Privacy Policy – Somnox 2 & Somnox App
Last updated: November 22th, 2022
This policy describes Somnox’ use of data from Somnox 2 and your data through the Somnox App in the Google Play Store (link) and the Apple App Store (link). References in this policy to Somnox, we or us shall mean Somnox B.V., a limited liability company with registered office at Rotterdam, Stationsplein 45, C3.063, 3013 AK, registered with the Dutch Chamber of Commerce (Kamer van Koophandel) under 67150179.
We would like to emphasize that we take the protection of your privacy and your personal data very seriously and that we process your data in accordance with applicable data protection laws.
We would like to explain to you below in more detail which personal data we collect in connection with our website www.somnox.com.
If you have any questions or remarks about this privacy policy, please contact us at privacy@somnox.nl.
Who is Somnox?
Somnox is the controller of your data and as such ultimately responsible with regard to the processing of your personal data on this website.
Which data do we collect?
Information you provide us with.
When using our app and/or device we may collect personal data from you such as your name, ip address, customer number, e-mail address, app usage, device interactions and sensor measurements.
You can also choose to provide us with personal data to get access to or use certain functionalities or services, for example when making an online purchase, subscribing to our newsletter, filling in a survey or providing us with feedback (e.g. reviews or messages).
Please see the overview data that we receive through the app and device attached to this policy at the end.
Where possible we will inform you which personal data we need from you to fulfill a certain request (marked with an asterisk*), and which personal data you share is optional.
You are not obligated to share your personal data and you may always decide not to share it. Please note however that if you decide not to provide personal data, it may not be possible to get access or use certain services or functionalities provided through the app.
Information your mobile device sends us
We collect information that is automatically sent to us by your mobile device. This most often includes your IP-address, the name of your mobile device and OS and the date and time of your visit. The information we receive depends on your own device settings. You can check your system to see which information it is providing and how you can change these settings.
We use this data to improve the content and functionality of our app, and to get better insights in the wants and needs of our users to provide them better services. The data we receive from your device is in itself insufficient to identify you as a person, but we are able to combine these data with other data which might make it possible to identify you.
For what purposes and on what legal basis do we use your data?
The personal data we collect via our app and device is used for various purposes.
- As required and necessary to establish and fulfill a contract with you, for example if you make a purchase from us. This may include verifying your identity, taking payments, communicating with you, providing customer services, and arranging the delivery or other provision of products, goods, or services.
- In order to enable our business and pursue our legitimate interests. In particular, we use your personal data for the following purposes:
- We will use your information to provide services you have requested and respond to any comments or complaints you may send us.
- We monitor the use of our products and services and may use your information to help us monitor, improve, and protect our products, content, services, and websites.
- We may monitor any customer account to prevent, investigate, and/or report fraud, terrorism, misrepresentation, security incidents, or crime, in accordance with applicable law.
- We may use your information to invite you to take part in market research, such as fulfilling online surveys and questionnaires.
- In order to comply with applicable laws and protection of Somnox’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).
- In addition, we may send you, based on your consent (if required), direct marketing communication in relation to our relevant products and services. If these communications are sent to you based on your consent, you have the right to withdraw your consent at any time (to “opt out”). You can opt-out, for example, by sending an e-mail to privacy@somnox.nl or in case of electronic direct marketing by following the instructions in the communication.
Who will we share this data with?
We may share your personal data with third party service providers, who will process it on behalf of Somnox for the purposes as mentioned above. Such third parties may include, but are not limited to payment providers, providers website hosting, maintenance, research agencies, identity checking, etc. The following parties process personal data from users:
Somnox Web Server
Somnox’s web servers (and databases) are hosted and stored within Amazon Web Services (AWS). These servers reside within Central Europe.
Klaviyo
Klaviyo is a tool that allows us to communicate with you through email and mobile push notifications. Their complete privacy policy can be found here.
Use of Klaviyo service: Whenever you create an account within our app or use the app while logged in, we will send limited information to Klaviyo. This information includes, but is not limited to, your email address and other mobile app or Somnox usage-related attributes and events (e.g. the latest software version to send you an update when a new version is out). We use Klaviyo to send you emails and/or push notifications about various topics, including educational content about using Somnox and our app, messages to help you on your path to better sleep and more relaxation, such as learning tips, reminders, and progress reports, and announcements of new product updates or research opportunities. For all communication that you receive through Klaviyo, you have the option to unsubscribe.
