Privacy policy

for the website www.somn.io/en / Last updated on 06/08/2026

1 Purpose, scope, general information

This privacy policy applies to the somnio website and contains information on data processing in the context of using the website, as well as on data processing by mementor DE GmbH.

The digital health application somnio has a separate privacy policy.

2 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 these 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

3 Services offered on the website

3.1 Transfer of your data to healthcare professionals

Purpose: You can fill out a form on our website instructing us to request a prescription from your responsible healthcare professional.
Data collected: Name, the address of the healthcare professional, and the name of your insurer.
Legal basis: Art. 6 (1)(a) GDPR in conjunction with Art. 9 (2)(a) GDPR.
Retention/deletion: Data is only kept for as long as necessary to carry out the request. After 3 months of inactivity, it is automatically deleted.
Service provider: GetResponse, Grunwaldzka 413, 80-309 Gdansk, Poland.

3.2 Contact and support

Purpose: You can contact us by phone or e-mail, or book a support call.
Data collected: Phone number or e-mail address.
Legal basis: Art. 6 (1) sentence 1 (a) GDPR (implied consent).
Retention/deletion: Depends on the type of request.
Service provider: Calenso, Sonnmatthof 3, 6023 Rothenburg, Switzerland (when booking a support call).

3.3 Sending information to medical and psychotherapeutic professionals

Purpose: To provide information about the therapies we offer, we send information material to healthcare professionals.
Data collected: Address (from publicly available sources).
Legal basis: Art. 6 (1) sentence 1 (f) GDPR; the legitimate interest lies in providing information about the therapies we offer.
Retention/deletion: Should you object to receiving these mailings, you can assert this either via support or in writing, in which case we will remove you from our distribution list.
Service provider: none.

3.4 Sending advertising and information material and trial accesses

Purpose: As a healthcare professional, you can order a trial access and information material to hand out to your patients. We store the data in our CRM for processing and follow-up.
Data collected: Address for sending the flyers, or your e-mail address for sending the trial access.
Legal basis: Art. 6 (1) sentence 1 (a) GDPR, Art. 6 (1) sentence 1 (f) GDPR; the legitimate interest lies in tracking shipments and obtaining feedback, as well as in advising and providing information about similar products.
Retention/deletion: Data is deleted without delay upon a deletion request.
Service provider: Pipedrive OÜ, Paldiski mnt 80, Tallinn 10617, Estonia; MailerLite Limited, 38 Mount Street Upper, Dublin 2, D02 PR89, Ireland.

3.5 Planning of CME events

Purpose: You can find information about, and register for, upcoming CME (Continuing Medical Education) training courses on relevant topics on our website. These courses are usually run together with partners, who are identified during registration. To award CME points, the data is forwarded to the respective State Medical Association (Landesärztekammer).
Data collected: Name, e-mail address, professional group, uniform continuing education number (EFN).
Legal basis: Art. 6 (1) sentence 1 (a) GDPR.
Retention/deletion: Data is retained until the event has been completed.
Service provider: Pipedrive OÜ, Paldiski mnt 80, Tallinn 10617, Estonia; MailerLite Limited, 38 Mount Street Upper, Dublin 2, D02 PR89, Ireland.

3.6 Sending newsletters

Purpose: You can subscribe to our newsletters.
Data collected: Name, e-mail address, and your professional group.
Legal basis: Art. 6 (1) sentence 1 (a) GDPR.
Retention/deletion: Data is stored until you revoke your consent.
Service provider: Pipedrive OÜ, Paldiski mnt 80, Tallinn 10617, Estonia; MailerLite Limited, 38 Mount Street Upper, Dublin 2, D02 PR89, Ireland.

3.7 Support with redeeming statutory health insurance prescriptions or e-prescriptions (prescription service)

This processing operation is covered in the privacy policy of the digital health application.

3.8 Raffles

Purpose: As part of surveys, we may offer participation in a raffle as an incentive.
Data collected: E-mail address.
Legal basis: Art. 6 (1) sentence 1 (a) GDPR.
Retention/deletion: Once the raffle has been carried out, the e-mail address is deleted without delay.
Service provider: none.

3.9 Processing in the context of selective agreements with private health insurers

Purpose: Where a cooperation with a private health insurer exists, we may offer you a way to redeem prescriptions.
Data collected: Name, e-mail address, postal address, health insurer, image of the health insurance prescription or printed e-prescription, phone number.
Legal basis: Art. 6 (1) sentence 1 (a) GDPR and Art. 9 (2) sentence 1 (a) GDPR.
Retention/deletion: Data is forwarded directly and not stored.
Service provider: none.

