Privacy Policy

1. Introduction

This Privacy Policy describes how Sleepmaxx AI ("Sleepmaxx", "we", "our", or "us") collects, uses, discloses, and protects your personal information when you use our mobile application, web platform, and related services (collectively, the "Service") for sleep tracking, sleep coaching, and AI-driven sleep insights.

Sleepmaxx AI is designed to help you track sleep, analyze sleep patterns, detect events such as snoring or awakenings (with your consent), and provide personalized recommendations. By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Data Controller

XF Agencija US Inc. is the controller of your personal data in relation to the Service, unless otherwise stated. As the data controller, we determine the purposes and means of processing your personal information.

3. Information We Collect

Information You Provide Directly

We collect information you provide when you register for an account, set up a sleep profile, subscribe to communications, purchase a subscription, contact customer support, respond to surveys, participate in research (if you opt in), or otherwise interact with the Service. This information may include:

• Contact information: name, email address, mailing address, phone number
• Account credentials and profile details: username, password, preferences, sleep goals
• Payment and billing information: credit card details, billing address (processed through our payment processors)
• Sleep-related information: bedtime, wake time, sleep quality notes, sleep disorders you disclose
• Feedback and communications: survey responses, support requests, and any other information you choose to provide

Sensitive Health-Related Information

Information About Your Use of the Service

We collect information about how you use the Service, including:

• Classes, programs, or guided sessions you access
• Features you use and engagement metrics (session length, interactions with content, recommendations you accept)
• Subscription status and purchase history

Information from Devices, Sensors, and Third Parties

When you use Sleepmaxx, we may collect data from devices and sensors you choose to connect, including:

• Device data: device model, operating system version, device identifiers
• Sensor data from wearables or connected devices: heart rate, movement/accelerometer, respiration rate, sleep stages, snore audio snippets (if you opt in)
• Integration data from third-party services: Apple HealthKit, Google Fit, compatible wearable vendors (in accordance with your permissions on those platforms)
• Location data: approximate or precise location if you enable location-based features

Information Collected Automatically

When you visit our websites or use our apps, we automatically collect certain information using cookies, web beacons, and similar technologies, including:

• IP address, browser type and version, operating system, and device identifiers
• URLs that refer visitors to our websites and search terms used to reach our sites
• Pages visited, time and date of visits, duration, and other usage details
• Email engagement data (opens, clicks) when you receive our communications

Video, Image, and Audio Data

If you enable any optional features that use audio or video for sleep analysis (for example, snore detection or in-room monitoring), brief audio or video data may be processed to generate sleep metrics and insights. Such features are optional and will only be activated with your clear consent. Where possible, we process audio/video locally on your device; if audio/video is uploaded for cloud processing, we will inform you and seek consent.

4. How We Use Information

We use the information we collect for purposes including:

• Providing, operating, and maintaining the Service
• Processing account registration and authentication, managing subscriptions and payments
• Delivering sleep analytics, AI-driven insights, personalized recommendations, and progress summaries
• Improving and developing new features, products, and services (including training and improving our AI models)
• Communicating with you about your account, updates, security alerts, and promotional offers (with your permission where required)
• Detecting, preventing, and responding to security incidents, fraud, or other illegal activity
• Complying with legal obligations and enforcing our terms

AI Processing and Model Training

Sleepmaxx may use automated processing and machine learning/AI to analyze sleep data and generate personalized recommendations and sleep scores. We may use de-identified or aggregated data to train and improve our models. If personal data or identifiable audio/video is used for model training or research, we will either obtain explicit consent or de-identify the data so individuals cannot be reasonably identified.

5. Sharing Your Information

We may share your information with:

• Service providers and vendors: who perform services on our behalf (payment processors, hosting providers, analytics services, email providers, customer support vendors)
• Third-party integrations you enable: wearable manufacturers, HealthKit, Google Fit (data shared with those services is governed by their privacy policies)
• Corporate transactions: in connection with a sale, merger, or asset transfer — we will require the transferee to honor this Privacy Policy
• Legal requirements: law enforcement, regulators, or other third parties when required by law, to respond to legal process, or to protect rights, property, or safety
• With your consent: at your explicit direction

6. Cookies, Tracking, and Advertising

We and our partners use cookies and similar technologies to collect usage information and to improve and personalize your experience. Third-party advertising and analytics providers may place cookies through our site.

You can manage cookie preferences through your browser settings and, where available, our in-app controls. Most browsers allow you to block or delete cookies, though this may affect functionality of the Service.

7. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we collect. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and monitoring
• Employee training on data protection

However, no system is completely secure and we cannot guarantee absolute security. If we learn of a security breach affecting your personal information, we will take steps required by law, which may include notifying affected users and regulators.

