Privacy policy
for the website www.somn.io/en
Last adjustment on 21/07/2025
1. Contact information
Responsible body within the meaning of data protection law
mementor DE GmbH
Karl-Heine-Strasse 15
04229 Leipzig
Germany
info[at]mementor.com
Contact details of the data protection officer
Paul Schmude
mementor DE GmbH
Karl-Heine-Strasse 15
04229 Leipzig
Germany
dataprivacy[at]mementor.de
2. Scope
Users receive with this privacy policy information about the type, scope and purpose of the collection and use of their data by the responsible provider, with exception of the use of digital health applications. Separate privacy policies can be found for each application on their respective websites.
3. Collection of general information
With each access to this offer, information is automatically collected by mementor or the web space provider. This information, also known as server log files, is of a general nature and does not allow any conclusions about your person.
Among other things, the following information is recorded: Name of the website, if applicable, file or subpage, date, amount of data, web browser and web browser version, operating system, the domain name of your internet provider, the so-called referrer URL (the page from which you accessed our offer).
Without this data, it would be technically impossible to deliver and display all of the content of the website. In this respect, the collection of data is necessary. Furthermore, we use the anonymous information for statistical purposes. They help us to optimise our offer and technology. We also reserve the right to subsequently check the log files if we suspect an illegal use of our offer.
The legal basis for the temporary storage of the data or log files is Art. 6 (1)(f) GDPR.
4. Services offered on the website
4.1 Transfer of your data to healthcare professionals
You can fill out a form on our website to have us request a prescription from your specialist for you. To do this, we need your name, the address of the specialist, and the name of your health insurance provider. We process this data as specified and store it until the associated order has been completed. Processing is carried out on the basis of your consent in accordance with Art. 6 (1)(a) GDPR in conjunction with Art. 9 (2)(a) GDPR.
4.2 Use of digital health applications
You have the option to use digital health applications via our website. Separate privacy statements are valid for each of these, which you can review during registration or from the main screen of the application.
4.3 Contact and support
If you contact mementor by e-mail or contact form, the information you provide (especially your e-mail address or phone number) will be stored in order to answer your inquiry and to be able to ask possible follow-up questions. Your data will be stored for as long as necessary for processing. If you contact us by form, you will find further information on data processing below.
In this case, your data will be processed on the basis of your (implied) consent in accordance with the first sentence of Art. 6 (1)(a) GDPR.
4.4 Sending information to medical and psychotherapeutic professionals
In order to inform and educate about our offer, we send information material by postal mail to professionals within the medical and psychotherapeutic services (e.g. sleep laboratories, physicians and psychotherapists). There is a legitimate interest of mementor in the form of marketing and providing information about the prescription and use of our products. For shipping purposes, the address is taken from publicly available sources. If you have objections to this shipment, you may assert them either by contacting our online support team or in writing, in which case we will remove you from our distribution list.
The legal basis for this is Art. 6 (1)(f) GDPR.
4.5 Sending flyers and trial accesses
As a healthcare professional, you can request a trial account and flyers to distribute to your patients. To fulfill your request, we need your postal address to send the flyers or your email address to send the trial access. Your contact information will also be processed for feedback, questions, further advice, or information, if necessary. The basis for this is your consent to data processing, which you can revoke at any time without giving reasons.
Transactional emails will be sent as part of the processing. These are sent via Pipedrive from Pipedrive Inc. A transfer of data to a third country cannot be completely ruled out.
The legal basis for this is Art. 6(1), first sentence (a) GDPR. The legitimate interest here lies in tracking mailings and obtaining feedback, as well as providing advice and information on similar products.
4.6 Planning of CME Events (Continuous Medical Education
You can find information about upcoming CME training courses (Continuing Medical Education) on relevant topics and register on our website. These CME training courses are usually conducted in collaboration with partners, who will be identified during the registration process. To register, we will collect your following data and forward it to the partner responsible for the course: We will need your name, email address, and specialization. After the training course has been completed, we may contact you again to send you slides or further information material.
The legal basis for this is Art. 6 (1) (a) GDPR. Your data will be stored until the event has been completed.
4.7 Sending newsletters
We use MailerLite, provided by MailerLite Inc., to send newsletters. A transfer of data to a third country cannot be completely ruled out.
The basis for sending the regular newsletter is your consent. You have the option to revoke your consent at any time without giving reasons.
The legal basis for this is Art. 6(1) first sentence (a) GDPR.
4.8 Cashing in health insurance prescriptions (prescription transfer service)
We offer you the option to upload your prescription with some additional information to us so that we can submit it to your health insurance company for you. The offer is voluntary and is only made on the basis of your consent, which you can revoke at any time without giving reasons. The following information is required to complete the form:
Surname, first name,
e-mail address,
postal address,
health insurance company,
picture of the prescription.
