IMPORTANT PRIVACY INFORMATION
When you access our service we automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, and hardware ID. We need this data to provide our services, analyze how our customers use the service and to measure ads.
For improving the service and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amazon, Amplitude, Appsflyer Google, Facebook, Firebase, PayPal, Sendios, TikTok, Pinterest, Zendesk. Therefore, some of the data is stored and processed on the servers of such third parties. This enables us to (1) analyze different interactions (how often users make purchases, what products our users viewed); (2) serve and measure ads (and show them only to a particular group of users, for example, only to those, who have made a purchase).
If you decide to make a purchase or to order a service on the website, we will ask you to provide your email, approximate age, and different information about your appearance. We will use this data to fulfil your order and render a personalized service.
Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). If any questions will remain unanswered, please contact us at support@mybecalmed.com.
PRIVACY POLICY
This Privacy Policy explains what personal data is collected when you use the website located at mybecalmed.com. BeCalmed mobile application, and the services and products provided through them (the “Service”), how such personal data will be processed.
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; (b) delete the App from your device or leave the Service and not access or use it; and (c) cancel any active subscriptions or trials.
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
TABLE OF CONTENTS
PERSONAL DATA CONTROLLER
SONIDORICO APPS LIMITED, a company registered under the laws of the Republic of Cyprus, having its registered office at Replace With: Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.
CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, email address, approximate age). We also collect data automatically (for example, your IP address).
Data you give us
If you decide to make a purchase on the website, we will ask you to provide email address which will be used to send you the personalized sleep plan, or any details on your payment. We may also ask your approximate age, your preferences to tailor our product to your personal needs.
If you also wish to receive sleep recommendations on the website and/or the app (when such option is possible), we will ask you to provide your preferences and other related information to render personalized advice.
Data we collect automatically:
Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).
Device and Location data.
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID. We also record the ads in our website with which you interact (and the Internet links to which those ads lead).
Usage data
We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the service, how long you are on the website, your purchases.
Transaction data
When you make payments through the website, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.
Cookies
A cookie is a small text file that is stored on a user‘s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.
Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.
FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. As a result of such processing, we will use your email, for example, for sending you the personalized sleep plans or sleep challenge.
To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.
To store data we may also use Firestorage. Privacy Policy.
To customize your experience
We process your personal data, such as your approximate age, preferences, and information about your appearance, to adjust the content of the Service and provide content tailored to your personal preferences. As a result of such processing, you receive, for example, a personalized sleep plan based on your answers to the questionnaire.
To provide you with customer support
We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.
To communicate with you regarding your use of our Service
We communicate with you, for example, by emails. These may include for example, emails with information about the Service. To opt out of receiving emails, you need to follow the instructions in the footer of the emails.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.
We use Zendesk ticketing system to handle customer inquiries. When you send us inquiries via contact form or via email, we will store the details provided by you via Zendesk ticketing system, which enables us to track, prioritize and quickly solve your requests. Privacy Policy.
To communicate with you we also use Firebase Notifications, which is message sending services provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our App across platforms such as Android and iOS. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send encouraging messages to users who have recently finished a training program. Google‘s privacy policy.
To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
To perform research and analysis about how users interact with our Service we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to our Website). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy. Appsflyer allows you to Opt Out of having data from my device sent to Appsflyer‘s servers for apps usage collection.
We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our website, how often users make purchases, and other interactions. Lean more about Facebook’s approach to data from its Privacy Policy.
To perform our App analysis, we also use Tableau, a company providing interactive data visualization products focused on business intelligence. Tableau Software Privacy Policy.
Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur in our Website. As a result, Amplitude helps us to decide what features we should focus on. Amplitude provides more information on how they process data in its Privacy Policy.
To track and analyze behavior of our Service users (in particular, how they react to changes of the Service structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users). Privacy Policy and Privacy and Security in Firebase.
BigQuery, an analytical service provided by Google, allows us to analyze large and complex datasets about the App. We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google‘s use of data, consult Google‘s partner policy. Firebase Privacy information. Google’s Privacy Policy.
To send you marketing communications
We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Website. We may show you advertisements on our website and/or app, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.
We use Sendios, which is a marketing personalization and retention platform, to deliver tailored email messages to our users.
To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our website, you might see ads of our products in your Facebook’s feed.
How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.
Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.
macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads
Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here.
To learn even more about how to affect advertising choices on various devices, please look at the information available here.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
Network Advertising Initiative – http://optout.networkadvertising.org/
Digital Advertising Alliance – http://optout.aboutads.info/
Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
DAA AppChoices page – http://www.aboutads.info/appchoices
Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.
Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook pixel together with Facebook Advanced Matching on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website (for example, enabled a trial or subscription), whereas Facebook Advanced Matching increases efficiency of Facebook pixel with additional conversion tracking pixel parameters.
We use Facebook Ads Manager together withFacebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, visited certain sections of the Website). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.
Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.
TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). TikTok’s Privacy Policy.
We use Pinterest Ads to deliver group-based advertisements. For example, you may see our ads if you are interested in specific services, information, or offers. Pinterest Privacy Policy.
To process your payments
We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors, such as PayPal and Solidgate). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made.
We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
3.10. To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
We process your personal data under the following legal bases:
your consent
Under this legal basis we:
Send you marketing communications. You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails. We will also send you push notifications if you allow us to. You can disable notifications any time in the settings of your device.
to perform our contract with you;
Under this legal basis we:
Provide our Service (in accordance with our Terms and Conditions of Use)
Customize your experience
Provide you with customer support
Communicate with you regarding your use of our Service
Process your payments
for our (or others‘) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
to communicate with you regarding your use of our Service
This includes, for example, sending you email to notify you that we have released a new product or reminding to finish a purchase. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.
to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
to comply with legal obligations.
WITH WHOM WE SHARE YOUR PERSONAL DATA
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:
Service providers
mb=2 We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
cloud storage providers (Amazon, Firebase)
data analytics providers (Facebook, Google, Amplitude, Appsflyer)
communication service providers (Firebase, Sendios, Zendesk)
marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, TikTok, Pinterest)
payment service providers (PayPal, Solidgate)
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
HOW YOU CAN EXERCISE YOUR RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
Deleting your personal data. You can request erasure of your personal data as permitted by law. To exercise your right you can send us an email indicating your request.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
Additional information for EEA-based users:
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request to us as described below.
To exercise any of your privacy rights, please send a request to support@mybecalmed.com.
AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
INTERNATIONAL DATA TRANSFERS
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details availablehere), or (ii) the European Commission adequacy decisions about certain countries (details available here).
CHANGES TO THIS PRIVACY POLICY
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties‘ direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to support@mybecalmed.com which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
DATA RETENTION
We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Except as otherwise stipulated in this Privacy Policy, this Service does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
CONTACT US
You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@mybecalmed.com
Effective as of: August 18, 2022