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Risely Privacy Policy

Effective Date: March 21, 2026 ยท Last Updated: October 17, 2026

This Privacy Policy describes how Two Player Labs LLC (“we,” “us,” or “our”) collects, uses, discloses, and protects your personal information when you use the Risely mobile application (“Risely” or the “App”), available on Android and iOS. By downloading, installing, or using Risely you agree to the practices described in this policy. If you do not agree, please do not use the App.

We encourage you to read this Privacy Policy carefully. If you have any questions, please contact us at [email protected].

Table of Contents

  1. Information We Collect
  2. How We Collect Information
  3. How We Use Your Information
  4. How We Share Your Information
  5. Third-Party Services and SDKs
  6. Data Retention
  7. Data Security
  8. Your Rights and Choices
  9. International Data Transfers
  10. Children's Privacy
  11. California Residents (CCPA/CPRA)
  12. European Economic Area, UK, and Switzerland (GDPR)
  13. Changes to This Policy
  14. Contact Us

1. Information We Collect

We collect several categories of information depending on how you interact with Risely. We have organized these into the categories below.

1.1 Account and Profile Information

When you create a Risely account, we collect the information necessary to set up and maintain your account:

  • Email address (as shared by Google Sign-In or Apple Sign-In; Risely has no email and password sign-up)
  • Display name and avatar (optional)
  • Authentication tokens from Google Sign-In or Apple Sign-In (if you choose those methods)
  • A unique user ID and friend code assigned to your account
  • Subscription tier and purchase history (managed through RevenueCat)

You may also use Risely as a guest without creating an account. In that case, a temporary anonymous identifier is assigned.

1.2 Sleep and Health Data

Risely's core purpose is to help you wake up and track your sleep. When you enable sleep tracking, we collect:

  • Accelerometer and motion data:Your device's accelerometer is sampled during sleep to classify sleep stages (awake, light, deep, REM) and detect movement patterns.
  • Sleep reports:Sleep start and end times, total duration, sleep stage breakdown, sleep quality score, and any notes or factors you record (e.g., caffeine, stress, exercise).
  • Snoring detection data:If you enable snoring detection, we use your device's microphone while sleep tracking runs and analyze the audio locally on your device using sound classification and signal analysis. We record snoring intensity, average and peak decibel levels, and short audio clips that are stored only on your device: clips of snoring, sleep talking, and coughing. Sleep-talk clips can capture anyone speaking in the room. The clips are deleted after 30 days, or sooner if you delete the sleep report. Raw audio is never transmitted to our servers, and neither are the audio clips. If you are signed in, the sleep report that is backed up to your account includes the snoring statistics and the time and type of each recorded sound, but not the audio.
  • Wearable health data:If you connect a wearable device (Fitbit, WHOOP, Apple Watch via HealthKit, or Health Connect, which is also how Galaxy Watch data shared by Samsung Health reaches Risely), we read sleep sessions, heart rate, blood oxygen saturation (SpO2), and heart rate variability (HRV) from those services via their respective APIs.
  • Saving nights to Apple Health or Health Connect:Risely writes to your health platform only if you turn on Save nights to Health in Sleep settings. It is off by default, and Risely asks for permission to write sleep data only when you turn it on. Risely then saves each night it tracked with your phone's own sensors to Apple Health (iOS) or Health Connect (Android): the time you went to bed and woke up, and the sleep stages Risely measured (awake, asleep, light, or deep sleep). Nights that came from a wearable or from Apple Health or Health Connect are never written back, and nothing else (heart rate, snoring, sleep-talk, or cough clips, notes, or scores) is written. Turning the setting off stops all further writes. Nights already saved stay in Apple Health or Health Connect until you delete them there; deleting a sleep report in Risely does not remove them. Once saved, those nights are governed by Apple's or Google's health settings, and other apps you have allowed to read your sleep data can see them. Health data is never used for advertising.

