PRIVACY POLICY

This Privacy Notice explains the data collection and data use notice of the SnoreLogic mobile app (“SnoreLogic”) developed by Passion for Life Healthcare LLC.

Unless otherwise mentioned in the privacy notice PFLH is the Controller and the Processor of the data collected by the app.

What personal data do we collect?

If you are using our SnoreLogic app we will collect and store the following information:

● Your email address
● Username
● Password
● Gender
● Year of birth
● Height
● Weight
● Self-reported (optional) data relating to things that could have affected your snoring (e.g. what you ate, drank, used to treat your snoring).
● 3 short audio recordings from each night’s analysis – examples of your snoring
● Data that describes the quantity, volume and time of snoring from each night.

It is our intention to ensure that data minimization principles are met. That means we only collect data that is necessary for the correct functioning of the SnoreLogic app and for the delivery of our associated services. It is therefore not possible to opt out of providing these 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 Consent to these uses can (only) be withdrawn by deleting your account (see below). If the purpose of data collection should change, you will be informed and consent re-obtained

How do we obtain your data?

When you download, install, complete registration with and use SnoreLogic app. 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.

How do we use your personal data?

● To check the performance of the SnoreLogic app.
● To provide you with in-app suggestions and information on your snoring and how to reduce it (based on in-app rules, not generated by humans).
● To reply to your enquires or feedback or to notify you of a serious health risk of one of our products you have purchased.
● To document and investigate feedback on the use of our products including complaints.
● To conduct research into snoring e.g. possible causes, the efficacy of treatments, variation in sound patterns (NB data used for research is anonymized first).

It is not possible to opt out of these data uses because they are necessary for the correct functioning of the SnoreLogic app and for the delivery of our associated services. Consent to these uses can only be withdrawn by deleting your account (see below).
If you have opted-in to receive Marketing communications from us;

● To send you information and offers relating to our products
● To send you invitations to participate in surveys, relating to our products

We will never share your personal data with third parties for marketing purposes. Every communication includes an opt-out link.
Under data protection law you have the right to restrict your data. Data collected by the app will not be shared or processed for any other reason than those outlined in this policy. 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.

Who is processing your data?

Data will be stored and processed by PFLH. Anonymised data may also be processed and stored by Research Partners, meaning partners working with PFLH to conduct research on snoring and other sleep disordered breathing.
Research Partners will only have access to data required to undertake research. If data is to be processed by our Research Partners, the data will be provided to them in a format that protects your anonymity.

PFLH has signed non-disclosure agreements with its Research Partners. Storing and processing of your data from our Research Partners falls under their privacy notice as well.

For how long do we store and process your data?

Your data will be stored and processed by PFLH and its Research Partners for a period of time at least equivalent to the lifetime of the SnoreLogic app but not less than two years from the date of the product release by the organization or as specified by the relevant regulatory authority”. When this has expired your data will be permanently erased from all the databases in which is stored.

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 analyzed and deleted continuously throughout the night. From all the audio processed on your phone only 3 short recordings of your snores are stored (locally and remotely on servers) along with the results of the analysis (times and volume of snores) and the other personal data defined above.
At PFLH we take your data and its security very seriously. The SnoreLogic app is compliant with US data protection laws. 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.

All personal data is processed and stored in compliance with the privacy laws of the country in which the data is collected.

More information regarding Firebase compliance with data protection laws https://firebase.google.com/support/privacy/

More information regarding compliance of MS Dynamics with data protection laws: https://docs.microsoft.com/en-us/dynamics365/get-started/gdpr/

Contacting us

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 dataprivacy@passionforlife.com.
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.

Your rights as a user

You as a user you have the right to access, delete, rectify and move your data. When logging in your app account, you have access to your profile data and the reports about your snoring from every night’s analysis. If you don’t want your data to be processed anymore, you as a user have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Through SnoreLogic app you will also be able to make any changes required in order for your data to be correct and up to date.
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.

Changes to this privacy notice

This notice will be updated from time to time to ensure it remains up to date and reflects how and why we use your personal data and new legal requirements