Sleepmaxx AI Privacy Notice

Effective Date: May 23, 2026

This Privacy Policy ("Policy") describes how Origo Holdings Inc. ("Sleepmaxx AI," "Sleepmaxx," "we," "our," or "us") collects, uses, discloses, and otherwise processes your personal information when you use our Services, including our website, mobile application, sleep tracking features, AI-powered sleep insights, subscription tools, and other interactions you may have with us.

This Policy forms a part of our Terms of Use, and terms not defined in this Policy are defined in the Terms of Use.

If you reside in the U.S. and are under 13 years of age, you should not use our Services. If we become aware that an individual under 13 years of age may have provided us with personal information, we will investigate and, if applicable, take steps to remove and delete the data and delete that individual's account. If you reside in the European Economic Area, Switzerland, or United Kingdom, please see the Additional Information for Certain Jurisdictions section below.

What's New in this Version

This Policy updates our previous version dated December 18, 2025 with a user-friendly format and streamlines how our users can exercise their privacy rights.

Personal Information We Collect

We may collect personal information directly from you, automatically through your use of the Services, and from third parties.

Personal Information We Collect Directly from You

Personal Information We Collect Automatically

Sleepmaxx AI may collect usage and device data. This may include details about your browser, operating system, or device, such as cookie identifiers, IP address, mobile advertising identifier, device identifiers, internet service provider, mobile carrier, general location information inferred from your IP address, actions that you take while using the Services, information about how you interact with the Services, feature usage, frequency and duration of activities, links you click, and other information about how you use the Services.

Sleepmaxx AI may collect information automatically through cookies and other tracking technologies (collectively, "Cookies") we use to enhance your experience when you use our Services.

We use Cookies for a variety of purposes, including to make our site work, ensure security, and prevent fraud (Required Cookies); to provide enhanced functionality and analyze usage to improve our website (Functional Cookies); and, where permitted, to provide you with personalized content and advertisements (Targeted Advertising Cookies).

What are Cookies? Cookies are small text files that are placed on your device when you visit certain websites. Like many other online service providers, we and our third-party service providers and partners may use cookies and similar technologies, such as pixels, web beacons, local storage objects, log files, software development kits, and analytics tools. We collect information through cookies set directly by us (First-Party Cookies) and cookies set by third parties (Third-Party Cookies).

Managing your Cookie Preferences. Depending on the country where you reside, you have choices with respect to Cookies. By modifying your browser preferences, you may accept all cookies, be notified when a cookie is set, or reject all cookies. If you reject all cookies, some of our Service's features may not work properly. Where available, you may also adjust in-app cookie choices or visit Manage your Cookie Preferences.

Personal Information We Receive From Third Parties

We may receive information about you from other sources, such as third-party connected health devices, service providers, research partners, marketing and advertising partners, and social login platforms.

Aggregated, Deidentified, or Anonymized Information

We may aggregate, de-identify, or anonymize information so that it will no longer be considered personal information under applicable law. We may use and disclose de-identified information for purposes consistent with those described in this Policy or as otherwise permitted by applicable law.

How We Use Personal Information

How We Disclose Personal Information

We disclose personal information to the categories of recipients described below:

Managing your Marketing and Personalized Advertising Preferences

You have the ability to manage your Sleepmaxx AI account and your preferences as described below.

Marketing Communications

We may send you periodic marketing and promotional emails or other similar communications, and we will obtain your consent where required by law. If you no longer wish to receive marketing and promotional communications from us, you may:

Cookie Preferences

Depending on the country where you reside, you have choices with respect to Cookies. You may modify your browser preferences to accept all cookies, be notified when a cookie is set, or reject all cookies. If you reject all cookies, some of the Services' features may not work properly. Where available, you can manage your cookie preferences via Manage your Cookie Preferences. These preferences are reflected at a browser level; if you use more than one browser, you will need to choose your preferences in each browser. If you use the same browser on multiple devices, you will also need to choose your preferences on each device.

Personalized Advertising Preferences

Where we engage in targeted advertising, you may be able to consent, opt in, or opt out through our app by visiting your profile settings, through your device settings, through cookie preferences, or through other controls we make available. These preferences are currently reflected at a browser or device level; if you use more than one browser, you will need to choose your preferences in each browser. If you use multiple devices, you will also need to choose your preferences on each device, for example by opting out both at the Cookie Preferences link and in the App.

International Transfers of Personal Information

Sleepmaxx AI is based in the United States and has service providers in the United States and throughout the world. As a result, your personal information may be transferred to the United States and other countries or regions with data protection and privacy laws that differ from those in your country of residence.

When we transfer personal information outside of your country of residence, we do so in accordance with applicable law and take appropriate steps to protect your information. However, please note that while outside of the jurisdiction in which you reside, your personal information will be subject to applicable local laws, which might permit foreign governments, courts, law enforcement, or regulatory agencies to access your information in certain circumstances.