1.3 Device and Technical Information

We automatically collect certain technical information about your device:

  • Device brand, model, and operating system version
  • App version and build number
  • Screen resolution, font scale, locale, and timezone
  • Available memory, storage, and battery level (for diagnostics)
  • Network connection type
  • A push notification token from Firebase Cloud Messaging and your platform (Android or iOS), if you are signed in, so our server can deliver buddy notifications. On iOS the token is registered only after you allow notifications. It is removed from our servers when you sign out or delete your account.
  • Advertising identifier on Android (Google Advertising ID), subject to your device settings. On iOS, Risely does not ask for App Tracking Transparency permission, so the IDFA is not collected or used for tracking, and ads on iOS are not personalised with it.

1.4 Location Data

Risely may ask once for access to your approximate location, solely to provide weather information on your alarm and “My Day” screens. Precise location is never used. The coordinates are rounded to about 1 km and sent through our server to our weather data provider, WeatherAPI.com, to retrieve local forecasts. If you decline location permission or turn off Use my location for weather, weather uses an approximate location based on your IP address instead, and our server passes that IP address to WeatherAPI.com. Our server keeps each forecast in a short-lived cache for 10 minutes, not linked to your account; we do not otherwise store your location on our servers.

1.5 Camera and Sensor Data

Risely requests camera and sensor access only for specific alarm dismissal challenges:

  • QR Code scanning:The camera reads QR codes you have registered. No images are stored or transmitted.
  • Photo verification:The camera captures a selfie to verify you are awake using on-device face detection (ML Kit). The photo is never uploaded or transmitted. Risely deletes it from your device right after the face check, and clears any photo left behind (for example after a crash) the next time the App starts.
  • Shake and step detection:The accelerometer and activity recognition sensor are used to detect shaking and steps. This data is processed locally and not stored.
  • Voice challenges:The microphone and your device's built-in speech recognition (Google on Android, Apple on iOS) are used to verify spoken phrases. Risely uses on-device speech recognition when your phone supports it. Only when it does not, or when on-device recognition cannot run (for example, the language is not downloaded), does the App fall back to Google's or Apple's speech service, which may process the audio on their servers under their privacy policies. Risely does not store the audio or send it to our servers.

1.6 Usage and Analytics Data

We use Firebase Analytics to understand how the App is used. It is on by default and, in app versions from 1.48 on, can be turned off at any time in Settings → Privacy → Share Usage Analytics (called “Anonymous Analytics” in earlier versions); while it is off, the App sends no analytics events. Analytics events are not anonymous: when you are signed in, they are linked to your account, because the App sets your Risely user ID as the Firebase Analytics user ID. The App also records a few properties with them: your subscription tier, your platform and your companion pet's species. It collects usage events such as:

  • Screen views and navigation patterns
  • Feature activations (e.g., enabling snoring detection, connecting a wearable)
  • Session duration and event counts
  • Platform, app version, a Firebase installation identifier, your Risely user ID if you are signed in, and, on the free tier on Android, the advertising identifier used by Google AdMob

Analytics events never contain your alarm labels, journal or sleep notes, AI Sleep Coach messages, audio recordings, sleep scores or other sleep data, or your location.

Diagnostics. To find silent-alarm failures, the App sends one reliability report a day to our servers (on by default; turn it off in Settings → Privacy → Share Diagnostics). It contains the device model, OS and app version, battery and memory state, alarm-permission state, an 8-character prefix of the device identifier, and technical log lines about alarms and sleep tracking. It never contains audio, journal text, or your conversations. Reports are kept for 60 days.

