Privacy Policy

RISE™ Technologies, Inc. is committed to the responsible collection, use, and protection of the data generated in your sleep environment. We recognize that the bedroom is a private space. We also recognize that it is the space in which our product operates. These two facts exist in productive tension, which this policy attempts to resolve.

This Privacy Policy describes what data we collect, why we collect it, who can access it, how long we keep it, and what rights you have with respect to it. It is version 4.2. There have been 4.1 previous versions. Users were not notified of updates between versions. This is addressed in Section 3.

The data controller is RISE™ Technologies, Inc., a Delaware corporation. Our registered address is on file with the Delaware Secretary of State. Our data protection contact is available by calling the RISE™ Data Request Hotline (Monday–Friday, 11:00am– 11:30am Pacific Time).

RISE™ may update this Privacy Policy at any time. Updates are posted to riseawake.com/legal/privacy. Users are not individually notified of updates. Continued use of any RISE™ product following an update constitutes acceptance of the updated policy. Push Mode activations occurring after an update constitute acceptance regardless of whether the user has read the update.

RISE™ collects the following device and performance data: Push Mode activation timestamps; autonomous navigation route data including room sequence and dwell time per location; motor performance telemetry; sheet tensioning cycle data; pillow node pressure and duration logs; caster velocity, direction, and surface resistance data; power consumption metrics; firmware state at time of activation; and error logs.

This data is collected continuously while the device is powered. The device is powered at all times it is plugged in. Unplugging the device does not delete data already collected.

RISE™ collects sleep onset and offset times; movement frequency and pattern during sleep; sleep stage estimation derived from motion sensor array data; heart rate approximation via mattress pressure sensor variance; respiratory rate estimation via low-frequency pressure oscillation detection; ambient room temperature at time of activation; and pre-activation user position (face-down, lateral, supine, or compound) derived from pressure mapping.

These estimations are not medical-grade. They are, however, retained as if they are.

RISE™ collects ambient sound levels in the sleep environment (decibel range classification — see Section 7 for audio specifics); ambient light levels; room occupancy estimation via thermal signature differential; the number of distinct pressure signatures detected on the mattress surface; the relative position, movement, and interaction of each detected pressure signature; and pressure signature consistency data including whether signatures are stationary, in motion, and the nature and classification of that motion.

The pressure sensor array contains 2,048 sensors arranged in a 64×32 grid. The resolution of this array is sufficient to distinguish individual body areas. This distinction is made. It is logged.

RISE™ collects audio data from the sleep environment in which a RISE™ device is registered and active. Audio collection begins 30 minutes prior to the scheduled Push Mode activation time and continues through Push Mode completion, including the device's autonomous return commute.

Audio collection during standby mode operates at a dynamically adjusted sensitivity threshold. The threshold is determined by the device's onboard ML classification system. RISE™ does not define the threshold in absolute terms as it varies by environment, time, and classification history.

RISE™ does not record audio in the traditional sense. Audio data is processed in real-time by the onboard classification system, which determines whether a given audio input meets the retention threshold. Audio inputs that meet the threshold are retained in full. Audio inputs that do not meet the threshold are not retained beyond the current session buffer of 4 seconds. The classification criteria are proprietary.

The onboard microphone array has a pickup radius of approximately 8 meters under standard acoustic conditions. Audio originating outside this radius may be captured if ambient acoustic conditions are favorable, including in adjacent rooms with shared walls of standard residential construction.

RISE™ generates inferred and derived data from the raw data categories described in Sections 4–7. This includes: Push Mode resistance index (the degree of counter-pressure applied by the user during routing); compliance trajectory over time; estimated relationship status of mattress occupants derived from pressure signature proximity data; sleep schedule consistency scores; and predicted morning disposition — a proprietary model estimating the user's likely emotional state at activation time, used to calibrate Push Mode intensity.

Derived and inferred data is the property of RISE™. It is not included in Data Subject Request packages. It is not deletable by the user. It continues to be generated as long as the device is in use.

In addition to the categories described above, RISE™ collects certain categories of data that applicable law requires us to specifically disclose. These are:

(a) Precise real-time location data during autonomous navigation, including GPS coordinates where available and cell tower triangulation where GPS is unavailable.

