Enerjoy Limited (“we”, “us”, “our”) believe that transparency is the key to any healthy relationship. We appreciate that you trust us with information about you, and we want to be transparent about how we use it.
This privacy policy (“notice”) describes how your personal data is processed by Me+ (“the app”, “the services”) and us. You will learn about the data we collect, how we use it, your rights, and the measures we take to keep it safe. We always make sure that your data is protected in accordance with applicable legislation.
You own your personal data. Therefore, we offer you several ways to control the privacy of your personal information and we are constantly striving to improve the functions and features needed in order for you to be in control.
We will process your personal data only in accordance with your consent and applicable legislation, such as the GDPR. We are not the data controller for personal data that is processed locally on your device.
If you have any questions, or feel you need any part of this notice explained, please contact us.
When using the app, you will enter certain personal data into the app (such as your email address, when you go to bed and wake up, etc.), some personal data will be collected through your device’s accelerometer (such as your movements), microphone (such as snoring or other noises), camera (pulse), or device location (for weather and sleep location statistics), and some personal data will be derived (such as sleep efficiency and sleep quality).
Depending on what personal data you choose to provide, the data processed within the app may, alone or together with other data, indicate information about your health. Personal data, including health data, may also be collected from other sources. You have control over what data are stored and accessed between the different apps and you can modify these settings at any time.
Additionally, if you create or log into your account through a social media service account, we will have access to certain information from that account, such as your name and other account information, in accordance with the authorization procedures set by that social media service.
Please note that this notice does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with, in or through the app, unless indicated otherwise. We will not be responsible or liable for: (i) the availability or accuracy of such third party apps or sites (ii) the content, products or services on or availability of such third party apps or sites; or (iii) your use of any such third party apps or sites.
We are delighted that you have chosen our app to get better insights into how you sleep and thereby hopefully improve your sleep quality. To manage our relationship and provide the app and thereto related services in a satisfactory and error free manner, we need to process your personal data. Please find more detailed information on how we process your data when we manage our relationship, below.
|
Why we process this data |
Description |
The personal data we process |
Where we got it from |
Legal basis for doing so |
How long will we keep your data? |
|
Create and manage your user account |
If you create a user account, we will process the data you have provided in order to create, maintain and manage your account. |
Name, email address, password. |
You. |
Our agreement with you (GDPR art 6.1(b)). If you do not provide the data, you will not be able to create an account. |
One (1) year after your last activity. |
|
Manage payments and returns |
Payments and returns are handled by iTunes and Google Play. If you have registered your email address in the app, we will receive information on your payments and returns.This data will also be kept for bookkeeping purposes. |
Active subscription and returns. |
iTunes or Google Play. |
Our agreement with you (GDPR art 6.1(b)). |
One (1) plus seven (7) years. |
|
Provide customer support |
If you have any questions or problems with the app, you can contact our customer support team who will help you with any questions or problems you may have. |
Primarily, we will only process technical data (e.g. IP addresses, timestamps, log files, device type and operating system).Only in limited situations, additional information (including health data) may be required to resolve the issue. |
You/the app. |
Technical data is processed based on our agreement with you (GDPR, art 6.1(b)). In most cases, we need to process this data to be able to help you with your request.Health data is processed based on your consent (GDPR, art 6.1(a) and art 9.2(a)). |
We will delete or anonymise the data as soon as the support ticket is resolved. |
|
Marketing and communication |
To send you notifications and respond to you when you contact us. If you have agreed to receiving e-mails from us, we may send you service and marketing related notices. If you want, you can unsubscribe to all our e-mails at any point. The information about how you unsubscribe is always presented in the email you’ve received. |
Email address. |
You. |
Legitimate interest assessment (GDPR, art 6.1(f)).We assess that our legitimate interest to communicate with you outweighs the potential (but unlikely) impact this may have on your rights and freedoms. For more information on this particular balancing test, please contact us. |
Until you opt-out from communication via email, or one (1) year after our relationship has ended. |
|
Improve and personalize the services and to develop new ones |
We may use your data to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services. |
Technical data (e.g. IP addresses, timestamps, log files, device type and operating system). For this purpose we may also process your location data. |
