You are a candidate to participate in a sleep apnea survey administered by Sleep Cycle (the “Survey”), which has the purposes of improving our software for sleep analysis and to identify which of our users run an elevated risk of suffering from sleep apnea. We believe that transparency is key to any healthy relationship and want to be transparent with how we intend to use your personal data. Therefore, we urge you to read this information. To be able to process your personal data within our development program, we need your consent.

It is voluntary to give your consent to our processing of your personal data described here. If you give your consent, we will only process your personal data in the manner stated in this information.

Data controller and responsible for the processing of your personal data is:

The personal data that we will process about you based on this consent is a recording of the sounds you make during your sleep. We may process personal data available through your profile such as age, gender, BMI (Body Mass Index) and nationality and connect this to the sound recording. We will also process the personal data that you submit to us through the Survey, such as information about sleep behavior and sleepiness.

If you accept and perform the sleep apnea home test (as described below), we may receive health information about you, such as diagnosis information and raw test data.

Your personal data will be processed by Sleep Cycle’s authorized personnel. We will listen to the sound recordings and annotate certain events during the night such as snoring, breathing, movements and other sounds. Sleep Cycle will use the annotated sound recordings together with the other personal data you have provided to us in your profile and through the Survey for the purposes to train, develop and improve our sleep analysis software as well as to identify which of our users run an elevated risk of suffering from sleep apnea.

Sleep Cycle may offer you a sleep apnea home test which is provided by our cooperation partner. You can use this test at home in order to test if and to what extent you are suffering from sleep apnea. If you accept the offer of the sleep apnea test, we will forward your name and contact information to our cooperation partner who will instruct and assist you with performing and analyzing the test. If you decline the offer, your personal data will not be forwarded.

After you have performed the sleep apnea home test, we may receive diagnosis information and raw test data from our cooperation partner, which we use for the purposes to train, develop and improve our sleep analysis software. We will anonymize such information instantly upon receipt, meaning that it no longer can be connected to you and that it will only be processed as personal data by Sleep Cycle for a brief time.

The legal basis for our processing of your personal data for the purposes stated above is your consent as it is described in this information.

Your consent to our processing of your personal data for the purposes described herein is valid as long as you are a registered user of Sleep Cycle’s services.

You may withdraw your consent at any time, at which point we will stop processing your personal data for the purposes described herein. If you withdraw your consent, we may keep and continue processing the sound recordings in an anonymized format, meaning that they in such case no longer constitute personal data.

Sleep Cycle’s processing of your personal data as described in this information does not include automated decision making that produces legal effects or otherwise significantly affects you.

Your personal data may be transferred to and processed by others. We may transfer personal data to third parties that we engage such as accountants, lawyers or other consultants who are independently responsible for their processing of personal data. If you accept an offer of a sleep apnea home test, we will transfer your name and contact information to our cooperation partner who will instruct and assist you with performing and analyzing the test.

We will also transfer your personal data to our business partners and suppliers who process personal data on our behalf as data processors. We have agreements in place with our data processors which ensure that they process your personal data in accordance with this consent and our instructions.

Your personal data will be transferred to and/or stored by entities in the USA. The recipients of personal data in the USA are either certified under the EU-U.S. Privacy Shield Framework or contractually bound to process your personal data securely in accordance with the European Commission’s Standard Contractual Clauses. We will take all necessary measures to ensure that your personal data continues to be protected, and we will also take all necessary steps to ensure that any transfer outside of the EU/EEA is made in accordance with what is set forth in law.

The processing of personal data described in this text will only be conducted with what is stated herein as well as in accordance with applicable law.

You may withdraw your consent at any time. To do so, use the contact information above.

You have the right to request information about which personal data we have registered about you and how this personal data is processed. You may have the right to request that we delete or correct personal data, or restrict the processing of your personal data. You also have the right to request a copy of your personal data in a commonly used format. If you have any questions regarding our processing of personal data, withdrawal of consent, request for correction or a copy of your personal data etc., contact us using the contact information above.

We encourage you to contact us if you have any questions regarding this information or regarding how Sleep Cycle processes your personal data. You have the right to submit complaints regarding our processing of your personal data, or the way we handle matters connected to our processing, to the Swedish Data Protection Authority (Sw. Datainspektionen) which is the competent supervisory authority .

Datainspektionen
Box 8114
104 20 Stockholm
[email protected]

www.datainspektionen.se