PRIVACY POLICY

Effective Date: August 26, 2025 | Last Updated: August 26, 2025

1. DEFINITIONS AND SCOPE

This Privacy Policy ("Policy") governs the collection, processing, and use of personal data by Cenvigo AB, a Swedish corporation ("Company," "we," "us," "our") in connection with the Cenvigo Mobile application ("Application") and related services ("Services"). By accessing or using the Application, you ("User," "you," "your") acknowledge and agree to be bound by this Policy.

2. DATA COLLECTION

2.1 User-Provided Information: Company collects information voluntarily provided by User including: (a) account credentials and registration data; (b) device configuration parameters; (c) user preferences and application settings; (d) communications with Company support services.

2.2 Automatically Collected Data: Company automatically collects: (a) sleep pattern metrics transmitted from connected Cenvigo sensors; (b) application usage analytics and performance data; (c) device identifiers, operating system information, and technical specifications; (d) system logs, error reports, and diagnostic information; (e) sensor connectivity and performance metrics.

2.3 Sensor-Generated Data: User authorizes collection of sleep monitoring data, sensor performance metrics, historical pattern records, and related telemetry data transmitted by Cenvigo hardware devices.

3. DATA PROCESSING AND USE

Company processes collected data for the following lawful purposes: (a) provision and maintenance of Application functionality; (b) processing, analysis, and display of sleep monitoring data; (c) service improvement, optimization, and technical support; (d) user communications regarding service updates and notifications; (e) security monitoring and unauthorized access prevention; (f) compliance with legal obligations and protection of Company rights.

4. DATA SHARING AND DISCLOSURE

Company does not sell, license, or otherwise transfer personal data to third parties for commercial purposes. Data may be disclosed solely under the following circumstances: (a) with User's explicit written consent; (b) pursuant to legal process, court orders, or governmental requests; (c) to protect Company's legitimate business interests, rights, or property; (d) in connection with corporate transactions including mergers, acquisitions, or asset transfers, subject to prior notice and equivalent privacy protections.

5. DATA SECURITY AND STORAGE

Company implements industry-standard security measures including: (a) encryption of data in transit and at rest; (b) access controls restricting data access to authorized personnel; (c) regular security audits and vulnerability assessments; (d) incident response procedures for data breaches. Data is stored on secure servers with appropriate technical and organizational safeguards.

6. DATA SUBJECT RIGHTS

Under applicable data protection laws, Users have the right to: (a) access personal data and obtain copies thereof; (b) rectify inaccurate or incomplete data; (c) erase personal data under certain circumstances; (d) restrict or object to data processing; (e) data portability; (f) withdraw consent where processing is based on consent. Requests should be submitted to privacy@cenvigo.com.

7. DATA RETENTION

Personal data is retained for the duration necessary to fulfill the purposes outlined in this Policy or as required by applicable law. Upon account termination or data deletion request, Company will delete personal data within thirty (30) days, except where retention is required for legal, regulatory, or legitimate business purposes.

8. INTERNATIONAL DATA TRANSFERS

User data may be transferred to, processed, and stored in countries outside User's jurisdiction. Company ensures adequate protection through appropriate safeguards including Standard Contractual Clauses approved by the European Commission and other legally recognized transfer mechanisms.

9. THIRD-PARTY SERVICES

The Application may contain links to external websites or services operated by third parties. This Policy does not govern third-party data practices. Users are advised to review the privacy policies of any third-party services accessed through the Application.

10. MINORS

The Services are not intended for individuals under thirteen (13) years of age. Company does not knowingly collect personal data from minors under 13. If Company becomes aware of such collection, the data will be promptly deleted.

11. POLICY AMENDMENTS

Company reserves the right to modify this Policy at any time. Material changes will be communicated through the Application or via email notification. Continued use of the Services following notification constitutes acceptance of the amended Policy.

12. GOVERNING LAW AND JURISDICTION

This Policy is governed by Swedish law. Any disputes arising hereunder shall be subject to the exclusive jurisdiction of Swedish courts.

13. CONTACT INFORMATION

For privacy-related inquiries, data subject requests, or concerns regarding this Policy, contact:

Data Protection Officer
Cenvigo AB
Uppsala Ekeby 2N
SE75263 Uppsala, Sweden
Email: privacy@cenvigo.com
Phone: +46 70 760 9855

14. EFFECTIVE DATE

This Policy is effective as of the date first written above and supersedes all prior privacy policies or statements regarding the Services.

© 2025 Cenvigo AB. All rights reserved. This Privacy Policy constitutes a legally binding agreement between Company and User regarding the collection, processing, and use of personal data in connection with the Services.