This Privacy Policy has been updated on December 10, 2025
If you have any privacy-related concerns, please contact us at: support@slowdive.app.
SLOWDIVE LTD is a company registered in Malta, with registration number C99274 and address at this date at 12 office 1, Trejqet Huggiega, Triq Victor Scerri, Naxxar, Nxr 1032, Malta (“Slowdive”, “We”, “Us”), who collects, uses and discloses information when you:
access or use the mobile app
“SLOWDIVE: MEDITATION & SLEEP” available at App Store and
Google Play (the “Application”, “App”,
“Slowdive”),
make purchases through https://slowdive.app/, including all subdomains of this Website (the
"Website"), or
otherwise interact with us.
In some Territories, certain independent service providers – such as payment processors, billing providers, merchants of record and payment collection partners (called “Payment Entities” in our Terms of Use) – process Personal Data on our behalf for billing, payment collection, tax and related support, as described in this Privacy Policy, our Terms of Use and our Refund & Cancellation Policy.
This Privacy Policy describes how we collect and use the Personal Data you provide. It also describes the choices available to you regarding our use of your Personal Data and how you can access the information. We respect your privacy, and we take protecting it seriously.
Reading this Privacy Policy is important, so we hope you will give it time and attention.
This Policy applies to the following people:
people who use the Application and/or the Website (for the purposes of
this policy, we define the term “User”, “you”,
"your", "yours" as a person who has
concluded the installation of an Application and/or uses the
Website);
people who make complaints to us by email.
Slowdive does not sell your personal data to third parties. A “sale” of Personal Data under the CCPA is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal Data of a Consumer to another business or third party “for monetary or other valuable consideration.” If we decide to sell the Application and/or the Website, we will inform you about this, so you can forbid us from transferring your personal data together with our business. If so, we will delete your data from the databases prior to a business transfer.
We adhere to the following principles in order to protect your privacy:
principle of purposefulness — we process personal data fairly
and in a transparent manner only for the achievement of determined and
lawful objectives, and they shall not be processed in a manner not
conforming to the objectives of data processing;
principle of minimalism — we collect personal data only to the
extent necessary for the achievement of determined purposes and do not
keep personal data if it is no longer needed;
principle of restricted use — we use personal data for other
purposes only with the consent of the data subject or with the
permission of a competent authority;
principle of data quality — personal data shall be up-to-date,
complete, and necessary for the achievement of the purpose of data
processing;
principle of security — security measures shall be applied in
order to protect personal data from unauthorised or unlawful
processing and against accidental loss, destruction, or damage, using
appropriate technical and organizational measures;
principle of individual participation — the persons shall be
notified of data collected concerning him or her, the persons shall be
granted access to the data concerning him or her, and the persons have
the right to demand the correction of inaccurate or misleading
data.
In order to fulfill our obligations to provision a license for the mobile app “Slowdive” for you and applicable terms of use, we are entitled to ask you to provide us with your Personal Data, including (but not limited to):
name;
anthropometric data;
age, weight, and height.
You may choose to provide additional information, but you are not required to do so.
Personal Data collected by or transmitted to Slowdive in the course of accessing, interacting, and operating the Application and/or the Website may include, without limitation, the following Personal Data:
device information, which may include (but is not limited to)
information about the computer or mobile device you use to access the
Application, including the hardware model, operating system and
version, the web browser you use, and other device identifiers;
server log information, which may include (but is not limited
to) your login details, the date and time of visits, the pages viewed,
your IP address, time spent at the Application, and the websites you
visit just before and just after the Application and/or the
Website;
information collected by cookies and other tracking
technologies.
We and our Application providers and Website providers use various
technologies to collect information when interacting with the
Application and/or the Website, including cookies and web beacons.
“Cookies” are small data files that are stored on your device when you
visit an Application and/or the Website which enable us to collect
information about your device identifiers, IP address, web browsers
used to access the Application, pages or features viewed, time spent
on pages, mobile app performance, and links clicked. Web beacons are
graphic images that are placed on a website or in an email that are
used to monitor the behavior of the user visiting the website or
sending the email. They are often used in combination with cookies.
