Last updated:
Privacy Policy
Last Updated: December 9, 2024
1. What This Privacy Policy Covers
2. What is Personal Information?
3. Personal Information We Collect
4. How We Collect Personal Information
5. Why We Collect and Use Personal Information
6. Reasons We Disclose Personal Information
7. Legal Grounds for Processing Personal Information
8. Cookies and Similar Technologies
9. Personalized Advertising and Ad Networks
B. Disclosures of Personal Information
C. “Sale,” “Sharing” and Personalized Ads
D. Sensitive Personal Information
F. Exercising Your Right to Know/Access, Right to Data Portability, Right to Correct or Right to Delete
G. Exercising Your Right to Opt-Out
14. Updates to the Privacy Policy
Hello, we are Ipnos Software Inc. (“Ipnos”, “we”, “our” or “us”).
The purpose of this Privacy Policy (this “Policy”) is to help you understand what personal data we collect and how; how we use, disclose or otherwise process your personal data, and your rights related to your personal data.
This Policy applies to individuals (natural persons) (“you” or “user”) who visit or use our mobile applications (“App(s)”), web applications (“WebApp(s)”), and websites (the “Website(s)” or “Web”) (collectively, the “Platform”), as well as the services related to our Platform (“Services”). Our Websites include:
● www.ipnos.com
● www.relaxmelodies.com
● my.bettersleep.com
● www.bettersleep.com
● my.relaxmelodies.com
This Policy also applies to individuals who provide or are interested in providing coaching services through our Platform (“Coaches”).
This Policy also applies to communications you may have with us via email, through live chat, push notifications, or through social media.
This Policy supplements our other terms and policies and does not override or replace them unless otherwise indicated or mutually agreed upon.
This Policy does not apply to any information you may share with third-party websites or services (for example, if you click on a link to a third party website or use a third party such as Google or Facebook to create an account on our Services). We encourage you to read the privacy policies of such third parties to understand their data privacy practices.
This Policy does not apply to the collection and use of personal data regarding Ipnos employees or independent contractors, unless as otherwise specified herein. If you are an employee or independent contractor, please contact us at [email protected] for the applicable privacy notice.
Our Platform and Services can be accessed and used from around the world. The laws that apply to the protection of your data may vary depending on where you reside. We strive to comply with all applicable laws – if you have questions based on your situation, feel free to contact us directly at [email protected].
For purposes of this Policy, “personal data” or “personal information” includes any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to an individual (natural person) or household.
“Personal information” does not include information that is deidentified or pseudonymized (meaning that it cannot reasonably be linked to an individual without the use of additional information, provided that measures are in place to secure such additional information) or aggregate consumer information (information that relates to a group or category of consumers and that is not linked or reasonably linkable to any consumer or household).
When we refer to “processing” personal information in this Policy, this means any operation performed on the information, including collection, organization, storage, retrieval, use and disclosure.
Depending on how you use our Platform and Services, we may collect the following types of personal information:
If you opt into and use the sleep tracker function within the Platform, we process the recordings to generate data points such as sleep and wake times, sleep scores, sleep phase graph data and recording classification. We store that data derived from the recordings (but not the recordings themselves) so you can see it in your profile. If you use certain third party sleep and fitness apps such as Apple HealthKit, Android Health Connect, and Google Fit, we give you the option to import information about your sleep from those apps into our Platform. In this Policy, we refer to any sleep information you choose to provide to us through any of the methods described above as “Sleep Data”).
We collect personal information from the following sources:
Directly From You. You directly provide us with information such as information you enter into questionnaires, web forms, inquiries, or during account creation.
Automatically From Your Use of the Platform. We collect certain information automatically as you use the Platform, in part using cookies and other tracking technologies (see Cookies and Other Tracking Technologies).
Information From External Sources. We also receive information from external sources such as:
Analytics and Advertising Tools. We use third-party analytics and advertising tools that provide us with your attribution data (information about the advertisement that brought you to the Platform). We use this information to customize and personalize your Platform and Services experience and to evaluate the effectiveness of our advertisements.
Advertising Networks. We also participate in advertising networks, which collect information about your visits to our Platform and the websites of Third Parties that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This process helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites.
Social Media Platforms. If you sign in to our Platform or Services through social media, we receive identifying information from the applicable social media platform in order to authenticate you.
Some of our content, such as blog posts, includes the option to share the content on your social media. When you share such content, we may collect indirect data about you, like your IP address and information derived from your IP address (geographic location and information about your device like your preferred language). We may also collect the time and date that you visited the page for sharing. As a reminder, if you share information on social media, you will be subject to the privacy policies of those platforms.
