EMPOWERING ESCAPES - THE BEST MOBILE APP FOR YOUR SLEEPLESS NIGHTS!

Privacy Policy – Empowering Escapes

Effective date: 1^st May 2024

1. Introduction

Welcome to the Empowering Escapes Sleep App ("App"), brought to you by KDB Media Corp., doing business as Empowering Escapes ("we," "us," or "our"). The App is an extension of our Empowering Escapes YouTube channel and is available on various platforms, including the Apple App Store, Google Play Store, and Amazon App Store. This Privacy Policy outlines how we collect, use, share, and protect your personal information when you use our App and related services. This policy applies wherever it is posted and ensures our commitment to protecting your privacy.

2. Definitions

• "Personal Information": Any information that identifies, relates to, describes, or could reasonably be associated with you as an individual. This includes, but is not limited to, your name, email address, usage data, device identifiers, and sleep tracking information.
• "Processing": Any operation performed on Personal Information, whether automated or manual, such as collection, use, storage, disclosure, and disposal.
• "Controller": The entity that determines the purposes and means of Processing Personal Information (KDB Media Corp. in this case).
• "Processor": An entity that Processes Personal Information on behalf of the Controller.

3. Types of Information Collected

Depending on the platform you use to access the App (Apple App Store, Google Play Store, Amazon App Store), we may collect data specific to each platform, such as purchase history and app download data, which is used to facilitate seamless integration and operational functionality on these platforms.

We may collect the following types of Personal Information:

• Account Data:
• Email address (if you choose to create an account)
• Username (optional)
• Usage Data:
• App interactions (features used, pages viewed, etc.)
• Sleep tracker data (if you enable this feature)
• Device Data:
• Device type and operating system
• IP address (for general location information)
• Content Data:
• Sleep sounds you download (indicates preferences)

4. Purposes of Data Collection

We collect and Process your Personal Information for the following purposes:

• Providing Core Functionality:
• Offering the sleep sound library, sleep tracking features, and sleep challenges.
• Managing your optional user account.
• Service Improvement:
• Understanding how users interact with the App to enhance features and develop new ones.
• Personalization:
• Recommending content and tailoring your in-app experience based on your usage patterns (if you consent).
• Troubleshooting and Security:
• Detecting and resolving technical errors.
• Preventing fraud and maintaining the security of the App.

5. Legal Basis for Processing

• Consent: We may Process some of your Personal Information based on your freely given, specific, informed, and unambiguous consent. You can withdraw consent at any time.
• Contract: We need to Process Personal Information to provide you with our services and fulfill our contractual obligations.
• Legitimate Interest: We may Process certain information for legitimate business interests such as non-invasive analytics and ensuring the security of the App, provided these interests don't outweigh your fundamental rights and freedoms.

6. Platform Privacy Policies

When you use the Empowering Escapes Sleep App through platforms such as the Apple App Store, Google Play Store, and Amazon App Store, you are also subject to the privacy policies and terms of service of these platforms. We recommend that you review the privacy policies of these platforms to better understand their data handling practices.

Apple, Google, and Amazon may have access to personal information as necessary for providing hosting and distribution services for our App. This may include, but is not limited to, personal information like your platform account ID and device information, necessary for purchase and download transactions, and app functionality.

For detailed information on the privacy practices of each platform, please visit their respective privacy policy pages:

• Apple Privacy Policy
• Google Privacy Policy

7. Data Sharing

We will only share your Personal Information in the following limited circumstances:

• Within KDB Media Corp: Your data may be shared internally to support our operations.
• Service Providers: We may share information with third-party service providers who help us with tasks like cloud storage, analytics, or payment processing (if applicable). These providers are bound by contract to protect your data.
• Legal Compliance: We may disclose Personal Information when required by law, court order, or other legal process, or if necessary to protect ourselves or others from harm.

8. International Data Transfers

Your Personal Information may be transferred to, stored in, or processed in countries outside your jurisdiction. We will implement appropriate safeguards to protect your data when it is transferred internationally, such as using Standard Contractual Clauses or adhering to the Privacy Shield Framework (if applicable).