We may also receive information about you from other sources, such as when you log in to the mobile app “Slowdive” using your account credentials for a separate third-party Application and/or visiting the Website. We will receive information from that Application and/or the Website as indicated in the relevant third party's authorization screen.
Slowdive may collect Personal Data from you in a variety of ways and circumstances, including, but not limited to, when you install the mobile app “Slowdive”, subscribe to our newsletter, fill out a form, provide us with feedback data, and visit the Website. Slowdive shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Application and/or the Website with any other relevant available information.
You may opt to integrate the Application with Apple's Health App Database. If you grant the Application access to Apple's Health App Database, the Application will import your data from the Health App Database into the Application in certain circumstances, such as to aid you in tracking fitness goals. In addition, the Application may transfer data that you store locally on your device, such as active energy, mindful minutes, and workouts, to the Health App Database. The Application cannot read from or write to the Health App Database unless you grant access. Data accessed from the Health App Database will never be shared with third parties, such as third-party Application providers and/or advertisers.
Slowdive is in no way responsible for the protection of the fitness data and/or other information stored within Apple's Health App Database. You and Apple are solely responsible for the protection of such information in the Health App Database. Please review Apple's applicable policies and procedures before syncing and backing up your fitness data and/or other information with the Health App Database.
Data accessed from the Health App Database will never be used for marketing, advertising, or similar purposes and will never be shared with third parties, such as third-party Application providers and/or advertisers.
We may use the information collected from you for a variety of purposes, primarily relating to providing our Application and information about our Application. We may also use the information for such other purposes as otherwise allowed by law. For example, we (or a supplier or our affiliate company acting on our behalf and only under our instructions) may use your Personal Data, including personally identifiable information, for such purposes, including but not limited to:
to provide license and access to the mobile app “Slowdive”;
to handle your orders and requests, including requests for technical
support and assistance;
to process payments, manage subscriptions, refunds, chargebacks,
fraud prevention and accounting with the help of our payment
processors, billing providers, merchants of record and payment
collection partners (Payment Entities), as described in Sections 9
and 10;
to properly fulfill tax-related and accounting obligations imposed by
applicable laws;
to detect, investigate, and prevent illegal activities or conduct that
may violate the Terms of Use of the mobile app “Slowdive” and this
Privacy Policy;
to personalize your experience with our Application and/or the
Website;
to contact you in relation to, and conduct, surveys or polls you
choose to take part in and to analyze the data collected for market
research purposes;
to conduct internal research and development and improve, test, and
enhance the features and functions of our Application and/or the
Website;
marketing and promotion of our Application and the Website or related
products, including those of a third party’s products that are related
to our Application and/or the Website (If you do not want us to use
your data in this way, please let us know by contacting us at:
support@slowdive.app);
to meet our internal and external audit requirements, including our
information security obligations;
tracking purchases and usage information;
any other purpose as we determine, in our sole discretion, to be
necessary or required to ensure the safety and/or integrity of our
users, employees, third parties, public, and/or our Application and
the Website, or to comply with requirements of any applicable law.
4.1.1 If you are an EU Person and, to process your Personal Data, we need to receive your consent, as it is prescribed by the General Data Protection Regulation (“GDPR”), we will process your Personal Data only in the case we have received from you a freely given, specific, informed and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data ("Consent").
4.1.2 You may give your Consent by ticking a box when visiting the Application. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that Slowdive shall be entitled to process your Personal Data as it is indicated by your Consent.
4.1.3 Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the Processing has multiple purposes, your Consent should be deemed given for all of them.
4.1.4 You have the right to withdraw your Consent at any time. You can submit such a request by sending us an email to support@slowdive.app. Your withdrawal of Consent shall not affect the lawfulness of your Personal Data processing based on Consent before its withdrawal.
4.1.5 Except as required or enabled by law we will not use or disclose your Personal Data for any purpose for which you refuse Consent or later withdraw your Consent. If you withdraw Consent, you agree that in spite of this withdrawal, we may continue to use those Personal Data previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards Slowdive or in any other way permitted by law.
