Privacy policy

Last updated: [Datum der Veröffentlichung] · applies to the "Dormo" app (iOS, Android, web) and this website

This is a convenience translation. The German version is legally binding.

Sleep, stress and habits are very personal. That's why we only collect what each feature needs, process audio exclusively on your device, show no ads in the app and use analytics and marketing services only with your consent. Here you'll find exactly which data we process and why.

1. Controller

[Vor- und Nachname bzw. Firma]
[Straße und Hausnummer], [PLZ Ort], Germany
Email: [datenschutz@deine-domain.de]

We have not appointed a data protection officer as we are not legally required to. For any privacy questions, contact us at the address above.

2. Key points

• Audio recordings never leave your phone. Sound detection runs entirely on the device.
• No ads in the app, no selling of data. We only use analytics and marketing services (website and app) if you explicitly agree.
• Our database is in the EU (France).
• Health-related details (sleep, stress, diary) are only processed with your explicit consent, which you can withdraw at any time.
• You can delete your account at any time, right in the app or via this page.

3. This website, cookies & tracking

When you visit this website, our hosting provider Cloudflare (see section 12) processes technically necessary data: IP address, date and time, page visited, browser and operating system details and the referring page. This data is needed to deliver the website securely and fend off attacks (legal basis: Art. 6(1)(f) GDPR, legitimate interest in secure operation). It is not combined with other data.

Fonts are hosted on our own server. The library loads our content list directly from our database at Supabase (EU); no personal data is stored in the process. Section 9 explains how we count clicks on partner links.

Cookie consent

On your first visit we ask whether you allow analytics and marketing services. None of these services is loaded before you agree. "Necessary only" is just as easy as "Accept all". We store your choice in your browser's local storage (key dormo-consent-v1, with date); this is technically necessary (§ 25(2) TDDDG). You can change or withdraw your choice at any time via "Cookie settings" at the bottom of every page.

• Analytics: Google Analytics 4 (Google Ireland Ltd.): how the website is used (pages viewed, time on page, device type, approximate location without the full IP address). Cookies _ga, _ga_*, lifetime up to 2 years.
• Marketing: Meta Pixel (Meta Platforms Ireland Ltd.), TikTok Pixel (TikTok Technology Ltd., Ireland) and Google Ads: measuring whether our ads lead to sign-ups or purchases, and building audiences for advertising on these platforms. Cookies e.g. _fbp, _ttp, _gcl_au, lifetime 3 to 13 months. Events measured: page view, waitlist sign-up, start and completion of a gift card purchase.

The legal basis is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). For the Meta Pixel we are jointly responsible with Meta for collection and transmission (Art. 26 GDPR); Meta is responsible for further processing. These providers may transfer data to the USA (EU-US Data Privacy Framework or standard contractual clauses).

4. Using the app without an account

You can use Dormo without registering. So that your progress, favourites and mixes are still saved, the app creates an anonymous guest account with our database provider Supabase on first launch. A random identifier is generated, without name, email address or phone number. Language and time zone are also stored so that content and statistics are displayed correctly.

The legal basis is Art. 6(1)(b) GDPR (providing the app features you use).

5. User account & sign-in

If you create an account to use Dormo on several devices, we process your email address and, if you provide it, your display name. Sign-in works via a one-time code or link sent to your email address, "Sign in with Apple" or "Sign in with Google". From Apple or Google we only receive the data you share there (usually email address and name; with Apple optionally an anonymous relay address). We don't store a password.

Legal basis: Art. 6(1)(b) GDPR.

6. Content, progress & sound mixes

So that the app works and looks the same on all your devices, we store in your account:

• content you've listened to with date and duration (for history, streaks and statistics),
• favourites, course progress and daily goals,
• your saved sound mixes (sounds, volumes, left/right position),
• your settings (e.g. language, reminder time, goals, meditation experience).

Legal basis: Art. 6(1)(b) GDPR.

To improve our service we evaluate this data only in aggregated form (e.g. "how often was a piece of content played"). Individual users are not looked at (Art. 6(1)(f) GDPR).

7. Optional details about you

At the start, Dormo optionally asks for your age group, gender, satisfaction with your sleep, stress level and typical sleep problems. You can skip every question and change or delete your answers at any time under Profile → Settings → About me.

We use these details to recommend suitable content and evaluate them only in aggregated form to develop the app. As details about sleep and stress may be health data, we only process them on the basis of your explicit consent (Art. 6(1)(a), Art. 9(2)(a) GDPR). You can withdraw it at any time with effect for the future by removing the details in the app or writing to us.

8. Sleep tracking & sleep diary

Microphone and audio recordings

For sleep tracking, Dormo uses your device's microphone, only with your permission and only during a recording you've started. Recording and detection of sounds (e.g. snoring, talking, coughing) take place exclusively on your device using a detection model stored there. Not the whole night is saved, only a short clip of each detected sound (at most about 12 seconds) so you can listen back in the morning. These clips are never transmitted to us or third parties and are deleted automatically after three nights by default. You can delete them earlier at any time or turn saving off completely.

Figures from your nights

If you're signed in, we sync the results of a night, without audio, so you can see your history on all your devices: start and end, wake-up time, sleep duration, time to fall asleep, share of quiet phases, snoring minutes, number of detected events, sleep score and a rough timeline of the night in 5-minute segments.

