Who we are
The Simba Sleep app is operated by Simba Sleep Limited (a company registered in England and Wales (company number
09703422), whose registered office is at 5th Floor, Halo, Counterslip, Bristol, United Kingdom, BS1 6AJ. Simba
Sleep Limited is a Data Controller and it is registered with the Information Commissioner’s Office under registration
number ZA841124.
This privacy policy explains how we will collect and use your personal information when you use our app. It should be
read in conjunction with the app’s End User Licensing Agreement - https://simbasleep.com/pages/simbasleepcoach-terms/
What personal data we collect, how we collect it and what we use it for
We will collect the following information from you:
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Basic information
- Account details
- Name
- Email address
- IP address
- Username and log in information, including hashed password
- Location – country and city
- Information about your device (for example, the operating system you are using)
-
Enhanced information
- Social network information
- Lifestyle information (for example, whether you drink coffee)
- Sleep tracking information, such as the time you go to sleep and when you wake up, sound recordings of your sleep,
information on the quality of sleep and your energy levels (typically tracked twice a day, once in the morning and
once in the evening). When you download the app, we will collect basic information from you so that we can set up
and manage your account.
Once your account is ready to go, we will then ask you to respond to a series of questions that give us a more
detailed picture of your current lifestyle and habits. These questions will collect enhanced information from you.
Depending on your device, you may use choose to use facial identification as a method of engaging with it and the
apps stored on it. If you use facial identification as a method of authorising access to our app, that biometric
information will be processed by your device provider only (e.g., Apple, Google); we will not receive a copy of any
biometric information you provide.
We process your information for the following purposes:
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Type of information
|
Purpose
|
|
Basic information
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- enable you to access and use the app
- improve and maintain the app, and provide technical
support
- ensure the security of the app
- evaluate your use of the app and to understand the
user experience
- to recognise you when you return to the app or use
the app across devices
|
|
Enhanced information
|
- to personalise your experience and upload information
to the social media channels you use
- customise the app according to your individual habits
and interests
- to store information about your preferences, and to
allow us to customise the app according to your individual interests;
- to evaluate your visit to the app and prepare reports
or compile statistics to understand the type of people who use our app, how they use our app and to make our
app more intuitive
- to operate, protect, improve, and optimize our app
and personalize and customize your experience), we conduct profiling on your characteristics and preferences
based on your interactions with the app, your search and purchase history, your profile information and
preferences, and other content you submit to the app.
|
By design, the app does not have access to other content on your device (such as your contacts or photos), and it does not use cookies, web beacons, pixels or other tracking tools.
Our lawful basis for processing
We rely on your consent to collect and process your information. You provide this consent when you download the app, and agree to our terms and conditions while signing up for an account via which you will use the app and the Services.
Who we share personal data with
We engage the following third parties to support us in delivering and managing the app:
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The app development and design company, MINDSEA DEVELOPMENT, INC. - mindsea.com. MindSea acts as a data processor; it may process your personal data on our behalf, but it will only do so in accordance with the contract we have in place with them. This includes managing the app and responding to any troubleshooting reports sent to appsupport@simbasleep.com.
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The app performance marketing agency, Consult My App https://www.consultmyapp.com/. Consult My App acts as a data processor; it may process your personal data on our behalf, but it will only do so in accordance with the contract we have in place with them. This includes reporting on the performance of the app like the number of downloads.
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The cloud computing platform, Microsoft Azure. We use Azure as a data processor to backup the information you provide in the app. This includes your basic and enhanced information.
When engaging data processors we endeavour to make sure the contract or terms and conditions we have in place requires them to put in place the same standard of requirements with any sub processors they separately engage.
We have configured our use of Microsoft Azure via a UK-based data centre, but your information may be processed outside the UK by other Microsoft entities to facilitate the delivering of the services we have purchased. Whenever Microsoft transfers personal data outside the UK, it agrees to protect that information to the same standard as it is protected in the UK. You can find out information on Microsoft’s business privacy practices at 
Microsoft Privacy Statement – Microsoft
privacy .
How we keep your information secure
To protect your information and keep it safe, we always encrypt it. We do that via the app itself and the platforms we use to maintain your information (e.g., Microsoft Azure). Whenever we move your information around, we will continue to make sure that it is encrypted so that it cannot be tampered with or read on its journey.
We store the password you use to access the app but the copy we keep is hashed. This means we make it unintelligible so we cannot read it. We store it because it helps you log in and if you forget your password, having a stored copy will help you to reset it.
