Last updated July 16, 2024
Need to cancel your RISEsubscription? View the to cancel or request a refund.
Maintaining the privacy of your information is of paramount importance to us as it helps foster confidence, goodwill and stronger relationships with our users. This Global Privacy Policy (“Privacy Policy”) describes the privacy practices of ĢƵ, Inc. (“RISE,” “we,” “us” or “our”) when you use or otherwise interact with our website at / (the “Site”) and our mobile application RISE Sleep (the “App”). The App allows users to track their sleep, sleep debt, and energy levels, along with offering guided support and educational content on a wide array of relevant topics. The Site and the App are referred to collectively in this Privacy Policy as the “Service.” Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. In this Privacy Policy, we also provide a supplementary privacy notice for California residents and a supplementary privacy notice for data subjects in the EEA, Switzerland and the UK (collectively, “Europe”) and Brazil.
This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any personal information to RISE, please review this Privacy Policy carefully and contact us at [email protected] if you have any questions.
Here’s a description of the categories of information we may collect when you interact with our Service, and examples of how we use the specific types of information.
We use personal information to:
Provide our Service, including to:
Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of feature releases or providing content that we think may be of interest to you. You may opt out of our email, push or text-message marketing communications as described in the “” section below. Please note that we may periodically send you transactional emails even after you opt out of direct marketing.
Interest-based advertising. We may engage advertising partners, including third party advertising companies and social media companies, to display ads on the Service. These companies may use cookies and similar technologies to collect information about your interaction with the Service, our communications and other online services (as further described in the “” section below), and use that information to serve online ads that they think will interest you. This is called interest-based advertising. You can learn more about your choices for limiting interest-based advertising in the “” section below.
Research and development. We may use your information to analyze the effectiveness of our Service, to improve and add features to our Service, and to analyze the general behavior and characteristics of users of our Service.
Support and maintenance. We use third party analytics services to automatically log certain information about your mobile device and how you interact with the App. The information collected is used to troubleshoot and prevent errors, perform data analysis, and develop new features.
Compliance and protection. We may use personal information to:
We do not sell personal information. In the ordinary course of business, we may share personal information with:
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as payment processors, providers of subscription and billing services, analytics service providers, marketing service providers, database service providers, backup and disaster recovery service providers, email communication service providers, push notification, text message service providers).
Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties as we believe necessary to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce our Terms of Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, RISE or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Sleep Health Partners
ĢƵ may share your de-identified personal data with other sleep health partners to provide you with more information on relevant sleep topics.
Like many services, we use cookies and similar technologies to operate the Service and to remember things about you so that we can provide you with a better experience.
We and our partners may use cookies, SDKs, and other tracking technologies on the App or Site provided by the following third parties:
a. Amplitude, a web analysis service provided by Amplitude, Inc., used to evaluate user access and to maintain and improve the Service. Amplitude’s privacy policy can be found here: https://amplitude.com/privacy.
b. Adjust, an analysis service provided by Adjust GmbH, used to track user interactions with the App in real time and to analyze the performance of marketing campaigns. Adjust’s privacy policy can be found here: https://www.adjust.com/terms/privacy-policy/.
c. Google Firebase Crashlytics (provided by Google LLC), used to get crash reports and metrics and to derive analytics information regarding the use of the App, including by collecting identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS). Firebase Crashlytics retains crash stack traces, extracted minidump data, and associated identifiers (including Crashlytics Installation UUIDs) for 90 days. To learn more about how Google uses data when you use the App please read .
d. Sentry, a service provided by Sentry that collects App usage information related to system crashes and bugs, including information about the device, the version of the App that is installed, and other information that can help fix bugs. Sentry privacy policy can be found here: https://sentry.io/privacy/.
f. Segment, used to collect analytics information relating to the Service. Segments privacy policy can be found here: https://segment.com/legal/privacy/.
g. Google Analytics, a web analytics service provided by Google. These cookies help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
h. Health Connect by Android, a general purpose data storage and sharing platform that allows users to aggregate health and fitness data from various sources on their Android device and share it with third parties at their election. The use of information received from Health Connect will adhere to the Health Connect Permissions policy, including the Limited Use requirements, which can be
Update, correct, or delete. You can contact us to ask us to update or correct your information. You may also delete your account. Please note that we will need to verify that you have the authority to update, correct, or delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions contained in the communications we send you.
