Privacy Policy

This Privacy Policy explains how JL App Studio LLC, a Florida limited liability company ("SleepQi," "we," "us," or "our"), collects, uses, shares, and protects personal information when you use the SleepQi mobile application on iOS and Android (the "App").

By creating an account or using the App, you agree to this Policy. If you do not agree, do not use the App.

Eligibility: The App is for users who are at least 18 years old. If you are under 18, do not create an account or use the App.

Related documents

• Terms of Service
• Consumer Health Data Privacy Policy (standalone supplement for U.S. state consumer health data laws)

Questions: support@sleepqi.com

1. Who We Are & Scope

SleepQi is a consumer sleep-tracking and wellness app. It lets you log sleep-related information, view insights derived from what you log, and listen to soundscapes to help you wind down.

Controller. JL App Studio LLC is the organization that determines why and how personal information is processed for the App.

This Policy applies to the SleepQi App on iOS and Android and related online services we operate for the App. It does not apply to third-party apps, websites, or services we link to but do not control (including Apple, Google, ad networks, or social login providers acting under their own policies).

Wellness notice. SleepQi is not a medical device and is not intended to diagnose, treat, cure, or prevent any disease. It is not a substitute for professional medical advice, diagnosis, or care. We are not operating as a HIPAA covered entity or business associate for App use described here. See also our Terms of Service and Consumer Health Data Privacy Policy.

Markets. Our primary commercial focus is the United States and Canada. We do not currently market the App as an offer into the European Economic Area (EEA) or United Kingdom until a dedicated GDPR/UK GDPR compliance pack is in place. Light references to those laws do not constitute an EEA/UK offer.

2. Relationship to the Consumer Health Data Privacy Policy

Some information you enter in the App (for example sleep logs, mood check-ins, journal text, and assessment answers) may qualify as "Consumer Health Data" under certain U.S. state laws. That topic is covered in detail in our Consumer Health Data Privacy Policy.

• This Privacy Policy covers personal information generally (account, device, ads, analytics, security, Canada/PIPEDA, California rights, etc.).
• The Consumer Health Data Privacy Policy covers Consumer Health Data under applicable U.S. state health-privacy laws.
• Where the two differ on Consumer Health Data, the Consumer Health Data Privacy Policy controls.
• Accepting the Terms of Service or this Privacy Policy is not the same as consenting to Consumer Health Data collection. That consent is requested separately in the App before those features can be used.

3. Information We Collect

3.1 Information you provide

3.2 Information collected automatically

3.3 Information we do not currently collect (as described here)

• Continuous biometric sensor streams from HealthKit, Google Fit, or medical wearables persisted to our servers (any wearable UI shown today is not a live clinical/device integration and does not store biometric sensor streams on our servers)
• Precise location used to infer health-service seeking
• Payment card numbers (subscriptions, if offered, are billed by Apple or Google)
• Data purchased from data brokers about your health

3.4 Sources

We collect personal information from you, from your device/app automatically, and from authentication providers (Apple/Google) when you choose those sign-in methods. We do not buy Consumer Health Data from data brokers.

4. How We Use Information

We use personal information to:

1. Provide the App — create/authenticate accounts, sync your data, deliver soundscapes (including signed audio delivery), and operate features you request
2. Personalize in-App experiences — insights and recommendations shown to you based on information you provide (Consumer Health Data uses are limited as described in the CHD Policy)
3. Secure and maintain the service — fraud/abuse prevention, debugging, backups, integrity
4. Communicate with you — account, security, and service messages (not optional while you have an account)
5. Show ads on the free tier — non-personalized AdMob ads, subject to platform consent frameworks where required
6. Optional analytics — only if you opt in under Settings
7. Optional research — only if you opt in under Settings (see Section 8)
8. Comply with law — respond to lawful requests; enforce Terms; protect rights, safety, and security

Uses we do not make

• We do not sell Consumer Health Data
• We do not use Consumer Health Data to personalize third-party ads or build advertising profiles from your sleep/mood/journal/assessment content
• We do not send your sleep logs to a third-party generative AI provider as of the date of this Policy (see also our Terms of Service). Optional research uses of de-identified / pseudonymous data are separate (Section 8)

5. Legal Bases & Consent Model (Practical Summary)

United States. We process personal information as described in this Policy and, for Consumer Health Data, under separate affirmative consent and the CHD Policy. State laws (including California and consumer health data laws in certain states) may provide additional rights (Sections 11–12).

Canada (PIPEDA and applicable provincial private-sector laws). We collect, use, and disclose personal information for the purposes identified in this Policy, with consent where required. For sensitive wellness-related information (sleep/mood/journals/assessment), we obtain express, separate consent before those features collect that information. You may withdraw consent subject to legal or contractual restrictions and reasonable notice; withdrawal may limit features that depend on that information.

