Privacy Policy

Effective Date: June 4, 2025

My Custom Sleep Journey, LLC ("we," "our," or "us") is a California-based wellness company dedicated to providing comprehensive, science-backed sleep and lifestyle optimization programs for night-shift medical professionals. This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you visit our website at https://mycustomsleepjourney.com (the "Website") and use our web application at app.mycustomsleepjourney.com (the "Web App"), collectively referred to as the "Services."

We are committed to protecting your privacy and handling your personal information with care and transparency.

1. Information We Collect

We collect various types of information from and about you, including:

1.1. Information You Provide Directly to Us

Contact and Identification Information: Your name, email address, phone number, mailing address, and other contact details when you register for an account, inquire about our programs, or communicate with us.

Health and Biometric Data (Highly Sensitive): This is central to our services. We collect detailed information related to your sleep patterns, recovery metrics, stress levels, and overall well-being. This includes:

- Data on your lifestyle upgrades, Apollo Neuro and other recovery device usage, and circadian-aligned routines.

- Information from daily mindset reinforcement activities (e.g., hypnosis, breathwork).

- Responses to questionnaires, assessments, and progress tracking within the Web App.

- Information shared during 1-on-1 performance coaching sessions.

Payment Information: While we use a lending partner for financing, we may collect certain payment-related information (e.g., confirmation of payment status, transaction details) to manage your enrollment. Full payment card details are typically processed directly by our secure third-party lending partner, and we do not store sensitive financial information on our servers.

Communications: Records of your correspondence with us, including emails, chat messages, and phone calls.

1.2. Information We Collect Automatically

When you access or use our Services, we may automatically collect certain information about your device and usage:

Usage Data: Information about how you interact with our Website and Web App, such as pages visited, features used, time spent on pages, and referring URLs.

Device Information: Your IP address, browser type, operating system, device identifiers, and mobile network information.

Cookies and Tracking Technologies: We use cookies and similar tracking technologies (e.g., web beacons, pixels) to collect information about your browsing activities, remember your preferences, analyze trends, and administer the Services. You can control cookie preferences through your browser settings.

1.3. Information from Third Parties

We may receive information about you from third-party sources, including:

Wearable Device Providers: Data from your Oura Ring is integrated with our Web App to provide personalized coaching. This integration requires your explicit consent.

Lending Partners: Information related to your financing application and payment status.

Analytics Providers: Data from analytics services (e.g., Google Analytics) that help us understand user behavior and improve our Services.

2. Cookies Policy

This section explains how My Custom Sleep Journey LLC uses cookies and similar tracking technologies on our Website and Web App.

2.1. What are Cookies?

Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work more efficiently, as well as to provide information to the owners of the site. Cookies can be "session cookies" (which are temporary and deleted when you close your browser) or "persistent cookies" (which remain on your device for a set period or until you delete them).

2.2. How We Use Cookies

We use cookies for various purposes, including:

Strictly Necessary Cookies: These cookies are essential for the operation of our Services. They enable core functionalities like security, network management, and accessibility. Without these cookies, the Services may not function properly.

Performance and Analytics Cookies: These cookies collect information about how you use our Services (e.g., which pages you visit most often, if you encounter error messages). This helps us understand and improve the performance of our Services and enhance your user experience. We use third-party analytics services like Google Analytics for this purpose.

Functionality Cookies: These cookies allow our Services to remember choices you make (e.g., your username, language, or region) and provide enhanced, more personalized features. They can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize.

Advertising and Targeting Cookies: These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. These cookies may be placed by us or by third-party advertising networks with our permission.

2.3. Third-Party Cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Services, deliver advertisements on and through the Services, and so on. These third parties may include analytics providers, advertising networks, and social media platforms.

2.4. Your Choices Regarding Cookies

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by:

Browser Settings: Most web browsers allow you to control cookies through their settings. You can usually find these settings in the "options" or "preferences" menu of your browser. Please note that if you choose to block or delete cookies, this may impact your ability to use certain features of our Services.

Opt-Out Tools: Some third-party advertising networks offer tools to opt out of their targeted advertising. For more information on how to do this, you can visit the Network Advertising Initiative (NAI) opt-out page at http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance (DAA) opt-out page at http://www.aboutads.info/choices/.

Specific Service Settings: For certain third-party services like Google Analytics, you may be able to opt out directly through their specific opt-out mechanisms.

For more information about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

3. How We Use Your Information

We use the information we collect for various purposes, primarily to provide, maintain, and improve our Services and to communicate with you:

To Provide and Personalize Services: To deliver your customized sleep and lifestyle optimization program, including 1-on-1 coaching, tailored protocols, and access to the Web App. This includes using your health and biometric data to personalize your journey and track your progress.

To Track Progress and Outcomes: To benchmark, verify, and demonstrate outcomes throughout your program using your biometric data and qualitative assessments. This data is essential for assessing program effectiveness and for the terms of our refund policy.

