Sleepbot
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Privacy Policy

Last updated: August 5, 2022

Welcome to Sleepbot, an SMS bot designed to assist you to sleep better by using evidenced-based clinical personal intervention (the “Service”). The Service is owned and operated by Docbotic Inc. (the “Company”, “we”, “us” and “our”). This Privacy Policy (the “Policy”) explains the privacy practices of our Service. It also describes the rights and options available to you with respect to your information. This Privacy Policy is incorporated by reference into the Service’s Terms of Use and constitutes an integral part thereof.

PERSONAL DATA WE COLLECT

Registration. We collect your name and telephone number and email when you first access our Service. You may start using our Service after you send us an SMS via Messages and accept our Terms of Use and this Privacy Policy. Once approved, you are registered to the Service. We then have access to your name and phone number, which we obtain and save in order to provide the Service. You may also provide us with your preferred name or nickname for future communications. We refer to this data as “Registration Information”.

Financial. We are using Stripe.com to process payments. Stripe’s Privacy Policy that refers to end users, as may be updated from time to time, is hereby incorporated herein by reference. We refer to this entire data as “Financial Information”.

Support. When you contact us for customer support requests, we will collect your contact details and the information included in your request and in any follow-up interactions between you and our team. We refer to this entire data as “Support Information”.

Content. We collect the content you provide us when you use Sleep Bot. We collect the content you upload when using Sleep Bot and your answers to its questions, which may include personal data and in certain jurisdictions may include data that is considered personal medical information. This information is provided by you and collected for us to personalize the Service and provide you with our recommendations. We refer to this entire data as “Content Information”.

You do not have a legal duty to provide us with any of the above information. However, note that you will not be able to sign up to and use the Service, or contact us for support, without providing the above information, and we will not be able to provide you with the Service without collecting such information.

Analytics. We collect information relating to your use of the Service and your interaction with our email and/or text messages. When you are using the Service, we will record and collect certain information in relation with your use of the Service and your interaction with our text and email messages, including your IP address (and the general location corresponding to the address). We refer to this entire information as “Analytics Information”.

HOW WE USE YOUR PERSONAL DATA

We use the information provided by you, including your personal information, in order to operate the Service and provide its features and functionality. We also use the information provided by you to prevent fraudulent use in the Service.

We use your Registration Information to verify your identity and enable you to access the Service and to operate the Service and provide you with its features and functionality. We also use it to facilitate our internal managerial, archival, administrative and audit activities. Providing us with your Registration Information to help us prevent fraud and unlawful use of the Service.

We use your Registration and Support Information to provide you with customer support and handle your requests, questions or inquiries effectively.

We use Financial Information to process your payments and fees for the use of the Service.

We use your Content Information to enable you to use the Service features and functionality. We also use the Content Information to analyze your answers and determine personalization of our evidenced-based recommendations.

We use Content and Analytics Information to:

  1. train, develop and enhance the Service. We also use it for business administration and marketing purposes as well as for understanding how users interact with the Service so that we can further train, improve, develop and enhance it.
  2. adjust the Service and our communications to users’ preferences.
  3. understand the market in which we operate in;
  4. for managerial reporting and business planning; and for marketing purposes such as publishing study reports to investors and other third parties.

When we use your Content and Analytics Information to train and improve the Service we will do so only after removing all of your personal information that directly identifies you.

When we process Content and Analytics Information for the purpose of marketing, we will use only aggregated de-identified information and we will not be able to directly identify the person who uses the Service.

WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS

WE DO NOT SELL YOUR PERSONAL INFORMATION TO THIRD PARTIES.

WE WILL NOT SHARE YOUR INFORMATION WITH ANY THIRD PARTIES, EXCEPT IN THE EVENTS LISTED BELOW OR WHEN YOU PROVIDE US YOUR EXPLICIT AND INFORMED CONSENT:

  1. We may share your information with service providers that we use to operate the Service and our business, including consultants and third party software providers.
  2. We may process your information by using services rendered to us by third party service providers in which we use to run the internal operations of our Service and our business. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own commercial or promotional purposes.
  3. We will share aggregated de-identified information with investors and other third parties for marketing purposes.
  4. We will share your information with investors and other third parties by publishing reports contain aggregated de-identified statistics of users’ use of the Service. Such reports will not directly identify you.
  5. We will share your information if we are legally required to do so and with any relevant authority if we are obligated to so by law.
  6. We will share your information if necessary to defend our Company from any legal claims.
  7. We may share your information with the relevant authorities and with third parties (such as legal counsels and advisors), if necessary to defend our Company from legal claims or if you have breached the Service’s Terms of Use, this Policy or any other agreement you have with us, for the purpose of handling of the violation or breach.
  8. We will share your information if the operation of the Service is organized within a different framework or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this Policy, with reasonable necessary changes taken into consideration.
  9. We will share your information in case of an emergency concerning you.
  10. If we need to act immediately to protect the personal safety and health of our customers or the public.

WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS

We may store and process your personal information outside your territory.

The Service, by its nature as an online Service, may store and process information and content in various locations throughout the globe, including through cloud services. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then by subscribing to the service and approving this policy, you hereby provide your express and unambiguous consent to such cross-border transfer. If you are an EU resident and we transfer your personal information to a jurisdiction out of the EU, we will do so by using adequate safeguards determined by the GDPR.

SECURITY AND DATA RETENTION

We retain your personal information for:

  1. as long as we need it to operate the Service and interact with users, and thereafter as needed for record-keeping matters; and

    the duration needed to support our ordinary business activities operating the Service and interacting with users.

  2. Thereafter, we will continue to retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our Terms of Use, this Policy and other agreements we have with our users.

We implement security measures to secure your Information and to reduce the risks of damage, loss of information and unauthorized access or use of your personal information. These measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.

SECURITY AND DATA RETENTION

The Company is the data controller for the purposes of the personal data we collect via the Service, in relation to the Service and for the performance of the Service.

The Company is incorporated in the State of Missouri (United States).

Our registered address is:

Adaptive LLC Jenna Xu

117 S Lexington St Harrisonville,

Missouri 64701

hello@adaptivedesign.studio

United States of America

LEGAL BASIS FOR PROCESSING UNDER THE GDPR

The legal basis for collecting and processing Registration, Financial, Content, and Support and Analytics Information is our Terms of Use agreement with you.

The legal basis for collecting and processing Financial Information and Content Information for the purpose of processing payments and fees for the use of the Service is our legal interests in receiving payments for our services.

The legal basis for collecting and processing Analytics Information and Content Information for the purpose of training and improving the Service is our legal interests in developing, improving and enhancing the Service, its features and functionality.

The legal basis for collecting and processing Analytics Information and Content Information for the purpose of publishing experimental reports is our legitimate interests in developing and promoting our business.

The legal basis for processing your information for the purpose of handling instances of abusive use of the Service is our legitimate interests in defending and enforcing against violations and breaches of our Terms of Use as well as other breaches that are harmful to the Service or our our business.

The legal basis for processing your information where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us.

The legal basis for processing your information in the event of a change in our corporate structure is our legitimate interests in our business continuity.

You have the right to access, update or delete your personal information, obtain a copy of your personal information, withdraw your consent and object or restrict certain data processing activities.

If you are an individual in the EU you have the following rights under the GDPR, subject to the limitations that the GDPR attaches to these rights:

  1. Right to Access your personal information that we process and receive a copy of it.
  2. Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.
  3. Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal information be transmitted directly from us to the service provider you designate.
  4. Right to Object, based on your particular situation, to using your personal information on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your personal information for direct marketing purposes.
  5. Right to Restrict the processing of your personal information (except for storing it) if you contest its accuracy, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal information and requests instead to restrict its use; if we no longer need the personal information for the purposes outlined in this Policy, but you require it to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
  6. Right to be Forgotten. Under certain circumstances, such as when the personal information is no longer necessary for the purposes for which they were processed, you have the right to ask us to erase your personal information. However, we may still process your personal information if it is necessary to comply with a legal obligation which we are subject to under laws in the EU Member State, or for the establishment, exercise or defense of legal claims.

If the legal basis for processing your personal information is your consent, you may Withdraw Your Consent at any time. If you do that, we will still process certain information on a legal basis other than the personal information in relation to which you withdraw your consent, as described in the Policy. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.If you wish to exercise any of the abovementioned rights, contact us at support@docbotic.care. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

You have a right to submit a complaint to the relevant supervisory data protection authority.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of our residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

MINORS

IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE SERVICE.

You must be at least 18 years of age to use the Service. The Service is not intended for minors under the age of 18. We do not knowingly or intentionally collect information about minors under the age of 18.

The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit personally identifiable information from children under 13 if you are a child under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn we have collected personal information from a child under 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at support@docbotic.care.

CHANGES TO THIS PRIVACY POLICY

If we change this Policy, we will provide you with notice of such change.

From time to time, we may change this Policy, in which case we will inform you of the updated Policy through the Service’s interface or via the email address you provided us. The latest version of the Policy will always be accessible through the Service.

CONTACT US

If you have any inquiries, complaints, requests or suggestions, you may contact us at support@docbotic.care. We will do our best to resolve your issue in a timely manner.

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