Introduction

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. Please read the following carefully to understand our views and practices regarding your sensitive information and how we will deal with it. For the purposes of the Data Protection Act and the GDPR, sensitive information includes what is defined as your ‘personal data’.

By using Sleepoo (‘Our App’) you accept and consent to the practices described in this Privacy Policy.

In this Privacy Policy, we seek to abide by the letter and spirit of the guidelines laid out by the UK Information Commissioner’s Office in the document ‘Privacy Notes – Code of Practice’.

Who We Are

More formally, we are WeCan. We are a team.

For the purposes of the Data Protection Act 1998 (the ‘DPA’) and in-line with the forthcoming European Union General Data Protection Regulations (the ‘GDPR’) WeCan is the Data Controller. 

If you have any concerns about the way we use your information or any questions about this Privacy Policy, please let us know.  We can be contacted via email at [email protected], or you can write to us at the address above.

What we do with your information

We will use your information to:

• Deliver our services to you;
• Allow you access to our app and help you to use our services to access or provide content through the Sleepoo platform.
• Improve our service continually, along with our App and user experience.

We compile statistics about user trends on Our App, which are used by third party organisations to understand how users interact with businesses, brands, and one another online and to advise about these things. These statistics are drawn from a dataset which does not contain any information from which you can be identified.

Information we collect from you

We will collect and process the following information about you:

Information you give us – this is information about you that you give us by filling in forms in Our App or by corresponding with us by phone, email or otherwise. It includes information you provide should you subscribe to our service through Our App.  We will only request from you the minimum data required for you to use our service.  The information you give us will include, as a minimum, your name and email address.

Information we collect about you – Whenever you visit our app we will automatically collect the following information:

technical information – including the Internet protocol (IP) address used to connect your computer or phone to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, advertiser id and platform;

information about your visit – this includes the pages you visit, and content you click on in Our App, page response times, download errors, length of visits to certain page and page interaction information (such as scrolling, clicks, and mouse-overs).

Information we receive from other sources – This is information we receive about you if you use any of the other websites or apps we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected from Our App. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Where we hold and what we do with your information

The information and content held on our system is deployed geographically to maximise user experience. All information that could identify individuals within the European Union is stored exclusively within the European Union.  We will never share your user information with third parties for promotional purposes.

We hold our data on Google App Engine who are contracted by us for the provision of technical services. We remain responsible at all times for the security of your information, but if you want to know more about how we interact with Google, you can view their Privacy Policy, amongst their other policies, here.

What we do to ensure the security of your personal information

We take the security of your personal data very seriously. Our approach to information security is constantly evolving and continually reviewed.

We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business.

We have policies and practices in place that not only ensure our compliance under the DPA but also the GDPR, including training and adequate procedures put in place for any staff that handle or have access to sensitive information.

Your rights regarding your personal information

We may contact you via email with updates about the services that we offer or any changes that we have made to Our App.

You can opt out at any time by toggling email opt-in to off within Our App’s ‘Account Settings’.

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our service may be advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we are not responsible or liable for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Access to Information

You have the right to find out about what information we hold about you. Your can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days.  Please contact us at [email protected].

You also have the right ‘to be forgotten’ and to have your information permanently deleted from our systems.  This can be performed automatically by using the ‘Delete Account’ functionality inside of our app under ‘Account Settings’, which will permanently and irrecoverably remove all our data from our systems.

There will be no charge made for electronic access to your information or for your right to be forgotten from our systems.

Changes to this Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you when you next log onto Our App. The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of the our services.

Our Cookie  Policy

Our App uses cookies to distinguish you from other users of Our App. This helps us to provide you with a good experience when you use Our App and also allows us to improve Our App.  By continuing to use Our App, you agree to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or phone if you agree. Cookies contain information that is transferred to your computer or phones’s hard drive.

As part of our overall approach to privacy and transparency, this section describes what cookies are in the context of our app and mobile interfaces, and what their use means to you. At the end, we’ve included some links to help you research cookies and their impact, and how you can use your web browser to control the way it manages cookies.

We use the following types of cookies:

• Strictly necessary cookies – these are cookies that are required for the operation of our app. They include, for example, cookies that enable you to log into secure areas of our app, use a shopping cart or make use of e-billing services. 
• Analytical/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our app when they are using it. This helps us to improve the way our app works, for example, by ensuring that users are finding what they are looking for easily. 
• Functionality cookies – these are used to recognise you when you return to our app. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies – these cookies record your visit to our app, the pages you have visited and the links you have followed. We will use this information to make our app and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but this will be contain no information capable of identifying you personally.

You can find more information about the individual cookies we use and the purposes for which we use below:

Health Kit

Our App supports the use of Apple Health Kit functionality. If enabled within Sleepoo; Health Kit support allows you to log the periods of time when you have been asleep using Sleepoo. This data is also used to award you “achievements” in app when you have accomplished specific goals in terms of your sleep (for instance sleeping 8 hours a night for 3 days in a row etc).

Health Kit access is strictly only used for the logging of Sleep times, and awarding of achievements within Sleepoo. All Health Kit data is only ever stored locally (on your phone) and is never passed to either our own server or any third parties. This feature is strictly optional, and Health Kit support must be explicitly enabled using the “Health Kit” button inside of Sleepoo in order to access this functionality.

Google Analytics

We use Google Analytics to understand general trends about our content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the amount of visits we receive.

Google’s statement about privacy can be found here.

Facebook Analytics

We use Facebook Analytics to understand general trends about our content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the amount of visits we receive.

Facebooks statement about privacy can be found here.

Twitter button

The Twitter button allows our users to share our platform and services with their followers more easily.

Twitter privacy policy states they use cookies “to collect additional Website usage data and to improve our Services” – You can read the policy in full here.

Facebook Button

We use Facebook button to allow you to share out platform with your friends and other Facebook users.

Facebook’s statement about privacy relating their Connect feature is here and also here.

Instagram button

Just like the Twitter and Facebook buttons, our Instagram button allows our users to share our content with their friends and followers.

A copy of their privacy policy can be located here.

Consent

In line with the latest advice from the Information Commissioner’s Office, we interpret your continued use of our platform as consent for us to use cookies to capture data about how you interact with our services, and those of other services we use.

More information about cookies

Links which provide more information about cookies:

http://www.allaboutcookies.org/

http://www.aboutcookies.org/default.aspx

Link explaining how to switch off cookies in various browsers:

http://www.aboutcookies.org/Default.aspx?page=1

Contact the Information Commissioner if there is a problem

If you consider we have not addressed your problem, you can contact the UK Information Commissioner’s Office for assistance. Further information can be found via https://ico.org.uk/for-the-public/raising-concerns/.