You/the app. |
We will only do this if we find that this use is compatible with the purpose for which the data was originally collected. If so, we will rely on the original legal basis. |
Three (3) years from collection. |
|
Respond to legal requests/requirements |
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the app or the physical safety of any person. |
All data in the app. |
You/the app. |
Use for this purpose is, by definition, compatible with the original purpose and no separate legal basis is required.Furthermore, any health data covered by the request which is necessary to process in order to establish, exercise or defend legal claims or whenever a court is acting in its judicial capacity will also be processed (GDPR; art 9.2(f)). |
As long as we have to to establish, exercise or defend the claim in question. |
|
|
We offer various financial incentives. For example, we may provide incentives to customers who participate in a survey or provide testimonials. You can opt into a financial incentive by following the sign-up or participation instructions provided. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you. |
Personal information from you, such as identifiers (like your name and email address) and information about your experiences using our Services |
You. |
Use for this purpose is, by definition, compatible with the original purpose and no separate legal basis is required. |
As long as we regard as necessary. |
We use different technologies to collect information, including cookies and web beacons. to collect information about your use of the app and other websites and online services, including your IP address, device identifiers, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the app and other websites and online services, and better understand your online activity. For more information about interest-based ads, including to use ad industry tools to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices (if you are in the EU, please visit www.youronlinechoices.eu/). Your mobile device should also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
To protect your health data (i.e. sleep data) from loss you can choose to use our backup service by creating an account in the app. Then, we ensure that your health data are saved even if something would happen to the app on your device. We will store all the data available in the app on our secure servers, hosted by Amazon Web Services, Inc. (Learn more about Amazon Web Services under “How we share your personal data and who we share it with”.)
We will keep your health data in the backup until you withdraw your consent by deleting your account in the app. If you withdraw your consent we will immediately delete or anonymise your health data. If you unsubscribe to the app, we will keep your data for up to one (1) year, in case you change your mind within this period of time and want to start a new subscription. We will delete or anonymise your data one (1) year after you unsubscribe.
As you may understand, this means that your data may be processed both within the United States, as well as in other locations outside the United States. In addition, your data will generally be encrypted during transit and rest, and the data stored by us and Amazon Web Services will be pseudonymised.
We appreciate if you would like to help us improve the app by contributing with your health data. If we know how you are using the app, know about your sleep patterns and surrounding circumstances, etc. we can improve the app – this will make our, and ultimately your, insights better and more to the point and this will also improve your user experience.
Whenever you use our app, we collect usage information, such as the sessions you use, videos you view or music you listen to, what screens or features you access, and other similar types of usage information. For this purpose, we will only use pseudonymised data, meaning that your health data will be awarded a hashed ID.
The pseudonymised data will be stored in our product development environment (separate from the backup environment) and their service provider Amazon Web Services. (Learn more Amazon Web Services under “How we share your personal data and who we share it with”.)
We will keep your pseudonymised data until you withdraw your consent or up to one(1) years from collection, whichever is longer. If you withdraw your consent we will immediately delete your pseudonymised health data.
In some scenarios, we may use your data and personal information to detect, investigate and prevent fraudulent transactions and other illegal activities so as to protect the rights and property of us and others, including to enforce our agreements and policies. If you feel your transaction was declined in error, please contact us for assistance at contact.meplus@enerjoy.life.
With your consent, we may use your personal information to facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
We also use other service providers that may process your data on our behalf. When we communicate with you, for example via e-mail, your e-mail address may be transferred to Microsoft, who provide e-mail and communication services.
You can exercise many of your rights directly in the app or on your device. You are always welcome to contact us directly and we will help you with your request.
You have the right to know if we process personal data about you. If we do, you also have the right to receive information about the personal data we process and why we do it. You also have the right to receive a copy of all personal data we have about you.