We do not require a separate "transfer consent" solely because processing occurs in the United States, but we remain accountable for personal information transferred for processing and we disclose cross-border processing clearly (Section 10).

6. How We Share Information

We do not sell your personal information for money in the ordinary sense. Under some U.S. state laws (for example California), "sale" or "sharing" can include certain advertising disclosures involving identifiers. See Section 11.

We disclose personal information only as described below:

6.1 Service providers / processors

Processors are engaged to help operate the App and are expected to process personal information under contractual limits consistent with this Policy.

6.2 Consumer Health Data

Identifiable Consumer Health Data is not shared with third parties or affiliates for advertising. Disclosure to Supabase as a processor to operate the App is described in the CHD Policy. That Policy controls on Consumer Health Data sharing questions.

6.3 Legal, safety, and business transfers

We may disclose information if required by law or legal process; to protect rights, safety, and security; or as part of a merger, acquisition, financing, or sale of assets, subject to applicable law and this Policy.

6.4 Affiliates

We currently have no affiliates that receive your personal information for their own purposes. If that changes, we will update this Policy.

7. Advertising, ATT, and Consent Frameworks (iOS & Android)

• Free-tier ads may be shown via Google AdMob.
• SleepQi configures ad requests as non-personalized (npa: true).
• Where required (for example Google UMP / privacy messaging), we use platform consent tooling and gate ad loading on whether ads can be requested.
• SleepQi does not call App Tracking Transparency and does not include a tracking-usage disclosure string. Ads are requested as non-personalized only (npa: true).
• Ads infrastructure may still process limited technical/identifier data as described by Google and the platform; it does not receive your sleep/mood/journal/assessment content from SleepQi for targeting.
• You can often reset or limit ad identifiers in iOS/Android system settings.

Paid tiers, if offered, may reduce or remove ads as described in the App and Terms.

8. Analytics, Research, and AI

8.1 Analytics (optional)

Product analytics (PostHog) run only if you enable analytics consent in Settings. You can turn this off later. Turning analytics off stops future analytics collection under that consent; it does not by itself delete historical analytics already processed by the provider.

8.2 Research (optional, separate)

If you enable research participation in Settings, that consent is optional and never required for core App use, and is separate from Consumer Health Data consent and analytics consent.

Research exports, if run, use a consent-gated administrative process: only designated operators with privileged backend access may run the export function; the App's normal user features do not trigger it. That process is designed to: include only users with active research consent; replace account identifiers with a non-reversible subject key; export allowlisted fields (and counts rather than raw free-text journal or note content); and suppress the export if fewer than 20 consented subjects would be included. Exports are audited, and generated artifacts are set to expire by default after 90 days under our internal research export controls.

As of this Policy's date, we do not operate an active commercial or third-party research-dataset licensing program. Opting in records your consent so that, if we later use research exports for internal research, AI/model improvement, or external/commercial research datasets, we can do so only for users who remain opted in. Before any external or commercial research use begins, we will update this Policy, describe what is involved, and obtain any additional consent required by law. De-identified research exports are not used to personalize advertising. Opting out stops inclusion in future exports; handling of any previously generated artifacts is subject to legal/privacy review.

More detail for U.S. Consumer Health Data context: CHD Policy §5.4.

8.3 AI / insights

In-App insights and personalization are first-party features based on information you provide. As of this Policy's date, we do not send your sleep logs, journal text, or assessment answers to a third-party generative AI provider. During signup we may ask for optional consent for AI-related coaching or analytics features; that consent is separate from Consumer Health Data consent, analytics consent, and research consent, and is not required for core App use. If we introduce features that send your content to a third-party AI provider or materially expand AI processing, we will update this Policy (and obtain any required consents) first. See also our Terms of Service.

9. Retention

We retain personal information for as long as needed to:

• Provide the App and maintain your account history
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Maintain security and prevent fraud

When you delete your account, we delete associated App data (including profile, assessment, and sleep/journal log data) from our database in accordance with our deletion process, subject to limited retention needed for security, fraud prevention, legal compliance, backup cycling, or compulsory records. As part of deletion, we may retain a small de-identified churn record for internal product analytics (for example approximate account tenure, count of logs created, platform, and exit reason — no name, email, or user id).

Research export artifacts, when created, are subject to documented retention/expiry controls under our internal research export practices.

Historical analytics events (PostHog), crash reports (Sentry), and advertising/consent records held by Google are not automatically fully erased by our in-App deletion flow; contact support@sleepqi.com if you want help pursuing deletion with those providers.

10. International Processing (including Canada → United States)

SleepQi is operated by a U.S. company. Personal information is processed in the United States and may be processed in other countries where our processors operate.