Detailed sleep and alarm data. While we are testing Risely, the App also sends detailed sleep and alarm data, on by default. It has its own switch under Share Diagnostics, and the App shows a one-time notice when it is on. For each tracked night it sends the movement and sound levels measured every 30 seconds, how snoring detection handled sounds, and when clips were saved. If you also turn on the testing option Compare with my watch, it sends the sleep stages your watch recorded for the same night (read from Health Connect or Apple Health), used only to compare them with what your phone measured. For each alarm ring it sends the alarm's settings (not its name), when the alarm was set for and when it rang, snoozes, how each challenge went, and whether Emergency Off was used. It never contains audio, alarm names, or anything you type. This data is kept for 60 days and deleted with your account.

We also use Firebase Crashlytics for crash and error reporting, which captures exception data, device context, and your user ID to help us diagnose and fix bugs.

Crash reporting with Sentry. Since September 7, 2026 the App also sends crash and error reports to Sentry, a service run by Functional Software, Inc. When the App crashes or hits an error, a report is sent to Sentry containing the stack trace (which part of the App's code failed), the device model, operating system and app version, a short trail of technical events leading up to the error (for example, alarm scheduling steps), and your Risely user ID if you are signed in. The App also tells Sentry when a session starts and ends so we can measure how often the App crashes. Like any web service, Sentry sees the IP address a report is sent from. We do not attach audio, journal notes, sleep reports, or AI coach conversations to these reports. Sentry stores the reports on its servers, and a copy of each report is forwarded to our own servers so we can track and fix the problem.

1.7 Alarm and App Configuration Data

We store your alarm settings (times, labels, repeat days, dismissal challenge configurations, sound selections), app preferences, and Rise Score statistics. Each wake-up is recorded with when the alarm rang and was stopped, your snoozes and the challenge you used, and also when the alarm was set, whether your phone was already in use when it rang, whether you passed the wake-up check, and, for challenges like math or memory, how long you took and how many mistakes you made. These decide which mornings count in battles, the friends league and streaks. This data is synced to the cloud if you have an account, to allow cross-device access and backup. Your cloud backup also includes your AI Sleep Coach conversations (the messages you type to the coach and its replies), together with your caffeine and screen-time logs, so they can be restored on a new device.

1.8 Social and Competitive Features

If you use Risely's social features (friends, buddy system, squads, streak battles, weekly challenges, leaderboards), certain data may be visible to other users based on your privacy settings:

  • Display name and avatar
  • Current streak and Rise Score (shown to friends unless you turn off Show my streak to friends or Show my Rise Score to friends)
  • Your alarm name in buddy notifications, and your average wake-up time on the duo page (only if you turn this on)
  • Leaderboard rankings and challenge performance (unless you turn off Show me on leaderboards)

You control what is shared through in-app privacy settings. Alarm details are shared only if you turn on Share alarm details with friends (called Share alarm name in notifications in older versions of the App); otherwise buddy notifications say only that you snoozed or woke up, without naming the alarm, and your duo page does not show your average wake-up time.

Squads and wake-up lines. If you join a squad (up to five friends), the other members see your display name and avatar, your wake-up state for the day (up, snoozing, asleep, or no alarm, worked out from your synced wake-ups and the snooze and wake-up updates the App sends), the squad messages and reactions you send, and your next alarm time only if you choose to share it with your squad. A wake-up line you send a friend is shown on their alarm screen. Squad names, squad messages, and wake-up lines pass an automatic filter: slurs, hate words, and links are refused and not stored (we only count that a message was refused), and swear words are stored and shown masked. A moderator can remove a message, pause someone's squad messages for 24 hours, or remove them from a squad.

Duo streaks, the friends league, and weekly recaps. Each friend sees, for the two of you, the days you woke on time or missed (your duo streak). On the duo page a friend also sees, for the current month, how many times you snoozed, how many battles between you each of you won, your fastest alarm stop (unless you turn off Show my Rise Score to friends), and your average wake-up time (only if you share alarm details). Your friends see your weekly league points and rank unless you turn off Show me in my friends' league. Once a week each squad gets a recap that its members see: the squad's average wake-up time and snoozes, its quest, and awards such as first up most often or most snoozes. An award winner wears a badge on their profile for a week, and a duo that keeps a 50-day streak earns a permanent badge.