Third Party Fitness and Sleep Apps and Services. Our Platform gives you the option to import data into the Platform from other services you use such as Apple HealthKit, Android Health Connect, and Google Fit. We import this data only with your explicit consent. We only access and import categories of data related to your sleep.
We collect and use personal information for the following reasons:
If you are a Coach on our Platform, or being recruited to join us, in addition to the above we may process Coach Data to:
We disclose personal information to other entities who provide services on our behalf and at our direction (“Service Providers”), including our data hosting and data storage partners, analytics and marketing providers, vendors providing technology services and support, payment processing, data security, and similar services. For the purposes of this Policy, a “Third Party” is any entity that is not Ipnos, not a Service Provider, not a Coach, or any other parties that are specifically defined in this Policy.
We may also disclose personal information as follows:
Certain jurisdictions require a legal basis for processing personal information. We rely on the following legal bases for processing personal information:
Consent: based on your consent or otherwise consistent with your choices.
Performance of Contract: to fulfill a contract, or take steps related to a contract. This applies where you register to use the Platform (whether as a free trial or on a subscription basis). This includes providing you with the Services, authenticating you, processing payments, sending necessary communications (for example, related to payments), and providing customer service or support.
Legitimate Interests: as required to conduct our business and pursue our legitimate interests. This includes: operating the Platform, providing the Services, analyzing your use of the Platform and Services, measuring the effectiveness of our Platform and Services, developing the Platform and Services, diagnosing problems in our Platform and Services, and otherwise improving the safety, security and performance of the Platform and Services.
Legal Obligation: as necessary to meet our legal obligations, including responding to requests by government or law enforcement authorities or as otherwise reasonably necessary to prevent, detect, or address illegal activity.
We will not collect any personal data that is not needed for the purposes described in this Policy. Nor will we process personal data in a way that is incompatible with the purposes for which it has been collected unless subsequently authorized by you.
A “cookie” is a small data file that a website places on your device to store data that can be recalled by the website at a later time. Other technologies such as web beacons, tags, pixels, and mobile identifiers are used for similar purposes. In this Policy, when we refer to “cookies” we include all of these similar technologies.
We use our own, Service Provider, and Third Party cookies to remember your and honor preferences, optimize your experience on our Platform, monitor and analyze usage, and for advertising purposes.
You can change your browser’s settings so it will stop accepting cookies or to prompt you before accepting a cookie. On a mobile device, you can adjust the device’s settings to control tracking technologies. For more information about managing cookie preferences and tracking technologies see here.
We advertise our Platform and Services on third-party websites through our participation in advertising networks and use of Third Party advertising partners.
Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including using cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Platform and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites.
For information about how to opt out of personalized advertising, see Exercising Your Right to Opt-Out below.
We retain personal information for as long as required to fulfill the purpose for which it was collected and or as otherwise required by applicable laws.
Our Service Providers are located in multiple jurisdictions, including Canada and the United States, which means that your personal information may be transferred outside of your country or jurisdiction of residence. We take steps to ensure that such transfers are subject to adequate protections, contractual or otherwise, so that personal information is transferred and processed in accordance with applicable data privacy laws.
We strive to protect your personal information by implementing security features that are proportionate to the risks, such as unauthorized access or disclosure. Our Platform and Services use encryption, and access to your data is only granted on a need-to-know basis to individuals who are subject to a non-disclosure agreement or similar confidentiality obligations.
While we take all of these precautions, no measure is perfect and we are unable to guarantee that your data will be absolutely safe from any unauthorized or unlawful access, loss, alteration, or destruction. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Policy. If we learn of a potential breach, together with other actions referred to in this Policy (such as notifying you in certain cases), we may also undertake actions to remedy the breach, including, but not limited to, logging you out from the Platform and Services, resetting a password (sending a temporary password for you to use) and performing other reasonably necessary activities and actions.
Some U.S. states have passed privacy laws that apply to residents of those states, including California (the California Consumer Privacy Act or the “CCPA”), Colorado (the Colorado Privacy Act), Connecticut (the Connecticut Act Concerning Personal Data Privacy and Online Monitoring), Utah (the Utah Consumer Privacy Act), and Virginia (the Virginia Consumer Data Protection Act) (we refer to these and other similar laws collectively as the “U.S. Privacy Laws”).
