Introduction
Welcome to the Privacy Policy of Cambridge Sleep Science (“CSS”, “we”, “our” and “us”) a company registered in England and Wales under company number 12401790 and with our registered office at 115b Innovation Drive, Milton, Abingdon, England, OX14 4RZ.
We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit or use our SleepEngine platform (our proprietary electronic technology that uses a dedicated streaming service to deliver sleep audio directly to you through a wireless stereo speaker solution) (the “App”) and tells you about your privacy rights and how the law protects you.
1. Consent to Installation of the App
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.
Having installed this App, please indicate in the App your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this Privacy Policy, before proceeding with your account set up.
How you can withdraw consent
Once you provide consent, you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
2. Important information and who we are
Purpose of this policy
This policy (together with our SleepEngine terms of service as set out at cambridgesleepsciences.com/pillow-app-terms (Terms of Service) and any additional terms incorporated by reference within the Terms of Service applies to your use of:
- The App (which was last updated in December 2024) - mobile application software available on an App Store (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
- Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
This App is not intended for children, and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Controller
We are the controller and responsible for your personal data.
We have appointed a data protection officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data protection officer using the details set out below.
Contact details
If you have any questions about this Privacy Policy or our privacy practices, please contact our data protection officer in the following ways:
Full name of legal entity: Cambridge Sleep Sciences Ltd
Postal address: 115b Innovation Drive, Milton Park, Abingdon, England, OX14 4RZ
Email address: support@sleepengine.com
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate, however, the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this policy and your duty to inform us of changes
We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use or share personal data, we will reflect such changes in this Privacy Policy. These changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the privacy policy of every website you visit before you submit any personal data.
We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data.
3. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, address (if different to billing address), email address and telephone numbers.
- Sleep Data which will include information about your sleep length, habits, and other metrics required to determine adequacy of your sleep.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us and/or via our platform.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our App.
- Profile Data includes your username and password, purchases or orders made by you, and your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our App and/or our products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data includes the use of GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of any of our sites and/or our App. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- download the App;
- register to use the App;
- apply for our products or services;
- subscribe to our service or publications;
- make an in-App purchase
- request marketing to be sent to you;
- enter a survey or promotion;
- give us feedback or contact us or report a problem; or
- if you contact us, we will keep a record of that correspondence.
- Automated technologies or interactions. As you interact with App, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Location Data. We may also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google Analytics based outside the United Kingdom (“UK”) and the European Union (“EU”), from advertising and other social media networks based inside and outside the EU, and from search information providers such as Google based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the UK and EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
- Health apps: our App may make use of third-party health apps (“HealthKit”) such as Apple Health App to collect Sleep Data. You can choose to connect and share information with HealthKit and your HealthKit information with our App. If you grant our App access to HealthKit, our App can access and add information reasonably incidental to your sleep habits and patterns, amongst other data.
- Your unique health data you choose to send to and from HealthKit (including age, gender, weight) is not accessible by us and is not transferred by us to any third parties. Our App cannot write data to HealthKit unless you grant access. You can remove access at any time either inside our App or inside the HealthKit app. We are in no way responsible for the protection of any of your information that you agree to store with HealthKit, which is governed by the respective HealthKit provider’s privacy policy and other terms. You and the provider of the HealthKit are solely responsible for the protection of such information. Please review the HealthKit provider’s applicable policies and procedures before syncing and backing up your health data and/or other information with the HealthKit.
5. How and why we use your personal data
Under data protection laws, we can only use your personal data if we have a lawful reason to do so e.g:
- where you have given your consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of how we perform this assessment by contacting us at support@sleepengine.com.
Please see the table below which explains what we use your personal data for and why.
Marketing
You can subscribe to our newsletters and marketing materials though our SleepEngine platform, which may include entering competitions, or receiving information from us through other channels.
We will use your personal data to send you the newsletters and marketing materials (either by email, text message, telephone or post). We may also send you updates on our products including exclusive offers, promotions and new products.
We have legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by clicking the unsubscribe link at the bottom of any of our newsletter emails or by emailing support@sleepengine.com.
We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the address listed above or email us at support@sleepengine.com at any time.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Who we share your personal data with
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, such as service providers acting as processors who provide IT and system administration services or provide services in relation to the tracking and monitoring of data in order for us to provide the Services. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
In rare cases we may disclose your personal information:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- if Cambridge Sleep Sciences or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements.
- to protect the rights, property, or safety of Cambridge Sleep Sciences, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Where we store your personal data and how we keep it secure
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, including but not limited to, such information which may be transferred to and stored in the United States. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
Countries where personal data relating to you may be stored and/or processed, or where recipients of personal data relating to you may be located, may have data protection laws which differ to the data protection laws in your country of residence. By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We take measures to ensure that any international transfer of information is managed carefully and in accordance with data protection law to protect your rights and interests and in accordance with this Privacy Policy.
These measures include:
- transfers of your personal data to countries which are recognised as providing an adequate level of legal protection for personal data;
- we have obtained the consent of data subjects to the international transfer of their personal data;
- transfers to organisations where we are satisfied about their data privacy and security standards and protected by contractual commitments such as signing the Standard Contractual Clauses and, where available, further assurances such as certification schemes.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password which enables you to access Cambridge Sleep Sciences, you are responsible for keeping this password confidential. You must not to share a password with anyone.
You have the right to ask us for more information about our safeguards. Please contact us if you would like to receive further details.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to Cambridge Sleep Sciences; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. How long do we retain your information
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will delete your personal data within 30 days if you delete your account.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. Your legal rights
You have certain rights regarding your personal data. These include the rights to:
- request a copy of the personal data we hold about you;
- request that we supply you (or a nominated third party) with an electronic copy of the personal data that you have provided us with;
- inform us of a correction to your personal data;
- exercise your right to restrict our use of your personal data;
- exercise your right to erase your personal data; or
- object to particular ways in which we are using your personal data (such as automated decision making, or profiling (for example to help us decide what products and services would suit you best); or
- understand the basis of international transfers of your personal data by us.
Where we rely on our legitimate interests to obtain and use your personal data then you have the right to object if you believe your fundamental rights and freedoms outweigh our legitimate interests. Where processing is carried out based upon your consent, you have the right to withdraw that consent.
Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right does not apply to the particular personal data we hold on you.
You should note that if you exercise certain of these rights we may be unable to continue to provide some or all of our products or services to you (for example where the personal data is required by us to comply with a statutory requirement, or is necessary in order for us to perform our contract with you).
We ask that you contact us to update or correct your personal data if it changes or if the personal information we hold about you is inaccurate.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How to complain
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Which country's laws apply to any disputes?
Please note that the terms of this Privacy Policy, their subject matter and their formation, are governed by the laws of England and Wales. You and we both agree that the English courts will have exclusive jurisdiction.
Version 1, updated December 2024