Optionally, you can also enter your telephone number so that any queries can be clarified more quickly.
We store the data on a server hosted in Germany until the DiGA code is redeemed, but for a maximum of 30 days. We check the completeness of the data and then forward it to the relevant health insurance company.
The legal basis for this is Art. 6 (1), first sentence (a) GDPR and Art. 9(2), first sentence (a) GDPR.
4.9 Application
If you would like to apply for a job with us, you have the option of doing so via our website http://www.mementor.de/jobs. In that case, the following privacy notice applies: https://careers.resmed.com/privacy/ .
4.10 On-demand webinars
You can watch webinars on our homepage. We use the services of Webinargeek, Chroomstraat 12, 2718 RR Zoetermeer, Netherlands, to host the webinars. Your email address, name, and institution will be recorded. These will be sent to Webinargeek for the purpose of issuing participation certificates and will also be used by mementor to evaluate participation and improve our services. Data will only be transferred with your consent; an AV contract has been concluded with Webinargeek.
The legal basis for this is Art. 6(1), first sentence (a) GDPR and Art. 6(1), first sentence (f) GDPR.
4.11 Raffles
In the context of surveys, we may offer participation in a raffle as an incentive. Participation in the raffle is voluntary and will in any case be conducted separately from the survey. To participate, you must enter your email address, which we will use to inform you if you have won a prize. Once the raffle has been concluded, your email address will be deleted immediately.
The legal basis for this is Art. 6(1), first sentence (a) GDPR.
5. Cookies and external services
5.1 Social networks
We have online presences on the social media platforms of the following providers:
a) YouTube, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Privacy Policy: https://policies.google.com/privacy?hl=en
b) LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Privacy Policy: https://www.linkedin.com/legal/privacy-policy?_l=en_UK
c) Meta Platforms, Inc., Willow Road 1601 94025 Menlo Park, CA https://www.facebook.com/policy.php
As a rule, personal data on the company’s website is stored in the respective social network for market research purposes. For this purpose, a cookie is stored in your browser, which enables the respective provider to recognise you when you visit a website. User profiles can be created, using the collected data. These are used to place advertisements within and outside the platform that presumably correspond to your interests. Furthermore, data can also be stored in the user profiles regardless of the devices you use. This is usually the case if you are a member of the respective platforms and are logged on to them. Cookies can only be set on the basis of consent in accordance with the first sentence of Art. 6 (1) (a) GDPR.
We ourselves collect personal data when you contact us, e.g. via contact form or through a messenger service such as Facebook Messenger. Which data is collected depends on your details and the contact details you have provided or released.
These are stored by us for the purpose of processing your inquiry and in case of follow-up questions. Under no circumstances will we pass the data on to third parties without your consent. The legal basis for the processing of the data is our legitimate interest in answering your request in accordance with Art. 6(1)(f) GDPR, and, if applicable, Art. 6(1)(b) GDPR, if your request is aimed at the conclusion of a contract.
Your data will be deleted after the final processing of your inquiry, provided that this does not conflict with any statutory retention obligations. We assume that the data will be processed conclusively if the circumstances indicate that the matter in question has been finally clarified.
If your communication with us via a social network or other platform is aimed at the conclusion of a contract for the delivery of goods or the provision of services with us, we will process your data for the purpose of fulfilling the contract or for the implementation of pre-contractual measures or for the provision of the requested services. The legal basis for the processing of your data in this case is Art. 6(1)(b) GDPR. Your data will be deleted if they are no longer required for the execution of the contract or if it is clear that the pre-contractual measures do not lead to a conclusion of contract corresponding to the purpose of the contact. Please note, however, that even after conclusion of the contract it may be necessary to store personal data of our contractual partners in order to comply with contractual or legal obligations.
If you are asked by the respective providers of the platforms to give your consent to the processing for a specific purpose, the legal basis for the processing is Art. 6(1)(a), and Art. 7 GDPR.
Please note that due to the use of the social media platforms, data processing may take place outside the EU and the European Economic Area, so that the European data protection level cannot necessarily be guaranteed. It cannot be ruled out that providers based in the EU may transfer your data to the USA for further processing. The processing of your personal data in social networks or platforms, including the transfer of your personal data to the operator of the platform in the USA, takes place on the basis of your (implied) consent in accordance with the first sentence of Art. 6 (1)(a) and the first sentence of Art. 49(1)(a) GDPR.
mementor expressly points out that in the case of an insecure third country (USA), it cannot be guaranteed that the data protection regulations of the General Data Protection Regulation will be observed when processing your personal data. In particular, the operator may be forced to disclose your personal data to authorities and other state institutions due to legal requirements in the respective third country.
