Privacy Policy

for the “Capybara Sleep” service

Last updated: 13 August 2026

1. Who we are

This Privacy Policy explains how personal data is processed in connection with the “Capybara Sleep” mobile application for iOS (the “App”) and the website available at https://capybarasleep.com (the “Website”, and together with the App, the “Service”).

The data controller responsible for your personal data is Kakhidze Sergei, an individual app developer (the “Developer”, “we”, “us”). You can contact us at any time at info@capybarasleep.com.

This Policy is designed to comply with the EU/EEA and UK General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act as amended by the CPRA (“CCPA”). Depending on where you live, some sections apply specifically to you (see §12 for EEA/UK rights and §13 for California rights).

2. Our privacy-first design

Capybara Sleep is built so that the most sensitive processing never leaves your device:

• Audio recorded during sleep tracking, and all sleep analysis derived from it, are processed and stored exclusively on your device. We do not receive, transmit to our servers, or store your recordings or sleep results, and we have no access to them.
• The App does not require you to create an account, log in, or provide your name to function.
• The App is free to download, but access to its core features requires an auto-renewable subscription processed by Apple. We never receive your payment-card details (see §6).
• The App contains no third-party advertising and no ad tracking.
• We do not operate our own servers that store your personal data. Purchase and subscription records are held by Apple and by our subscription-analytics provider, Adapty (see §6–§7).

3. Personal data we process

We limit our processing to what is necessary to provide the Service.

3.1. Data that stays on your device (we have no access)

• audio recorded by the microphone during an active sleep-tracking session;
• detected sound events (snoring, talking, coughing and similar) and sleep-phase classification;
• sleep parameters you enter, alarm settings, goals, preferences and recommendations.

This data is stored locally and is deleted when you delete it in the App or uninstall the App.

3.2. Data we may process to operate the Service

• Technical and device data — a pseudonymous Adapty profile or installation identifier, app and operating-system versions, device model, language, region, time zone and app-store information. Adapty’s collection of IP addresses and Apple’s advertising identifier (IDFA) is disabled in the App.
• Subscription and purchase data — your subscription product, status, term and events such as purchase, renewal, cancellation, expiration, grace period and restoration, together with paywall views and interactions. These are processed through Apple and Adapty to deliver paid access and measure paywall performance. We do not receive your payment-card details.
• Onboarding answers sent to Adapty — age range, gender, primary sleep goal and concern, how you feel in the morning, frequency of nighttime awakenings, usual bedtime and wake-up time, and selected alarm challenges. We use these answers for personalization, audience segmentation and subscription analytics. Adapty does not receive your nighttime recordings, detected sound events, sleep-session history, sleep-analysis results or recommendations.
• Support communications — if you contact us by email or messenger, the content of your message and the contact identifier you use (e.g. your email address or Telegram handle).
• Website usage data — when you visit the Website, our analytics provider sets cookies and collects technical usage data (see §9).

Some onboarding answers relate to sleep and general wellbeing and may be treated as health-related or sensitive data under applicable law. We use them only for the purposes described above and rely on consent where the law requires it. They are not medical records or clinical measurements. Audio is not used to identify you and is not biometric identification data.

4. Why we process data and our legal bases (GDPR)

5. No advertising

The App is supported by subscriptions, not by advertising. We do not display third-party ads in the App, we do not use advertising identifiers (such as IDFA or AAID) for advertising, and we do not sell or share your personal data for cross-context behavioural advertising.

6. Purchases and payments

Capybara Sleep is free to download from the Apple App Store, but its core features require an auto-renewable subscription. Available plans, localized pricing, billing periods and any trial eligibility are shown in the App before you confirm a purchase. All subscription charges and refunds are processed by Apple Inc. as part of the App Store, under Apple’s own terms and privacy policy. We do not collect or store your payment-card number or full billing details; we receive only the purchase and subscription information needed to provide access. Please review Apple’s privacy policy at https://www.apple.com/legal/privacy/ for details of Apple’s processing.

To display and personalize paywalls, manage access, process purchase and restore results, and analyse subscription performance, we use Adapty (adapty.io). Acting as our data processor, Adapty receives the technical, paywall, purchase, subscription and onboarding data described in §3.2. Adapty does not receive your audio recordings, detected nighttime sounds, sleep-session history, sleep-analysis results or recommendations. See Adapty’s privacy policy at https://adapty.io/privacy/ for details.

7. Who we share data with

We do not sell your personal data. We share personal data only with the following categories of recipients, and only as needed:

8. International transfers

Where personal data is transferred outside the EEA, the UK or your country of residence, we rely on an appropriate safeguard recognised under applicable law — such as an adequacy decision or the European Commission’s Standard Contractual Clauses — or another lawful transfer mechanism.

9. Cookies and website analytics

The Website uses cookies and similar technologies that are strictly necessary for its operation, and — subject to your consent where required — analytics cookies to understand how the Website is used. The Website currently uses the Yandex.Metrica analytics service for this purpose. You can control or delete cookies through your browser settings. Declining analytics cookies does not affect your ability to use the Website.

10. How long we keep data

• On-device sleep data is retained only on your device until you delete it or uninstall the App.
• Adapty profile, onboarding and subscription data is retained for as long as needed to manage access, perform subscription analytics, comply with law and resolve disputes, subject to Adapty’s applicable retention controls.
• Support correspondence is retained for as long as needed to handle your request and for a reasonable period afterwards.

11. Security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss or misuse, including encryption in transit (TLS) and access controls. No method of transmission or storage is completely secure, but we work to protect your data using commercially reasonable measures.

12. Your rights (EEA / UK)

If you are in the EEA or the UK, you have the right to access, rectify, erase, restrict and port your personal data, to object to processing based on legitimate interests, and to withdraw consent at any time (without affecting prior processing). To exercise these rights, contact us at info@capybarasleep.com. You also have the right to lodge a complaint with your local data protection supervisory authority.

13. Your rights (California)

If you are a California resident, you have the right to know what personal information we collect and how we use it, to request deletion of your personal information, to correct inaccurate information, and to be free from discrimination for exercising your rights. We do not “sell” or “share” personal information as those terms are defined under the CCPA. To make a request, contact us at info@capybarasleep.com.

14. Children

The Service is not directed to children under the age of 16, and we do not knowingly collect their personal data. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

15. Changes to this Policy

We may update this Policy from time to time. The current version is always available at https://capybarasleep.com/docs/privacy, with the “Last updated” date shown above. Material changes will be communicated by appropriate means.

16. Contact

Kakhidze Sergei
Last updated: 13 August 2026