Goodsomnia AB – Privacy Policy

Effective Date: May 2019

Goodsomnia AB respects your privacy and shares your concern about the security of information you may submit to Goodsomnia AB’s websites and the related mobile applications and services (collectively, the “Services”). Our Privacy Policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy settings and your rights in connection with the Services. Please also read the Terms of Service which sets out the terms governing the Services.

Goodsomnia is headquartered in Stockholm, Sweden and our Services are provided to you by Goodsomnia AB. If you are a resident of the European Union (“EU”), Goodsomnia AB is the Controller of your personal and health data for the purposes of EU data protection law.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy 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 on or through the Services.

Questions or comments about this Privacy Policy may be submitted by mail to the address below or via support@goodsomnia.com.

Contact Information:

Goodsomnia AB, Registration company number: 559058-3265

Tomtebogatan, 34, 113 38, Stockholm, Sweden

Email of the Chief Data protection Officer – cdpo@goodsomnia.com

We collect, use, share and otherwise process information

Goodsomnia AB relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

• as necessary to provide the Services and fulfil our obligations pursuant to the Terms of Service. For example, we cannot provide the Services unless we collect and use your health data;
• where you have consented to the processing, which you can revoke at any time. For example, you may consent to the processing of health-related information;
• where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
• to protect your vital interests, or those of others, such as in the case of emergencies;
• where you have made the information public;
• where necessary in the public interest; and
• where necessary for the purposes of Goodsomnia AB’s or a third party’s legitimate interests.

Our legitimate interests

We process your information in furtherance of our legitimate interests, including:

• providing and improving the Services, including any personalized Services. We do so as it is necessary to pursue our legitimate interests of providing and developing innovative and tailored offerings to our members on a sustained basis; and
• keeping the Services safe and secure. We do so as it is necessary to pursue the legitimate interests of Goodsomnia AB and its members in ensuring the Services are secure, and to protect against fraud, spam and abuse, etc.

Information Goodsomnia AB collects

Goodsomnia AB collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with Goodsomnia AB. We receive information in a few different ways, including when you track, complete or upload activities using the Services. Goodsomnia AB also collects information about how you use the Services. There are also several opportunities for you to share information about yourself and your activities with Goodsomnia AB. For example:

• We collect basic Personal account information such as your name, email address, date of birth, gender, height, weight, username and password that helps secure and provide you with access to our Services;
• Profile and use information are collected about you when you choose to upload a picture, health tracking activity (including date, time and the information about your biomarkers) or otherwise use the Services;
• Goodsomnia AB collects information from the company’s or approved partner’s devices and apps (For example, Apple Health app / Google Fit / Samsung Health) you, connect to Goodsomnia Lab app. For example, you may connect Goodsomnia Pocket ECG or Goodsomnia Sleep sensors (incl. ECG) to Goodsomnia Lab app and information from these devices will be passed along to Goodsomnia Analytics Platform (cloud-based analytic platform);
• Goodsomnia AB may collect or infer your Health information «Health data» which may include information such as Heart rate / ECG / HRV / Sleep statistics \ or other Biometric information, such as height and weight or other indicators which the company getting during the Sleep events recording process. Before you can upload health information to Goodsomnia AB or information from which Goodsomnia AB can infer health information, you must give your explicit consent to the processing of that health information by Goodsomnia AB during the registration process. You can withdraw your consent to Goodsomnia AB processing your health information at any time, by using the option on the Personal account page inside the Goodsomnia Lab app;
• We gather information from the photos, posts, comments, snoring sounds and other content you share on the Services, including when you participate in partner events or create records or reports;
• When you make a payment on Goodsomnia AB, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry compliant third-party payment services and we do not store your credit card information;
• Goodsomnia AB allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook or Google (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts, we will collect information that you have agreed to make available such as your name, email address, profile information and preferences with the applicable Third-Party Account. This information is collected by the Third-Party Account provider and is provided to Goodsomnia AB under their privacy policies. You can generally control the information that we receive from these sources using the privacy settings in your Third-Party Account;
• To help us to provide you with the best possible service, you can choose to provide us with your contact information, so we can better respond to your support requests and comments;
• We also obtain additional third-party information about members from marketers, partners, researchers, and others. We may combine information that we collect from you with information obtained from other members, third parties and information derived from any other subscription, product, or service we provide;
• We collect non-personal information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information.