Opt out of push notifications. If you opt-in to receive push notifications within the App, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the App, or deleting the App.
Opt out of text communications. If you opt in to receive text message communications, we may send SMS messages to your mobile device from time to time. You may opt out of marketing-related text messages at any time by following the opt out or unsubscribe instructions contained in the communications we send you. Message and data rates may apply.
Online tracking opt out. There are a number of ways to limit online tracking, which we have summarized below:
Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit .
The Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.
This Privacy Policy does not apply to any third-party applications or software that integrate with the Service, or any other third-party products, services or businesses.
RISE has users located across the globe. We are headquartered in the United States with services providers that operate in other countries. We may transfer your personal information to the United States and other countries which may not have the same data protection laws as your home country or territory, but we will protect your personal information in accordance with this Privacy Policy, or as otherwise disclosed to you.
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the App, or third party websites.
The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Service from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App or Site. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the App. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment of the modified Privacy Policy.
If you have any questions about this Privacy Policy or complaint about our handling of your personal information, please contact us at [email protected] or sending a letter to the following mailing address:
ĢƵ
548 Market St. PMB 79836
San Francisco, CA 94104
United States
We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).
The CCPA grants California residents the following rights:
The CCPA limits these rights. For example, companies may not provide users in response to access requests certain sensitive information and other consumers’ personal information, and may exclude information that would compromise the confidentiality of trade secrets. The CCPA also places limits on when companies must comply with a deletion request.
You are entitled to exercise the rights described above free from discrimination.
Here is how you can submit requests:
We are providing this supplemental privacy notice to European data subjects, pursuant to European data protection laws (“GDPR”) and Brazilian data subjects, pursuant to Brazilian data protection laws (“LGPD”).
Controller and Representative. RISE is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR. You can find our contact information in the “How to Contact Us” section above.
VeraSafe has been appointed as ĢƵ, Inc’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to [email protected], only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
Personal Data We Collect From You and How We Use It. You can read about the personal data we collect from you in the “Personal Information We May Collect” section above, and how we use it in the “How We Use Personal Information” section above.
Justification for Data Processing. European and Brazilian data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to consumers the specific justifications for the company’s data processing activities. We generally rely on one of the following justifications to process personal data:
Provision of some of this data is necessary to establish an account on RISE.
Account data
Purpose: To create and maintain your account.
Justification for Processing Personal Data: Contractual Necessity
Account data
Purpose: To respond to your inquiries. To send you notifications, SMS messages, or emails of feature releases or provide content that we think may be of interest to you
Justification for Processing Personal Data: Contractual Necessity. Legitimate Interests: Providing you with the support that you request, and improving our App and related Services. Sending you information on our own products and Services that may be of interest to you.
Steps, sleep, and movement data
Purpose: To generate insights and analysis as to users sleep habits, sleep debt, and energy levels.
Justification for Processing Personal Data: Contractual Necessity.
Communications
Purpose: To address users’ inquiries. To improve the Service, in relation to information (such as feedback) about your experience with the Service.
Justification for Processing Personal Data: Legitimate Interests: Providing user support. Enabling us to prevent and detect harmful or unauthorized conduct. Improving and developing the App and developing new features and Services. For example, we may decide to build a new feature in response to feedback received from users.
Payment and Transactional Data
Purpose: To authorize Stripe to process your transactions.
Justification for Processing Personal Data: Contractual Necessity.
Device Data
Purpose: To provide functionality, security, and for analytics and marketing purposes.
Justification for Processing Personal Data: Legitimate Interests: Developing and improving the Service.
Recipients of Data. We may disclose your personal data to the recipients described in the “How We Share Personal Information” section above.
Retention of Data. We keep your personal data for as long as you have a RISE account. To protect the safety and security of our users, your personal data will be retained for a reasonable period of time following account deletion. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Storage. We are based in the United States and rely on cloud storage providers that store user data on our behalf in the United States. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in Europe. We have taken measures to protect the confidentiality and security of your personal data, and your rights as a data subject.