If you use the App from Canada, your information will be transferred to and processed in the United States (and possibly other jurisdictions). While information is outside Canada, it may be subject to the laws of that jurisdiction, including lawful access by courts, law enforcement, and national security authorities.

Under PIPEDA's accountability model, we remain responsible for personal information we transfer for processing and use contractual or other means intended to provide a comparable level of protection while the information is with our processors.

11. Your Privacy Rights (United States)

Depending on your state of residence, you may have rights to:

• Access / know what personal information we hold
• Correct inaccurate personal information
• Delete personal information
• Obtain a copy / portability (including in-App Settings → data export for logged-in users)
• Opt out of certain "sale" or "sharing" of personal information for cross-context behavioral advertising, where those definitions apply
• Limit use of sensitive personal information, where applicable
• Non-discrimination for exercising privacy rights

California (CCPA/CPRA) notice (summary). We collect the categories described in Section 3. We use them for the purposes in Section 4. We disclose categories to service providers as in Section 6. We do not use Consumer Health Data content for cross-context behavioral advertising. Advertising partners may receive device/ad identifiers in connection with non-personalized ads; depending on interpretation, some advertising disclosures can be treated as "sharing." You may use platform ad settings and in-App consent tools where available. To exercise California rights, email support@sleepqi.com with subject "California Privacy Request."

Consumer Health Data rights (access, deletion, withdraw consent, etc.) are described in the CHD Policy.

Authorized agents may submit requests where permitted by law; we may require proof of authorization and identity verification.

Response timing. We aim to respond within 45 days, or as otherwise required by applicable law. We may extend once where permitted, with notice.

12. Your Privacy Rights (Canada)

If you are in Canada, you may have rights under PIPEDA and applicable provincial private-sector privacy laws (including, where applicable, Québec, Alberta, and British Columbia), such as:

• Be informed about our practices (this Policy)
• Access your personal information
• Request correction of inaccurate information
• Withdraw consent (subject to legal/contractual restrictions and reasonable notice)
• Challenge compliance / complain to SleepQi and, if unresolved, to the Office of the Privacy Commissioner of Canada or a provincial commissioner where applicable

How to exercise: email support@sleepqi.com with subject "Canada Privacy Request." Include the email on your account and enough detail for us to verify your identity and respond.

You may also use in-App Settings to export data, manage analytics/research/health consents, or delete your account.

Québec note. If you are in Québec, additional requirements under Law 25 may apply. We do not currently provide a French version of this Policy; if we expand Québec marketing, we will update our notices as required.

13. How to Exercise Rights & Delete Your Account

Sign in with Apple

If you use Sign in with Apple:

• If Apple notifies us that you deleted your Apple account relationship in a way that requires account deletion, we process a full account purge consistent with our deletion pipeline.
• If Apple notifies us that you revoked consent for SleepQi to use your Apple identity, we unlink the Apple identity from your SleepQi account; we do not automatically delete your entire SleepQi account or data solely for a consent-revoked event. You can still delete your SleepQi account in Settings.

14. Security

We implement administrative, technical, and organizational measures designed to protect personal information, including access controls, encryption in transit, database access policies (including row-level security where applicable), and contractual limits on processors.

No method of transmission or storage is 100% secure. We cannot guarantee absolute security.

If we become aware of a breach affecting personal information in a way that triggers legal notice duties (including under applicable U.S. state law or PIPEDA's breach regime), we will provide notices required by law.

15. Children's Privacy

The App is intended only for users 18+. We do not knowingly collect personal information from anyone under 18. We block account setup in the App when the birthday you provide indicates you are under 18. If we learn we have collected personal information from someone under 18, we will take steps to delete it. Contact support@sleepqi.com if you believe a minor has created an account.

This App is also not directed to children under 13 under COPPA.

16. Third-Party Links and SDKs

The App may contain links to third-party sites or use third-party SDKs (Apple, Google, AdMob, PostHog, Sentry, Supabase, Cloudflare). Those parties' privacy practices govern their own processing. We encourage you to read their policies.

17. Changes to This Policy

We may update this Policy from time to time. The "Last updated" date will change when we do. For material changes, we may provide notice in the App and, where required, obtain additional consent.

If Consumer Health Data categories, purposes, or recipients change, we will also follow the update/consent rules in the CHD Policy.

18. Contact Us

JL App Studio LLC 7901 4th St N, Ste 300 St. Petersburg, FL 33702, US

Email: support@sleepqi.com

For Consumer Health Data–specific requests, you may also use the process in the CHD Policy. For Canada privacy requests, use subject line "Canada Privacy Request." For California privacy requests, use subject line "California Privacy Request."