Privacy Policy

Information about the processing of personal data in the somna app and website

1. Introduction

The Somna App website and Somna App is operated by revolv GmbH, Sandhoferstrasse 176, 68305 Mannheim, Germany.  (referred to as “we”, “us” or “our” in this Privacy Policy). 

This Privacy Policy describes how Somna (the “Site and App” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site. 

2. Contact 

If you want to exercise your data subject rights or if you have any other questions concerning this Privacy Policy, please email your request to: hello@revolv.vc  

revolv GmbH, Sandhoferstrasse 176, 68305 Mannheim, Germany.

We respect your privacy and are dedicated to safeguarding your personal information. This Privacy Policy outlines how we collect and manage your personal data and establishes the framework for processing any personal data we collect from you or that you provide to us. Your use of our website or mobile application (collectively referred to as our “Platform”) is subject to this Privacy Policy. The policy also applies whenever you communicate with us, whether in person, by letter, phone, email, or any other method. Please read the following carefully to understand our practices and how we handle your personal data.

This policy is updated periodically. The most recent version, updated on 2 December 2025, is available on this page of the Website. All subsequent updates will also be published here.

3. Whose personal data do we process and where do we obtain your personal data?

We process personal data about you if you have or will create an account on the somna app.

We obtain your personal data from you. When you create an account, we ask you to provide us with certain personal data.

Based on analyses of member data, as a member you receive various offers and discounts based on, for example, purchase history, age, place of residence, market surveys, and information about your activities when you visit our channels and social media. We perform an analysis at the individual level in order to personalise the functions you use and the communication you receive, such as product recommendations, offers, the ability to save your shopping basket, receive reminders about forgotten or abandoned shopping baskets, the option to save certain settings, such as your chosen delivery method, for a smoother experience, or other similar measures that make your use and experience of our services as good and smooth as possible.

3.1 Why and how do we process your personal data within the framework of the somna app?

Purpose: To register you as a member and administer your membership.

Personal data: Name (or pseudonym), email address, child name (or pseudonym), child age

Legal basis: Performance of a contract (GDPR, Article 6.1 (b))

Retention period: For as long as you have an account on somna.

Purpose: To be able to deliver a personalised experience of the somna app and revolv's other services.

Personal data: Email address, child's date of birth, purchase history, other information if you have provided additional information such as: name, mobile number, postcode

Legal basis: Legitimate interest (GDPR, Article 6.1 (f) – our legitimate interest in personalising the content and features of the somna app and revolv's other services based on the member's preferences)

Retention period: For as long as you have an account on somna.

Purpose: To in the future be able to offer you, as a member, personalised benefits, offers and discount codes via our website or app that relate to the somna app or revolv's other services.

Personal data: Email address, child’s age, purchase history, other information if you have provided additional information such as name, Mobile number, Postcode.

Legal basis: Legitimate interest (GDPR, Article 6.1 (f) – our legitimate interest in offering personalised benefits and offers to our members)

Retention period: As long as you have an account on somna.

Purpose: To provide improved website navigation, functionality and a more personalised experience of the somna app, webb and revolv's other services.

Personal data: Personal data based on your use of our services, collected via cookies (‘behavioural data’)

Legal basis: Consent, Article 6.1 (a) GDPR) for the use of your behavioural data.

Retention period: During the lifetime of the cookie or until you withdraw your consent.

Purpose: To be able to offer you, as a member, personalised benefits and offers and discount codes via email, SMS.

Personal data: Name, Mobile number, Address

Legal basis: Consent – we will only send you information about benefits and offers via electronic communications such as email and SMS if you have consented to this in accordance with the Marketing Act

Retention period: For as long as you are a member or until you withdraw your consent

Purpose: To send you newsletters in the future, that are relevant to you.

Personal data: Email address, Postcode, Child’s date of birth.

Legal basis: Consent (GDPR, Article 6.1 (a)) – we ask for your consent to send you newsletters that we believe are relevant to you. You always have the right to withdraw your consent.

Retention period: For as long as you subscribe to the newsletter.

Purpose: To evaluate, develop and improve our services, products and systems.

Personal data: All personal data collected at an aggregated level

Legal basis: Legitimate interest (GDPR, Article 6.1 (f)) – our legitimate interest in evaluating, developing and improving our services, products and systems, for example to evaluate which feature or content is most relevant to our users.

Retention period: For as long as you have a somna account or until you withdraw your consent

Purpose: To market revolvs products on third-party platforms, including social media, and to tailor our marketing so that you receive personalised offers and avoid irrelevant ads

Personal data: All personal data collected.

Legal basis: Consent (GDPR 6.1 (a) – we ask for your consent to market our products on third-party platforms. You always have the right to withdraw your consent.

Retention period: Depending on the platform, 180 days to 540 days.

4. Metadata 

You may use our website or app without providing any personal data about you. In this case, we will collect only the following metadata that result from your usage: 

Referral page, data and time of access, data volume transmitted, status of transmission, type of web browser, IP-address, operating system and interface, language and version of browser software. 

