Health Data

Consumer Health Data Privacy Policy

Last Updated: August 12, 2025.

This Consumer Health Data Privacy Policy (“Health Privacy Policy”) supplements the information contained in our Privacy Policy and describes our practices for “Consumer Health Data” as such term is defined by applicable laws, including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, as each are amended and as and when they become effective including any regulations thereunder (“U.S. Health Privacy Laws”). This Health Privacy Policy is only applicable to residents of states with U.S. Health Privacy Laws.

“Consumer Health Data” is broadly defined to mean personal information that is linked or can be reasonably linked to a consumer and that identifies past, present or future physical or mental health status. Consumer Health Data includes information about medical conditions as well as non-medical information, such as information about use of non-prescription medication or use of health-related products, for example. Consumer Health Data does not include any information that is exempt from or outside of the scope of U.S. Health Privacy Laws, including information pertaining to individuals with whom we have an employment relationship and information subject to the Health Insurance Portability and Accountability Act (“HIPAA”).

If we make any material updates to this Health Privacy Policy, we will notify you as required by U.S. Health Privacy Laws, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Health Privacy Policy and its effective date. We reserve the right to amend this Health Privacy Policy at our discretion and at any time.

Categories of Consumer Health Data that We Collect. Ozlo collects the following categories of Consumer Health Data:

  • Bodily functions, vital signs, symptoms or similar health measurements. This includes, for example, information such as respiration rate and movement collected when you use our products.
  • Social, psychological, behavioral, and medical interventions, health-related surgeries or procedures, diagnoses, health conditions, treatments and medication use, should you voluntarily provide such information to us through our mobile app, through connections with third-party services such as Apple Health or Google Fit, or otherwise.
  • Health-related data derived or inferred from the above or from non-health information, including information and insights regarding your sleep hygiene and quality.

Purposes for Collecting Consumer Health Data and How We Use It. We may use your Consumer Health Data for the following Processing Purposes:

  • Products/Services. To provide you with our products and services, including our sleep tracking device and related app, and to fulfill your requests.
  • Preference Management, such as helping you manage your app preferences.
  • System administration and technology management, including troubleshooting and optimizing our applications and devices and for purposes of preserving the security and integrity of our systems and services.
  • Legal/Compliance, including risk management, audit, investigations, reporting and other legal and compliance reasons.
  • Research/Development. To engage in research and development, including to improve our services and our business.
  • For other purposes with your consent.

Disclosures of Consumer Health Data. We do not sell your Consumer Health Data.

We may disclose the categories of Consumer Health Data described above in the following circumstances:

  • We may disclose Consumer Health Data to our service providers who assist us in providing products and services to you. These service providers may only use the data as permitted by our contracts with them.
  • We may also disclose Consumer Health Data (i) as required by law or legal process, (ii) if needed to protect your vital interests, such as in the event of a medical emergency, (iii) to an acquiring organization if we are involved in or contemplating a sale or a transfer of our business or all or some of its assets, (iv) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (v) as needed to preserve the integrity or security of our systems, (vi) to investigate, report, or prosecute those responsible for any action that is illegal under applicable law, and/or (vii) to payment processors as needed to complete your transactions.
  • We may also disclose Consumer Health Data with your consent or at your request.

Your Privacy Rights. Residents of states with U.S. Health Privacy Laws have some or all of the following rights. These rights are not absolute. We may decline your request in certain cases as permitted by law.

  • The right to know if we are collecting, using or disclosing your Consumer Health Data and to access that Consumer Health Data, including receiving a list of the entities and affiliates with whom we have shared or sold your Consumer Health Data.
  • The right to request that we delete your Consumer Health Data.
  • If we are processing your Consumer Health Data with your consent, the right to withdraw that consent.

We will not discriminate against you for exercising any of your rights.

To exercise these rights, please visit https://ozlosleep.com/pages/privacy-choices or email us at support@ozlosleep.com. We will authenticate your request and process it as required by law. Please allow up to 45 days for a response. If we deny your request, you may appeal that denial by following the instructions in the denial notice or clicking here. If your appeal is unsuccessful, you can file a complaint with the relevant government body in your state, including:

Please contact us using the contact information in our Privacy Policy with any questions or concerns you may have about your Consumer Health Data privacy or this Health Privacy Policy.