Cookies and similar technologies

When you visit the Services, a cookie will be stored on your computer. Generally, cookies and similar technologies work by assigning to your browser or device a unique number that has no meaning outside of Goodsomnia AB. Goodsomnia AB uses these technologies to personalize your experience and to assist in delivering content specific to your interests. Additionally, after you’ve entered your member ID and password during a session on the Services, Goodsomnia AB saves that information so you don’t have to re-enter it repeatedly during that session..

Most browsers automatically accept cookies. To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device. Goodsomnia AB is committed to providing you choices to manage your privacy and sharing. However, Goodsomnia AB does not recognize or respond to browser-initiated Do Not Track signals, as the internet industry has not fully developed Do Not Track standards, implementations and solutions. To learn more about Do Not Track signals, you can visit https://allaboutdnt.com. Not accepting cookies may make certain features of the Services unavailable to you. Goodsomnia AB may also use your IP address to identify you, to administer the Services and to assist in diagnosing problems with Goodsomnia AB’s servers.

Log files

The Services use log files. The stored information includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and a number of clicks. This information is used to analyse trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc., may be linked to session IDs, user IDs and device identifiers.

How Goodsomnia AB uses information

Goodsomnia AB uses the information we collect and receive to administer and operate the Services and as otherwise described in this Privacy Policy. For example, we use your Health data to provide you with statistics and visualizations representing key data points like:

Snore value %, Snore levels %, Breathing rate, Factors impact, Snoring index (number of snores per hour), Sleep goals, Sleep duration, Sleep debt, Sleep notes, Time in bed, Time out of bed, Awakes, Sleep stages (Light / Deep / REM), Sleep quality, Sleep depth, Body positions, Morning mood / Feelings markers, Apnoea/hypopnea index, Body biomarkers analysis during sleep, Heart attack \ events prediction, Dangerous arrhythmias detection (including AFib); Heart rate, HRV, ECG graphs and ECG Scores, QRS complex.

Subject to your privacy settings, your information, including your profile, username, photo, members who observing your health data statistic (loved one) or added by you as observer of your health condition and treatment progress (doctors), your activities, comments you give via chat function and receive will be shared on Goodsomnia AB to participate in the Services, for example, to show your health statistics and trends on a dashboard inside the cloud-based analytics platform.

We also use your information to analyse, develop and improve the Services. To do this, Goodsomnia AB may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services. We may also use your information to market the Services, credit or accept payments, provide support related to the Services, protect members and enforce our Terms of Service, promote safety, and communicate with you. Additionally, your information may be shared with third parties, as set forth below.

Goodsomnia AB may de-identify or aggregate the content you make available in connection with the Services, in ways that do not personally identify you. Examples of such aggregated information or statistical data include information about own hardware products, usage, demographics and performance. Goodsomnia AB may use, sell, license, and share this information with third parties for research, business or other purposes. Goodsomnia AB also uses aggregated data to generate the global heatmap. Please visit your privacy settings if you object to Goodsomnia AB using your information for these purposes.

We use your information to communicate with you about the Services, send you marketing communications (where you have agreed to receive such messages during account registration), or let you know about new features or updates to our Terms of Service. We also use your information to respond to you when you contact us. Goodsomnia AB will use your information to communicate with you, for example by sending you notifications.

How information is shared

Service Providers

We may share your information with third parties who provide services to Goodsomnia AB such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. 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 overtime on our behalf so that we or they may promote Goodsomnia AB or display information that may be relevant to your interests on the Services or other websites or services.

Publicly available information

Subject to your privacy settings, your information and content may be accessible for the other users which you added as an observer to your health dashboard.

Third party business via API or other integrations

When you choose to use third-party apps, plug-ins, or websites that integrate with the Services, they may receive your information and content, including your personal information, photos, and your activity data (including private activities). Information collected by these third parties is subject to their terms and policies. Goodsomnia AB is not responsible for the terms or policies of third parties.

