Document
Privacy Policy
Draft: the passages in square brackets are to be filled in before publication.
Somméo is an app that listens to your nights to pick out snoring, breathing and noise, and sets them against what was going on outside (weather, pollen, air quality). This page explains which data is processed, why, where it goes and how you stay in control of it.
1. Who is responsible
[PUBLISHER’S FULL NAME], sole trader (French micro-entreprise), [ADDRESS], SIRET [NUMBER]. Contact: [CONTACT E-MAIL].
2. What Somméo processes
Your nights (health data)
- The sound of your bedroom is analysed on your phone, as it comes, and never leaves the device. Apart from the sound clips (below), it is not recorded at all: it is discarded once analysed.
- Sound clips (on by default, can be turned off): unless you uncheck “Keep short sound clips of my nights” when you first open the app, or turn off “Sound clips” in your profile later, Somméo saves up to 12 clips of about 10 seconds per night on your phone, when it hears snoring or a loud noise, so that you can listen back to them. A clip contains whatever could be heard in the room at that moment, voices included. Clips stay in the app’s storage on your phone: they are left out of device backups and are never sent to your account, the online backup, the data export, the usage statistics or any provider.
- What was detected: the kind of event (snoring, breathing, noise, speech, cough, phone unlock), its time, its length and a confidence figure, plus when the night started and ended.
- Your answers: number of wake-ups, how you feel in the morning, evening habits (coffee, alcohol, exercise…), pollen allergy.
This information says something about your health. It is only analysed with your explicit agreement, asked for before your first night. It stays on your phone, and, once you have an account, is backed up with it as described below, unless you turn that off; it goes to Apple Health only if you turn that on. Sound clips are a separate choice: the box that keeps them is shown already checked when you first open the app, and you can uncheck it there or turn them off in your profile at any time.
Online backup
If you have an account, a copy of the detected events, your answers and each night’s outside conditions is kept with it. The backup is on from the start: you are told so on the screen where you agree to the analysis of your nights, before your first night. You can turn it off at any time in your profile (“Online backup”); turning it off, or deleting your history, erases that copy.
Apple Health (optional, iPhone only)
Two separate switches in your profile, both off by default. Each one shows Apple’s own permission screen when you turn it on, and each can be turned off at any time.
- Write my nights: Somméo writes the nights recorded on your phone to Apple Health as sleep: the time in bed and the stretches it counts as time asleep. It writes no sleep stages. Once in Apple Health, a night is kept by Apple Health under your control, and can be read by the other apps you have allowed to read your sleep there. Turning the switch off stops new writes; the nights already written stay in Apple Health until you remove them, from Somméo’s profile or from the Health app. When you delete your history, Somméo asks whether to remove them from Apple Health too.
- Read steps and heart rate: Somméo reads your step count and your resting heart rate for the day before each night, and nothing else. They are used for one thing: testing them as possible factors in your own correlations. They are read on your phone when the analyses are shown and no copy is kept: they are not stored by Somméo, not sent to your account, the online backup, the data export, the usage statistics or any provider.
Information obtained from Apple Health is never used for advertising or marketing, never sold and never passed on to anyone.
Home Screen widget (optional, iPhone only)
If you add the Somméo widget to your Home Screen, it shows the score of your last night, its label and your time asleep, and tonight’s outside conditions. These figures are then visible to anyone who sees your screen. They are handed to the widget on your phone only and go nowhere else. You can make the widget show no figure from your profile.
Your account (optional)
Your e-mail address, or the identifier passed on by Apple or Google if you sign in through them. Somméo also works without an account.
Your approximate location
To read the weather, pollen and air, Somméo uses your location rounded to 0.01 degree (about 1 km, or half a mile): enough for the weather of your town, too coarse to locate a home. Only that rounded location leaves the phone. You can refuse and pick a city by hand; only the name you type is then sent for the search.
Your purchases
The Premium subscription is paid through the App Store. Somméo never sees your card. It only receives the state of your subscription (plan, trial, end date).