Your Rights. The GDPR and the LGPD grant European and Brazilian data subjects the following rights:
To exercise these rights, please email [email protected]. You may also contact us using the contact information referenced in the “How to Contact Us” section above. You also have the right to complain to a data protection authority in your country about our processing of your personal data.
Last updated September 27, 2021
Need to cancel your RISEsubscription? View the to cancel or request a refund.
Maintaining the privacy of your information is of paramount importance to us as it helps foster confidence, goodwill and stronger relationships with our users. This Global Privacy Policy (“Privacy Policy”) describes the privacy practices of ĢƵ, Inc. (“RISE,” “we,” “us” or “our”) when you use or otherwise interact with our website at / (the “Site”) and our mobile application RISE Sleep (the “App”). The App allows users to track their sleep, sleep debt, and energy levels, along with offering guided support and educational content on a wide array of relevant topics. The Site and the App are referred to collectively in this Privacy Policy as the “Service.” Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. In this Privacy Policy, we also provide a supplementary privacy notice for California residents and a supplementary privacy notice for data subjects in the EEA, Switzerland and the UK (collectively, “Europe”) and Brazil.
This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any personal information to RISE, please review this Privacy Policy carefully and contact us at [email protected] if you have any questions.
Here’s a description of the categories of information we may collect when you interact with our Service, and examples of how we use the specific types of information.
We use personal information to:
Provide our Service, including to:
Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of feature releases or providing content that we think may be of interest to you. You may opt out of our email, push or text-message marketing communications as described in the “” section below. Please note that we may periodically send you transactional emails even after you opt out of direct marketing.
Interest-based advertising. We may engage advertising partners, including third party advertising companies and social media companies, to display ads on the Service. These companies may use cookies and similar technologies to collect information about your interaction with the Service, our communications and other online services (as further described in the “” section below), and use that information to serve online ads that they think will interest you. This is called interest-based advertising. You can learn more about your choices for limiting interest-based advertising in the “” section below.
Research and development. We may use your information to analyze the effectiveness of our Service, to improve and add features to our Service, and to analyze the general behavior and characteristics of users of our Service.
Support and maintenance. We use third party analytics services to automatically log certain information about your mobile device and how you interact with the App. The information collected is used to troubleshoot and prevent errors, perform data analysis, and develop new features.
Compliance and protection. We may use personal information to:
We do not sell personal information. In the ordinary course of business, we may share personal information with:
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as payment processors, providers of subscription and billing services, analytics service providers, marketing service providers, database service providers, backup and disaster recovery service providers, email communication service providers, push notification, text message service providers).
Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties as we believe necessary to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce our Terms of Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, RISE or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Like many services, we use cookies and similar technologies to operate the Service and to remember things about you so that we can provide you with a better experience.
We and our partners may use cookies, SDKs, and other tracking technologies on the App or Site provided by the following third parties:
a. Amplitude, a web analysis service provided by Amplitude, Inc., used to evaluate user access and to maintain and improve the Service. Amplitude’s privacy policy can be found here: https://amplitude.com/privacy.
b. Adjust, an analysis service provided by Adjust GmbH, used to track user interactions with the App in real time and to analyze the performance of marketing campaigns. Adjust’s privacy policy can be found here: https://www.adjust.com/terms/privacy-policy/.
c. Google Firebase Crashlytics (provided by Google LLC), used to get crash reports and metrics and to derive analytics information regarding the use of the App, including by collecting identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS). Firebase Crashlytics retains crash stack traces, extracted minidump data, and associated identifiers (including Crashlytics Installation UUIDs) for 90 days. To learn more about how Google uses data when you use the App please read .
d. Sentry, a service provided by Sentry that collects App usage information related to system crashes and bugs, including information about the device, the version of the App that is installed, and other information that can help fix bugs. Sentry privacy policy can be found here: https://sentry.io/privacy/.
f. Segment, used to collect analytics information relating to the Service. Segments privacy policy can be found here: https://segment.com/legal/privacy/.
g. Google Analytics, a web analytics service provided by Google. These cookies help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
Update, correct, or delete. You can contact us to ask us to update or correct your information. You may also delete your account. Please note that we will need to verify that you have the authority to update, correct, or delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions contained in the communications we send you.