Sleep diary

Entries in your sleep diary (mood, bed and wake-up time, factors such as caffeine, alcohol, exercise or stress, and optional dream notes) are also stored in your account so you get a weekly review and insights.

This data may be health data. We only process it with your explicit consent, which you give in the app before the first recording (Art. 6(1)(a), Art. 9(2)(a) GDPR). You can withdraw it at any time by deleting individual nights or entries or deleting your account. The lawfulness of processing carried out until then remains unaffected.

9. Subscriptions, gifts & partner programme

In-app purchases are handled by Apple (App Store) or Google (Google Play). We don't receive payment data. We only learn which subscription you have, whether it's active, whether a trial is running and when it ends. We use RevenueCat to manage subscriptions; this processes your app identifier, store receipts and subscription status.

Purchases on our website are handled by Stripe. Stripe processes your payment and billing data under its own responsibility; we receive subscription status, amount and a customer identifier, but no full card details.

Legal basis: Art. 6(1)(b) GDPR (performance of contract) and Art. 6(1)(c) GDPR (statutory retention obligations for payment records).

Gift subscriptions

If you buy a gift card on our website, we process your email address and, if provided, your name, the recipient's name and your personal message to create and display the gift card. Payment is handled by Stripe. When the gift card is redeemed, we store which account redeemed it. Legal basis: Art. 6(1)(b) GDPR.

Partner programme & referral links

Partner applications: If you apply via our "Become a partner" page, we process the details from the form (name, email, profile link, channels, audience, country, message) to review the application and run the partnership, including settling your commission and your payout details (Art. 6(1)(a) and (b) GDPR). We delete rejected applications after 6 months at the latest.

Referral links: If you open a partner's link (e.g. ?ref=CODE), we count the click for that partner, with page, time and referring domain, but without IP address, without cookies and without storing anything on your device. The code is only passed on via the links on the page (e.g. to the Play Store). If you download the app via such a link or enter a creator code, your account is assigned to the partner. If you then buy a subscription, the partner receives a commission; they do not learn who you are. The legal basis is our legitimate interest in settling accounts with our partners (Art. 6(1)(f) GDPR).

10. Audio, video & app updates

Meditations, stories and sounds are delivered via Cloudflare's network. This checks whether you're entitled to a piece of content and generates a time-limited download link. Cloudflare processes your IP address and technical access data.

We deliver bug fixes and small improvements directly into the app via Expo's "EAS Update" service. On launch, the app checks there for new versions; your IP address and technical details such as app version, operating system and update channel are transmitted, but no content or account data.

Legal basis: Art. 6(1)(b) GDPR and Art. 6(1)(f) GDPR (a secure, up-to-date and working app).

Analytics and marketing in the app

In the app, too, we ask for your consent before collecting usage statistics (e.g. "paywall opened", "programme started", stored in our own database, without an advertising ID) or measuring which ad brought you to Dormo. On iPhones the system additionally asks for permission to track across apps. You can change both at any time under Profile → Settings → Privacy. We send error reports (crash reports without content) to keep the service running even without consent (Art. 6(1)(f) GDPR). Legal basis for analytics and marketing: Art. 6(1)(a) GDPR, § 25(1) TDDDG.

11. Data that stays on your device

• sound clips from sleep tracking and the detection model,
• content downloaded for offline listening,
• reminders: they're scheduled directly on your device,
• the data for the home screen widget.

12. Service providers & transfers to third countries

We use carefully selected service providers who process data only on our instructions (processing on behalf under Art. 28 GDPR) or, in the case of app stores and payment providers, act under their own responsibility.

We'll provide a copy of the respective safeguards on request.

13. Retention

• Account data, progress, mixes, sleep figures, diary: until you delete them or your account.
• Anonymous guest accounts: until you delete them in the app.
• Audio recordings: on the device only, 3 nights by default.
• Payment and subscription receipts: up to 10 years due to statutory retention obligations (§ 147 AO, § 257 HGB), then deleted.
• Server logs of the website and media delivery: usually 30 days at most.
• Cookie choice: in your browser until you change it or clear your browser data.

14. Your rights

You have the right at any time to

• access your stored data (Art. 15 GDPR),
• rectification of inaccurate data (Art. 16 GDPR),
• erasure (Art. 17 GDPR), right in the app under Profile → Account → Delete account,
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• object to processing based on legitimate interests (Art. 21 GDPR),
• withdraw consent with effect for the future (Art. 7(3) GDPR).

Just email us at [datenschutz@deine-domain.de]. You can also lodge a complaint with a data protection supervisory authority, for example in your place of residence or the authority responsible for us: [Landesdatenschutzbehörde deines Bundeslandes].

15. Children & teenagers

Dormo is intended for people aged 16 and over. Younger people may only use the app with their parents' consent. A family plan may only be purchased by adults.

16. Security & changes to this policy

All connections are encrypted (TLS). Our database technically ensures that each person can only read their own data. Media are only delivered via short-lived, signed links. Only a few administrators bound to confidentiality have access to individual data, and only as far as needed for support or operations.

We update this privacy policy when the app or the law changes. We'll inform you about significant changes in the app.