Intercom
Data that is stored on Intercom is also shared with them. Intercom is a functionality of the mobile app that allows users to contact customer support. Their complete privacy policy can be read here (Privacy Policy | Intercom) and Somnox also complies with them.
Data that is stored on intercom is secured and certified by SOC 2, EU-US Privacy Shield, Cloud Security Alliance (CSA), HIPAA (Health insurance Portability and Accountability Act), ISO 27001 Certification, and also is GPDR compliant. Also, all communication between Intercom and Somnox products are over https and encrypted using 256-bit encryption.
Use of Intercom Services: We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third party applications such as Stripe. You should consult these third parties’ privacy notices for further information on their use of your personal data. As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.
The data (and Intercom services) are stored and hosted in Amazon Web Services (AWS) facilities in the USA, Dublin, Ireland, and Sydney Australia.
Firebase Analytics and Crashlytics
Firebase Analytics and Crashlytics by Google is used by Somnox for app usage tracking purposes.
Firebase Analytics stores data in Google Cloud platforms servers that are chosen randomly across the globe, but with the U.S. as preference. Data stored using Firebase Analytics are always anonymous and is used to improve Somnox’s products and services.
By using Firebase Analytics, Somnox also complies with their terms of use and policies.
GOOGLE ANALYTICS FOR FIREBASE TERMS OF SERVICE | Firebase
Google Analytics for Firebase Use Policy
Firebase Crashlytics is used by Somnox to identify faulty software within the mobile apps. It allows Somnox to receive crash and bug reports to identify problems and fix them accordingly. The crash logs are also anonymous.
By using Firebase Crashlytics, Somnox also complies with their of use and policies.
FIREBASE CRASHLYTICS AND FIREBASE APP DISTRIBUTION TERMS OF SERVICE | Firebase (google.com)
Crashlytics and App Distribution Data Processing and Security Terms | Firebase (google.com)
Government authorities and/or law enforcement officials
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes as described above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
In the event that our business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Where will we send your data?
For technical and operations purposes, such as customer support, we may share your personal data with the parties mentioned above. Some of these parties are located outside the European Economic Area. The adequate level of data protection is ensured by either EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a third party’s Processor Binding Corporate Rules.
What are your rights in relation to your data?
You may be entitled to ask Somnox for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organizations. You may also have rights to object to some processing activities, such as the profiling we may perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent.
These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional. As mentioned earlier, we will inform you which personal data we need from you to fulfil a certain request (marked with an asterisk*), and which personal data you share is optional.
How to contact Somnox
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of marketing, you can get in touch at privacy@somnox.nl. Somnox will comply with your request as soon as possible and in any case no later than one month after Somnox has received such a request. If Somnox rejects your request, we will indicate in our reply why the request was rejected.
In the event you have unresolved concerns, you also have the right to complain to a data protection authority. The relevant data protection authority will be the Autoriteit Persoonsgegevens (https://www.autoriteitpersoonsgegevens.nl/) in the Netherlands.
How long will you retain my data?
Where you are a customer, Somnox will keep your information for the duration of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this privacy policy. Laws may require Somnox to hold certain information for specific periods. In other cases, Somnox may retain data for an appropriate period after any relationship with you ends to protect itself from legal claims, or to administer its business.
How do you protect my data?
We strive to maintain the highest standards of security and Somnox has put in place robust technical and organizational measures for the protection of your data in accordance with the current, general state of the art technologies, especially to protect the data against loss, falsification or access by unauthorized third persons. However the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission is at your own risk. Once we have received your personal data we will use strict procedures and security features to prevent unauthorized access.
Changes to this privacy policy
Somnox reserves the right to make changes to this privacy policy. You can access the latest version of our privacy policy by clicking on “Privacy Policy” at the bottom of every page on our website.
If you have any questions regarding our Privacy Policy, please contact us via:
E-mail: | info@somnox.nl |
Telephone: | +31 (0)10 899 4105 (available 10:00 – 17:00 GMT+2) |
Address | Stationsplein 45, C3.063 3013 AK, Rotterdam |