Opt out of push notifications. If you opt-in to receive push notifications within the App, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the App, or deleting the App.
Opt out of text communications. If you opt in to receive text message communications, we may send SMS messages to your mobile device from time to time. You may opt out of marketing-related text messages at any time by following the opt out or unsubscribe instructions contained in the communications we send you. Message and data rates may apply.
Online tracking opt out. There are a number of ways to limit online tracking, which we have summarized below:
Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit .
The Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.
This Privacy Policy does not apply to any third-party applications or software that integrate with the Service, or any other third-party products, services or businesses.
RISE has users located across the globe. We are headquartered in the United States with services providers that operate in other countries. We may transfer your personal information to the United States and other countries which may not have the same data protection laws as your home country or territory, but we will protect your personal information in accordance with this Privacy Policy, or as otherwise disclosed to you.
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the App, or third party websites.
The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Service from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App or Site. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the App. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment of the modified Privacy Policy.
If you have any questions about this Privacy Policy or complaint about our handling of your personal information, please contact us at [email protected] or sending a letter to the following mailing address:
ĢƵ
548 Market St. PMB 79836
San Francisco, CA 94104
United States
We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).
The CCPA grants California residents the following rights:
The CCPA limits these rights. For example, companies may not provide users in response to access requests certain sensitive information and other consumers’ personal information, and may exclude information that would compromise the confidentiality of trade secrets. The CCPA also places limits on when companies must comply with a deletion request.
You are entitled to exercise the rights described above free from discrimination.
Here is how you can submit requests:
We are providing this supplemental privacy notice to European data subjects, pursuant to European data protection laws (“GDPR”) and Brazilian data subjects, pursuant to Brazilian data protection laws (“LGPD”).
Controller and Representative. RISE is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR. You can find our contact information in the “How to Contact Us” section above.
VeraSafe has been appointed as ĢƵ, Inc’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to [email protected], only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
Personal Data We Collect From You and How We Use It. You can read about the personal data we collect from you in the “Personal Information We May Collect” section above, and how we use it in the “How We Use Personal Information” section above.
Justification for Data Processing. European and Brazilian data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to consumers the specific justifications for the company’s data processing activities. We generally rely on one of the following justifications to process personal data:
Provision of some of this data is necessary to establish an account on RISE.
Account data
Purpose: To create and maintain your account.
Justification for Processing Personal Data: Contractual Necessity
Account data
Purpose: To respond to your inquiries. To send you notifications, SMS messages, or emails of feature releases or provide content that we think may be of interest to you
Justification for Processing Personal Data: Contractual Necessity. Legitimate Interests: Providing you with the support that you request, and improving our App and related Services. Sending you information on our own products and Services that may be of interest to you.
Steps, sleep, and movement data
Purpose: To generate insights and analysis as to users sleep habits, sleep debt, and energy levels.
Justification for Processing Personal Data: Contractual Necessity.
Communications
Purpose: To address users’ inquiries. To improve the Service, in relation to information (such as feedback) about your experience with the Service.
Justification for Processing Personal Data: Legitimate Interests: Providing user support. Enabling us to prevent and detect harmful or unauthorized conduct. Improving and developing the App and developing new features and Services. For example, we may decide to build a new feature in response to feedback received from users.
Payment and Transactional Data
Purpose: To authorize Stripe to process your transactions.
Justification for Processing Personal Data: Contractual Necessity.
Device Data
Purpose: To provide functionality, security, and for analytics and marketing purposes.
Justification for Processing Personal Data: Legitimate Interests: Developing and improving the Service.
Recipients of Data. We may disclose your personal data to the recipients described in the “How We Share Personal Information” section above.
Retention of Data. We keep your personal data for as long as you have a RISE account. To protect the safety and security of our users, your personal data will be retained for a reasonable period of time following account deletion. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Storage. We are based in the United States and rely on cloud storage providers that store user data on our behalf in the United States. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in Europe. We have taken measures to protect the confidentiality and security of your personal data, and your rights as a data subject.
Your Rights. The GDPR and the LGPD grant European and Brazilian data subjects the following rights:
To exercise these rights, please email [email protected]. You may also contact us using the contact information referenced in the “How to Contact Us” section above. You also have the right to complain to a data protection authority in your country about our processing of your personal data.
