Privacy Policy

Introduction

Full Spectrum Services LLP operates the website sleepalora.com with the brand name Sleep Alora. We, at Sleep Alora (accessible from sleepalora.com and its related applications), prioritise the privacy of our visitors. This Privacy Policy explains how Full Spectrum Services LLP (“Sleep Alora”, “we” or “us”) collects, uses, and discloses information about you when you access or use our websites, mobile application, and other online products and services (collectively, the “Services”), and when you contact our customer service team, engage with us on social media, or otherwise interact with us. Sleep Alora is based in the India and processes information in India. This privacy policy is in accordance with applicable law in the jurisdictions where we operate as well. We may also provide additional data privacy notices specific to certain jurisdictions. The Privacy policy statement also contains necessary disclosures as per the California Consumer Privacy Act of 2018 (CCPA) and the European Union’s GDPR, which is enunciated in this document.

LEGAL COMPLIANCE:

In order to comply with multiple jurisdictional legal requirements, we at Sleep Alora shall stipulate your statutory rights and obligations through overlapping documentation through our “Cookies Policy” and “Privacy Policy” pages. We shall comply with our obligations in a clear manner as stipulated under the purview of all legal requirements through our legal documentation and disclosures. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the bottom 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.

Consent

By using our website, you hereby consent to our Privacy Policy and agree to our Terms of Use.

Information we collect

- The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
- The information you may provide includes your name, email, password, goals, previous wellness/meditation experience, street address, payment method information, feedback and survey responses, and other information about you included within your messages to us.
- Some users also provide health-related information in connection with providing feedback or other messages to us, and we process that information consistent with the purpose for which it was provided.
- If you contact us directly, we receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you send us, and any other information you may choose to provide.

When you use our Services, we collect the following information about you:
- Usage Information: Whenever you use our Services, 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.
- Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product description, price, subscription or free trial expiration date, and time and date of the transaction.
- Log Information: We collect standard log files when you use our Services, which include the type of web browser you use, app version, access times and dates, pages viewed, your IP address, and the page you visited before navigating to our websites.
- Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type, carrier and region).
- Information we Generate: We generate some information about you based on other information we have collected. For example, like most platforms, we use your IP address to derive the approximate location of your device. We also use your first name to make an educated guess about your gender and use information about your activity to help determine the likelihood of you continuing to use our Services in the future (which we hope will be the case!).
- Information Collected by Cookies and Similar Tracking Technologies: We use different technologies to collect information, including cookies and web beacons.
Information We Collect from Other Sources:
-We also obtain information about you from other sources, including transaction information from third-party app stores you use to install our app or purchase a subscription and name and contact information from third-party calendar services. 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.

Usage of information

We use the information we collect in various ways, including:
Provide, maintain and improve our Services, and develop new products and services
Improve, personalize, and expand our products and services
Understand and analyze how you use our products and services
Develop new products, services, features, and functionality
Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
Process transactions and fulfil orders; send you transactional or relationship messages, such as receipts, account notifications, customer service responses, and other administrative messages
Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Sleep Alora and others. If you feel your transaction was declined in error, please contact us for assistance at contact@sleepalora.com
Comply with the law, such as by processing transactional records for tax filings

Sharing of information

We may share information about you as follows and as otherwise described in this Privacy Policy:
- With companies and contractors that perform services for us, including email service providers, payment processors, fraud prevention vendors and other service providers only at the extent allowed by law
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements
- If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Sleep Alora or others
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, at the extent permitted by law
- Between and among Sleep Alora and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership
- With your consent or at your direction. For instance, you may choose to share actions you take on our Services with third-party social media services via the integrated tools we provide via our Services
- We also share aggregated or other information not subject to obligations under the data protection laws of your jurisdiction with third parties. For example, we sometimes share aggregate information with research organizations to help facilitate their research, only to the extent permitted by law.

Advertising and Analytics Services Provided by Others

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services 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 Sleep Alora 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 our Services and other websites and online services, and better understand your online activity.

Advertising Partners’ Privacy Policies

-You can visit the web pages and proceed to find the Privacy Policy for each of the advertising partners of Sleep Alora.
-Third-party ad servers or ad networks uses technologies like Cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on SleepAlora, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.
-Note that Sleep Alora has no access to or control over these cookies that are used by third-party advertisers, but we at SleepAlora shall always strive to collaborate with Partners that have transparent and appropriate Privacy practices.

Third-Party Privacy Policies

Sleep Alora's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found on the browsers' respective websites.

Your Choices

-Account Information: You may update certain account information you provide to us (such as your password, name and email address) by logging into your account or contacting us through our Help Center at contact@sleepalora.com. If you wish to disable your account, please contact us at contact@sleepalora.com, but note that we retain certain information when required or permitted by law. We also retain cached or archived copies of information about you for a certain period of time.
-Promotional Communications: You may opt out of receiving promotional emails from Sleep Alora by following the instructions in those emails or by logging into your account. If you opt-out, we may still send you non-promotional emails, such as those about your account or our appropriate ongoing business relations.
-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.

