SleepScore companies below:
Consumer Sleep Solutions LLC 2175,
Salk Avenue, Suite 200, Carlsbad CA 92007. USA
dpo@sleepscorelabs.com.
SleepScore Labs International Limited
6th Floor, 2 Grand Canal Square, Dublin 2, Ireland.
dpo@sleepscorelabs.com.
Note: The Services (including the App and related sleep guidance and product recommendations) do not constitute a medical device or the practice of medicine. If you are seeking information on how to diagnose and/or treat a sleep disorder, you should consult with your healthcare professional.
To find the SleepScore affiliate or subsidiary in your country or region, see www.sleepscore.com.