Need to cancel your subscription? View the to cancel RISE or request a refund.
Last updated September 27, 2021
Maintaining the privacy of your information is of paramount importance to us as it helps foster confidence, goodwill and stronger relationships with our users. This Global Privacy Policy (“Privacy Policy”) describes the privacy practices of ĢƵ, Inc. (“RISE,” “we,” “us” or “our”) when you use or otherwise interact with our website at / (the “Site”) and our mobile application RISE Sleep (the “App”). The App allows users to track their sleep, sleep debt, and energy levels, along with offering guided support and educational content on a wide array of relevant topics. The Site and the App are referred to collectively in this Privacy Policy as the “Service.” Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. In this Privacy Policy, we also provide a supplementary privacy notice for California residents and a supplementary privacy notice for data subjects in the EEA, Switzerland and the UK (collectively, “Europe”) and Brazil.
This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any personal information to RISE, please review this Privacy Policy carefully and contact us at [email protected] if you have any questions.
Here’s a description of the categories of information we may collect when you interact with our Service, and examples of how we use the specific types of information.
We use personal information to:
Provide our Service, including to:
Direct marketing. We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of feature releases or providing content that we think may be of interest to you. You may opt out of our email, push or text-message marketing communications as described in the “” section below. Please note that we may periodically send you transactional emails even after you opt out of direct marketing.
Interest-based advertising. We may engage advertising partners, including third party advertising companies and social media companies, to display ads on the Service. These companies may use cookies and similar technologies to collect information about your interaction with the Service, our communications and other online services (as further described in the “” section below), and use that information to serve online ads that they think will interest you. This is called interest-based advertising. You can learn more about your choices for limiting interest-based advertising in the “” section below.
Research and development. We may use your information to analyze the effectiveness of our Service, to improve and add features to our Service, and to analyze the general behavior and characteristics of users of our Service.
Support and maintenance. We use third party analytics services to automatically log certain information about your mobile device and how you interact with the App. The information collected is used to troubleshoot and prevent errors, perform data analysis, and develop new features.
Compliance and protection. We may use personal information to:
We do not sell personal information. In the ordinary course of business, we may share personal information with:
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as payment processors, providers of subscription and billing services, analytics service providers, marketing service providers, database service providers, backup and disaster recovery service providers, email communication service providers, push notification, text message service providers).
Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties as we believe necessary to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce our Terms of Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, RISE or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Like many services, we use cookies and similar technologies to operate the Service and to remember things about you so that we can provide you with a better experience.
We and our partners may use cookies, SDKs, and other tracking technologies on the App or Site provided by the following third parties:
a. Amplitude, a web analysis service provided by Amplitude, Inc., used to evaluate user access and to maintain and improve the Service. Amplitude’s privacy policy can be found here: https://amplitude.com/privacy.
b. Adjust, an analysis service provided by Adjust GmbH, used to track user interactions with the App in real time and to analyze the performance of marketing campaigns. Adjust’s privacy policy can be found here: https://www.adjust.com/terms/privacy-policy/.
c. Google Firebase Crashlytics (provided by Google LLC), used to get crash reports and metrics and to derive analytics information regarding the use of the App, including by collecting identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS). Firebase Crashlytics retains crash stack traces, extracted minidump data, and associated identifiers (including Crashlytics Installation UUIDs) for 90 days. To learn more about how Google uses data when you use the App please read .
d. Sentry, a service provided by Sentry that collects App usage information related to system crashes and bugs, including information about the device, the version of the App that is installed, and other information that can help fix bugs. Sentry privacy policy can be found here: https://sentry.io/privacy/.
f. Segment, used to collect analytics information relating to the Service. Segments privacy policy can be found here: https://segment.com/legal/privacy/.
g. Google Analytics, a web analytics service provided by Google. These cookies help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
Update, correct, or delete. You can contact us to ask us to update or correct your information. You may also delete your account. Please note that we will need to verify that you have the authority to update, correct, or delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions contained in the communications we send you.
Opt out of push notifications. If you opt-in to receive push notifications within the App, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the App, or deleting the App.