Reporting a user. If you report another user, we store who filed the report, the user you reported, the reason you chose, and where in the App you saw them. The report also keeps a copy of the reported user's display name and avatar as they were when you reported them, so a moderator sees what you saw even if the user changes them later. If you report a squad message, the report also keeps a copy of that message. The reported user is not told who reported them. Reports are kept as described in Section 6.

Blocking a user. A block is stored as the pair of user IDs (yours and the blocked user's) and the time you blocked them. It hides the two of you from each other on leaderboards, in weekly challenges, in friends lists, and in buddy notifications. The blocked user is not told.

2. How We Collect Information

2.1 Directly From You

When you create an account, configure alarms, enter sleep notes, connect wearables, or adjust privacy settings.

2.2 Automatically From Your Device

Sensor data (accelerometer, microphone, camera) is collected only when you actively initiate the relevant feature (sleep tracking, snoring detection, alarm dismissal challenges). Device and technical information is collected automatically to ensure app functionality.

2.3 From Third-Party Services

When you connect external services, we receive data from those providers:

  • Fitbit, WHOOP, Apple HealthKit, Health Connect:Sleep, heart rate, SpO2, HRV data
  • Google, Apple:Authentication tokens and basic profile information
  • Google AdMob:Ad interaction and impression data
  • RevenueCat:Subscription status and purchase verification
  • Firebase Cloud Messaging:A push notification token for your device, if you are signed in

3. How We Use Your Information

We use the information we collect for the following purposes:

  • Provide core functionality:Schedule and trigger alarms, process dismissal challenges, track sleep, and generate sleep reports and Rise Scores.
  • Personalize your experience:Offer AI-powered sleep coaching and AI sleep summaries (processed by Google Gemini, see Section 4.6; the AI Sleep Coach is a Pro feature, and AI summaries are available on the free tier in limited numbers), display weather, daily horoscope, and tailored wellness tips.
  • Cloud sync and backup:Synchronize your alarms, settings, sleep reports, statistics, and AI Sleep Coach conversations across devices and back them up to your account.
  • Social features:Enable friends, buddy systems, streak battles, leaderboards, and shared sleep sound mixes.
  • Improve the App:Analyze usage patterns, diagnose crashes, and fix bugs through analytics and error reporting.
  • Display advertising:Serve ads to free-tier users through Google AdMob. Risely Pro and Lifetime show no ads.
  • Process payments:Manage subscriptions and in-app purchases through RevenueCat and platform billing (Google Play, App Store).
  • Smart home integration:Communicate with connected smart lights (Philips Hue, LIFX, Govee) and IFTTT webhooks to automate your wake-up routine.
  • Communicate with you:Respond to support requests and send important service-related notices.

4. How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

4.1 Service Providers

We engage trusted third-party companies to perform services on our behalf (hosting, analytics, crash reporting, payment processing, ad serving). These providers access your data only to perform tasks for us and are contractually obligated to protect it. Crash and error reports go to Firebase Crashlytics (Google) and Sentry (Functional Software, Inc.), as described in Section 1.6.

4.2 Third-Party Integrations You Authorize

When you connect wearables, smart home devices, or sign in with Google/Apple, data flows between Risely and those services as described in Section 5. These integrations are always initiated by you and can be disconnected at any time.

4.3 Social Features

If you participate in friends, buddy, or competitive features, certain data (display name, avatar, streak, Rise Score) may be visible to other Risely users, subject to your privacy settings.

