This Privacy Notice explains the data collection and data use of the SoundSleep app (“SoundSleep”) developed by Passion for Life Healthcare (UK) Limited (“PFLH”).
Unless otherwise indicated PFLH is the Controller and the Processor of the data collected by SoundSleep.
Data We Collect from You
SoundSleep only collects data that is relevant to providing, improving, and personalizing your experience with SoundSleep. It is our intention to ensure that data minimisation principles are met. That means we only collect data that is necessary for the correct functioning of SoundSleep and for the delivery of our associated services. It is therefore not possible to opt out of providing this data if you wish to use SoundSleep.
Personal Data You Provide
If you use SoundSleep we will collect and store Personal Data; this means:
- Identity Data includes your username and where applicable any unique user ID we may assign you.
- Contact Data includes email address and any communication we have had with you (including emails, phone calls, voicemail, and conversations you may have had with our support team).
- Data that you input into the app (such as age, weight, snoring solutions you used, drank…)
- Short audio recordings from each night’s analysis – examples of your snoring and sleep breath events. We do not collect audio recordings or other media unless you explicitly provide them (for example, via a support request).
- Data that describes the quantity, volume and time of snoring and sleep breathing evens from each night.
Anonymous Usage Data
We also collect, store and share Aggregated Anonymous Data. This means data drawn from Personal Data from all SoundSleep users, but it does not reveal your identity and it cannot be linked or traced back to you personally;
- Demographic data, statistical data and audio data.
- How you interact with the app (e.g. which features you use, how often you log in).
- Anonymised summaries of app usage and responses, which may be used in research or reporting.
Aggregated Anonymous Data helps us to understand more about how people sleep and what the data supplied by you means. Aggregated Anonymous Data is a key tool for developing algorithms that help us interpret your data and advise and support you.
Technical Information we collect automatically
- Device information — information about the mobile device you use to access SoundSleep; including the hardware model, operating system and version, log files, timestamps and unique device identifiers.
How we use this information?
In summary, we use all of the above information to:
- check the performance of SoundSleep.
- provide you with suggestions and information based on your data.
- reply to your enquires or feedback.
- monitor and analyse trends in usage and engagements
- document and investigate feedback on the use of our service including complaints.
- conduct research into sleep, sleep breathing, snoring and the human body.
- check troubleshoot issues with the app or website
Your data will never be shared without your consent.
In the unlikely event of a data confidentiality breach, we will notify you immediately and take every reasonable step to limit potentially damaging consequences of the breach.
Analytics Use in the SoundSleep App
What Services We Use and Why
Firebase Analytics
We use Firebase Analytics to help us understand how our app is used. It also supports essential features like crash reporting (for quick fixes), performance monitoring (for a smooth experience), and remote configuration (allowing us to improve features without app updates). You can learn more about Firebase Analytics here: Privacy and Security in Firebase.
BigQuery
We use BigQuery to securely store and analyse large volumes of anonymous usage data collected from the app. This enables us to spot trends, identify common issues, and measure the effectiveness of features over time. BigQuery acts solely as a data processor on our behalf and does not access or use your data for advertising or unrelated purposes. You can learn more about BigQuery’s security and compliance standards here.
Mixpanel
We use Mixpanel to gain deeper insights into how people navigate and engage with specific features within SoundSleep. This helps us improve app usability and deliver a more personalized and effective experience. Mixpanel acts as a data processor on our behalf. This means it only uses your data according to our instructions and does not sell or share your personal data for advertising purposes. You can review Mixpanel’s privacy and security practices here.
What Data Is Collected
These services may collect:
- Device information (e.g., type, operating system)
- App usage data (e.g., time spent on certain screens, button taps)
- Technical data (e.g., crash logs, performance metrics)
- IP address (used to determine approximate location, then anonymised or discarded)
We do not collect personally identifiable information (such as name or email) through these services unless you explicitly provide or accept the marketing permit. If you want us to delete this information, contact with us and we will do it.
How We Use This Data
We use this data to:
- Improve app functionality and user experience
- Monitor and fix bugs or performance issues
- Make decisions about future app features
- Understand user engagement and behaviour trends
We do not use this data for third-party advertising or sell it to other companies.
Anonymised Aggregate Data may also be processed and stored by Research Partners. Research Partners means partners working with PFLH to conduct research on sleep, sleep breathing, snoring and the human body. Research Partners will only have access to data required to undertake research. If data is to be processed by our Research Partners, the data is only provided to them in a format that protects your anonymity.