Usage statistics (optional)
If you turn them on in your profile: which offer screens are opened, when a recording starts and ends, whether a purchase goes through, along with the device model and app version. Never what a night contains. Off by default.
3. Why, and on what basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Analysing your nights and showing you the result | Your explicit consent (Art. 6(1)(a) and 9(2)(a)) |
| Keeping sound clips on your phone | [TO CHECK WITH A LAWYER: the clips are kept by default and offered as a pre-checked box, which the GDPR does not accept as consent (Art. 4(11) and 7; CJEU, Planet49, C-673/17). Either the box is left unchecked and the basis is your explicit consent (Art. 6(1)(a) and 9(2)(a)), or another basis has to be found and written here.] |
| Online backup of your nights | Your explicit consent (Art. 6(1)(a) and 9(2)(a)) |
| Writing your nights to Apple Health | Your explicit consent (Art. 6(1)(a) and 9(2)(a)) |
| Reading your steps and resting heart rate from Apple Health, for your correlations | Your explicit consent (Art. 6(1)(a) and 9(2)(a)) |
| Account, subscription, restoring purchases | Performance of the contract (Art. 6(1)(b)) |
| Weather, pollen and air for your area | Your consent, through the location permission or the choice of a city (Art. 6(1)(a)) |
| Usage statistics | Your consent (Art. 6(1)(a)) |
Somméo sells no data, shows no advertising and makes no automated decision with legal effects.
4. Who receives what
| Provider | Role | Data | Place |
|---|---|---|---|
| Supabase | Account and online backup | E-mail, copy of the nights unless turned off | European Union |
| Open-Meteo | Weather, pollen, air, city search | Rounded location or city name, with no account identifier | [TO CHECK: Europe] |
| Apple | Payment, Sign in with Apple | Purchase, sign-in identifier | As set by Apple |
| Apple Health (on your phone) | Keeps the nights Somméo writes to it, if turned on | Time in bed and time asleep of each night | Your phone, and your iCloud if you sync Health there [TO CHECK: wording about iCloud] |
| Sign in with Google | Sign-in identifier | As set by Google | |
| RevenueCat | Subscription tracking | Account identifier, subscription state | United States |
| PostHog | Usage statistics, if turned on | The events listed above | European Union |
Transfers outside the European Union (RevenueCat, and where applicable Apple and Google) are covered by the safeguards the GDPR provides for [TO CHECK: standard contractual clauses or the EU–US Data Privacy Framework, depending on each provider’s contract]. No provider receives the sound of your nights.
5. How long
- On your phone: until you delete your history or uninstall the app.
- Sound clips: 3, 7 or 30 days after they were recorded, as you choose (7 by default); sooner if you delete them, turn the option off or delete your history.
- Online backup: until you turn it off, delete your history or delete your account.
- Nights written to Apple Health: kept by Apple Health until you remove them, from Somméo’s profile or from the Health app. Uninstalling Somméo does not remove them.
- Steps and resting heart rate read from Apple Health: not kept by Somméo at all.
- Account: until you delete it, which you can do at any time from the profile.
- Usage statistics: [RETENTION PERIOD SET IN POSTHOG].
6. Your rights
At any time, from your profile, you can: withdraw your agreement to the analysis of your nights, turn off the online backup, the sound clips, the statistics, the writing to Apple Health and the reading from it, remove from Apple Health the nights Somméo wrote there, hide the figures of the widget, delete your sound clips, export your data, delete your history, delete your account.
You also have the rights of access, rectification, erasure, restriction, objection and portability. Write to [CONTACT E-MAIL]; you will get an answer within one month. You may also lodge a complaint with your data protection authority; in France, the CNIL (cnil.fr).
7. Children
Somméo is not intended for people under [AGE: 13 in the US and UK, 15 in France] without the agreement of a parent or guardian.
8. Not a medical device
Somméo informs. It does not diagnose, does not treat and does not replace medical advice.
9. Changes
If this policy changes in a significant way, the app will tell you before the change applies.