9. Data Security

We take the security of your Personal Information seriously. We implement appropriate technical and organizational security measures to protect it from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption: Data may be encrypted in transit and at rest.
• Access Controls: Access to Personal Information is limited to authorized personnel with a legitimate need-to-know basis.
• Firewalls and Intrusion Detection: We use security systems to detect and prevent unauthorized activity.
• Employee Training: Our staff is trained on data privacy and security practices.
• Incident Response Plan: We have procedures in place for responding to suspected or actual data security breaches.

Please note: No security system is impenetrable. While we strive to protect your information, we cannot guarantee absolute security.

10. Data Retention

We will retain your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. The retention period depends on the type of information and its use. For example:

• Account Data: Will be retained for as long as your account remains active.
• Usage Data: May be retained in anonymized form for longer periods for analytical purposes.
• Sleep Tracker Data: May be retained for a period to provide you with insights and historical trends, unless you request deletion.

We will regularly review our data retention practices and delete inactive account data or anonymize information when appropriate.

11. User Rights

Depending on your jurisdiction, you have certain rights regarding your Personal Information:

• Right to Access: You have the right to obtain confirmation as to whether we are Processing your data and to access a copy of it.
• Right to Rectification: You may request that we correct inaccurate or incomplete Personal Information.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you can ask us to delete your Personal Information.
• Right to Restriction of Processing: You may request that we limit the way we Process your information in certain situations.
• Right to Data Portability: You may have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and transmit it to another controller.
• Right to Object: You may have the right to object to the Processing of your information, including for direct marketing or where Processing is based on our legitimate interests.
• Right to Withdraw Consent: Where we rely on your consent to Process data, you can withdraw that consent at any time.

12. Children's Privacy

Our App is intended for adults aged 18 and over. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently collected information from a child under 13, we will take steps to delete it promptly.

13. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

• Right to Know: You can request information about the categories and specific pieces of Personal Information we collected, used, disclosed, and sold about you in the past 12 months.
• Right to Opt-Out of Sale: You have the right to opt-out of the "sale" of your Personal Information as defined by the CCPA.
• Right to Non-Discrimination: We will not discriminate against you if you exercise your CCPA rights.

14. Nevada Privacy Rights

If you are a Nevada resident, you have the right to opt-out of the sale of certain covered information to third parties who intend to resell or license the information. Currently, we do not sell covered information as defined under Nevada law.

15. Do Not Track Signals

Our App does not currently respond to "Do Not Track" (DNT) signals sent by web browsers.

16. Cookies & Similar Technologies

Our App may use cookies and similar technologies (like pixels, web beacons) to collect information about your usage and preferences. Please refer to the Cookie Policy for more information.

17. Changes to the Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, laws, or technology. If we make material changes, we will provide you with prominent notice, such as through the App or by email (if you have an account). We encourage you to review this policy periodically for the latest information.

18. Data Controller & Processor

KDB Media Corp. is the Data Controller for your Personal Information. Our contact information is as follows:

• KDB Media Corp.
• app@kdbempoweringescapes.com

19. Automated Decision-Making

We may use limited automated decision-making to provide you with personalized content recommendations based on your in-app activity. You have the right to object to automated decision-making, including profiling, where it produces legal effects concerning you or significantly affects you. Please contact us if you'd like more information or to exercise this right.

20. California Shine the Light Law

California's "Shine the Light" law permits California residents to request information about our sharing of their Personal Information with third parties for their direct marketing purposes. As we do not share your information in this way, this provision doesn't apply.

21. Complaints & Dispute Resolution

If you have concerns about our handling of your Personal Information, please contact us first using the contact details in Section 18. We will strive to address your concerns promptly.

You may also have the right to lodge a complaint with a data protection authority in your jurisdiction.

22. Jurisdiction

This Privacy Policy and any disputes arising from it shall be governed by and construed in accordance with the laws of the jurisdiction where the entity is based in.

23. Severability

If any part of this Privacy Policy is deemed invalid or unenforceable, that portion will be interpreted in a manner consistent with applicable law. The remaining provisions will remain in full force and effect.

25. Effective Date

This Privacy Policy is effective as of 1^st May 2024.