Privacy Policy

Orion Longevity, Inc.

Owner contact email: support@orionsleep.com

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; various types of Data; email address; geographic position; shopping history; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); first name; last name; phone number; payment info; billing address; shipping address; website; Data communicated while using the service; Universally unique identifier (UUID); device information; number of Users; session statistics; city; country; User ID; IP address; session duration; scroll-to-page interactions; clicks; time zone; mouse movements; interaction events; page events; custom events; layout details; positional information; password.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies — or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Remarketing and behavioral targeting, Advertising, Analytics, Interaction with external social networks and platforms, Heat mapping and session recording, Interaction with online survey platforms, Tag Management, Commercial affiliation, Contacting the User, Content performance and features testing (A/B testing), Handling payments, Infrastructure monitoring, Platform services and hosting, User database management, Displaying content from external platforms, Location-based interactions, Managing contacts and sending messages, Traffic optimization and distribution, Hosting and backend infrastructure, Managing data collection and online surveys, Managing support and contact requests, Registration and authentication, Interaction with live chat platforms, Access to third-party accounts, Interaction with data collection platforms and other third parties, Beta Testing, Managing landing and invitation pages and Registration and authentication provided directly by this Application.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Personal Data is collected for the following purposes and using the following services:

• Access to third-party accounts
• Advertising
• Analytics
• Beta Testing
• Commercial affiliation
• Contacting the User
• Content performance and features testing (A/B testing)
• Displaying content from external platforms
• Handling payments
• Heat mapping and session recording
• Hosting and backend infrastructure
• Infrastructure monitoring
• Interaction with data collection platforms and other third parties
• Interaction with external social networks and platforms
• Interaction with live chat platforms
• Interaction with online survey platforms
• Location-based interactions
• Managing contacts and sending messages
• Managing data collection and online surveys
• Managing landing and invitation pages
• Managing support and contact requests
• Platform services and hosting
• Registration and authentication
• Registration and authentication provided directly by this Application
• Remarketing and behavioral targeting
• Tag Management
• Traffic optimization and distribution
• User database management

Orion may store Personal Data, including biometric and sleep-related data such as temperature and heart rate, whether collected directly or imported from connected devices and health platforms. This stored data may remain associated with you.

Before sharing any of this data with researchers, including those from academic, scientific, and medical institutions, for sleep, health, and longevity research, Orion de-identifies it so that it cannot reasonably be linked back to you.

When you opt in to receive text messages from Orion Sleep, we collect your mobile phone number and your messaging consent status. This information is used solely to send you the text messages you have consented to receive and to manage your messaging preferences.

We do not sell, rent, share, or disclose your text messaging consent, opt-in data, or mobile phone number to any third parties or affiliates for their own marketing or promotional purposes. This includes any information collected as part of SMS, MMS, or RCS opt-in processes.

Your messaging consent and phone number may only be shared with service providers who assist us in delivering text messages (such as our messaging platform provider), and only to the extent necessary to fulfill the messaging service. These service providers are contractually prohibited from using your information for any purpose other than delivering messages on our behalf.

For more information about our text messaging program, including how to opt out, please see the SMS and Text Messaging Terms in our Terms of Service.

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which the Owner is subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.