4.4 Legal Requirements

We may disclose information if required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

4.5 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

4.6 AI Processing (Google Gemini)

The AI Sleep Coach, weekly and monthly AI sleep summaries, and pattern alerts are generated by Google's Gemini models. To produce a response, the app sends the relevant context through our server to Google. Depending on the feature this can include:

  • Your recent sleep reports (bed and wake times, duration, sleep stages, quality score, snoring statistics, but never audio)
  • Journal entries: morning mood, sleep factors, and free-text notes you write
  • Caffeine and screen-time logs, your sleep goal, and your alarm settings and labels
  • Wearable metrics when a device is connected: heart rate, heart rate variability (HRV), and blood oxygen (SpO2)
  • The messages you type to the coach and the coach's previous replies in that conversation

Our server relays these requests and records only the request status, the model used, and token counts for rate limiting and billing; it does not store the content of your messages or the sleep data sent with them. Google's handling of this data is governed by the Gemini API Terms of Service. AI responses are not medical advice. Automatic weekly and monthly AI summaries and pattern alerts can be turned off in the app's Sleep settings.

5. Third-Party Services and SDKs

Risely integrates with the following third-party services. Each has its own privacy policy governing its use of data. We encourage you to review them.

Service Purpose Data Shared
Google AdMob Advertising Device ID, ad interactions, demographics
RevenueCat Subscription management User ID, purchase data, device type
Google Gemini AI sleep coaching, AI sleep summaries, pattern alerts Sleep reports, journal mood/notes, caffeine and screen-time logs, alarm settings, wearable metrics (HR, HRV, SpO2) when connected, conversation messages (see Section 4.6)
Firebase Crashlytics Crash reporting Error data, device context, user ID
Firebase Analytics Product analytics Usage events, app version, Firebase installation identifier, user ID when signed in (see Section 1.6)
Firebase Cloud Messaging Push notifications (buddy notifications) Device push token and the notification text our server sends
Sentry (Functional Software, Inc.) Crash and error reporting Stack traces, device model, OS and app version, recent technical events, user ID, IP address. No audio, journal notes, sleep reports, or coach conversations.
WeatherAPI.com Weather data Approximate location (coordinates rounded to about 1 km) or IP address, sent through our server
Fitbit API Wearable data Sleep, heart rate, SpO2, HRV, profile
Whoop API Wearable data Sleep and recovery metrics
Google Health Connect Wearable data (Android); saving nights if you turn on Save nights to Health Reads sleep sessions and heart rate. Writes nights tracked with your phone (bed and wake time, sleep stages) only if you turn on Save nights to Health. Stays on your device.
Apple HealthKit Wearable data (iOS); saving nights if you turn on Save nights to Health Reads sleep sessions, heart rate, and HRV. Writes nights tracked with your phone (bed and wake time, sleep stages) only if you turn on Save nights to Health. Stays on your device.
Philips Hue / LIFX / Govee Smart home Light state commands
IFTTT Webhooks Automation Alarm name, time, custom value
Google Sign-In Authentication ID token, email, profile
Apple Sign-In Authentication User ID, email (if shared)
Cloudflare (R2 CDN) Content delivery Sleep sound downloads

6. Data Retention

We retain your information for the periods outlined below, unless a longer retention is required by law:

Data Category Retention Period
Account data Until you delete your account
Sleep reports 90 days locally; synced copies retained until account deletion
Wake-up history 90 days, then permanently deleted
Analytics events 12 months from collection
Crash reports (Firebase Crashlytics) 90 days (per Crashlytics default)
Crash reports (Sentry) Up to 90 days in Sentry. The copy forwarded to our servers is kept for debugging; deleting your account removes its link to your account.
Diagnostic logs Cleared daily from device; kept on our own servers for 60 days
Detailed sleep and alarm data (nights and alarm rings) Kept on our own servers for 60 days and deleted with your account
Snoring, sleep-talk, and cough audio clips Stored only on device for 30 days, or until you delete the sleep report; never uploaded
Alarm configurations Until you delete the alarm or your account
Push notification tokens Until you sign out, the token stops working, or you delete your account
Reports about other users Until a moderator resolves the report, then 60 days, the same period we keep diagnostic reports. Deleted with the reported user's account. If you delete your account, reports you filed stay until resolved but are no longer linked to you.
Squad messages and reactions 90 days, then permanently deleted. When the last member leaves a squad, its messages are deleted 30 days later. Yours are deleted with your account.
Squad weekly recaps One year, then permanently deleted. Deleted with the squad. If you delete your account, your awards no longer appear in them.
Blocks Until you unblock the user or either account is deleted
Nights saved to Apple Health or Health Connect Kept in Apple Health or Health Connect on your device until you delete them there
Advertising data Governed by Google AdMob retention policies
Payment/subscription data Governed by RevenueCat and platform store policies

