Hello, we are Ipnos Software Inc. (“Ipnos” or “We”)!
The respect of your privacy is important to you, and we understand that. It’s essential for us that we trust each other, and that our practices are respectful of your privacy. In this spirit, we redacted this policy to help you comprehend how we collect, use, disclose or otherwise process your personal data. We also included information about your rights and other important stuff, like how we secure your personal data. We hope you’ll find the answers to your questions, but otherwise, feel free to just email our privacy officer at [email protected].
As a participant of the Digital Advertising Alliance (DAA), we adhere to DAA’s interest-based advertising principles by providing you enhanced notice, transparency and control of our digital marketing practices as stated at http://www.aboutads.info/principles.
When does this policy applies?
This policy also applies to communications you may have with us via email or social media.
Our Apps and websites can be accessed and used from everywhere in the world. The laws that apply to the protection of your personal data may vary depending on where you are located. Ipnos strives to comply with all applicable laws – if you have questions based on your situation, feel free to contact our privacy officer at [email protected]
What do we mean by ‘personal data’?
We want to protect your privacy as much as possible, so we consider that personal data means any information which allows us to identify you directly or indirectly, including cookies and other electronic data.
What do we mean by ‘cookies’?
A cookie is an information that a website puts on your computer’s hard disk so that the website can remember something about you at a later time. If you are looking for more information on cookies, you can refer to websites such as http://www.cookiecentral.com/.
There are different types of cookies. Ipnos uses both first party and third party cookies:
- First Party Cookies – First party cookies are those that are issued by us, and they can only be set or retrieved by us. They are used for purposes specific to us, such as to personalize the website.
- Third Party Cookies – Third party cookies are placed on our websites or Apps by other entities, such as to create new functionalities or conduct advertising.
Cookies can also be classified based on their roles. These are the types of cookies we use on our websites and Apps:
- Strictly Necessary – These cookies are essential to enable you to navigate our website and use its key features.
- Performance Cookies – Performance cookies collect information about how users use our websites or Apps, such as the pages they go most often, and whether they get error messages from our webpages. These cookies do not collect dat allowing us to track you individually; they provide us with aggregated information about traffic and performance.
- Functionality Cookies – These cookies are used for enhanced functionalities that are useful to you, such as social media sharing, but which are not necessary for our websites or Apps to perform its essential functions.
What personal data do we process about you, and why?
We process your personal data to deliver the services you requested, based on your consent, our contract with you, or our legitimate interests.
To respond to your request ticket on our website
If you submit a request ticket through our help center, we will collect your email address, the request type, the product concerned by the ticket, the subject of the request, as well as the description of the issue and any supporting attachments you may add.
To process your online job application
On our websites, you can apply to some amazing job opportunities at Ipnos! If you decide to apply, we will process your email, name, phone number, address, how your learned about us, your resume and any information you make available to us. Keep in mind that we may also consider publicly available information about you, such as your LinkedIn profile.
To sign you up to our blog and newsletters
If you want to sign up to our blog and learn about better sleeping habits, meditation practices, the science of sounds and the likes, you can do so on our websites. We will only need your email for this!
We comply with legislations requiring that we obtain your explicit consent before sending marketing electronic communications. Click here for more information on how you can unsubscribe to these communications.
To respond to your emails or to your messages on social media
If you communicate with us by email, we will respond using your e-mail address and the information you make available to us. If you contact us on social media, we will be able to see your name, picture and whichever information you make available to us, or is publicly available on your profile.
To allow you to reply to our blog posts
If you decide to reply or comment on one of our blog posts, we will collect your name, e-mail, comment and additional information you may decide to make available to us. We will not publish your e-mail address as part of your reply or comment to the blog.
To allow you to participate in our contests, events and other activities
From time to time, we may organize contests, events or other activities. In these circumstances, we will collect the personal data required to subscribe you or allow you to participate, if you wish to do so. When these contests occur on social media, we may have access to your profile information which you make available to us, or which are publicly available.