By using the Services or sharing your personal information with Sleepmaxx AI, you are informed that your personal information may be transferred to countries outside your country of residence.

User-Generated Content

We may offer public-facing interactive features, community forums, discussion areas, or other features that enable you to submit content, feedback, notes, reviews, testimonials, achievements, or other information. Any information you post to any public-facing section of the Services may be publicly viewable.

By posting to such interactive features, you acknowledge and agree that you have no expectation of privacy or confidentiality in the content you submit through such features, whether or not it contains your personal information. For more information about how this information is used, see our Terms of Use.

How We Protect Your Information

We maintain reasonable technical, organizational, and administrative safeguards designed to protect personal information under our control from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no information security measures can guarantee security.

How We Retain Your Information

We will retain your personal information as long as necessary to fulfill the purposes outlined in this Policy, including to satisfy legal or reporting requirements, unless a longer retention period is required or allowed under law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we use the information; whether we can achieve those purposes through other means; and applicable legal requirements.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify it except as required or permitted by law.

Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at support@sleepmaxx.ai, or write us at:

Sleepmaxx AI
ATTN: Sleepmaxx AI Privacy/Legal
Origo Holdings Inc.
152 North Durbin Street
Suite 150
Casper, Wyoming 82601
United States

Your Privacy Rights

Depending on where you live, the laws of your country, state, or province may provide certain privacy rights over how your personal information is collected, stored, used, and shared, including:

How do I exercise my rights?

You can exercise your privacy rights by submitting your request to support@sleepmaxx.ai. In your communication, please state the request you would like to make and the rights you wish to exercise.

Where legally permitted, you may submit requests through an authorized agent or representative. To process these requests, we may need to verify the identity of the agent and confirm that you authorized them to act on your behalf.

Questions. You can also contact us at support@sleepmaxx.ai if you have inquiries or complaints regarding our processing of your personal information.

Additional Information for Certain Jurisdictions

Residents of certain jurisdictions have additional rights under applicable laws, including residents of certain states within the United States, such as California and Washington, the European Economic Area, Switzerland, the United Kingdom, Canada, and Quebec.

United States - California

California Shine the Light

Residents of the State of California have the right to request information from Sleepmaxx AI regarding other companies to whom we have disclosed certain categories of information during the preceding year for the other companies' direct marketing purposes. To make such a request, please contact us at support@sleepmaxx.ai.

California Consumer Privacy Act

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of Personal Information, as well as the right to know/access, delete, and limit sharing of Personal Information.

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Certain information we collect may be exempt from the CCPA because it is considered public information or covered by a specific federal privacy law.

Right to notice at collection regarding the categories of Personal Information collected

You have the right to receive notice of the categories of Personal Information we collect and the purposes for which those categories of Personal Information will be used. Depending on your use of the Services, we may collect the following categories:

Category of Personal Information Required Information
Personal Identifiers We may collect names, email addresses, phone numbers, postal addresses, account names, online identifiers, IP addresses, and other similar identifiers.

Source: Our users directly and automatically, third parties, business partners, service providers, other users where social features are used, analytics providers, and research partners.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Business partners, service providers, other users where applicable, analytics providers, and research partners.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: While Sleepmaxx AI does not expressly sell information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies may constitute sales or sharing of personal information or targeted advertising under applicable privacy laws.
Protected classification characteristics We may collect protected classification characteristics under California or federal law, including age or date of birth and sex or gender where you provide it.

Source: Our users directly.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Service providers and, if applicable, other users through social features.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: N/A.
Commercial Information We may collect records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Source: Our users directly and automatically and third parties.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Service providers, analytics providers, research partners, and marketing and advertising partners, including social media platforms and third-party advertising networks.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: While Sleepmaxx AI does not expressly sell information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies may constitute sales or sharing of personal information or targeted advertising under applicable privacy laws.
Internet or other electronic network activity information This may include browsing history, search history, and information regarding interactions with the Services and advertisements.

Source: Our users directly and automatically and third parties.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Service providers, analytics providers, research partners, and marketing and advertising partners, including social media platforms and third-party advertising networks.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: While Sleepmaxx AI does not expressly sell information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies may constitute sales or sharing of personal information or targeted advertising under applicable privacy laws.
Geolocation data This may include IP address, country in which you reside, zip code, and approximate location information. Sleepmaxx AI does not collect precise geolocation information unless you enable a feature that requires it.

Source: Our users directly and automatically.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Service providers, analytics providers, research partners, and marketing and advertising partners, including social media platforms and third-party advertising networks.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: While Sleepmaxx AI does not expressly sell information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies may constitute sales or sharing of personal information or targeted advertising under applicable privacy laws.
Audio, electronic, visual, or similar information This may include audio input, sleep diary voice entries, uploaded images, profile photos, screenshots, support attachments, or other content you choose to provide.