4.2.1 If you are not an EU Person, by transferring to us your Personal Data via the Application and/or the Website or otherwise, you irrevocably and unconditionally consent and agree that Slowdive shall be entitled, in accordance with this Policy:
to Process in any manner, including to collect, store, use, disclose,
share and transfer (including cross-border), your Personal Data so
provided to us, as well as your Personal Data collected from your use
of the Application (i.e. your Personal Data which we collect
automatically and/or from other sources); and
to use cookies and web beacons (pixel tags) to collect your Personal
Data.
5.1 If you are located in the European Economic Area (EEA), privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).
5.2 If you are located in California, all processing of Personal Data is performed in accordance with regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”), as amended, and any implementing regulations, to the extent applicable.
5.3 If you are located in Brazil, all processing of Personal Data is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados (“LGPD”).
5.4 The Child Online Privacy and Protection Act (“COPPA”) regulates the online collection of information from persons under the age of 13 (covered person). Covered persons are required to obtain parental consent before providing personal data via the Application and/or the Website. If you are a parent of a COPPA covered person, you have the option to agree to the collection and use of your COPPA covered person’s information. You may revoke your consent, review your COPPA-covered person’s personal data, ask to have it deleted, and/or refuse to allow any further collection or use of your COPPA-covered person’s information at any time, by contacting us at support@slowdive.app.
5.5 We process Personal Data as a Controller, as defined in the GDPR.
6.1 You can review, correct, update, delete or transfer your personally identifiable information. For that, contact us directly at support@slowdive.app. We will acknowledge your request within seventy-two (72) hours and handle it promptly and as required by law.
You may have the following rights (subject to applicable law):
Right to access. You may contact us to get confirmation as to
whether or not we are processing your personal data. When we process
your personal data, we will inform you of what categories of personal
data we process regarding you, the processing purposes, the categories
of recipients to whom personal data have been or will be disclosed and
the envisaged storage period or criteria to determine that period.
Right to withdraw consent. In case our processing is based on
the consent granted, you may withdraw the consent at any time by
contacting us or by using the functionalities of our Application. You
can withdraw your consent at any time by replying to the email with
your withdrawal, and your Personal Data will be deleted in forty-eight
(48) hours, subject to legal retention obligations. Withdrawing
consent may lead to fewer possibilities to use our Application.
Right to object. In case our processing is based on our
legitimate interest to run, maintain and develop our business, you
have the right to object at any time to our processing. We shall then
no longer process your personal data unless for the provision of our
Application or if we demonstrate other compelling legitimate grounds
for our processing that override your interests, rights, and freedoms
or for legal claims. Notwithstanding any consent granted beforehand
for direct marketing purposes, you have the right to prohibit us from
using personal data for direct marketing purposes, by contacting us or
by using the functionalities of the Application or unsubscribe options
in connection with our direct marketing messages.
Right to restriction of the processing. You have the right to
obtain from us restriction of processing of your personal data, as
foreseen by applicable data protection law, e.g., to allow our
verification of the accuracy of personal data after your contesting of
accuracy or to prevent us from erasing personal data when personal
data are no longer necessary for the purposes but still required for
your legal claims or when our processing is unlawful. Restriction of
processing may lead to fewer possibilities to use our Application.
Right to data portability. You have the right to receive your
personal data from us in a structured, commonly used, and
machine-readable format and to independently transmit those data to a
third party, in case our processing is based on your consent and
carried out by automated means.
6.2 How to use these rights.
To exercise any of the
above-mentioned rights, you should primarily use the functions offered by
our Application and/or the Website. If such functions are not sufficient
for exercising such rights, you shall send us a letter or email to the
address set out below under Contact, including the following
information: name, address, phone number, email address, and a copy of a
valid proof of identity. We may request additional information necessary
to confirm your identity. We may reject requests that are unreasonably
repetitive, excessive, or manifestly unfounded.
7.1 We store your Personal Data for as long as needed to provide you with our Application and/or Website. We may store data longer, but only in a way that it cannot be tracked back to you. When Personal Data is no longer needed, we delete it using reasonable measures to protect the Personal Data from unauthorized access or use.