8. Data Retention

We retain personal information for as long as necessary to provide the Service and for legitimate and lawful business purposes, to comply with our legal obligations, resolve disputes, and enforce our agreements.

Retention periods vary by data type and purpose:

• Account information: retained for the life of your account plus a reasonable period after account termination
• Sleep data: retained as long as your account is active, or until you request deletion
• Diagnostic logs and analytics: typically retained for shorter periods (e.g., 90 days to 2 years)
• Audio/video data: processed and typically deleted within 30 days unless you opt to retain it

9. Your Rights and Choices

Account Access and Control

• You can access, correct, or update certain account information by logging into your account or contacting us
• You may delete your account by following the account deletion process in the app or contacting support; some information may remain in backups or as required by law

Communications

• You may opt out of promotional emails by following the unsubscribe link in those emails
• You cannot opt out of transactional messages necessary for account operation

Device and Sensor Permissions

• You control device permissions (microphone, motion sensors, Bluetooth, location) via your device settings
• Disabling permissions may limit functionality

Data Portability, Deletion, and Other Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, restrict processing of, or obtain a copy of personal data we hold about you, or to object to certain processing. To exercise your rights, contact us using the information below.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You can request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the business purposes for collecting it, and the categories of third parties with whom we share it.
• Right to Delete: You can request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You can request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell your personal information. If we engage in "sharing" for cross-context behavioral advertising, you can opt out.
• Right to Limit Use of Sensitive Personal Information: You can limit our use of sensitive personal information to purposes necessary for providing the Service.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at support@sleepmaxx.ai or use the contact information below. We will verify your identity before fulfilling your request.

Authorized Agents: You may designate an authorized agent to make a request on your behalf. We may require verification of the agent's authorization.

11. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

Legal Bases for Processing

We process your personal data based on:

• Contract: Processing necessary to perform our contract with you (providing the Service)
• Consent: Where you have given explicit consent (e.g., for health data processing, marketing communications)
• Legitimate Interests: Processing for our legitimate interests that do not override your rights (e.g., improving our Service, fraud prevention)
• Legal Obligation: Processing required to comply with applicable laws

Your GDPR Rights

• Right of Access: Request access to your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: File a complaint with your local supervisory authority

To exercise these rights, contact us at support@sleepmaxx.ai.

12. Children's Privacy

We do not knowingly collect personal information from children under the age of 13 without parental consent. If you are under 13, you must obtain consent from a parent or guardian before providing us with any personal information.

If we learn we have collected personal information from a child under 13 without proper consent, we will take steps to delete that information promptly. If you believe we may have collected information from a child under 13, please contact us immediately.

13. International Data Transfers

Sleepmaxx may transfer and store personal information on systems located in the United States and other countries. If you are located outside the United States, please be aware that your information may be transferred to, stored, and processed in a country with different data protection laws.

When data is transferred across borders, we take steps to ensure an adequate level of protection, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Other legally approved transfer mechanisms
• Ensuring recipients provide adequate protection for personal data

14. Links to Third-Party Sites and Services

Our Service may include links to third-party websites or services. This Privacy Policy does not apply to those third parties. We encourage you to read the privacy policies of any third-party services you connect to or visit. We are not responsible for the privacy practices of third-party sites.

15. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time. If we make material changes, we will notify you by:

• Posting the updated policy in the app and on our website
• Updating the "Last Updated" date at the top of this page
• Sending you an email notification (for significant changes)

Your continued use of the Service after changes are posted constitutes your acceptance of the revised policy. We encourage you to review this Privacy Policy periodically.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Subscription Information

Sleepmaxx AI offers auto-renewable subscriptions as part of our Sleep Improvement Membership — guided support for better nights and brighter days.

Available Subscription Plans

Auto-Renewal Terms

Subscriptions automatically renew unless auto-renew is turned off at least 24 hours before the end of the current subscription period. Your account will be charged for renewal within 24 hours prior to the end of the current period at the subscription price.

Free Trial

If offered, any unused portion of a free trial period will be forfeited when you purchase a subscription. After the free trial expires, you will be automatically charged the subscription price unless you cancel at least 24 hours before the trial ends.

Managing Your Subscription

You can manage or cancel your subscription at any time:

• iOS: Go to Settings → [Your Name] → Subscriptions → Sleepmaxx AI
• Android: Go to Google Play Store → Menu → Subscriptions → Sleepmaxx AI

Cancellation will take effect at the end of the current billing period. No refunds are provided for partial subscription periods.

Related Policies

• Terms of Use
• Privacy Policy (this document)

Additional Information

• Marketing communications: You may opt out of marketing communications at any time as described above. Transactional and safety notices may still be sent.
• Text messaging: If you provide your phone number for text messages, you consent to receive SMS messages as described at the time of collection; message frequency and opt-out instructions will be provided.