Privacy Policy

This Privacy Policy explains how Bula Media Ltd (“SleepSats”, “we”, “us”, “our”) collects, uses, discloses, and protects your information when you use the SleepSats mobile application, website, and related services (the “Service”).

Bula Media Ltd
20-22 Wenlock Road
London, N1 7GU
United Kingdom

By using SleepSats, you agree to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

• Email address (account creation, waitlist signup)
• Account credentials and profile details
• Lightning wallet address for withdrawals
• Support requests and any content you send to us directly

1.2 Health & Sleep Data

• Sleep sessions, duration, and quality metrics retrieved through Apple Health or Google Health Connect with your explicit permission
• Streaks, reward history, and other activity generated inside the app

Health data is only accessed when you grant permission, and you can revoke access at any time through your device settings.

1.3 Device & Usage Data

• Device model, operating system, and app version
• Approximate location derived from IP address
• Language, timezone, and screen size
• Referrer and UTM campaign parameters
• In-app events, crash logs, and diagnostic data

1.4 Payment & Subscription Data

Subscription purchases are processed by Apple App Store or Google Play. We do not receive or store your payment card details. We receive confirmation of subscription status from these platforms.

2. How We Use Your Information

• Provide, operate, and maintain the Service
• Calculate and distribute Bitcoin (sats) rewards
• Process Lightning withdrawals
• Manage subscriptions and premium features
• Detect, prevent, and investigate fraud, abuse, or reward manipulation
• Communicate updates, waitlist status, and support replies
• Improve app performance, stability, and user experience
• Comply with legal and regulatory obligations

3. Legal Bases (UK / EEA Users)

We rely on the following legal bases under UK GDPR / GDPR:

• Contract: to provide the Service you signed up for
• Consent: for health data access and marketing communications
• Legitimate interests: for fraud prevention, analytics, and service improvement
• Legal obligation: to comply with applicable laws

4. Sharing of Information

We do not sell your personal data. We may share information with:

• Service providers: hosting, analytics, crash reporting, email delivery, customer support
• Advertising partners: for rewarded ads and measurement (subject to your consent where required)
• Payment platforms: Apple App Store and Google Play for subscription processing
• Lightning payment providers: to facilitate Bitcoin withdrawals
• Legal authorities: where required by law, court order, or to protect rights and safety
• Successors: in connection with a merger, acquisition, or asset sale

5. Advertising & Analytics

SleepSats displays rewarded advertisements provided by third-party ad networks. These networks may collect identifiers and usage data to deliver and measure ads. We also use analytics tools to understand how the app is used. Where required, we will request your consent before enabling non-essential tracking.

6. Data Retention

• Account data is retained for as long as your account is active.
• Reward and transaction records may be retained for up to 7 years for accounting and compliance.
• Diagnostic and analytics data is retained for a shorter period appropriate to its purpose.
• You may request deletion of your account and associated personal data at any time.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Request deletion of your data
• Restrict or object to certain processing
• Withdraw consent at any time
• Request data portability
• Lodge a complaint with your local data protection authority (for UK residents, the ICO)

To exercise these rights, contact us at sleepsatsapp@gmail.com.

8. Data Security

We implement reasonable technical and organisational measures to protect your information against unauthorised access, loss, or misuse. However, no system is completely secure, and we cannot guarantee absolute security.

9. International Transfers

Your data may be processed in countries outside of your own, including the United Kingdom, European Economic Area, and United States. Where required, we use appropriate safeguards such as Standard Contractual Clauses to protect transferred data.

10. Children’s Privacy

SleepSats is not intended for users under the age of 18. We do not knowingly collect data from children. If you believe a child has provided us with personal data, please contact us so we can remove it.

11. Health Data Specifics

• Health data is accessed only with your explicit permission through Apple HealthKit or Google Health Connect.
• Health data is never sold, used for advertising, or shared with third parties for marketing.
• Health data is used solely to calculate rewards and provide the core functionality of SleepSats.

12. Third-Party Links

SleepSats may link to third-party websites or services. We are not responsible for their privacy practices. Please review their privacy policies before providing personal data.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted here with an updated “Last Updated” date. Your continued use of the Service after changes take effect constitutes acceptance of the revised policy.

14. Contact

For privacy questions or requests, contact us at: sleepsatsapp@gmail.com