To create your account and to personalize the content offered to you via our Apps and websites;
You can create an account on some of our Apps and websites using your Facebook, Google or Twitter account. You can also register using the form available on the Apps or websites, in which case, we will ask for your name and email addressYou will also be required to create a password and accept our terms and conditions to create an account.
We do not collect precise location data about you, although we are able to see in which country you are located, such as based on your IP address. This allows us to personalize your experience and ensure that you are receiving relevant content.
To conduct interest-based advertising
We collect mobile identifiers such as Android’s Advertising ID (AAID/IFA) or Apple’s Identifier for Advertising and cookies to conduct interest-based advertising, also referred to as targeted advertising or behavioral advertising. Click here to learn more about interest-based advertising.
We do not conduct any interest-based advertising on the paid versions of our Apps.
We do not conduct any interest-based advertising on the app titled Relax Melodies Seasons. The only advertising which takes place on this app is done by ourselves, for ourselves!
To comply with legal and regulatory stuff
We may be required to process your personal data to comply with applicable laws and court orders. In this case, we make sure that our legal counsels assist us in ensuring that we only process your personal data as required by the law, or court orders.
To ensure the security and proper maintenance of our websites and Apps
We may have to process some of your personal data to help ensure that our websites and Apps can be used safely, and that your data is protected.
To assess the performance of our websites and Apps
We may collect electronic data that is not always considered personal data, such as the type of device or Internet browser that you are using through cookies.
- To deliver our services and allow you to enjoy our Apps
We collect personal data as required to deliver the services you requested, including by sharing information with Apple’s HealthKit based on your instructions and consent. Click here for more information about Apple Healthkit.
We do not retain or use the email addresses or other personal information you provide when inviting your contacts to join or download our Apps, unless your contacts become users of our Apps.
Do you share my personal data with third-parties
We also share your personal data with trusted partners which we may use to deliver the services or other purposes as explained below.
- Service providers. We use service providers to host our website, process your payments, and offer some functionalities. As an example, we use Google Firebase as a mobile and web application platform (back-end-as-a-service).
Our Apps contain tools from third party service providers, such as Apple or Google, enable these third parties to separately collect and/or analyze non-personally identifiable information from the users’ devices in accordance with such third parties’ own privacy policies.
- Auditors and consultants. We may have to share your personal data with auditors and other third parties who work with us to help us comply with laws and improve our services. If we need to do this, we ensure that a non-confidentiality agreement is in place
- Advertising partners.
We do collect behavioural information about you when you are using the free versions of our Apps or some of our websites. This behavioural information is shared with third-party partners to conduct interest-based advertising. If you would like more information on how we use your personal data for interest-based advertising and how some of your information may be shared with third parties in this context, click here.
- Analytics and Performance Partners
We share your personal data with third parties to measure our performance and increase our conversion rates, such as Facebook Analytics and Clevertap. These third parties provide us with analytics for our websites and Apps, which can then be used to segment users based on demographic information, custom events and user or session activity as part of our interest-based advertising activities.
These partners do not use your personal data for their own benefits. They only provide us with services to conduct analytics, diagnosticate issues, and improve our marketing strategy. We only allow our employees to see such data on a need-to-know basis, and subject to a non-disclosure agreement.
We also use Google Analytics Demographics and Interest Reporting to better understand our websites’ performance. Google Analytics uses third party cookies to get information about how you arrived on our website, the search times which were leveraged, the time of you visit, etc. This data is then leveraged by Google to create traffic data, which is what Ipnos. We can’t see what you are doing by isolating you or another user.
If you want to opt-out from Google Analytics Demographics and Interest Reporting, you can do so by clicking here.
- Social Medias
Some of our pages, such as our blog posts, have an option allowing you to share the content on your social media. This occurs through a tool which can collect indirect data about you, like your IP address and information derived from your IP address (geographic location and information about your device like your preferred language). It may also collect the time and date that you visited the page for sharing.