3.10 On-demand webinar

Purpose: You can watch webinars on our homepage. Afterwards, a certificate of participation is created and sent to you. Data is stored in the CRM for evaluation and follow-up.
Data collected: E-mail address, name, address of the institution.
Legal basis: Art. 6 (1) sentence 1 (a) GDPR and Art. 6 (1) sentence 1 (f) GDPR.
Retention/deletion: Data is forwarded directly and not stored.
Service provider: Webinargeek, Einsteinlaan 28, 2719 EP Zoetermeer, Netherlands; Pipedrive OÜ, Paldiski mnt 80, Tallinn 10617, Estonia.

4.2 CAPTCHA Fox

We use CAPTCHA Fox from Scoria Labs GmbH, Fokkerstr. 2, 85399 Hallbergmoos, to help protect our forms against bots. CAPTCHA Fox is integrated directly into the forms. No data is stored.

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 page in the respective social network is processed for market research and advertising 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 a matter has been conclusively processed 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, for example the sending of a whitepaper, 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 it is 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, for example to subscribe to a newsletter, the legal basis for the processing is Art. 6 (1)(a) and Art. 7 GDPR.

We embed YouTube videos on our website. These are hidden and can only be viewed by clicking the “Load video” button. The YouTube privacy policy, which is linked above the button, then applies.

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, and we do not have any information on this. For further information, please check the privacy policies of the respective providers mentioned above.

5.2 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 anonymisation of IP addresses is activated by default. Due to IP anonymisation, 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 behaviour 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 analyse 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 10 July 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
The legal basis for this data processing is your consent in accordance with Art. 6 (1) sentence 1 (a) GDPR and Section 25 (1) sentence 1 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:

a. not giving your consent to the setting of cookies, or
b. 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/en/ and at Privacy & Terms – Google .

5.3 Google Ads and 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 recognise 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 the first sentence of Art. 6 (1)(a) GDPR.

5.4 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 analyse user behaviour. In order to improve the website, we examine the behaviour of users on the website, which areas are visited for long periods of time and what the click behaviour 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 anonymised 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/en-us/concern/privacy.

5.5 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)(f) 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.

5.6 The Trade Desk website pixel

This website uses The Trade Desk technology from The Trade Desk Ltd, 1 Bartholomew Close, London EC1A 7BL, United Kingdom, to collect and store data for marketing and optimisation purposes. Among other things, pseudonymised 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.

5.7 Microsoft Teams

We use the Microsoft Teams service, provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, in order to prepare and conduct meetings online. The following data is processed:

  • Registration data

    • name,

    • e-mail address,

    • telephone (if connected via phone),

    • password,

  • Meeting data

    • subject,

    • participant IP address,

    • device information,

    • video and audio data (if camera or microphone are used),

    • text data (if you use the chat function).

Microsoft necessarily has to obtain knowledge of this data in order to conduct the seminars, as far as provided for in the data processing agreement. As a rule, we do not record the seminars. Should a seminar be recorded, the organiser will inform you in advance and ask for your permission.

A transfer of the data to Microsoft’s servers in the USA is possible.

The legal basis for use is Art. 6 (1)(f) GDPR; our legitimate interest lies in the effective organisation and conduct of online events.

Further information on data protection at Microsoft can be found at https://www.microsoft.com/en-us/privacy/privacystatement.

6 Your rights

You can best exercise each of the following rights by sending an e-mail to support@mementor.de.

You have the right to:

  • information about the personal data we process about you pursuant to Art. 15 GDPR;

  • rectification of inaccurate personal data, or completion of the personal data stored by us, pursuant to Art. 16 GDPR;

  • erasure of your personal data stored by us pursuant to Art. 17 GDPR;

  • restriction of the processing of your personal data pursuant to Art. 18 GDPR;

  • receive the personal data you have provided to us in a structured, commonly used and machine-readable format, or to request its transfer to another controller, pursuant to Art. 20 GDPR;

  • where processing is based on Art. 6 (1) sentence 1 (f) GDPR, object to the processing of your personal data pursuant to Art. 21 GDPR;

  • lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR;

  • revoke consent you have given pursuant to Art. 7 (3) GDPR.

7 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

mementor DE GmbH
Karl-Heine-Strasse 15
04229 Leipzig
Germany
dataprivacy[at]mementor.de

8 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 offerings.