How long we keep your personal data
We will keep a copy of your personal data for as long as you continue to use the app. If you decide that you no
longer want to use the app and you delete it from your device, this will not automatically delete the copy of your
information that we or any third parties engaged by us hold. If you want to delete that information, please see the
section “Your rights” below. If you delete the app and don’t exercise your right to erasure, we will keep a copy of
your information for 7 years.
Your rights
Data protection law provides individuals with several rights over their information. If you would like to exercise any of these rights, please contact us via email at appsupport@simbasleep.com or by writing
to our registered office address.
Withdraw consent
As stated above in the section “Our lawful basis for processing”, we rely on consent to facilitate your use of the
app. You have the right to withdraw your consent at any time and you can exercise this right by contacting us via
email at appsupport@simbasleep.com or by writing to our registered
office address.
Access your information
You can request a copy of the personal information we hold about you at any time. This is commonly called a “subject
access request” and you can make a request via email at appsupport@simbasleep.com or by writing
to our registered office address.
Request correction of your personal data
This right enables you to have incomplete or inaccurate data we hold about you corrected.
The information you store in the mobile app can be amended at any time by contacting us via email at appsupport@simbasleep.com or by writing to our registered
office address. Whenever you change any information about you that is stored in the app, the copy we hold in our
backup environment will be updated, generally, in real time. If you have made changes to your information in the app
but you still think we might be holding incorrect information about you, you can let us know and we will amend it.
Please note that we may ask you to verify the accuracy of any new information you give us.
Request deletion of your personal data
In certain circumstances, you have the right to ask us to delete any information we hold about you. This is commonly
called a “right to erasure” or a “right to be forgotten” request. If you want to exercise this right, please contact
us. Please note that if you delete the app from your device this will not automatically erase any copy of your
personal data we hold on our server. If you wish to delete any information we hold outside of the app, please let us
know via email at appsupport@simbasleep.com or by writing to our registered
office address
Request restriction
As with the right to request the deletion of your information, this right only applies in certain circumstances and
if it applies, it requires us to restrict or suppress the use of your personal data.
Request transfer of your information
This right is known as the “right to data portability” and it enables you to move, copy or transfer your information
from one environment to another, and this must be done in a secure way. Please note this right applies to the basic
and enhanced information you provided to us when you started using the app; it does not apply to any data that we have
created based on information you have provided to us. It would therefore not apply to any user profile data within the
app. We cannot guarantee that another system or software will be able to make use of or properly interpret information
extracted from our systems where you exercise this right, but will provide the raw data in a commonly used,
machine-readable format.
Make a complaint
We welcome feedback from mobile app users and whenever we haven’t got something quite right, we would welcome the
opportunity to put it right. However, if you need to (and we hope you never will!) you have the right to make a
complaint to the Information Commissioner’s Office at any time about the way we handle your information. The ICO is
the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by
public bodies and data privacy for individuals. You can find out more at
https://ico.org.uk/make-a-complaint.
Automated decision-making and profiling
Our app relies on pre-programmed algorithms and criteria. When you set up your profile in our app and you answer our
detailed questionnaire about your lifestyle and habits, the app automatically evaluates the responses you give and profiles them against that criteria to assign you a persona. We use personas to help us to deliver advice and tips on how to manage your approach to sleep-related behaviours. Continued use of the app then enables it to understand more about you and predict your behaviours so it can continue to deliver tailored support and advice on your sleep journey. The intention of the automated decision-making and profiling is to suggest behaviours aimed at refining the user’s sleep-influencing behaviours. There is no human involvement in the evaluation of your responses, so the app processes this information purely by automated means.
When an organisation processes personal data solely by automated means, rights relating to automated decision-making
in data protection law may apply. These rights are there to ensure that any decisions made because of processing
carried out by automated means do not have a serious affect on you.
We do not believe that any features in the app make or inform any decisions that would substantially impact you, and
therefore we do not think this right applies to individuals that use our app. If you have any concerns over the way
the app uses your information, we recommend that you discontinue using it and exercise your right to erasure.
How to tell us when things change
To exercise any of your personal data rights or to raise any questions or complaints you may have, please contact us
via email at appsupport@simbasleep.com or by writing to our registered
office address You can find out more information on Simba’s collection and use of personal data in its main privacy
policy on its website at https://simbasleep.com/pages/privacy/. You
may wish to refer to this if you have other relationships with Simba (for example, if you have purchased products from
us or otherwise interacted with us in some way).
This policy was created in March 2024. We will keep this policy under review, and we may update it from time to
time.