Affiliates and acquirers of our business or assets

We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Goodsomnia AB 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 transaction.

Legal requirements

We may preserve and share your information with 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 to respond 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 Goodsomnia AB 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.

DMCA Notices

We may share your information with third parties when we forward the Digital Millennium Copyright Act (DMCA) notifications, which will be forwarded as submitted to us without any deletions.

How we protect information

We take several measures to safeguard the collection, transmission and storage of the data we collect. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure. The Services uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Goodsomnia AB engages a company that is an industry leader in online security and Services verification to strengthen the security of Goodsomnia AB’s Services. The Services are registered with site identification authorities so that your browser can confirm Goodsomnia AB’s identity before any personally identifiable information is sent. In addition, Goodsomnia AB’s secure servers protect this information using advanced firewall technology.

To help ensure that these measures are effective in preventing unauthorized access to your private information, you should be aware of the security features available to you through your browser. You should use a security-enabled browser to submit your credit card information and other personal information at the Services. Please note that if you do not use an SSL-capable browser, you are at risk for having data intercepted.

Most browsers have the ability to notify you if you change between secure and insecure communications, receive invalid services identification information for the Services you are communicating with, or send information over an unsecured connection. Goodsomnia AB recommends that you enable these browser functions to help ensure that your communications are secure. You can also monitor the URL of the services you are visiting (secure URLs begin with https:// rather than http://), along with the security symbol of your browser to help identify when you are communicating with a secure server. You can also view the details of the security certificate of the services to which you are connected. Please check the validity of any Services you connect to using secure communications.

Disclaimer

While Goodsomnia AB continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and Goodsomnia AB cannot ensure or warrant the security of any information you transmit to Goodsomnia AB. Transmitting personal information is done at your own risk.

Managing your settings

Privacy settings

Goodsomnia AB offers several features and settings to help you manage your privacy and how you share your Health data information. The privacy settings are located in your Account settings page. Goodsomnia AB provides you with the option to make your health recording and analysis private. To manage your privacy settings, please visit Goodsomnia Lab app on the Personal account page.

Adjust notification and email preferences

Goodsomnia AB offers various ways to manage the notifications you receive. You can choose to stop receiving certain emails and notifications by indicating your preference at the Goodsomnia Lab app, on the Personal account page. You may also unsubscribe by following the instructions contained at the bottom of each type of email. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or the Terms of Service, etc.) generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.

Updating account information

You may correct, amend or update profile or account information that is inaccurate at any time by adjusting that information in your Personal account settings. If you need further assistance, please contact Goodsomnia AB at support@goodsomnia.com . Goodsomnia AB will generally respond to your request within 10 business days.

Deleting information and accounts

You may request that your account is deleted by visiting Goodsomnia Lab app page – Personal account \ Account settings. Once deleted, your data, including your account, activities and health data cannot be reinstated.

Note that content you have shared with others (for example, through Share option) or that others have copied may also remain visible after you have deleted your account or deleted the information from your own profile.

EU Members’ rights

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict an object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

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 Goodsomnia AB member, contact us at support@goodsomnia.com. To download a copy of your data – visit the Goodsomnia Lab app – Personal Account \ Account settings or send an email request to support@goodsomnia.com and we will generate this info package for you.

Rectify, restrict, limit, delete

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@goodsomnia.com. Goodsomnia AB will generally respond to your request within 10 business days.

Object

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.

Revoke 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 withdraw your consent to the processing of your information at any time. For example, you can 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.

Complain

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or send a request to our Chief Data Protection Officer – cdpo@goodsomnia.com.

Transfers

The services are operated from the territory of the EU. If you are located outside the EU and choose to use the services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in the EU, as it is necessary to provide the services and perform the Terms of Service.

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 infor mation. 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, where you withdraw your consent to Goodsomnia AB processing your health-related information, Goodsomnia AB will delete all health-related information you uploaded. Following your 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, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

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 Goodsomnia AB, such as statistics of the use of the Services.

Privacy Policy information

Goodsomnia AB reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Goodsomnia AB makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.