Privacy Notice

Last reviewed: 15th May 2025

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This privacy notice describes how we will collect, use, share and otherwise process your personal data in connection with your use of this website and our services, including any data you may provide when you purchase services from us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

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This website is not intended for children and we do not knowingly collect data relating to children.

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1. Important information and who we are

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Bluesleep UK Limited is the controller and is responsible for your personal data (Bluesleep, we, us or our in this notice). If you have any questions about this privacy notice, please contact us using the information set out in the contact details section.

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2. The types of personal data we collect about you

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Personal data means any information that can be used to identify directly or indirectly a specific individual.

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We may collect, use, store and transfer different kinds of personal data about you. What information we collect will depend on which of our services you use. The information we may typically collect is as follows:

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For our customers

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Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, age and gender.
Contact Data includes billing address, home address, email address and telephone numbers.
Financial Data includes bank account and payment card details, insurance policy details where applicable.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your purchases or orders made by you, your interests, preferences including marketing and communication preferences, feedback and survey responses.
Wellbeing Data includes any information you provide to us, or consent to being shared with us, about your wellbeing, including the information provided by you in the Bluesleep Sleep Screener form and including any details about your background and medical history, details of any treatments or medication taken, your Body Mass Index (BMI), neck circumference, details of your sleep quality symptoms, sleep test results, details of your referral to a medical service provider.

For website users (including customers that use our website):

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Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website, including cookies.
Usage Data includes information about how you interact with and use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and any third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

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3. How is your personal data collected?

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We use different methods to collect data from and about you including through:

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Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase our services, or register your interest for our services;
- complete our Sleep Screener online form;
- book one of our online appointments or register to receive communications;
- contact us via telephone or email. If you do, we may keep a record of that correspondence;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data is collected from the following types of company:
  - analytics providers;
  - advertising networks; and
  - search information providers.
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
- Third party provider of medical sleep tests. The results of the medical sleep test should only be shared with us where you have given your consent to the third party provider.
- Medical services providers we have referred you to, including registered health care professionals such as sleep doctors and sleep dentists. These medical services providers are independent to us and act as separate controllers of the personal data. Where you have given your consent we may receive personal data about you, including Wellbeing Data, from these providers.
- Insurance providers where you have commenced a claim and you require treatment with us. This will normally be in the form of a referral and may consist of basic personal and contact details as well as the type of treatment required.

4. How we use your personal data

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Legal basis

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The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

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Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you are not an existing customer and subscribe to an email newsletter.

There are special rules about how we can use any data concerning health. For data concerning health, in addition to the lawful bases outlined above, we must also comply with an Article 9 UK GDPR condition. In the table below we have set out the conditions that we rely upon when processing any data concerning health, for example any details of medication taken by you.

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Purposes for which we will use your personal data

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We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, the categories of personal data we may typically use for each processing activity, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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Type of personal data	Purpose for processing	Legal basis for processing	Article 9 UK GDPR Condition
Identity Data Contact Data Wellbeing Data	To register you as a new customer	Performance of a contract with you	Article 9(2)(h) – necessary for the provision of health care or the management of health systems and services pursuant to contract with a health professional
Identity Data Contact Data Transaction Data Financial Data Profile Data Wellbeing Data	To process and deliver services to you including: (a) Manage payments, fees and charges, and liaise with insurer as applicable. Much of this processing is completed by our payment partner, currently Stripe. (b) Collect and recover money owed to us	Performance of a contract with you Necessary for our legitimate interests (to deliver our services to customers; and recover debts due to us)	Article 9(2)(h) – necessary for the provision of health care or the management of health systems and services pursuant to contract with a health professional
Identity Data Contact Data Profile Data Marketing and Communications Data Wellbeing Data	To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated, manage our relationship with you, improve our services and keep people up to date about our services)	Article 9(2)(a) with your explicit consent
Identity Data Contact Data Financial Data Transaction Data Profile Data Marketing and Communications Data	To enable our suppliers to perform business activities on our behalf (e.g. credit card processing, customer support services or market research)	Necessary for our legitimate interests (to provide customers with services and to enable us to manage our operations)	Not applicable.
Identity Data Contact Data Technical Data	To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation	Not applicable.
Identity Data Contact Data Profile Data Usage Data Technical Data Marketing and Communications Data	To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)	Not applicable.
Technical Data Usage Data	To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)	Not applicable.
Identity Data Contact Data Transaction Data Profile Data Technical Data Usage Data Marketing and Communications Data	To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data (or, where you are a prospective customer, you have told us you would like our marketing materials).	Necessary for our legitimate interests (to carry out direct marketing to our customers or those who have expressed an interest in our services, develop our products/services and grow our business) For other individuals, your prior consent to receiving direct marketing communications	Not applicable.
Identity Data Contact Data Transaction Data Profile Data Technical Data Usage Data Marketing and Communications Data Wellbeing Data	To comply with legal or regulatory requirements, which may be set out in law or a court order To assist regulators or comply with their guidance, including cooperating with regulators. To exercise our rights or defend legal claims	Necessary for our legitimate interests (to enforce our legal rights; to co-operate with the regulator and comply with our contractual and other obligations) Necessary to comply with a legal obligation	Article 9(2)(g) - substantial public interest, including complying with or assisting others to comply with a regulatory requirement including protecting the public against malpractice or other seriously improper conduct Article 9(2)(f) – necessary for the establishment, exercise or defence of legal claims

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Direct marketing

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During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Bluesleep via email, telephone or post.

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We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

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Third-party marketing

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We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

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Opting out of marketing

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You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the contact details below.

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If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, updates to our Terms and Conditions, or checking that your contact details are correct.

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Cookies

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For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

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Disclosures of your personal data

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We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

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external third parties including our service providers:
- that provide us with marketing, customer service, IT and other administrative or technical services;
- that provide us with payment processing services including Stripe;
- test partners such as our third party provider of medical sleep tests;
- where we make referrals to third parties which may offer you products, such as device distributors;
- that assist with the management and fulfilment of deliveries, including couriers.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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medical services providers we have referred you to, including registered health care professionals such as sleep doctors and sleep dentists. These medical services providers are independent to us and act as separate controllers of the personal data.
your medical insurer, to provide information about your treatment and its cost, only if they are paying for all or part of your treatment with us.
our professional advisors.

courts, tribunals, law enforcement authorities and regulators to comply with our legal obligations or to support them in carrying out their duties.

third parties with which we may negotiate or choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

6. International transfers

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In order to provide our help centre services for customers your personal data is accessed outside of the UK. This will involve transferring your personal data outside the UK to the Philippines. Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, such as the Philippines, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

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We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement.

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7. Data security

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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8. Data retention

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How long will you use my personal data for?

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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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9. Your legal rights

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You have a number of rights under data protection laws in relation to your personal data.

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You have the right to:

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Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us – see Contact details in paragraph 10. For more information on any of the rights set out above, please refer to the ICO guidance (available here).

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No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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Time limit to respond

We try to respond to all valid requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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10. Contact details

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If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

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Email address: admin@bluesleep.uk
Postal address: UNTIL, 1 Orchard Street, London, W1H 6HJ
Telephone number: 0333 090 4252

11. Complaints

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You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues www.ico.org.uk at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

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We would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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12. Changes to the privacy policy and your duty to inform us of changes

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We keep our privacy policy under regular review and may update this privacy notice to reflect changes to our information practices. In that case, the “last updated” at the top of this page will also change. We encourage you to periodically review this page for the latest information on our privacy practices.

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It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

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13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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