Source: Our users directly and automatically, third parties, and service providers.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Service providers.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: N/A.
Inferences drawn from other personal information This may include inferences drawn from any of the information in the above-listed categories reflecting preferences, characteristics, behaviors, attitudes, abilities, and aptitudes, including sleep-related insights and recommendations.

Source: Our users directly and automatically, business partners, and service providers.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Service providers.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: While Sleepmaxx AI does not expressly sell information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies may constitute sales or sharing of personal information or targeted advertising under applicable privacy laws.
Sensitive Personal Information This may include Sleep and Wellness Data, connected health or wearable data, health-related symptoms, physiological information, medications, or other information that may reveal or allow inferences about health conditions.

Source: Our users, business partners, service providers, and connected health or wearable platforms.

Purpose of Collection and Use: Business purpose.

Categories of Parties with whom the Information may be Shared: Service providers.

Has this information been shared with these parties within the last 12 months? Yes.

Categories of Parties to whom the Information may be Sold: We do not use unique health information from HealthKit, Google Health Connect, Google Fit, or compatible wearable platforms for marketing and advertising or transfer it to third parties for marketing and advertising.

While Sleepmaxx AI does not expressly sell information for money, certain uses of Functional Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose information may constitute sales or sharing of personal information or the use of personal information for targeted advertising purposes under applicable privacy laws. Where required, you may opt out through the controls we make available or by contacting us.

California-specific rights

How to submit a request

You can exercise your California privacy rights by submitting your request to support@sleepmaxx.ai. We may need to verify your identity before fulfilling your request.

United States - Washington

The Washington My Health My Data Act requires certain disclosures to Washington residents regarding the use of consumer health data. Sleep and wellness information, connected device information, physiological information, and health-related inferences may be considered consumer health data. You may contact us at support@sleepmaxx.ai to request access, deletion, withdrawal of consent, or other rights available under applicable law.

European Economic Area (EEA), Switzerland, and United Kingdom (UK) Residents

If you reside in the EEA and are under 18 years of age, you should not use our Services. If we become aware that an individual under 18 years of age may have provided us with personal information, we will investigate and, if applicable, take steps to remove and delete the data and delete that individual's account.

Data controller Information

For the purposes of applicable data protection laws, Origo Holdings Inc. is the controller of the personal information you provide to us.

How to contact Origo Holdings Inc.

Your rights

How to exercise your rights

Please contact us at support@sleepmaxx.ai if you wish to exercise any of your rights. Regarding our use of tracking technologies for targeted advertising and personalization, you may revise your choices by visiting Manage your Cookie Preferences on our website or by visiting Manage your Personalization Preferences in the App, where available.

How to lodge a complaint

If you consider that the processing of your personal information violates applicable data protection laws, you also have the right to lodge a complaint about our processing of your personal information or our handling of your rights request with the appropriate data protection regulator, such as the regulator located where you reside, at your place of work, or at the place of the alleged infringement.

Lawful Bases for Processing Personal Information

Applicable data protection laws require us to set out the lawful basis that we rely on to collect and process personal information. Here is a list of the lawful bases that we rely on for each of our processing activities:

Information Retention

We retain personal information for as long as necessary for the purposes set out in this Policy, including to comply with legal obligations, resolve disputes, and enforce our legal agreements and policies.

International Transfers of Personal Information

Your personal information may be transferred to countries outside of the EEA, Switzerland, and the UK, including the United States, to companies that may not be certified under the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, or the Swiss-US Data Privacy Framework. We have put in place adequate measures, and where necessary, we have implemented additional contractual, organizational, and technical measures to protect your personal information. You can request information about these measures by contacting us at support@sleepmaxx.ai.

Canada

Processing of Personal Information

If you reside in Canada, you may have privacy rights under Canadian federal or provincial privacy laws. Unless otherwise allowed by the laws applicable in your province or territory of residence, we will only collect, use, or communicate your personal information with your consent, which may be express or implied. You are generally not obliged to provide your personal information, but we may be unable to provide certain services to you if you refuse to disclose certain personal information.

Privacy Rights and Requests

You have the right to access the personal information we hold about you and correct or amend your information as appropriate. You may also have rights to withdraw consent and request information about our privacy practices. If you have unresolved concerns regarding our handling of your personal information, you have the right to complain to the relevant data protection authority. You may submit privacy requests to support@sleepmaxx.ai.

Quebec residents

Quebec residents may have additional rights under Quebec privacy law, including rights related to access, correction, withdrawal of consent, information about automated processing, data portability, and de-indexation.

To exercise your rights, please submit your request to support@sleepmaxx.ai.