Your IP-address will be used to enable your access to our website or app. Once the IP-address is no longer necessary for this purpose, we will shorten your IP-address by removing the last octet of your IP-address. The metadata, including the shortened IP-address will be used to improve the quality and services of our website or app by analysing the usage behavior of our users. 

5. Behavioural Advertising 

As described above, we use your anonymised personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example: 

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

You can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/. 

6. Who do we share your personal data with?

We share your personal data with our suppliers and partners, such as:

7. Where is your data processed?

We always strive to ensure that your personal data is processed within the EU/EEA, and all our data storage takes place within the EU/EEA. However, in certain situations, we may need to transfer your personal data to partners or service providers located outside the EU/EEA (third countries). The third countries to which we transfer your personal data are the United Kingdom.

Regardless of where your personal data is processed, we take all reasonable contractual, technical and organisational measures to ensure that the level of protection is equivalent to that applicable within the EU/EEA. We always ensure that a transfer mechanism is in place if the transfer is not covered by the European Commission's adequacy decision, in which case we use the European Commission's standard contractual clauses, which you can find here. We also take additional technical and organisational security measures when necessary, such as encryption and pseudonymisation.

8. Do you have to provide us with your personal data?

In order for us to register and set up your account, it is necessary for you to provide us with your email address, name and the age of your child. We ask for the age of your children to ensure that we provide relevant information and sleep routines related to the child's age.

You also have the option of providing us with additional personal data, such as your, mobile number, postcode and your child's name. It is not mandatory to provide this additional information in order to create an account on the somna app and you may also use pseudonyms. This information is processed in order to provide you with features and content that are as relevant as possible.

9. Lawful basis:

We may process your sensitive personal data on the following legal grounds:

The provision of your personal data may be necessary due to legal or contractual requirements, in order to enter into a contract with us or to receive the products and services you have ordered. You may also provide personal data voluntarily.

If you do not provide your personal data, this may be to your disadvantage, for example, you may not be able to access certain products or services. However, unless otherwise stated, there will be no legal consequences for you if you do not provide your personal data.

10. Payments 

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). 

We will not store or collect Your personal and payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. 

Apple Store In-App Payments 
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/ 

Google Play In-App Payments 
Their Privacy Policy can viewed at https://www.google.com/policies/privacy/ 

11. What rights do you have and how can you assert your rights? 

If you have declared your consent regarding certain collecting, processing, and use of your personal data, you can revoke this consent at any time with future effect. Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs in accordance with the basic tariffs. 

Pursuant to the applicable data protection law you have the right (i) to request access to your personal data, (ii) to request rectification of your personal data, (iii) to request erasure of your personal data, (iv) to request restriction of processing of your personal data, (v) to request data portability, (vi) to object to the processing of your personal Data (including objection to profiling), and (vii) to object to automated decision making (including profiling).

To exercise your rights please contact us as stated under Sec. 1 (Contact us) aYou have certain rights regarding our processing of your personal data. To discontinue your participation in the app and initiate the complete removal of your account, please follow the procedure outlined below: 

1.Delete the app from your device.

This action will effectively erase all associated account data. If you have any questions or require further assistance, feel free to reach us at the contact below. 

11.1 Unenrollment and Account Removal Policy:  

To discontinue your participation in the app and initiate the complete removal of your account, please follow the procedure outlined below: 

1.Delete the app from your device. 

This action will effectively erase all associated account data. If you have any questions or require further assistance, feel free to reach us at the contact below. 

In case of complaints, you also have the right to lodge a complaint with the competent data protection supervisory authority. 

12. Changes to this Privacy Policy 

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. 

We recommend that you periodically review this Privacy Policy for any updates. The changes to this Privacy Policy will become effective once they are posted on this page. 

13. Cookies and other tracking technologies 

This website or app uses cookies. For further information please visit our Cookie Policy  

14. How long do we keep your Personal Data? 

Your personal data will be retained as long as necessary to provide you with the services and products requested. Once our relationship has come to an end, we will either delete your personal data or anonymize your personal data, unless statutory retention requirements apply (such as for taxation purposes). Also, we may be required by applicable law to retain certain of your personal data for a period of 10 years after the relevant taxation year. We may also retain your personal data after the termination of the contractual relationship if your personal data are necessary to comply with other applicable laws or if we need your personal data to establish, exercise or defend a legal claim, on a need-to-know basis only. To the extent possible, we will restrict the processing of your personal data for such limited purposes after the termination of the contractual relationship. 

15. Children's Privacy 

Our Service is not directed to individuals under the age of 13. We do not intentionally collect personally identifiable information from individuals under 13 years of age. If you are a parent or guardian and you become aware that your child has provided us with Personal Data without your consent, please contact us immediately.  

In the event that we discover we have collected Personal Data from an individual under the age of 13 without parental consent, we will take appropriate steps to delete such information from our records. Should we need to rely on consent as the legal basis for processing your information, and if your jurisdiction requires parental consent, we may seek your parent's consent before collecting and using your information. 

16. Links to Other Websites 

Our Service may include links to external websites that are not operated by us. If you click on a third-party link, you will be redirected to that third party's site.  

We strongly recommend reviewing the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. 

17. Complaints 

As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact” above. 

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://www.dataprotectionauthority.be/citizen  

Last updated: 10/12/2025