PRIVACY POLICY
Last updated April 05, 2026
This Privacy Notice for Jan Kohlhaas (“we,” “us,” or “our”), describes how and why we might
access, collect, store, use, and/or share (“process”) your personal information when you use our
services (“Services”), including when you:
• Download and use our mobile application SleepTrace – SleepTracker, or any other application
of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights
and choices. We are responsible for making decisions about how your personal information is
processed. If you do not agree with our policies and practices, please do not use our Services. If
you still have any questions or concerns, please contact us at support@sleeptrace.app.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice. You can find more details by
using the table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with us and the Services, the
choices you make, and the products and features you use.
Do we process any sensitive personal information? Some of the information may be considered
“special” or “sensitive” in certain jurisdictions. We may process sensitive personal information when
necessary with your consent or as otherwise permitted by applicable law.
Do we collect any information from third parties? We do not collect any information from third
parties.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent.
In what situations and with which parties do we share personal information? We may share
information in specific situations and with specific third parties.
How do we keep your information safe? We have adequate organizational and technical
processes and procedures in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be guaranteed to be 100%
secure.
What are your rights? Depending on where you are located geographically, the applicable privacy
law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by visiting
support@sleeptrace.app, or by contacting us. We will consider and act upon any request inaccordance with applicable data protection laws.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services,
express an interest in obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect may include the
following:
• email addresses
• usernames
• contact or authentication data
• contact preferences
• health data via healthkit
• mood ratings
• wake/alarm time preferences
• audio recordings (extracted as mel spectrograms)
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable
law, we process the following categories of sensitive information:
• health dataPayment Data. We may collect data necessary to process your payment if you choose to make
purchases, such as your payment instrument number, and the security code associated with your
payment instrument. All payment data is handled and stored by Apple. You may find their privacy
notice here: https://www.apple.com/legal/privacy/en-ww/
Social Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, X, or other social media account. If you
choose to register in this way, we will collect certain profile information about you from the social
media provider, as described in the section “HOW DO WE HANDLE YOUR SOCIAL LOGINS?”
below.
Application Data. If you use our application(s), we also may collect the following information if you
choose to provide us with access or permission:
• Mobile Device Access. We may request access or permission to certain features from your
mobile device, including your mobile device’s sensors, microphone, lockscreen widget, and
other features. If you wish to change our access or permissions, you may do so in your device’s
settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID,
model, and manufacturer), operating system, version information and system configuration
information, device and application identification numbers, browser type and version, hardware
model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or
proxy server).
• Push Notifications. We may request to send you push notifications regarding your account or
certain features of the application(s). If you wish to opt out from receiving these types of
communications, you may turn them off in your device’s settings.
This information is primarily needed to maintain the security and operation of our application(s), for
troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must
notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser
and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device characteristics,
operating system, language preferences, referring URLs, device name, country, location,
information about how and when you use our Services, and other technical information. The
information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our Services
and which we record in log files. Depending on how you interact with us, this log data may
include your IP address, device information, browser type, and settings and information about
your activity in the Services (such as the date/time stamps associated with your usage, pages
and files viewed, searches, and other actions you take such as which features you use), deviceevent information (such as system activity, error reports (sometimes called “crash dumps”), and
hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or
other device you use to access the Services. This may include information such as your IP
address (or proxy server), device and application identification numbers, location, browser type,
hardware model, Internet service provider and/or mobile carrier, operating system, and system
configuration information.
• Location Data. We collect location data such as information about your device’s location, which
can be either precise or imprecise. How much information we collect depends on the type and
settings of the device you use to access the Services. You can opt out of allowing us to collect
this information either by refusing access to the information or by disabling your Location
setting on your device.
• App usage data. Analytics to analyze user behavior inside the app
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes only with your prior explicit consent.
We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
• To facilitate account creation and authentication and otherwise manage user accounts.
We may process your information so you can create and log in to your account, as well as keep
your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to
provide you with the requested service.
• To send administrative information to you. We may process your information to send you
details about our products and services, changes to our terms and policies, and other similar
information.
• To request feedback. We may process your information when necessary to request feedback
and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal
information you send to us for our marketing purposes, if this is in accordance with your
marketing preferences. You can opt out of our marketing emails at any time.
• To deliver targeted advertising to you. We may process your information to develop and
display personalized content and advertising tailored to your interests, location, and more.
• To protect our Services. We may process your information as part of our efforts to keep our
Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to
better understand how they are being used so we can improve them.
• To save or protect an individual’s vital interest. We may process your information when
necessary to save or protect an individual’s vital interest, such as to prevent harm.3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we
have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal
bases we rely on in order to process your personal information. As such, we may rely on the
following legal bases to process your personal information:
• Consent. We may process your information if you have given us permission (i.e., consent) to
use your personal information for a specific purpose. You can withdraw your consent at any
time.