Opt out of text communications. If you opt in to receive text message communications, we may send SMS messages to your mobile device from time to time. You may opt out of marketing-related text messages at any time by following the opt out or unsubscribe instructions contained in the communications we send you. Message and data rates may apply.
Online tracking opt out. There are a number of ways to limit online tracking, which we have summarized below:
Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit .
The Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.
This Privacy Policy does not apply to any third-party applications or software that integrate with the Service, or any other third-party products, services or businesses.
RISE has users located across the globe. We are headquartered in the United States with services providers that operate in other countries. We may transfer your personal information to the United States and other countries which may not have the same data protection laws as your home country or territory, but we will protect your personal information in accordance with this Privacy Policy, or as otherwise disclosed to you.
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the App, or third party websites.
The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Service from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App or Site. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the App. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment of the modified Privacy Policy.
If you have any questions about this Privacy Policy or complaint about our handling of your personal information, please contact us at [email protected] or sending a letter to the following mailing address:
ĢƵ
548 Market St. PMB 79836
San Francisco, CA 94104
United States
We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).
The CCPA grants California residents the following rights:
The CCPA limits these rights. For example, companies may not provide users in response to access requests certain sensitive information and other consumers’ personal information, and may exclude information that would compromise the confidentiality of trade secrets. The CCPA also places limits on when companies must comply with a deletion request.
You are entitled to exercise the rights described above free from discrimination.
Here is how you can submit requests:
We are providing this supplemental privacy notice to European data subjects, pursuant to European data protection laws (“GDPR”) and Brazilian data subjects, pursuant to Brazilian data protection laws (“LGPD”).
Controller and Representative. RISE is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR. You can find our contact information in the “How to Contact Us” section above.
VeraSafe has been appointed as ĢƵ, Inc’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to [email protected], only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
Personal Data We Collect From You and How We Use It. You can read about the personal data we collect from you in the “Personal Information We May Collect” section above, and how we use it in the “How We Use Personal Information” section above.
Justification for Data Processing. European and Brazilian data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to consumers the specific justifications for the company’s data processing activities. We generally rely on one of the following justifications to process personal data:
Provision of some of this data is necessary to establish an account on RISE.
Account data
Purpose: To create and maintain your account.
Justification for Processing Personal Data: Contractual Necessity
Account data
Purpose: To respond to your inquiries. To send you notifications, SMS messages, or emails of feature releases or provide content that we think may be of interest to you
Justification for Processing Personal Data: Contractual Necessity. Legitimate Interests: Providing you with the support that you request, and improving our App and related Services. Sending you information on our own products and Services that may be of interest to you.
Steps, sleep, and movement data
Purpose: To generate insights and analysis as to users sleep habits, sleep debt, and energy levels.
Justification for Processing Personal Data: Contractual Necessity.
Communications
Purpose: To address users’ inquiries. To improve the Service, in relation to information (such as feedback) about your experience with the Service.
Justification for Processing Personal Data: Legitimate Interests: Providing user support. Enabling us to prevent and detect harmful or unauthorized conduct. Improving and developing the App and developing new features and Services. For example, we may decide to build a new feature in response to feedback received from users.
Payment and Transactional Data
Purpose: To authorize Stripe to process your transactions.
Justification for Processing Personal Data: Contractual Necessity.
Device Data
Purpose: To provide functionality, security, and for analytics and marketing purposes.
Justification for Processing Personal Data: Legitimate Interests: Developing and improving the Service.
Recipients of Data. We may disclose your personal data to the recipients described in the “How We Share Personal Information” section above.
Retention of Data. We keep your personal data for as long as you have a RISE account. To protect the safety and security of our users, your personal data will be retained for a reasonable period of time following account deletion. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Storage. We are based in the United States and rely on cloud storage providers that store user data on our behalf in the United States. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in Europe. We have taken measures to protect the confidentiality and security of your personal data, and your rights as a data subject.
Your Rights. The GDPR and the LGPD grant European and Brazilian data subjects the following rights:
To exercise these rights, please email [email protected]. You may also contact us using the contact information referenced in the “How to Contact Us” section above. You also have the right to complain to a data protection authority in your country about our processing of your personal data.
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