How do we obtain your consent to collect your Personal Data?
Your consent for us to process your Personal Data for the specific purposes set out in this policy is the lawful basis on which we undertake the processing of that data. Consent to these uses can only be withdrawn by you asking us to delete your account (see below).
We obtain your consent when you download, install, complete registration with and use SoundSleep. In our Terms of Service, we ask for your agreement to use your data in accordance with this Privacy Policy and you give your agreement by completing the registration process for this app. If you are not in agreement DO NOT CLICK “I AGREE” or register an account.
Where is data stored and processed?
All data is processed locally on your device. Most of the audio data processed locally on your device is analysed and deleted continuously throughout the night. From all the audio processed on your phone only short recordings of your snores and sleep breathing events are stored (locally and remotely on servers) along with the results of the analysis (times and volume of snores and time of sleep breathing eve) and the other personal data defined above.
Personal Data is stored by Google on a Firebase server located in Western Europe and the location of the default bucket for the Firebase storage is also located in EU. Anonymised Data exported from Firebase for research purposes and identifiable data exported for customer service purposes will be stored inside the European Union. Data cannot be transferred to countries outside the European Union without gaining written consent from PFLH. If any changes are required to the storage of your data and the location of the data centres where your data is stored, we will notify you accordingly.
At PFLH we take your Personal Data and its security very seriously. SoundSleep is compliant with EU GDPR 2018 and other appropriate regulatory requirements. For processing and storage of your data we are using certified and secure cloud solutions from Google and Microsoft which use standardised protocols for encryption of data in transit and at rest.
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For how long do we store and process data?
We retain your data securely for as long as your account remains active. If you choose to delete your account, we will remove your Personal Data in accordance with applicable data protection regulations. Aggregated Anonymous Data will be stored for as long as it is useful for research purposes.
Your data protection rights
As a data subject, depending upon the lawful basis we are relying on, you have a number of rights, in accordance with the UK GDPR and EU GDPR. These rights relate to all Personal Data, as defined in this policy, but does not apply to Aggregated Anonymous Data, as similarly defined. The rights are:
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Your right |
What does it mean? |
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Right to access |
You have the right to access and receive a copy of your Personal Data. This is sometimes referred to as submitting a “data subject access request”. |
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Right to data portability |
This right relates to moving or copying your Personal Data from one data controller to another. |
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Rights to rectify |
You have the right to update, correct or complete your personal data. |
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Right to object |
You have the right to object to or ask us to restrict the processing of your personal data, including for the purposes of direct marketing. |
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Right to be forgotten |
Subject to certain exceptions, you are entitled to have your Personal Data deleted, at any time. From time to time, we may be required to retain data for example to comply with a legal obligation, or exercise or defend legal claims. If you wish to have your Personal Data deleted please contact us. |
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Right to withdrawal of consent |
You have the right to withdraw your consent to us processing or holding your Personal Data at any time by asking us to delete your account. |
Changes to this privacy notice
This Privacy Policy is subject to change at any time when necessary. This may be based on user feedback and/or changes to our services. We reserve the right to make changes to this Privacy Policy. As we do not collect personal information such as email addresses, we are unable to personally notify you of changes to the privacy policy. You are therefore advised to review this Privacy Policy from time to time.
Your continued use of SoundSleep after any changes made to the Privacy Policy constitutes your acceptance of the modified terms within. If you object to any changes to this Privacy Policy you should stop using SoundSleep.
Contacting us
Under UK GDPR and EU GDPR you have the right to object to the processing of your Personal Data. You also have the right to request that you are not subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We welcome your correspondence on this or any other questions regarding our privacy notice or the use of your information. Please also contact us to report any knowledge of a child accessing the app and providing personal data, without parental consent.
You can contact our Data Protection Officer by email [email protected] or by writing to:
PFLH Data Protection Officer
Passion for Life Healthcare (UK) Limited
HQ 5th Floor, Nicholas Street, Chester,
CH1 2NP
United Kingdom
You will need to provide information that will help us confirm your identity. Once we have all the information to respond to your request, we will provide the information to you as soon as possible and always within 1 month of receiving your request.
If for any reason and after you have raised with our Data Protection Officer any concerns regarding your data, you have the right to lodge a complaint with your Local Supervisory Authority.