• Performance of a Contract. We may process your personal information when we believe it is
necessary to fulfill our contractual obligations to you, including providing our Services or at your
request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably
necessary to achieve our legitimate business interests and those interests do not outweigh your
interests and fundamental rights and freedoms. For example, we may process your personal
information to:
• Send users information about special offers and discounts on our products and services
• Develop and display personalized and relevant advertising content for our users
• Analyze how our Services are used so we can improve them to engage and retain users
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user
experience
• Legal Obligations. We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your information as evidence
in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect
your vital interests or the vital interests of a third party, such as situations involving potential
threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to
use your personal information for a specific purpose, or in situations where your permission can be
inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your
information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely
way• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or
settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial
abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or
the accuracy of the information and the collection is reasonable for purposes related to
investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession
and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to
ethics oversight and confidentiality commitments
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations described in this section and/or
with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with
third-party vendors, service providers, contractors, or agents (“third parties”) who perform services
for us or on our behalf and require access to such information to do that work. We have contracts in
place with our third parties, which are designed to help safeguard your personal information. They
will also not share your personal information with any organization apart from us. They also commit
to protect the data they hold on our behalf and to retain it for the period we instruct.
The third parties we may share personal information with are as follows:
• Allow Users to Connect to Their Third-Party Accounts: Google account
• Cloud Computing Services: Google Cloud Platform
• Functionality and Infrastructure Optimization: r2 and Google Cloud Storage
• Invoice and Billing: Apple Pay and PayPal
• Retargeting Platforms: Brevo
• User Account Registration and Authentication: Auth0, Google OAuth 2.0 and Google
Sign-In
• Web and Mobile Analytics: PostHog, Google Analytics for Firebase and Firebase Crashlytics
• Website Hosting: WordPress.com
• Website Performance Monitoring: Firebase Crash Reporting and Firebase Performance
Monitoring• Analytics: PostHog
• Communication: Brevo
We also may need to share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
• Offer Wall. Our application(s) may display a third-party hosted “offer wall.” Such an offer wall
allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for
the acceptance and completion of an advertisement offer. When you click on an offer wall, you
will be brought to an external website belonging to other persons and will leave our
application(s). A unique identifier, such as your user ID, will be shared with the offer wall
provider in order to prevent fraud and properly credit your account with the relevant reward.
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we
may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account
details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile information we receive may vary
depending on the social media provider concerned, but will often include your name, email address,
friends list, and profile picture, as well as other information you choose to make public on such a
social media platform.
We will use the information we receive only for the purposes that are described in this Privacy
Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not
control, and are not responsible for, other uses of your personal information by your third-party
social media provider. We recommend that you review their privacy notice to understand how they
collect, use, and share your personal information, and how you can set your privacy preferences on
their sites and apps.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined
in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in
this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will require us keeping your
personal information for longer than six (6) months past the termination of the user’s account.
When we have no ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?In Short: We aim to protect your personal information through a system of organizational
and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures
designed to protect the security of any personal information we process. However, despite our
safeguards and efforts to secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat
our security and improperly collect, access, steal, or modify your information. Although we will do
our best to protect your personal information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age
or the equivalent age as specified by law in your jurisdiction.
We do not knowingly collect, solicit data from, or market to children under 18 years of age or the
equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal
information. By using the Services, you represent that you are at least 18 or the equivalent age as
specified by law in your jurisdiction or that you are the parent or guardian of such a minor and
consent to such minor dependent’s use of the Services. If we learn that personal information from
users less than 18 years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you become aware of any
data we may have collected from children under age 18, please contact us at
support@sleeptrace.app.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the
European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have
rights that allow you greater access to and control over your personal information. You may
review, change, or terminate your account at any time, depending on your country, province,
or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request access and obtain a copy
of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of
your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated
decision-making. If a decision that produces legal or similarly significant effects is made solely by
automated means, we will inform you, explain the main factors, and offer a simple way to request
human review. In certain circumstances, you may also have the right to object to the processing of
your personal information.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your Member State data protection authority or
UK data protection authority.If you are located in Switzerland, you may contact the Federal Data Protection and Information
Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information,
you have the right to withdraw your consent at any time. You can withdraw your consent at any time
by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal
nor, when applicable law allows, will it affect the processing of your personal information conducted
in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our
marketing and promotional communications at any time by clicking on the unsubscribe link in the
emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists.
However, we may still communicate with you — for example, to send you service-related messages
that are necessary for the administration and use of your account, to respond to service requests, or
for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your
account, you can:
• Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at
support@sleeptrace.app.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage, no uniform
technology standard for recognizing and implementing DNT signals has been finalized. As such, we
do not currently respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised version of this
Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because
there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do
not respond to them at this time.11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida,
Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New
Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to
request access to and receive details about the personal information we maintain about you
and how we have processed it, correct inaccuracies, get a copy of, or delete your personal
information. You may also have the right to withdraw your consent to our processing of your
personal information. These rights may be limited in some circumstances by applicable law.