If you connect to our Apps or websites through your social media, we receive the information which you accept to share with us to authenticate you.
Apple Health Kit
Apple HealthKit offers its users a central repository for health and fitness data on iPhone and Apple Watch. If you authorize the use of Apple HealthKit, our Apps will communicate with Apple Healthkit to access and share your data. Apple HealthKit is designed to manage and merge data from multiple sources – this means that with your permission, our data are merged with those of your other apps in HealthKit.
We only share your data with HealthKit based on your consent, such as the time spent meditation through meditation logs. Under no circumstances can we share the information collected via the HealthKit to any third party, except if such third party is already providing you health services with your prior consent.
We do not use the information collected via HealthKit for advertising purposes nor are we selling the data collected to any advertising platforms, data brokers or information resellers
We may be obliged to comply with requests to share your personal data with regulatory authorities or as a result of a court order. When we receive these requests, we consult our legal counsels to ensure that we only share your data when we are really required to do so. If we are allowed by law, we’ll let you know if we get a request that concerns you.
In the event of a merger, acquisition, or change of control, your personal data would be considered a business asset and would be transferred.
- The personal data shared is limited to what is reasonable required for third parties to perform their services or functions;
- Our agreements with them include reasonable terms and conditions to protect your personal data;
- These third parties provide sufficient guarantees that they will protect your personal data and comply with applicable laws.
Where do you store my personal data?
Your personal information is stored inside and outside of Canada, including in the United States. In this situation, regarding personal data of European Union residents, we may transfer Personal Data to a Third Party outside the European Union after entering into a data transfer agreement with the other party/parties, based on standard contractual clauses adopted by the European Commission, or after adopting Binding Corporate Rules where necessary.
How do you ensure the security of my personal data?
We strive to protect your personal data by implementing security features that are proportionate to the risks, such as unauthorized access or disclosure. Our Apps and websites use encryption, and access to your data is only granted on a need-to-know basis to individuals with a non disclosure agreement or similar confidentiality obligations.
How long do you hold my personal data for
We keep your personal data as long as required to fulfill the purpose for which it was collected, or in accordance with the law (whichever is longer), for evidence and accounting purposes, for a period not exceeding the statutory limitation periods applicable. If you are using our Apps, we keep your profile information as long as your subscription is active.
We use both session cookies and persistent cookies.
- Session cookies – Those are files set temporarily on your device and deleted once you close your browser.
- Persistent cookies – Those remain active on your device for some time, which may vary from a few days to two years after your visit on our website
What is interest-based advertising ?
Interest-based advertising is also referred to as targeted advertising or behavioral advertising.
Simply put, we collect personal information about you which we or our partners use to provide you with ads which are relevant to you.
Here’s an example. We collect data about your behavior on our freeApps – such as how long you spend meditating, and how often. It’s important to understand that this behavior is linked to an anonymous cookie ID, and not to directly identifying information such as your name, address or credit card number.
The behavior linked to the anonymous cookie ID can then be used for retargeting or advertising.. For instance, we could target all users who are meditating frequently with a specific promotion based on their usage. We can also use this behavior linked to the anonymous cookie ID as part of real-time bidding (RTB).
Real-time bidding is a type of automated buying of advertising placements.If a third party decides to buy the data associated with the anonymous cookie ID, it is then provided with data such as an encrypted email or mobile advertising identifiers which is used to serve you with the relevant ads – such as comfortable pillows for a better sleep!
If you want to opt-out of interest-based advertising, click here to jump to the right section of this policy. You can also visit the Digital Advertising Alliance of Canada for more information on the tools available to you to control your participation in interest-based advertising.
Do you conduct interest-based advertising, and how?
We conduct interest-based advertising on the free versions of our Apps. This allows us to deliver these services without cost to you. Otherwise, you can use the paid versions of our Apps – we will not use your data for interest-based advertising if you pay for our services. We also conduct interest-based advertising through some of our websites.
