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MOBILE APP PRIVACY POLICY

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 2 Temple Back East, Temple Quay, Bristol, United Kingdom BS1 6EG. 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:

  • 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
    • Gender
    • Social network information
    • Lifestyle information (for example, whether you drink coffee)
    • Professional details – if you are working or not and your current occupation
    • Family details – whether you have children
    • Information on your health and wellbeing (for example, if you are perimenopausal/menopausal, pregnant)
    • Information on your sex life that can be inferred from information you provide relating to your sex and your health and wellbeing
  • 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. We will use your answers to understand which pre-established sleep persona you best align to. Determining your persona is important for helping you improve your sleep habits, set yourself challenges and get the most out of using the app. You will not get the full benefit of the app and the sleep coaching it provides if you do not complete the questionnaire. (Please see the section titled “Automated decision-making and profiling” below for more information on the way personas are determined within the app).

If you decide to fill in the persona questionnaire, your responses to the additional, sensitive questions, will be stored locally on your device, and we will not access it or process it in a way that can identify you until you submit your responses. This means that up to the point where we assign your persona, we may receive anonymised information about your use of the app, but we will never be able to identify you from that information. When you submit the questionnaire, the information will remain on your device but will also be backed up in our cloud-based server environment. We back up your information to make sure that your logged data in the app always remains up to date and secure, and for administrative purposes (to facilitate verification emails and password resets).

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:

Type of information

Purpose

Basic information

-          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.

When you complete the persona questionnaire, you will reveal more sensitive information to us. When processing this special category information, we will rely on the separate condition of explicit consent. You do not have to tell us sensitive information about you but doing so will maximise the benefit to you from the sleep coaching the app provides.

Who we share personal data with

We engage the following third parties to support us in delivering and managing the app:

  • The app development and design company, COMPSOFT (UK) LTD trading as Compsoft Creative - compsoft.co.uk. Compsoft 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 we send to it via its own reporting tool, Sherlock
  • 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.

Compsoft is a UK-based company and will not transfer any of your information outside of the UK.

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 https://privacy.microsoft.com/en-gb/privacystatement

We do not otherwise transfer any of your information outside of the UK.

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 hello@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 hello@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 hello@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 hello@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 hello@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 c

an 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 hello@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 December 2022. We will keep this policy under review, and we may update it from time to time.

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