More information is provided below.
Categories of Personal Information We Collect
The table below shows the categories of personal information we have collected in the past twelve
(12) months. The table includes illustrative examples of each category and does not reflect the
personal information we collect from you.
Category Examples Collecte
d
A. Identifiers Contact details, such as real name, alias, postal
address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol
address, email address, and account name
YES
B. Personal information
as defined in the
California Customer
Records statute
Name, contact information, education, employment,
employment history, and financial information
NO
C. Protected classification
characteristics under
state or federal law
Gender, age, date of birth, race and ethnicity, national
origin, marital status, and other demographic data
YES
D. Commercial
information
Transaction information, purchase history, financial
details, and payment information
NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar
network activity
Browsing history, search history, online behavior,
interest data, and interactions with our and other
websites, applications, systems, and advertisements
NO
G. Geolocation data Device location NO
H. Audio, electronic,
sensory, or similar
information
Images and audio, video or call recordings created in
connection with our business activities
YESCategory Examples Collecte
d
I. Professional or
employment-related
information
Business contact details in order to provide you our
Services at a business level or job title, work history,
and professional qualifications if you apply for a job
with us
NO
J. Education Information Student records and directory information NO
K. Inferences drawn from
collected personal
information
Inferences drawn from any of the collected personal
information listed above to create a profile or summary
about, for example, an individual’s preferences and
characteristics
YES
L. Sensitive personal
Information
Health data YES
We only collect sensitive personal information, as defined by applicable privacy laws or the
purposes allowed by law or with your consent. We do not collect or process sensitive personal
information for the purpose of inferring characteristics about you.
We will use and retain the collected personal information as needed to provide the Services
or for:
• Category A – As long as the user has an account with us + 6 months after deleting the account
• Category C – As long as the user has an account with us
• Category H – Mel spectrograms kept as long as none disagrees with usage to evolve algorithm,
consent already through settings
• Category K – As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE
COLLECT?”
How We Use and Share Personal Information
Learn more about how we use your personal information in the section, “HOW DO WE PROCESS
YOUR INFORMATION?”
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Learn more about how we disclose personal information in
the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”
We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to be
“selling” of your personal information.We have not sold or shared any personal information to third parties for a business or commercial
purpose in the preceding twelve (12) months. We have disclosed the following categories of
personal information to third parties for a business or commercial purpose in the preceding twelve
(12) months.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute,
and in certain cases, we may decline your request as permitted by law. These rights include:
• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or
sharing as defined under California’s privacy law), the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant effects (“profiling”)
Depending upon the state where you live, you may also have the following rights:
• Right to access the categories of personal data being processed (as permitted by applicable
law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data
(as permitted by applicable law, including the privacy law in California, Delaware, and
Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as
permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by
applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal
data has been profiled (as permitted by applicable law, including the privacy law in Connecticut
and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law,
including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the
operation of a voice or facial recognition feature (as permitted by applicable law, including the
privacy law in Florida)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting support@sleeptrace.app, by emailing us at
support@sleeptrace.app, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a
request on your behalf. We may deny a request from an authorized agent that does not submit proof
that they have been validly authorized to act on your behalf in accordance with applicable laws.Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. We will only use personal information
provided in your request to verify your identity or authority to make the request. However, if we
cannot verify your identity from the information already maintained by us, we may request that you
provide additional information for the purposes of verifying your identity and for security or
fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information
to verify your identity before processing your request and the agent will need to provide a written
and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you
may appeal our decision by emailing us at support@sleeptrace.app. We will inform you in writing of
any action taken or not taken in response to the appeal, including a written explanation of the
reasons for the decisions. If your appeal is denied, you may submit a complaint to your state
attorney general.
California “Shine The Light” Law
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users
who are California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a California resident and would
like to make such a request, please submit your request in writing to us by using the contact details
provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”
12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by
Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).
This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what
personal information we collect from you, from which sources, for which purposes, and other
recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it
may affect our ability to provide our services, in particular:
• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your accountAt any time, you have the right to request access to or correction of your personal information. You
can make such a request by contacting us by using the contact details provided in the section “HOW
CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”
If you believe we are unlawfully processing your personal information, you have the right to submit a
complaint about a breach of the Australian Privacy Principles to the Office of the Australian
Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New
Zealand Privacy Commissioner.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an
updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy
Notice, we may notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this Privacy Notice frequently to be informed
of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at support@sleeptrace.app
or contact us by post at:
Jan Kohlhaas
Elsa-Brandström-Straße 3
Haan, NRW 42781
Germany
support@sleeptrace.app
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right
to request access to the personal information we collect from you, details about how we have
processed it, correct inaccuracies, or delete your personal information. You may also have the right
to withdraw your consent to our processing of your personal information. These rights may be
limited in some circumstances by applicable law. To request to review, update, or delete your
personal information, please visit: support@sleeptrace.app.