If you are interested in specific information, please indicate it in your request. For example, you can specify if you are interested in a certain type of information (e.g. what contact and identification information we have about you) or if you want information from a certain time period.
If the data we hold about you are incorrect, you have the right to have it corrected. You also have the right to supplement incomplete information with additional information that may be needed for the information to be correct.
Once we have corrected your data, or it has been supplemented, we will inform those we have shared your data with about the update, provided that it is not impossible or too cumbersome. If you ask us, we will also tell you who we have shared your data with.
If you request to have data corrected, you also have the right to request that we limit our processing during the time we investigate the matter.
Right to have data deleted
In some cases, you have the right to have your data deleted. You have the right to have your data deleted if:
1. The data is no longer needed for the purposes for which we collected it,
2. You withdraw your consent, if applicable,
3. The data is used for direct marketing and you unsubscribe from it,
4. You oppose use that is based on our legitimate interest and we cannot show compelling grounds that outweigh your interests,
5. The personal data has been used illegally, or
6. Deletion is required to fulfill a legal obligation.
You can delete specific data points, for example sleep sessions or comments posted by yourself, directly in the app. If you are not using the online backup services you can simply just uninstall the app in order to remove any stored data. If you choose to delete your account (or if you withdraw your consent), please note that while most of your information will be deleted within a few days, it may take up to thirty (30) days to delete all of your information, like the data stored in our backup systems. We may preserve data for legal reasons or to prevent harm.
If we delete data following your request, we will also inform those we have shared your data with, provided that it is not impossible or too cumbersome. If you ask us, we will also tell you who we have shared your data with.
You have the right to object to processing that is based on our legitimate interest. If you object to the use, we will, based on your particular situation, evaluate if our interests in using the data outweigh your interests in the data not being used for that purpose. If we are unable to provide compelling legitimate grounds that outweigh yours, we will stop using the data you object to – provided we do not have to use the data to establish, exercise or defend legal claims. If you object to the use, you also have the right to request that we restrict our use during the time we investigate the matter.
You always have the right to object to, and thus unsubscribe from, direct marketing.
You have the right to withdraw your consent for a specific processing at any time. You can withdraw your consent in the privacy settings by contacting us at contact.meplus@enerjoy.life.
Your withdrawal will not affect processing that has already been carried out.
Right to turn off mobile push notifications/alerts
With your consent, we send promotional and other push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Restriction means that the data is marked so that it may only be used for certain limited purposes. The right to restriction applies:
1. When you believe the data are incorrect and you have requested correction. If so, you can also request that we limit our use while we investigate if the data are correct or not.
2. If the use is illegal but you do not want the data to be deleted.
3. When we no longer need the data for the purposes for which we collected it, but you need it to be able to establish, assert or defend legal claims.
4. If you object to the use. If so, you can request that we limit our use while we investigate if our interest in processing your data outweighs your interests.
Even if you have requested that we restrict our use of your data, we may also use the information for reasons relating to an important public interest.
We appreciate the importance of taking additional measures to protect children’s privacy.
We do not knowingly collect personal data from children under the age of 18. If you have reason to believe that a child under the age of 18 uses the app please contact us and we will endeavor to delete that information from our databases.
We reserve the right to change this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
Supplementary Clause
This Privacy Policy also applies to users in California under the California Consumer Privacy Act of 2018 ("CCPA"). We guarantee that the information we collect will never be sold.
In addition, your rights under the CCPA:
1) To know what information we collect.
You can request the details of the information we have collected from you by contacting us at contact.meplus@enerjoy.life.
2) To delete the information we collect.
You can request the deletion of your data by contacting us at contact.meplus@enerjoy.life . After that, you can use our application as usual, without any discrimination.
E-mail address: contact.meplus@enerjoy.life
The original version of this Privacy Notice is written in English. To the extent a translated version of the Privacy Notice is in conflict with the English version, the English version shall prevail.