We have no influence on the processing and handling of your personal data by the respective providers. Likewise, we do not have any information on this. For further information, please check the data protection declarations of the respective providers mentioned above.
5.2 Pipedrive
We use Pipedrive, offered by the company
Pipedrive OÜ, Paldiski mnt 80, Tallinn 10617, Estonia
as our customer relationship management tool (“CRM tool”) to process and store contact data. When contacting us (via contact form), user data is collected and processed in Pipedrive. Pipedrive allows us to process and respond to requests and messages faster. For this purpose, data is transferred to Pipedrive and stored on the Pipedrive servers. We use the CRM system Pipedrive of the provider Pipedrive OÜ based on our legitimate interests (efficient and fast processing of user requests, existing customer management, new customer business). An order data processing contract has been concluded with Pipedrive. You can access Pipedrive’s privacy policy here: https://www.pipedrive.com/en/privacy . The legal basis for the use of Pipedrive is Art. 6(1)(f). GDPR, our legitimate interest is the fast and effective processing of contact requests and the organization of our CRM. For more information on data protection at Pipedrive, please also visit: https://support.pipedrive.com/en/article/pipedrive-and-gdpr .
5.3 Calendly
We use Calendly by
Calendly, LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, United States
to organize our online seminars.
Your data from the form will be transferred to our appointment account at Calendly after pressing the “Book appointment” button.
You will then receive a confirmation email with a link to the event. Your data will be kept by Calendly until the purpose for storing it (appointment made) no longer applies or you send us a request to delete it.
A “Data Processing Addendum” has been concluded with Calendly. This obligates Calendly to protect the personal data collected by us and to process the data only in accordance with its data protection regulations on our behalf. Calendly undertakes not to disclose your data to third parties.
The legal basis for the use of Calendly is Art. 6(1)(f), our legitimate interest is the effective organization of our seminar dates.
For more information on data protection at Calendly, please visit https://calendly.com/pages/privacy .
5.4 Zoom
We use Zoom for our online seminars, offered by
ZOOM Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113.
During a Zoom meeting, the following data is collected:
Video data (if your camera is used),
Audio data (if your microphone is used),
Text data (if you use the chat feature),
Phone number (if you dial in by phone),
User details: user-selected name, IP address, other details in your Zoom account (if you have one).
Zoom requires this data in order to carry out the seminars, as far as it is provided for in the order data processing contract. We do not record the seminars. The legal basis for the use of Zoom is Art. 6(1)(f), our legitimate interest is the implementation of our seminar appointments. For more information on data protection at Zoom, please visit https://zoom.us/en-us/privacy.html .
5.5 Google Maps
We use the Google Maps service, provided by
Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
to display maps. The following data is automatically transmitted to Google when the map is displayed
IP address
Location data, if applicable
Search terms, if applicable
The transmission of the IP address is necessary for the function of the service. Location data is transmitted if your browser allows this. This is for your orientation and allows you to see your own location on the map. Any search terms you enter are transmitted and processed accordingly.
Data may be transferred to Google's servers in the USA.
The legal basis for the use of Google Maps is Art. 6(1)(a). Google is certified in accordance with the Data Privacy Framework, which means that the EU has issued an adequacy decision for the transfer of data to the USA. You give your consent to the processing in the cookie banner. You can withdraw your consent at any time.
Further information on data protection at Google Maps can be found at Data Privacy Google Maps.
5.6 Google Meet
We use Google Meet services, provided by
Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
in order to be able to conduct meetings online. During such a meeting, the following data is processed:
Registration data
Registration data
name,
e-mail address,
telephone (if connected via telephone),
password,
Meeting data,
subject,
participant IP address,
device information,
video and audio data (if camera or microphone are being used),
text data (if you are using the chat function).
Google are required to obtain knowledge of this data in order to conduct the seminars, as far as provided for in the data processing agreement. We do not record the seminars.
A transfer of data to Google's servers in the USA may occur.
The legal basis for the use of Google Meet is Art. 6(1)(f), our legitimate interest is the effective organization and implementation of online meetings.
Further information on data protection at Google Meet can be found at http://policies.google.com/privacy .
5.7 Google Analytics
If you have given your consent, Google Analytics 4, a web analysis service of Google LLC, is used on this website. The controller for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").
Nature and purpose of processing
We use Google Analytics 4 without the User ID and Google Signals functions.
