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Privacy policy

CleverSleep® EU / UK / Switzerland Privacy Notice

Last Updated: 02/23/2026

This Privacy Notice applies to individuals located in the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland (“you”).

It explains how CleverSleep® collects, uses, stores, and discloses your personal data when you access our website, use the CleverSleep® application, integrate wearable devices, or otherwise interact with us.

For the purposes of EU and UK data protection law (including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the UK GDPR), the data controller is:

SleepDrops International Limited
Intellectual Property owner of CleverSleep®
A company incorporated in New Zealand
(“CleverSleep”, “we”, “us”, or “our”)

1. Personal Data We Collect

Information You Provide Directly

  • Name
  • Email address
  • Contact details
  • Billing and payment information
  • Account login credentials
  • Responses to the CleverSleep Sleep Assessment Survey (SAS™)
  • Customer support communications

Wearable & Sleep Data

When you sync your wearable device, we collect sleep-related biometric and behavioural data, which may include:

  • Sleep onset latency (SOL)
  • Wake after sleep onset (WASO)
  • REM and deep sleep distribution
  • Sleep duration
  • Recovery markers (e.g., HRV)
  • Device-derived metrics

This information is processed for sleep guidance purposes only and is not used for medical diagnosis.

Automatically Collected Technical Data

  • IP address
  • Browser type and version
  • Device type
  • Operating system
  • Access times
  • App usage activity
  • Cookie and tracking data

2. Special Category Data & Pseudonymised Data Modelling

Sleep-related biometric and wearable-derived information may constitute health-related data under GDPR.

We process this data:

  • With your explicit consent
  • For the purpose of delivering the CleverSleep service
  • For ongoing optimisation, analytics, and medium-term modelling of sleep pattern trends and pathway performance
  • In accordance with Article 9(2)(a) GDPR

Where possible, modelling and analytics are conducted using pseudonymised or aggregated data.

We do not use your identifiable health data for automated medical decision-making.

You may withdraw your consent at any time. Withdrawal will not affect processing already carried out but may limit continued use of the CleverSleep service.

3. How We Use Your Personal Data

Purpose Lawful Basis
Provide the CleverSleep service and structured sleep pathway Performance of a contract
Integrate wearable data and generate adaptive guidance Explicit consent (health data) + Contract
Manage subscription and payments Contract
Respond to support enquiries Legitimate interest
Improve and optimise platform Legitimate interest
Comply with legal obligations Legal obligation
Send marketing communications Consent (where required) or legitimate interest
Analyse anonymised or pseudonymised sleep trends Legitimate interest + Explicit consent (where applicable)

You have the right to object to processing based on legitimate interests.

4. Consequences of Not Providing Data

If you do not provide required personal data (including wearable data and survey responses), we may not be able to deliver the CleverSleep service.

5. Sharing of Personal Data

  • Payment processors
  • Cloud hosting providers
  • Data analytics providers
  • Customer support providers
  • Legal and regulatory authorities where required

All service providers are contractually bound to process data only in accordance with our instructions and applicable data protection laws.

We do not sell your personal data.

6. International Data Transfers

Personal data may be transferred outside the EEA/UK/Switzerland, including to New Zealand and other jurisdictions where our service providers are located.

Where required, we implement appropriate safeguards, including:

  • European Commission Standard Contractual Clauses (SCCs)
  • UK International Data Transfer Addendum
  • Contractual and technical security protections

7. Data Security

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

While we use industry-standard security measures, no internet transmission can be guaranteed to be 100% secure.

8. Data Retention

  • Provide the CleverSleep service
  • Comply with legal obligations
  • Resolve disputes
  • Enforce agreements

Sleep and wearable data may be retained for service continuity unless deletion is requested.

9. Your Rights (EEA / UK / Switzerland)

  • Access your personal data
  • Rectify inaccurate data
  • Request erasure
  • Restrict processing
  • Object to processing
  • Withdraw consent
  • Request data portability
  • Lodge a complaint with your supervisory authority

We will respond to requests within one month, subject to verification of identity.

10. Cookies & Tracking

We use cookies and similar technologies to:

  • Improve functionality
  • Analyse usage
  • Provide relevant marketing (with consent where required)

11. Age Restriction

CleverSleep is intended for individuals aged 18 years or older. We do not knowingly collect personal data from individuals under 18.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. Any material changes will be notified via the website or app.

13. Contact Information

If you have questions or wish to exercise your data protection rights, please contact:

support@cleversleepapp.com

If required under EU/UK law, we may appoint an EU/UK representative and will publish their details here.