When data is no longer needed, we delete or anonymize it. Local data stored on your device is under your control and can be cleared by uninstalling the App or clearing app storage.

7. Data Security

We implement industry-standard measures to protect your information:

  • All network communications use HTTPS/TLS encryption in transit.
  • Sensitive tokens (OAuth, API keys) are stored using the device's secure keychain (iOS Keychain, Android Keystore).
  • Our backend authenticates every request with your account's access token and checks that you are allowed to see the data you ask for, so you can access only your own data plus what other users share with you (see Section 1.8).
  • Audio data from snoring detection is processed entirely on-device and is never transmitted over the network. The same goes for the snoring, sleep-talk, and cough clips: they stay on your device and are deleted after 30 days, or sooner if you delete the sleep report.
  • Photo verification images are checked by on-device face detection, are never uploaded, and are deleted from your device right after the check.

While we strive to use commercially acceptable means to protect your personal information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

8.1 Access and Portability

You may request a copy of the personal information we hold about you. To do so, email [email protected] from the address on your Risely account with the subject “Data request”. We verify that the request came from the account holder and reply within 30 days. The copy is a machine-readable JSON file covering your profile, settings, alarms, sleep reports, statistics, achievements, friends, battles, the reports you filed, the users you blocked, your squad membership, the squad messages you sent and your squad awards, and subscription status. Sleep reports and alarm data are also accessible directly through the App.

8.2 Correction

You may update your display name, avatar, and other profile information directly within the App.

8.3 Deletion

You can delete your account and all associated data at any time from inside the app (Settings → Danger Zone → Delete Account). Deletion is immediate and permanent. If you no longer have the app, follow the steps at twoplayerlabs.com/risely/delete-account or email [email protected] from the address on your account; we complete emailed requests within 30 days. Deleting your account does not cancel an App Store or Google Play subscription.

8.4 Opt-Out of Advertising Tracking

Risely Pro and Lifetime show no ads. On the free tier, you can limit ad personalization:

  • In the App: Where the law requires it (for example in the EEA and the UK), Risely asks for your consent to advertising through Google's consent form. You can change your choice at any time in Settings → Privacy → Manage ad preferences (this option appears when Google's consent form applies to you).
  • Android: Settings > Privacy > Ads > Delete advertising ID
  • iOS: Risely does not ask for App Tracking Transparency permission, so the IDFA is not collected or used for tracking, and ads on iOS are not personalised with it. No device setting is needed.

8.5 Withdraw Consent

You may withdraw consent for optional data collection (location, microphone, camera, wearables) at any time by revoking the relevant permissions in your device settings or disconnecting integrations within the App.

8.6 Manage Social Visibility

In-app privacy settings allow you to control whether your streak, Rise Score, alarm name, and other data are visible to friends or on leaderboards.

9. International Data Transfers

Two Player Labs LLC is based in the United States. If you use Risely from outside the United States, your information may be transferred to, stored in, and processed in the United States or other countries where our service providers operate. By using the App, you consent to the transfer of your information to the United States and other jurisdictions that may not have equivalent data protection laws.

For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, or other legally recognized transfer mechanisms, to ensure adequate protection for cross-border data transfers.

