Consumer Health Data Privacy Policy

Last updated and effective date: July 11, 2026

This Consumer Health Data Privacy Policy (“Health Data Policy”) describes how Somnus Technologies, Inc. (“Somnus,” “we,” “us,” or “our”) processes regulated health information and consumer health data (collectively “Consumer Health Data,”) as those terms are defined under applicable state privacy law, about consumers who reside in the states of Nevada, New York, Washington, and any other applicable U.S. jurisdiction in connection with our proprietary mobile application (the “Digital Platform”) as well as our website, https://somnustech.ai (the “Website”). Please carefully read this Health Data Policy as it contains important information concerning your Consumer Health Data and how we use it.

This Health Data Policy relates only to Consumer Health Data. This Health Data Policy does not describe how we process your personal information. For more information about our information practices with respect to personal information, please refer to our Privacy Policy.

The Information We Process

Our use, collection, and disclosure activities may differ depending on your relationship with us. We provide categories of these activities below, some or all of which may apply to Consumer Health Data about you.

We may collect the following categories of Consumer Health Data:

Bodily functions, vital signs, and measurements collected during sleep, such as breathing sounds processed on your device, breathing rate, snoring sounds, heart rate, heart rate variability, blood oxygen level, and sleep stages and duration;
Any inferences based on the above categories or derived or extrapolated from non-health information that identify your past, present, or future physical or mental status.

We may collect Consumer Health Data from the following categories of sources:

Directly from you when you share it with us through the Digital Platform (such as when you log or upload your sleep data); and
Through our third-party service providers that support the Digital Platform. Please note that we do not “sell” Consumer Health Data as that term is defined under applicable law.

We may collect, process, and disclose Consumer Health Data for the following business purposes:

To provide, operate, maintain, and protect our Digital Platform, including determining your eligibility to use the Digital Platform;
To analyze and improve our Digital Platform, including developing new products or services;
To communicate with you, respond to your inquiries, and send you information by email, postal mail, telephone, text message, notifications, or other means, including promotional content about our products and services;
To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences in our Digital Platform;
To protect the security or integrity of the Digital Platform, including to perform security analyses to verify that the Digital Platform is working properly;
To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, and monitor and enforce compliance with our contracts, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable; and
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our customers is among the assets transferred.

We may disclose some or all of the above categories of Consumer Health Data for the purposes described above with the following third parties and affiliates:

As legally required in relevant legal proceedings and otherwise to the extent required or explicitly authorized by applicable law, including laws requiring the reporting of certain circumstances;
Service providers that support the Digital Platform and similar advisors (such as attorneys, consultants, or accountants);
Third parties within the context of a merger or similar business transaction; and
Other third parties at your express direction.

De-Identified Data. We may process de-identified data derived from Consumer Health Data. Where we do, we take reasonable measures to ensure the data cannot be associated with any consumer or device, we publicly commit to process such data only in a de-identified fashion and not to attempt to re-identify it, and we contractually obligate any recipient of such data to comply with these same requirements.

Your Privacy Rights

Depending on your place of residency, you may have some or all of the following rights regarding your Consumer Health Data, subject to applicable law and certain exceptions:

Right to Confirm and Access: If you ask us, we will confirm whether we are collecting, sharing, or selling your Consumer Health Data. At your request, we will provide a list of all third parties and affiliates with whom we have shared or sold your Consumer Health Data. You may request that we provide you with a copy of the Consumer Health Data that we maintain about you.
Right to Correct: If your Consumer Health Data that we maintain is inaccurate and you would like us to correct it, you may request that we make changes to it.
Right to Withdraw Consent: Where we have relied on your consent or authorization for certain processing of your Consumer Health Data, you may withdraw that consent or authorization at any time.
Right to Delete: You may request that we delete the Consumer Health Data we maintain about you.
Right to Appeal: If we deny your request to exercise any of the above rights, you may request to appeal this decision.

To exercise any of the above rights, you or your authorized agent may do so by following the instructions in “Contact Us” below. To process your request, we may ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as your most recent interaction with us, if applicable.

Updates to this Health Data Policy

We may update this Health Data Policy from time to time and notify you in accordance with law, which may include email or other notice posted to the Digital Platform or Website. Any changes to this Health Data Policy will become effective when we notify you of the changes. Your use of the Platform or Website following any such updates will constitute your acceptance of such updates.

Contact Us

For questions about our Health Data Policy, to make choices about receiving promotional communications, or to request to exercise a right described in this Health Data Policy, you can contact us through any of the methods listed below:

Mail: Somnus Technologies, Inc.
c/o Godfrey & Kahn, S.C.
833 East Michigan Street, Suite 1800
Milwaukee, WI 53202
Phone: 920.284.9099
Email: [email protected]