Privacy Statement - Somnox

Introduction

Somnox takes your privacy very seriously and shall handle your personal data with the utmost security and care. In this Privacy Statement you will learn how we handle your data as well as learn about your rights concerning our processing of your data. We advise that you read this Privacy Statement thoroughly. Should you have any questions or remarks, please contact us at privacy@somnox.nl.

Who is Somnox?

Somnox is the limited liability company Somnox B.V., with registered office in Delft, 2629 JD Molengraaffsingel 12, listed at the Traderegister of the Dutch Chamber of Commerce (KvK) under 67150179.

Somnox is as the controller ultimately responsible with regard to the processing of your personal data.

What personal data is collected?

The use of our products and Services requires the collection of your personal data which allows us to identify you directly or indirectly. We collect all data on the legal basis of consent, with the exception of economic information that is required for handling transactions.

Directly or within the framework of the use of the Services, we collect the following data:

  1. For general use of this website (including job applications):
    • Usage analytics (Click behaviour, online behaviour, social media account, location, IP address)
  2. If you have signed up for the newsletter:
    • Aforementioned usage analytics
    • Email address
  3. If you have purchased a physical item from our webshop or have created a Somnox account:
    • Identity and civil status (surname, first name, email address, home address)
    • Economic information (data relating to the means of payment, data relating to transactions, including billing address, order number, account number, customer number)
  4. If you have installed and setup the Somnox Companion app (on Android or iOS):
    • Personal life (date of birth, fitness, weight, height, activities, substance use, stress levels, etc.)
  5. If you regularly use the Somnox app in conjunction with the Somnox sleeprobot:
    • Health data (data on breathing rate, interpreted data on heart rate, data on motion during usage)
    • General usage data (how often you use the product, sleep time, wake time)
    • Preference data (music choice(s), sleeprobot settings)

Data retention period

Somnox retains your personal data for a period that does not exceed the period necessary for the purposes set forth in this Privacy Policy. After this period, your personal data may be archived to comply with the legal and regulatory obligations to which Somnox is subject, or deleted.

In this context, the retention period of your personal data concerning your orders applied by Somnox is two (2) years.

In addition, your personal data relating to your use of our Services, Application and Site is kept for the entire period of use of said Services, Application and Site.

How did we obtain your personal data?

Somnox has obtained your data because you have provided this data to us, and because Somnox has obtained your information from third parties. These third parties are: Google Analytics, Google Tag Manager, Google Optimize, Hotjar, and Facebook Tracking Pixel.

Purposes of the processing of your personal data

Your personal data is subject to processing by Somnox for the exclusive purpose of providing, exploiting, maintaining and improving our Products, Applications and Services and to manage the customer relationship.

The processing implemented by Somnox is for the following purposes:

  • To process a business transaction or manage an order
  • To perform operations relating to customer management (CRM)
  • For monitoring the customer relationship such as conducting satisfaction surveys, management of claims and the after-sales service;
  • Accounting and in particular the management of customer accounts
  • Handling complaints or messages and managing reviews
  • A/B testing
  • Management of requests for rights of access, rectification, opposition, deletion, the limitation of processing, information, the portability of data and opposition to profiling

In addition, we can use your usage analytics for:

  • Implementing improvements to our products or services, including this website
  • General market research, including social media marketing and retargeting

Finally, we can use your health data and Somnox Sleeprobot usage statistics to:

  • Customize your use of our products or applications
  • Provide personalized recommendations
  • Update processing algorithms
  • Research and develop new products and services

What are your rights?

Under the European General Data Protection Regulation you have a number of rights with regard to your data and the processing thereof:

Access

You may access your personal information and make any necessary changes in your account. If you would like to see what personal data Somnox has obtained about you, you may exercise your right of access by submitting a request to Somnox.

Making changes

If you wish to make changes to the personal information that you have seen as a result of a request for access and you are unable to make the changes yourself in your account, you may request that Somnox makes these changes for you. You may request that Somnox modifies, corrects, supplements, erases or shields your information.

Restriction of processing of personal data

You also have the right, under certain conditions, to ask Somnox to restrict the processing of your personal data.

Right to object

If processing of your data takes place on the grounds of 'legitimate interest' by Somnox or a third party, you have the right to object to that processing.

Portability of data

You have the right to obtain your personal data from Somnox. Somnox will provide this in a structured and commonly used format, which can easily be opened using commonly used digital systems.

Automated processing

Whenever a decision about you is taken that is completely based on automated processing of your personal data, you have the right to request that that decision be re-evaluated by a person. You may at all times let us know your position on that decision or let us know that you do not agree with our decision.

Withdrawing consent

When the legal basis for a particular processing is your explicit consent, you have the right to withdraw that consent. This does not affect past processing, but does mean that we will no longer be allowed to process this data in the future. It may also result in Somnox no longer being able to provide you with certain services.

Response from Somnox

A request can be sent to privacy@somnox.nl. Somnox will comply with your request as soon as possible and in any case no later than one (1) month after Somnox has received such a request. If Somnox rejects your request, we will indicate in our reply why the request was rejected.

Recipients of your personal data

It is possible that Somnox is required to submit your data to a third party, for example to fulfill a legal obligation.

Transfer to third countries or international organisations

It may be necessary, for instance for technical and operational reasons, to transfer your (personal) data to affiliates of Somnox located outside the European Economic Area. Due to the possibility that the regulations in the area of privacy protection do not offer the same protection as within the European Economic Area, Somnox will use the Privacy Shield or the EU Model Clauses to protect your privacy as much as possible. If that is not possible, Somnox will ask your consent to transfer your (personal) data to countries that do not maintain an adequate protection level. You may withdraw your consent at any time

Automated Decision Making

Somnox can use automated decision-making processes based on your data, when you have given us permission to do so. In particular, we may use your health data and general usage statistics to automatically alter the settings of your Somnox Sleeprobot. Additionally, if you have purchased a certain product previously you might not get access to certain promotional deals for that given product.

What are cookies and how does Somnox use them?

Cookies are small pieces of (text) information that are sent to your browser when you visit the website of Somnox and then stored on the hard disk or in the memory of your device. The cookies placed via Somnox’s website cannot damage your device or the files stored on it. With 'cookies', we also mean comparable techniques collecting information, such as device fingerprinting.

Can changes be made to this Privacy Statement?

This Privacy Statement is subject to changes. We therefore advise you to regularly read the Privacy Statement for any such changes.

Questions, remarks, and complaints

If you have any questions regarding this Privacy Statement or the way in which Somnox uses your data, you can send an e-mail to privacy@somnox.nl. If you have a complaint about the way your data is processed, please send an e-mail to privacy@somnox.nl. Furthermore, you always have the right to contact the competent national data protection authority. In The Netherlands, this is the Autoriteit Persoonsgegevens.