In Google Analytics 4, the anonymization of IP addresses is activated by default. Due to IP anonymization, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. According to Google, the IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.during your website visit, your user behavior is recorded in the form of "events". Events can be
Page views
First visit to the website
Start of the session
Websites visited
Your "click path", interaction with the website
Scrolls (whenever a user scrolls to the end of the page (90%))
Clicks on external links
Internal search queries
Interaction with videos
file downloads
Viewed / clicked ads
language setting
Also recorded:
Your approximate location (region)
Date and time of your visit
Your IP address (in abbreviated form)
Technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
your internet provider
the referrer URL (via which website/advertising medium you came to this website)
Purposes of processing
On behalf of the operator of this website, Google will use this information to evaluate your pseudonymous use of the website and to compile reports on website activity. The reports provided by Google Analytics are used to analyze the performance of our website.
Recipients
Recipients of the data are/may be
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor pursuant to Art. 28 GDPR)
Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
Third country transfer
For the USA, the European Commission adopted its adequacy decision on July 10, 2023. Google LLC is certified under the EU-US Privacy Framework. Since Google servers are distributed worldwide and a transfer to third countries (for example to Singapore) cannot be completely ruled out, we have also concluded the EU standard contractual clauses with the provider.
Storage period
The data sent by us and linked to cookies is automatically deleted after 14 months. The maximum lifespan of Google Analytics cookies is 2 years. Data whose retention period has been reached is automatically deleted once a month.
Legal basis
Legal basis for this data processing is your consent in accordance with Art. 6(1), first sentence (a) GDPR and Section 25(1), first sentence TTDSG.
Revocation
You can revoke your consent at any time with effect for the future by accessing the cookie settings and changing your selection there. This does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.
You can also prevent the storage of cookies from the outset by setting your browser software accordingly. However, if you configure your browser to reject all cookies, this may restrict the functionality of this and other websites. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by
a. Not giving your consent to the setting of cookies orb. Downloading and installing the browser add-on to deactivate Google Analytics HERE.
You can find more information on the terms of use of Google Analytics and on data protection at Google at https://marketingplatform.google.com/about/analytics/terms/de/ and at https://policies.google.com/?hl=de.
5.8 Google Ads, Microsoft Ads
We use Microsoft Advertising from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA and Google Ads from Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043 to place ads on other websites and for remarketing. With remarketing, you are shown advertisements about our products on other sites after visiting our site. For this purpose, a cookie is set in your browser, which enables the respective provider to recognize you when you visit a website. The data collected can be used to create user profiles. These are used to place advertisements inside and outside the platform that presumably correspond to your interests. Furthermore, data can also be stored in the usage profiles independently of the devices you use. This is regularly the case if you are a member of the respective platforms and are logged in to them. Cookies can only be set on the basis of consent in accordance with Art. 6(1), first sentence (a) GDPR.
5.9 Microsoft Clarity
We use Microsoft Clarity from Microsoft Ireland Operations Ltd, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland to compile statistics and analyze user behavior. In order to improve the website, we examine the behavior of users on the website, which areas are visited for long periods of time and what the click behavior is like. The following data is processed:
IP address
Visited website/subpages
Date/time of access to the website
Clicks, scrolls, mouse movements
This data is only made available to us by Microsoft in anonymized form. A transfer outside the EU, especially to the USA, cannot be ruled out. Collected data is stored for a maximum of 3 months, the cookie set is automatically deleted after 1 year.
You consent to the use of Microsoft Clarity and the setting of a cookie as part of the cookie banner. The legal basis for the processing is Art. 6 (1)(a) GDPR; you can withdraw your consent at any time.
Further information on data protection at Microsoft can be found at https://www.microsoft.com/de-at/concern/privacy.
5.10 Typeform
We use Typeform from the company TYPEFORM SL, Carrer de Pallars 108 (Aticco), 08018 Barcelona Spain to design our contact form and feedback forms.
When you use the contact form, your e-mail address, the content of your message and your name are transmitted to Typeform. The processing and transmission of data via the contact form only takes place if you accept the data protection provisions. The legal basis in this case is Art. 6 (1)(a) GDPR.
When using the feedback form, connection data in the form of IP address, time stamp and browser information is transmitted. The legal basis for this is Art. 6 (1)(a) GDPR; the legitimate interest lies in the secure and functioning operation of the website.
In any case, your data will only be stored for as long as is absolutely necessary for processing.
5.11 The Trade Desk Websitepixel
This website uses The Trade Desk technology from TheTrade Desk Ltd, 1 Bartholomew Close, London EC1A 7BL, United Kingdom, to collect and store data for marketing and optimization purposes. Among other things, pseudonymized user profiles can be created from this data. Browser cookies can be used for this purpose. The data collected using The Trade Desk technology is not used by The Trade Desk to personally identify visitors to this website. The collection and storage of data can be revoked here at any time with effect for the future. Further information on data protection at The Trade Desk can be found here.
