Big Health Ltd (“we”) are committed to protecting and respecting your privacy. We are registered with the UK Information Commissioner’s Office as a Data Controller (Reg No. Z2141968), and have in place a comprehensive Company data protection policy and code of practice.
Big Health provides you (the “User”) with access to the online and mobile services associated with Sleepio, including but not limited to, sleepio.com and all associated subdomains (the “Website”), and the Sleepio mobile application (the “App”), collectively the “System”.
We may collect and process information provided by filling in forms on the Website or App, including information provided during completion of surveys, sleep diaries and other online tools, posting of comments in the Community or requesting further services, information provided when purchasing a product or paying for access to restricted content, entering a competition or promotion and when you report a problem with our System. If you contact us, we may also keep a record of that correspondence.
Throughout your use of the System we may collect and process information on pre existing medical conditions, medication along with other health profile information such as height, weight, body mass index (BMI), and smoking status, and details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
The health information described in this Policy is known as “protected health information” (“PHI”). We are required by law to maintain the privacy of your PHI and to provide you with this notice of our legal duties and privacy practices with respect to your PHI. When we use or disclose your PHI, we are required to abide by the terms of this Policy (or other Policy in effect at the time of the use or disclosure).
We may collect information about your device, including where available your IP address, operating system, browser type and screen size for use in system administration, to tailor your experience of the System, provide you with customer support and to report aggregate information internally and to advertisers, for example.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your device. Cookies help us to give you a smooth user experience, improve the System and deliver a better and more personalized service. They enable us:
Both Sleepio and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to the Website or App on sites across the Internet (also known as 'remarketing'). If you would like to opt out of this you can do so via your Google Ads Preferences Manager.
Big Health understands that your PHI is private and personal and is dedicated to maintaining the privacy and integrity of your PHI. As such, we have policies and procedures and other safeguards to help protect your PHI from improper use and disclosure.
The following categories describe different ways that we use your PHI within Big Health and disclose your PHI to persons and entities outside of Big Health. We have not listed every use or disclosure within the categories below, but all permitted uses and disclosures will fall within one of the following categories. In addition, there are some uses and disclosures that may require your specific authorization.
How much PHI is used or disclosed without your written permission will vary depending, for example, on the intended purpose of the use or disclosure.
Information you provide to us is stored in encrypted form on secure servers located in the US. We have signed European Commission approved Standard Contractual Clauses (also called 'model clauses') with our hosting providers in the US, to ensure that they adequately protect the data of EU data subjects that they store for us. All passwords are stored in encrypted form and all sensitive traffic is transmitted securely via SSL by default.
It may be possible that your data is transferred to, and stored at, other destinations inside the EEA by or to staff who work for Big Health or one of our suppliers. Such staff may be engaged in, among other things the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Unfortunately, despite these measures, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the System, and any transmission is at your own risk. Once we have received your information, we will use strict procedures to try to prevent unauthorized access in accordance with our Company data protection policy and code of practice, and responsibilities as a registered Data Controller in the UK.
You have certain rights with respect to your PHI. If we do not agree to a request by you with respect to your PHI, please consult the Big Health Privacy and Security Officer whose contact information is below.
If you believe that any of your rights with respect to your Health Information have been violated by us, our employees or agents, please communicate with the Big Health Privacy and Security Officer at:
Privacy and Security Officer
If we are subject to the Health Insurance Portability and Accountability Act (“HIPAA”), you may also contact the Secretary of the U.S. Department of Health and Human Services. Under no circumstances will we take any retaliation against you for filing a complaint.
We reserve the right to revise this Policy and to make the revised Policy effective for all PHI that we created or received prior to the effective date of the revised Policy. Questions relating to revisions to this Policy may be addressed to the Privacy and Security Officer whose contact information is above. This Policy will be promptly revised if there is a material change to a policy described herein.
Effective Date: This Policy is effective as of September 9, 2014