- We use third parties such ad exchanges to deliver interest-based advertising
Through our free mobile Apps, we conduct real-time bidding to automate the buying of advertising placements. In order to effectively sell our advertising placements, we use MoPub, which is an ad exchange. This means that MoPub is an intermediary which itself resells to other networks. These third parties have access to mobile advertising identifiers which are then used to serve the ads. We can use other parties than MoPub to deliver interest-based advertising.
We use Facebook for re-targeting
We may display interest-based ads to you when you are using Facebook through a tool offered by Facebook called the Custom Audience Tool. This tool allows us to personalize our ads based on your behavior. We do not share any of your personal information, including your behavior, with Facebook. The tool lets us convert your email address to a unique number that Facebook uses to match to unique numbers it generates from email addresses of its users as part of real-time bidding.
- We use Google Analytics for retargeting
Google Analytics offers a function about remarketing audiences. It allows us to create segments based on the analytics that we have obtained, and then use it as part of remarketing campaigns on our Google Ads account. Google Ads uses a different cookie than Google Analytic.
How can I opt-out of interest-based advertising?
You can opt-out of interest-based advertising by clicking on the link below the get the instructions for your type of mobile devices:
If you want to opt-out from Facebook Custom Audience Tool and Conversion Tracking Pixels, you can do so by clicking here. If you opt out, we will remove you from all our custom audiences.
Rights, Preferences and Opt-Outs
How can I manage my cookie preferences?
Browsers and devices have tools that allow you to control cookies; you can block them, ensure that you are notified when you are subject to cookies and control the cookies already stored on your device. However, if you block all of the cookies, you may not be able to access all the functionalities on our websites.
Depending on the browser that you are using, different instructions are applicable. Click on your browser to have more information:
If you want to opt-out from Google Analytics Demographics and Interest Reporting, you can do so by clicking here.
For more information on how to opt-out of interest-based advertising, click here.
How can I delete my account(s) with Ipnos?
You can cancel your subscription anytime on our paid Apps by following the instructions on our Help Center, here.
How can I withdraw my consent for electronic communications?
All our marketing communications include a link to unsubscribe. Alternatively, you can contact us directly at [email protected]
What are my rights regarding my personal data?
You have the right to exercise your rights on your personal data, and we will try our best to help you. Your rights vary depending on the laws that apply to your situation, and the specific circumstances of the request. Some of the rights that may apply to you include the following rights:
- Right to access your personal data;
- Right to request additional information about how we process your personal data;
- Right to rectify your personal data if incorrect, incomplete, invalid or ambiguous;
- Right to object to the processing of your data in certain circumstances;
- Right to request request the erasure of your personal data;
- Right to data portability of your personal data (Click here to see how we can help you transfer your subscription from iOS phone or table to an Android device or the opposite).
- For French individuals, Right to define guidelines regarding the fate of your personal data in the event of death.
If you want to exercise one of these rights and the situation allows for such exercise, we will generally help you without additional charges. If you request a transcription, reproduction or transmission of your personal information, we may have to charge a reasonable fee to process your request, subject to applicable laws. In this case, we will contact you about these charges before addressing your request.
For security reasons and to avoid any fraudulent request, we may be required to provide proof of identity with the request. After the request has been processed, this receipt will be destroyed.
If you request is denied, we will notify you in writing, provide you with detailed motives and information on how to contest our decision. We will keep the relevant personal data until you have exhausted your options. In any event, we will respond to your request within thirty (30) days, unless agreed otherwise.
To exercise your right, you can simply reach out to us at [email protected]
How does this policy affect individuals in California?
Legislation in California provides that California residents be entitled to know how we respond to “Do Not Track” browser settings. If activated by you, this setting sends a special signal to the websites you encounter while web browsing indicating that you do not wish to be tracked. We do not respond to Do Not Track signals at this time. If we do so in the future, we will describe how so in this policy.
Last update: March 28th 2020