We store Personal Data as long as it is needed for the provision of our Application and/or Website. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable Application, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added Application information (including traffic information used for these purposes) is stored as long as the same is necessary for the provision of these activities or up to the time when a user opts out from such use in accordance with this Privacy Policy. Other information is stored for as long as we consider it to be necessary for the provision of our Application and/or Website. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the Application you requested.
7.3 As explained in the GDPR statement, we strive to anonymize the data when possible. If you decide to exercise your right to erasure, we will also inform our Providers to delete all your data, to the extent required by applicable law and feasible.
We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.
7.5 Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving, or personalizing our Application and/or the Website.
7.6 We do not use the Application and/or the Website to knowingly solicit information from or market to children under the age of 13. In the event that we learn that we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any personal information from or about a child under 13 years of age, please contact us at support@slowdive.app.
8.1 We care to ensure the security of personal data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When we or our contractors process your information, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.
8.2 There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, we cannot guarantee its absolute security.
8.3 We never process any kind of criminal offense data. Also, we never undertake profiling of personal data that produces legal effects concerning you or similarly significantly affects you, unless permitted by law and subject to appropriate safeguards.
We work with third-party service providers who provide website and application development, hosting, payment processing, billing, merchant-of-record services, customer communications, analytics, experimentation and error tracking, maintenance, and other services for us. They may be located outside of the EEA. These contractors may have access to or process Personal Data on our behalf as part of providing those services for us. We limit the information provided to these providers to that which is reasonably necessary for them to perform their functions and require them to process it in accordance with our instructions and applicable data protection law.
Some of these contractors are located outside the European Economic Area, the United Kingdom or Switzerland, including in the United States. When we transfer Personal Data to such countries, we do so in accordance with Chapter V of the GDPR and equivalent local rules. This may include:
relying on an adequacy decision of the European Commission (for
example, the EU–U.S. Data Privacy Framework for U.S. organisations
that are certified under it); and/or
using Standard Contractual Clauses adopted by the European
Commission or other appropriate safeguards, where required, sometimes
supplemented by additional technical and organisational measures;
and
in specific cases, relying on your explicit consent or another
applicable derogation where this is appropriate and lawful.
Your data collected from Apple Health will never be used for marketing or advertising purposes.
All data processed by us is stored in secure hosting facilities provided by Amazon Web Services (AWS), subject to appropriate data protection and security safeguards.
We use Facebook. Facebook remarketing Application is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/247395082112892. To opt out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation. Your data may be stored in Facebook data centers located in Sweden, Denmark, Ireland or other locations as determined by Facebook.
We use the Facebook SDK to integrate Facebook into mobile applications, which allows our Website and Application to be integrated into Facebook. For additional information about the Facebook SDK Privacy Policy, please review its Privacy Policy at: https://developers.facebook.com/terms/dfc_platform_terms/.
We use Mixpanel to analyze the behavior of users and understand how users navigate through the Application(s) and which features appeal the most to them. Mixpanel provides product and usage analytics services and processes Personal Data on our behalf under a data processing agreement and appropriate data transfer safeguards. For more information about Mixpanel’s privacy practices, please see: https://mixpanel.com/legal/privacy-policy/.
We use Google Analytics to create statistics about visitors to the Websites on the Internet. For more information about the Google Analytics Privacy Policy, please review it at: https://policies.google.com/privacy?hl=en-US.
We use Appsflyer. For more information on the privacy practices of Appsflyer, please visit the Privacy Policy: https://www.appsflyer.com/legal/services-privacy-policy/.
We use Firebase. Firebase is Google's mobile application development platform that helps to build, improve, and grow applications. For more information on the privacy practices of Firebase, please visit the Privacy Policy: https://firebase.google.com/support/privacy.
We use MailerLite. MailerLite is an email and messaging platform that allows us to send newsletters and other email communications, and to manage mailing lists and campaign performance. MailerLite processes your email address and related communication data on our behalf in accordance with its privacy policy and data processing addendum: https://www.mailerlite.com/legal/privacy-policy.
We use GrowthBook. GrowthBook is a feature flagging and experimentation platform that helps us run A/B tests and measure product changes. It may process limited usage and experiment data on our behalf, subject to a data processing agreement and appropriate safeguards. For more information, see GrowthBook’s legal and privacy documentation at: https://www.growthbook.io/legal/.