The legal basis for the processing is Art. 6 (1)(a) GDPR, you give your consent via the cookie banner.
5.12 Heyflow
We use Heyflow from Heyflow GmbH, Jungfernstieg 49, 20354 Hamburg, Germany, to create interactive forms. Data collected within the forms is processed by Heyflow exclusively on our behalf. Heyflow uses Google Cloud from Google LLC as its hosting partner, with the EU specified as the server location. For more information on data protection at Heyflow, please visit https://heyflow.app/de/datenschutz .
6. Retention period
Unless otherwise stated, mementor only stores personal data for as long as it is necessary to fulfill contractual or legal obligations. After that time, personal data will be deleted, unless we need the data until the end of the statutory limitation period for the purpose of providing evidence for civil law claims or due to statutory retention obligations.
Irrespective of the storage period, you have the option of triggering the deletion of the data at any time, provided that there are no legal storage obligations to the contrary.
7. Information about joint responsibility pursuant to Art. 26 (2) GDPR - Neuronation -
mementor DE GmbH and Synaptikon GmbH work closely together to coordinate communication with medical practices and participants regarding CME (Continuing Medical Education) events. This also applies to the processing of your personal data. The following data is collected and processed by the companies involved:
Contact details (in particular first and last names, addresses, email addresses, and telephone numbers) of participants in joint CME events.
We have therefore entered into an agreement with the above-mentioned parties on joint responsibility for the processing of your data in accordance with Art. 26 GDPR. The agreement regulates the following, among other things:
Within the scope of their joint responsibility under data protection law, the parties have agreed which of them will fulfill which obligations under the GDPR. This applies in particular to the exercise of the rights of data subjects and the fulfillment of the information obligations under Articles 13 and 14 GDPR.
The parties have agreed to store data relating to communication with participants independently of each other in their own systems.
Data subjects may assert their rights under Articles 15 et seq. GDPR against either party. The parties will either respond themselves or forward the request to the correct party based on their joint responsibility.
Further information about the parties can be found via the following links:
Privacy policy of mementor DE GmbH
8. Your rights
In the following, you will find information on the rights of data subjects that the applicable data protection law grants you regarding the person responsible for processing your personal data:
a) The right to request information about your personal data processed by us in accordance with Art. 15 of GDPR. In particular, you may request information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right of rectification, cancellation, restriction of processing or opposition, the existence of a right to appeal, the origin of your data, if not collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information on the details of such data.
b) The right, in accordance with Art. 16 GDPR, to demand without delay the correction of incorrect or incomplete personal data stored by us.
c) The right, in accordance with Art. 17 GDPR, to demand the deletion of your personal data stored with us, unless processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.
d) The right to demand, in accordance with Art. 18 GDPR, the restriction of the processing of your personal data, if the accuracy of the data is disputed by you, if the processing is unlawful but you refuse to delete it and we no longer require the data, but you require it for the assertion, exercise or defence of legal claims or if you have lodged an objection to the processing in accordance with Art. 21 GDPR.
e) The right, in accordance with Art. 20 GDPR, to receive your personal data that you have provided us with in a structured, commonplace and machine-readable format or to request data transfer to another responsible party. In the profile, you can export all your stored data in a machine-readable format. You also have the option of giving a clinical specialist (doctor / psychotherapist) access to an evaluation report. The report contains data from your sleep journal as well as data on your progress in the sleep training. The access cannot be triggered by the clinical professional himself, but only by an action from your profile in the application. Any access is only possible by explicit authorisation from you.
f) The right to complain to a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of the federal state of our registered office mentioned above or, if applicable, that of your usual place of residence or work.
g) Right to revoke consent granted in accordance with Art. 7 (3) GDPR: You have the right to revoke at any time with future effect any consent you have given to the processing of data. In the event of revocation, we will immediately delete the data concerned, unless further processing cannot be based on a legal basis for processing without consent. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.
h) If your personal data are processed by us on the basis of legitimate interests pursuant to the first sentence of Art. 6 (1) (f) GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that this is done for reasons arising from your particular situation. Insofar as the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right of objection without the need to indicate a special situation.
If you wish to exercise your right of revocation or objection, simply send an e-mail to support@mementor.de
9. Amendment of our privacy policy
In order to ensure that our data protection declaration always complies with the current legal requirements, mementor reserves the right to make changes at any time. This also applies in the event that the data protection declaration has to be adapted due to new or revised services, for example new services.