10. Children's Privacy

Risely is not directed at children under the age of 13 (or 16 in the EEA/UK). We do not knowingly collect personal information from children under these ages. If we learn that we have collected personal information from a child under the applicable minimum age without verified parental consent, we will take steps to delete that information promptly.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at [email protected] so we can take appropriate action.

11. California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information.

11.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information:

Category Examples
Identifiers Email, display name, user ID, friend code, device IDs
Internet/electronic activity App usage, screen views, feature usage, crash reports
Geolocation data Approximate location (for weather)
Sensory data Accelerometer, audio (snoring, sleep talking, and coughing, analyzed and kept on device), camera (photo challenge)
Health information Sleep stages, duration, heart rate, SpO2, HRV (from wearables)
Commercial information Subscription tier, purchase history
Inferences Sleep quality scores, Rise Scores, sleep pattern analysis

11.2 Your CCPA/CPRA Rights

  • Right to Know:You may request details about the categories and specific pieces of personal information we have collected.
  • Right to Delete:You may request deletion of your personal information, subject to certain exceptions.
  • Right to Correct:You may request correction of inaccurate personal information.
  • Right to Opt-Out of Sale/Sharing:We do not sell your personal information. We share information with advertising partners (Google AdMob) for cross-context behavioral advertising. You may opt out of this sharing as described in Section 8.4.
  • Right to Limit Use of Sensitive Data:You may limit our use of sensitive personal information (such as health data) to what is necessary to provide the services.
  • Right to Non-Discrimination:We will not discriminate against you for exercising any of these rights.

To exercise these rights, contact us at [email protected]. We will verify your identity before fulfilling your request.

12. European Economic Area, UK, and Switzerland (GDPR)

12.1 Data Controller

Two Player Labs LLC is the data controller for the personal data processed through Risely. Contact: [email protected].

12.2 Legal Bases for Processing

We process your personal data on the following legal bases:

Legal Basis Processing Activities
Performance of a contract Providing alarm, sleep tracking, cloud sync, and subscription features you have requested.
Consent Processing health/biometric data (sleep, snoring, wearable data), location data, camera access, microphone access, and sending optional communications. You may withdraw consent at any time.
Consent Advertising on the free tier through Google AdMob. Where the law requires it, including the EEA and the UK, we ask for your consent through Google's consent form (Google User Messaging Platform). You can change your choice at any time in Settings → Privacy → Manage ad preferences. Risely Pro and Lifetime show no ads.
Legitimate interests Improving the App, diagnosing bugs (analytics, crash reporting), preventing fraud, and securing our services.
Legal obligation Complying with applicable laws and regulations.

12.3 Your GDPR Rights

If you are located in the EEA, UK, or Switzerland, you have the following rights:

  • Access:Request a copy of your personal data.
  • Rectification:Request correction of inaccurate data.
  • Erasure (“Right to be Forgotten”):Request deletion of your data in certain circumstances.
  • Restriction:Request that we limit processing of your data.
  • Data Portability:Receive your data in a structured, machine-readable format.
  • Object:Object to processing based on legitimate interests, including profiling.
  • Withdraw Consent:Withdraw consent at any time without affecting the lawfulness of prior processing.
  • Lodge a Complaint:File a complaint with your local Data Protection Authority.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days (extendable by 60 days for complex requests).

12.4 Special Category Data

Sleep and health-related data (sleep stages, heart rate, SpO2, HRV, snoring data) may constitute special category data under GDPR Article 9. We process this data only with your explicit consent, which you provide by enabling sleep tracking, snoring detection, connecting a wearable device, or turning on Save nights to Health. You may withdraw consent at any time.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the App's features. When we make material changes, we will notify you by posting the updated policy within the App and updating the “Last Updated” date at the top. For significant changes, we may also provide additional notice, such as an in-app notification. Your continued use of Risely after the effective date of the updated policy constitutes acceptance of the changes.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Two Player Labs LLC

Email: [email protected]

For GDPR-related inquiries, you may also contact your local Data Protection Authority.


End of Privacy Policy