To Improve and Develop Services: We collect and utilize aggregated and anonymized (randomized) datasets derived from client biometric and program data to analyze trends, conduct research, and continuously improve the effectiveness, features, and long-term growth of our Services. This data helps us to maximize the effectiveness of our programs for all clients.

For AI Integration: As part of our commitment to accelerating personalization and client outcomes, we intend to integrate ethical data-driven AI into our services. Randomized and anonymized datasets, as described above, will be utilized by our AI systems to further enhance program effectiveness and scalability, starting from month two of our AI implementation.

To Communicate with You: To send you program updates, coaching session reminders, progress reports, administrative messages, and respond to your inquiries.

To Process Payments: To manage your enrollment and track payment status, working with our lending partner as necessary.

For Internal Analytics and Service Improvement: To understand how our Services are used, analyze trends, troubleshoot technical issues, and improve the functionality, content, and effectiveness of our programs.

For Marketing and Promotion: To send you marketing communications about our Services, special offers, or other information we think may be of interest to you, where you have provided consent or where permitted by law. You can opt-out of marketing communications at any time.

For Legal Compliance and Protection: To comply with applicable laws, regulations, legal processes, or governmental requests; to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and to detect, prevent, or investigate fraud or other illegal activities.

4. How We Share Your Information

We may share your information with third parties in the following circumstances:

With Our Team and Coaches: Your personal and health data will be shared with our qualified performance coaches and internal team members who are directly involved in delivering and supporting your program. All personnel are bound by strict confidentiality obligations.

With Third-Party Service Providers: We engage trusted third-party companies and individuals to perform services on our behalf, such as:

- Data Hosting and Storage: For secure storage of your information.

- Analytics Services: To analyze Service usage and performance.

- Payment Processors/Lending Partners: To facilitate payment transactions and financing options.

- Communication Tools: For email, messaging, and video conferencing.

- Wearable Device Integration: To connect with and receive data from your Oura Ring (with your explicit consent). We ensure that any third-party services utilized for our Web App and data handling meet stringent security standards, including practices aligned with HIPAA compliance, to protect your sensitive information. These providers have access to your personal information only to perform their functions and are obligated not to disclose or use it for any other purpose.

For Legal Reasons: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of My Custom Sleep Journey LLC, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

Aggregated or Anonymized Data: We may share aggregated or anonymized data that cannot reasonably be used to identify you, for purposes such as research, analytics, marketing, or improving our services. For example, we may share de-identified sleep improvement statistics with clinical and strategic experts or for academic purposes.

5. Data Security

We implement robust technical, administrative, and physical safeguards designed to protect your personal information, especially your sensitive health and biometric data, from unauthorized access, use, alteration, and disclosure. These measures include:

Encryption: Using encryption for data in transit and at rest where appropriate.

Access Controls: Limiting access to your personal information to only those employees, contractors, and agents who need to know that information to operate, develop, or improve our Services.

Regular Security Audits: Conducting periodic security assessments and updates to our systems.

Confidentiality Agreements: Ensuring all personnel handling your data are bound by strict confidentiality obligations.

HIPAA-Aligned Practices: We strive to maintain security practices that align with HIPAA compliance standards for handling sensitive health information, ensuring a high level of data protection within our Web App and associated services.

Despite these measures, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the duration of your program, to provide ongoing support, to comply with our legal obligations (e.g., tax, accounting, or audit requirements), resolve disputes, and enforce our agreements. Your health and biometric data will be retained for a period consistent with the long-term effectiveness and potential future enhancements of our programs, and for the purposes of historical progress tracking unless you request its deletion, subject to legal limitations.

7. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information:

Right to Access: You have the right to request a copy of the personal information we hold about you.

Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

Right to Erasure ("Right to Be Forgotten"): You have the right to request the deletion of your personal information under certain circumstances. Please note that we may need to retain certain information for legal or legitimate business purposes.

Right to Data Portability: You have the right to request that we transfer your personal information to another organization or directly to you, where technically feasible.

Right to Object to Processing: You have the right to object to the processing of your personal information under certain conditions.

Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

California Privacy Rights (for California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding your personal information, including:

Right to Know: The right to request that we disclose what personal information we collect, use, disclose, and sell/share.

Right to Delete: The right to request the deletion of personal information that we have collected from you, subject to certain exceptions.

Right to Correct: The right to request the correction of inaccurate personal information.

Right to Opt-Out of Sale/Sharing: My Custom Sleep Journey LLC does not sell or share your personal information for cross-context behavioral advertising.

Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit the use and disclosure of your sensitive personal information (such as health and biometric data) to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer.

To exercise any of these rights, please contact us using the "Contact Us" section below. We will respond to your request in accordance with applicable law. We will not discriminate against you for exercising any of your privacy rights.

8. Third-Party Links

Our Services may contain links to third-party websites or services that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies of any third-party sites you visit.

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verifiable parental consent, we will take steps to remove that information from our servers. If you believe that a child under 18 has provided us with personal information, please contact us.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of the Services after any changes indicates your acceptance of the updated Privacy Policy.

11. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

Email: [email protected]