Privacy Policy

Your privacy matters. This policy explains what personal data Ommode collects, how it is used, where it is stored, and what rights you have. We have written it in plain language on purpose.

1. Who Is Responsible for Your Data

The data controller for all personal data collected through Ommode is:

Dr. Kukel is personally responsible for the collection, storage, and processing of your data in accordance with Swiss data protection law (nFADP, in force since September 2023).

2. What Data We Collect

We collect only the data necessary to run the sleep programme.

Account data:

• First name, last name
• Email address
• Age and gender
• Country of residence
• Password (stored in encrypted form — we never see it in plain text)

Health and lifestyle data (from the onboarding questionnaire):

• Sleep satisfaction and patterns
• Physical symptoms that may affect sleep (pain, breathing, etc.)
• Daytime energy and alertness levels
• Stress and emotional wellbeing indicators
• Lifestyle factors (exercise, diet, work schedule)
• Employment status

Sleep diary data (logged daily during the 14-day cycle):

• Bedtime and wake time
• Estimated sleep duration
• Number of night wakings
• Nap information
• Daily sleep quality and alertness ratings

Usage data:

• Programme progress (days completed, group assignment)
• Recommendations marked as complete or saved
• Podcast listening progress
• Habit tracking logs

We do not collect device identifiers, IP addresses beyond what is technically necessary for the connection, or any data not listed above.

3. Why We Collect This Data (Legal Basis)

We collect and process your data for the following purposes:

• To run the sleep programme — delivering the 14-day tracking cycle, calculating your sleep profile, and providing personalised content.
  Legal basis: your explicit consent given at registration.
• To improve the programme — analysing anonymised, aggregated data to validate and refine the methodology.
  Legal basis: legitimate research interest, with anonymisation.
• To communicate with you — sending programme reminders and updates.
  Legal basis: your explicit consent, which you can withdraw at any time.

The health and lifestyle information you provide (section 2) constitutes sensitive personal data under Swiss law. We collect it only with your explicit, informed consent, given at the point of account creation.

4. Where Your Data Is Stored

All data is stored exclusively in Switzerland on a dedicated server under the direct control of the programme operator. Your data never leaves Switzerland. It is not processed, transferred, or accessible on servers located in other countries.

All communications between your device and our servers are encrypted using HTTPS (TLS). Your password is encrypted using industry-standard hashing and is never stored or visible in plain text.

Our infrastructure runs on renewable energy in certified green data centres in Switzerland.

5. Who Has Access to Your Data

Only Dr. Tatiana Kukel has access to your personal data.

We do not:

• Sell your data to anyone
• Share your data with third parties
• Use your data for advertising or profiling
• Transfer your data outside Switzerland
• Use your data for any purpose other than running and improving this sleep programme

Email communications (reminders, programme updates) are sent via our own infrastructure hosted in Switzerland. No third-party email service provider processes your data.

6. How Long We Keep Your Data

Your data is kept for the duration of your active participation in the programme, plus a maximum of 30 days after account deletion to allow for backup cleanup.

If the beta test programme ends, all participant data will be deleted within 60 days. You will be notified by email before deletion occurs.

Anonymised, aggregated data (with no link to any individual) may be retained for research purposes after your data is deleted.

7. Your Rights

Under Swiss data protection law (nFADP), you have the following rights:

• Right to access — You can request a copy of all personal data we hold about you.
• Right to correction — You can ask us to correct inaccurate data.
• Right to deletion — You can request that all your personal data be permanently deleted. We will action this within 30 days.
• Right to withdraw consent — You can withdraw your consent to data processing at any time. This does not affect the lawfulness of processing carried out before withdrawal. Withdrawing consent means we can no longer provide the programme to you.
• Right to data portability — You can request your data in a structured, machine-readable format.

To exercise any of these rights, contact:

tania.kukel@ommode.com

Subject line: "Data rights request — [your name]"

We will respond within 30 days.

8. Cookies and Tracking

Ommode uses only technically necessary session cookies required for authentication (keeping you logged in). We do not use:

• Analytics cookies
• Advertising cookies
• Third-party tracking scripts
• Any form of behavioural tracking

9. Children

Ommode is not intended for anyone under the age of 18. We do not knowingly collect data from minors. If you believe a minor has registered, contact us and we will delete the account immediately.

10. Changes to This Policy

If we make significant changes to this privacy policy, we will notify you by email at least 14 days before the changes take effect. The date at the top of this page always reflects the most recent version.

11. Questions and Contact

For any privacy-related questions, requests, or concerns:

We are committed to responding within 30 days.