Information for Individuals in Switzerland, UK and the EEA:

The sections below apply to you if you use our Services while in Switzerland, the United Kingdom or the European Economic Area (collectively, “Europe”).
(i) Legal Basis for Processing:
When we process your personal data we will only do so in the following situations:
As necessary to perform our responsibilities under our contract with you (like processing payments and providing the products or services you have requested) (ii) When we have a legitimate interest in processing your personal data, including to communicate with you about changes to our Services, to help secure and improve our Services (including to prevent fraud) and to analyze use of our Services; (iii) As necessary to comply with our legal obligations; and When we have your consent to do so. (ii) Data Retention:
We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.
(iii) Data Subject Requests:
Subject to certain limits and conditions provided under law, you have the following rights: You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or made available in a portable form. You also have the right to object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim). When we ask for your consent, you may withdraw that consent at any time. You have the right to file a complaint regarding our data protection practices with a supervisory authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en/ If you are in Switzerland, please visit this FDPIC site for contact details: here. If you would like to exercise any of these rights and can’t do so directly via the Services or your device, you may contact us as indicated below.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights as per the GDPR. Every user is entitled to the following: The right to access: You have the right to request copies of your personal data. The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete. The right to erasure: You have the right to request that we erase your personal data, under certain conditions. The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions. The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions. The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. If you make a request, we have one (1) month to respond to you. If you would like to exercise any of these rights, please contact us. Note: We, at Sleep Alora, would like to explicitly mention that this Privacy Policy shall be considered as the ‘Privacy Notice’ as well. The Privacy Policy/Notice is as per Articles 12, 13 and 14 of the GDPR Statutory document.

CCPA Privacy Rights (Including Non-sale of Personal Information)

As a website that functions in multiple jurisdictions, we serve and also comply with the California Consumer Privacy Act of 2018 (CCPA) for natural persons residing in the State of California, and this statement explains the rights of California consumers under the CCPA.
Under the CCPA, among other rights, California consumers have the right to:
“Right to Disclosure” “Right to Access” “Right to be Forgotten” Access to the “Do Not Sell My Information” option “Right to Opt-Out of Marketing” “Right to Fair Treatment”- Request that a business that collects consumer’s personal data disclose the categories and the specific pieces of personal data that a business has collected about consumers.
- Request that a business delete any personal data about the consumer that a business has collected.
- Request that a business that sells consumers' personal data, not sell the consumer's personal data.
As per the above rights granted to you by California law, we duly comply with the requirements. As per the CCPA, ‘Personal Information’ is the information that “identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Though, personal information does not include publicly accessible, identity-less, or aggregate consumer information (which are all defined under the CCPA). Sleep Alora explicitly establishes the definition of Personal Information under the purview of CCPA as enunciated in subsection (o)(1) of 1798.140. Note: In line with universal data protection standards, we strictly do not negligently appropriate the information we collect (explicitly defined in this document, and on the Cookies Policy page as well). If in the future, we decide to process or transmit this information in the form of a sale service, we shall comply with the legal obligations and make necessary changes to this statement., and more importantly shall take your permission to conduct such activities.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. In line with the compliance as per CCPA, we shall update this Privacy Policy page every 12 months. For the purpose of compliance with the California Privacy Law, we have made the due disclosures in the above section, ‘Usage of Information’. In the last 12 months, we collected the following categories of personal information: identifiers (such as name, contact information and device identifiers), internet or other electronic network activity information (such as browsing behavior), approximate geolocation data, inferences (such as approximate location or product interests) and other personal information (such as payment method information, user credentials or health-related information).
For more details about the personal information we collect, including the categories of sources, please see the “Collection of Information” section above. We collect this information for the business and commercial purposes described in the “Use of Information” section above. We share this information with the categories of third parties described in the “Sharing of Information” section above.
Subject to certain limitations and exceptions, the CCPA provides California consumers with the right to request to know more details about the categories and specific pieces of personal information, to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
We do not “sell” the personal information we collect (and will not sell it in the future without providing a right to opt-out).
California consumers may make a rights request by emailing us at contact@sleepalora.com, We will verify your request by asking you to provide information that matches the information we have on file about you. Consumers can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.

Children’s Privacy Protection

A very integral facet of Sleep Alora’s priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. This policy is in accordance with the US Children’s Online Privacy Protection Act (“COPPA”) and outlines Sleep Alora’s practices in the United States regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online. Sleep Alora does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our products or services, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Contact Information

If you have a comment or question or rectification request or any request around your data, please email us at: contact@sleepalora.com
Privacy Policy Update: 24-07-2023