We use Sentry. Sentry provides application monitoring and error tracking services, helping us identify, log and fix crashes, bugs and performance issues in our Application. Sentry processes technical data such as error logs, device and app version information on our behalf. For more information about Sentry’s privacy practices, see: https://sentry.io/privacy/.
For website purchases, we use specialised third parties to process payments and manage billing, which may include:
PayPro Global, acting as merchant of record for certain
purchases and handling tax, invoicing and compliance;
Adyen and Braintree, acting as payment processors that
securely process card and alternative payments;
Recurly, acting as a subscription billing and recurring
payments platform.
These providers receive and process payment-related Personal Data (such as billing details, transaction identifiers and limited card data) either as independent controllers or as our processors, in accordance with their own privacy notices and data protection obligations.
For certain Territories, we use independent payment collection partners that act as our limited payment collection agents (referred to as “Payment Entities” in our Terms of Use). These entities may include, for example:
ASCETIX INC., a corporation organised and existing under the
laws of the State of Delaware, United States of America, with
registered office at 8 The Green, Suite R, Dover, DE 19901, USA.
Such partners are authorised to receive payments for Slowdive subscriptions and other fees on our behalf. For this purpose they may process payment-related Personal Data (for example, billing address, transaction identifiers and payment method information) strictly as service providers under our instructions, based on appropriate data processing agreements and international transfer safeguards as described in Sections 9.2 and 10 of this Privacy Policy. The involvement of a Payment Entity does not change your contractual counterparty under the Terms of Use (which remains Slowdive Ltd).
When you purchase a subscription or other paid product directly through the Website, payments are processed via specialised third parties. Depending on your Territory, payment method and the specific offer, these may include:
a merchant of record (such as PayPro Global) that sells the
digital product to you in its own name, issues invoices/receipts and
handles certain tax and compliance obligations;
payment processors (such as Adyen or Braintree) that securely
process your card or alternative payment method details and settle the
transaction;
a subscription billing platform (such as Recurly) that manages
recurring billing, proration, dunning and subscription lifecycle
events;
payment collection partners (Payment Entities) such as ASCETIX
INC., which may act as our limited payment collection agents for
certain Territories and are authorised to receive payments on our
behalf.
If you pay by credit card or a similar payment method, your payment information is normally encrypted and transmitted directly to these providers. We do not receive or store your full card number or full payment instrument data. We may receive and store limited payment information such as the last four digits of your card number, card type, expiration date, billing country, and transaction identifiers in order to:
match payments to your account;
manage subscriptions, refunds, chargebacks and customer support;
and
comply with tax, accounting and anti-fraud obligations.
These third-party providers process your payment data in accordance with their own privacy policies and applicable law. We are not responsible or liable for such providers’ independent collection or use of your Personal Data, but we select them with due care and enter into appropriate contracts to safeguard your data.
11.1 You can deactivate local notifications by changing the notification settings in accordance with the instructions of the operating system running on the Users’ device.
Where we send you marketing emails, you can opt out at any time by using the unsubscribe link included in such emails or by contacting us at support@slowdive.app.
12.1 This Privacy Policy is applicable to our Application and/or the Website. Once redirected to another website or App, this Policy is no longer applicable, and you should review the privacy policy applicable to that other website or App.
13.1 We assume that all Users have carefully read this document and agree to its content. If one does not agree with this Privacy Policy, they should refrain from using the Application and/or the Website.
If you continue to use the Application and/or the Website after we have updated this Privacy Policy, we will treat this as your acceptance of the updated terms to the extent permitted by applicable law.
14.1 From time to time, we may update this Privacy Policy. We encourage you to periodically check back and review this Policy so that you always will know what information we collect, how we use it, and with whom we share it.
If we make material changes (for example, affecting your rights or our purposes of processing), we will notify you by email and/or by an in-app or Website notice, where required by applicable law.
15.1 If you have any questions, requests or complaints regarding this Privacy Policy or our processing of your Personal Data, please contact us at:
Email: support@slowdive.app
Postal address:
Slowdive Ltd
12 office 1, Trejqet Huggiega, Triq Victor Scerri
Naxxar, Nxr 1032
Malta