This notice supplements our Privacy Policy by explaining your rights if you are a resident of one of those states and contains additional required information about the personal information we collect and use.
The following sections of this Policy describe the personal information we collect, the sources from which the personal information is collected, and our purposes for collecting and using personal information.
Personal Information We Collect
How We Collect Personal Information
Why We Collect and Use Personal Information
U.S. Privacy Laws, in particular the CCPA, define certain categories of personal information. The personal information we have collected in the last 12 months falls into the following categories under the CCPA:
During the last 12 months, we made the following disclosures of personal information to Third Parties for the purposes described above in the section Reasons We Disclose Personal Information. (For clarity, all categories of information may be disclosed to our Service Providers, as defined above. All categories of information may also have been disclosed to our affiliates).
| Category of Personal Information | Category of Third-Party |
|---|---|
| Identifiers | Analytics Providers; Advertising Networks/Advertising Partners; Integrated Apps (only if user opts in) |
| Personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | N/A (not disclosed to Third Parties) |
| Characteristics of protected classifications under California or federal law | Analytics Providers |
| Commercial Activity | Analytics Providers; Advertising Networks/Advertising Partners |
| Internet Activity | Analytics Providers; Advertising Networks/Advertising Partners |
| Geolocation | Analytics Providers; Advertising Networks/Advertising Partners |
| Audio Information | N/A (not disclosed to Third Parties) |
| Professional or employment-related information | N/A (not disclosed to Third Parties) |
| Inferences | Analytics Providers; Advertising Networks/Advertising Partners |
| Sensitive Personal Information (Sleep Data) | Integrated Apps (only if user opts in); Analytics Providers |
We do not sell personal information to Third Parties in exchange for money. Some U.S. Privacy laws, however, define “sale” and “sharing” broadly to include certain common advertising practices that allow us to advertise our App on other websites and show you ads that are tailored to your interests. Our use of ad networks (see Personalized Advertising / Ad Networks) falls within these broader definitions.
The information that we have “sold” or “shared” in the last 12 months includes the following categories of information, disclosed to our advertising networks and advertising partners for personalized advertising purposes:
The Sleep Data we collect and process may be considered sensitive personal information in some jurisdictions. Except with your explicit consent or as required by law, we do not use or disclose your sensitive information for purposes other than:
Depending on where you live and subject to certain exceptions under applicable law, you may have some or all of the following rights.
Right to Know / Right of Access. The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Right to Data Portability. In exercising your right to access personal information, you have the right to obtain the data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
Right to Delete. The right to delete personal information we have collected about you, subject to certain exceptions.
Right to Correct. The right to correct any inaccurate personal information we have about you.
Right to Opt-Out. The right to opt out of the sharing/processing of your personal information for targeted advertising/cross-context behavioral advertising purposes.
Non-Discrimination. The right not to receive discriminatory treatment by us for the exercise of rights conferred on you by any applicable U.S. state privacy law.
To the extent any of the information we collect may be considered sensitive personal information under applicable law, we limit the use of such information to certain specific uses permitted by law. For example, to provide you with the Services you request.
To Exercise Your Right to Know/Right of Access, Right to Data Portability, Right to Correct, or Right to Delete, please submit a request by one of the following methods:
Your request must include sufficient detail to allow us to understand, evaluate, and respond to it. It must also include sufficient information to allow us to verify that the person making the request is the person about whom we have collected information. If you have an account with us, we may verify your identity through existing authentication procedures for the account, provided your request relates to personal information associated with that account.
You may be entitled, under applicable law, to use an authorized agent to submit a request on your behalf. The agent must submit with the request your signed written permission authorizing them to make the request. Even if your agent provides this written permission, we may also require you to verify your identity directly with us or confirm with us that you gave the authorized agent permission to submit the request.
You may appeal any decision we have made about your request by following the instructions in the communication you receive from us.
You can opt out of targeted advertising (“sale” or “sharing” under the CCPA) or withdraw your consent to targeted advertising using one of the following options:
You may be entitled, under applicable law, to use an authorized agent to submit an opt-out request on your behalf. The agent must submit with the request your signed written permission authorizing them to make the request (this does not apply to requests made by an opt-out preference signal).
This Policy may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Privacy Policy from time to time to view any such changes.
If you have any questions or comments regarding this Policy or our privacy practices, or to submit a request, please email us at [email protected] or use the contact details below:
Ipnos Software Inc.
Attn: Legal Department
1010-615 Boul Rene-Levesque O
Montreal, QC, H3B 1P5, CANADA