Our Data Protection Policy
Apparent Group Limited ("we", "us" or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, SnoreCare ("the App").
Please read this Privacy Policy carefully. If you do not agree with the contents of this privacy policy, please do not access the App.
Data Controller
The data controller responsible for your personal data is:
Apparent Group Limited
PLATFORM 10-06, 38/F, HOLLYWOOD PLAZA
610 NATHAN ROAD, KL, Hong Kong
Contact Email: [email protected]
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your DEVICE.
A. Personal Information
Account Data:
Name, email address, and password when you register.
Social/Google Data:
If you sign in via Google or Apple, we collect your email and public profile information provided by those services.
B. Health and Biometric Data (Special Category Data)
To provide the core functionality of the App (snore detection, apnea risk assessment, and sleep tracking), we collect identified health data, including:
Audio Recordings:
Audio data recorded during sleep sessions to detect snoring patterns.
Sleep Data:
Snoring frequency, intensity, duration, and sleep quality scores.
Health Questionnaires:
Answers related to age, gender, height, weight, neck circumference, lifestyle factors (alcohol, smoking), medical conditions, and sleep patterns.
Chat Logs:
Information you share with our AI Coach and Risk Assessment features about your sleep, symptoms, and health.
C. Device and Usage Data
Device Information:
Device model, operating system version, unique device identifiers.
Usage Data:
App features used, time spent, interaction with notifications, and error logs.
How We Use Your Information
We use the collected data for the following purposes:
Service Provision:
To record sleep sessions, analyze snoring, provide apnea risk assessment, and deliver personalized coaching.
AI Analysis:
To process your inputs (audio and text) through our AI and Machine Learning models (including third-party LLM providers) to generate insights and recommendations.
Account Management:
To manage your registration, subscription, and profile.
Improvement:
To train and improve our machine learning models and app functionality.
Communication:
To send you updates, security alerts, and support messages.
Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA), our legal basis for collecting and using your personal data depends on the specific context.
Consent:
We ask for your explicit consent to process health data if required for marketing communications. You may withdraw this consent at any time.
Contract:
We process your data to fulfill our contract with you.
Legitimate Interests:
We process data for security, fraud prevention, and app improvement, provided these interests are not overridden by your data protection rights.
Data Sharing & Disclosure
We do not sell your personal data. We may share your information with:
Service Providers:
Third-party vendors who perform services on our behalf, such as:
Firebase (Google): For authentication, database storage, and file storage.
Adapty, Apple App Store and Google Play: For managing subscriptions and processing payments.
AI Providers (e.g., OpenAI): To process text inputs for the AI Coach and Risk Assessment features.
Legal Compliance:
If required by law, court order, or government regulation.
International Data Transfers
Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.
Specifically, we, a Hong Kong-based company, your data may be processed in Hong Kong. Furthermore, our vendor's providers (like Firebase) may process data in the United States or other global locations. We will take appropriate safeguards where applicable.
Data Retention
We retain your personal data only for so long as is necessary for the purposes set out in this Privacy Policy.
Audio Data:
Retained according to your settings or until you delete specific sessions.
Account Data:
Retained as long as your account is active. If you delete your account, we will delete your personal data within a reasonable timeframe, subject to legal retention obligations.
Your Data Protection Rights (GDPR)
If you are in the EEA, you have the following rights:
Right to Access:
Request copies of your personal data.
Right to Rectification:
Request correction of inaccurate information.
Right to Erasure:
Request deletion of your personal data ('Right to be forgotten').
Right to Restrict Processing:
Request restriction of how we use your data.
Right to Data Portability:
Request transfer of your data to another organization.
Right to Object:
Object to our processing of your data.
To exercise these rights, please contact us at: [email protected]
Data Security
We implement appropriate technical and organizational security measures to protect your data. This includes encryption of data in transit and at rest. However, no electronic transmission or storage method is 100% secure, and we cannot guarantee absolute security.
Children's Privacy
The App is not intended for use by children under the age of 18. We do not knowingly collect personal data from children.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Apparent Group Limited
PLATFORM 10-06, 38/F, HOLLYWOOD PLAZA
610 NATHAN ROAD, KL, Hong Kong
Email: [email protected]