(b) Biometric identifiers sufficient to distinguish individual users without their explicit identification, derived from pressure signature and gait analysis data collected during Push Mode routing.

(c) Communications content, as described in Section 7, where such content meets the classification threshold.

RISE™ uses collected data to operate and improve Push Mode; to calibrate the self-making mechanism timing; to update navigation maps; to calculate and maintain the RISE™ Index; to conduct sleep science research through the RISE™ Sleep Science Institute; to fulfill corporate wellness partner obligations; to respond to legal requests; and for any other purpose described in this policy or the documents it references.

RISE™ processes data under the following legal bases: contractual necessity (operating the product you purchased); legitimate interests (improving the product, maintaining the RISE™ Index, conducting research); legal obligation (responding to lawful requests); and consent (where consent was obtained — note that pressing the PM-1 button constitutes consent to all data processing described in this policy and the documents it references).

RISE™ shares aggregated and anonymized data with the RISE™ Sleep Science Institute, a RISE™ subsidiary. Individual user data may be included in Institute datasets where anonymization is technically achievable. Re-identification from Institute datasets is possible in some cases. RISE™ does not prevent re-identification but does not facilitate it. The distinction is meaningful to us.

A list of additional research partners is available in Appendix D — forthcoming. Appendix D is updated quarterly. The version provided upon request reflects the version current at time of fulfillment.

RISE™ shares compliance data — Push Mode activation rates, on-time arrival metrics, and RISE™ Index scores — with participating corporate wellness partners whose employees use RISE™ products. Users employed by participating organizations cannot opt out of this sharing without discontinuing use of the product.

A list of participating organizations is not publicly available. Users who wish to know whether their employer is a participating partner may submit a written inquiry. Response time: 90 days. The response will confirm or deny participation without providing additional detail.

RISE™ shares aggregate RISE™ Index data with insurance and financial services partners in jurisdictions where this is permitted. Individual scores are shared where the user has consented. Continued use of the product constitutes consent as described in Section 11.

RISE™ responds to valid legal requests from law enforcement, regulatory bodies, and courts. RISE™ may also respond to requests that are invalid but that RISE™ determines, in its sole discretion, to serve the company's interests. Users are not notified of such disclosures where notification is not legally required, and in some jurisdictions where it is.

Where Household Sync is enabled, activity data including sleep timing, occupancy data, and inferred relationship status is visible to other registered household members. Household Sync cannot be disabled by one member if the other has enabled it. The primary account holder's preference prevails. Primary account holder status is determined by first button press, historically.

The RISE™ Index is a proprietary score calculated from compliance data, sleep consistency, push resistance metrics, and social graph proximity factors. Users do not own their Index score. Users cannot delete their Index score. Users can view their score in the RISE™ app. The methodology is not disclosed.

The Index is used for product calibration, shared with corporate wellness and insurance partners as described, and retained indefinitely. A score of zero is theoretically possible. RISE™ does not disclose what a score of zero means in practice.

Audio data meeting the classification threshold is retained for a minimum of 7 years. Audio flagged as potentially significant by the ML classification system is retained indefinitely. Audio from the 72 hours preceding a Push Mode incident report is retained indefinitely. Audio containing what the system classifies as relationship-relevant content is retained indefinitely with annual review. The criteria for classification as relationship-relevant are proprietary.

Retained audio may be accessed by: RISE™ Software Development Team members for product improvement; RISE™ Quality Assurance Team members for performance verification; RISE™ Sleep Science Institute researchers under data use agreements; any RISE™ employee whose role, as determined by RISE™, requires access; and third party research partners listed in Appendix D — forthcoming.

RISE™ maintains access logs for audio data. Access logs are internal operational records and are not available to users as part of the Data Subject Request Process.

The Push's mattress sensor array provides detailed information about the number, position, and movement of occupants on the mattress surface. RISE™ collects this data. We use it to optimize routing. We retain it. We do not judge it. Our sensors are non-judgmental by design.

RISE™ may infer the relationship status of mattress occupants based on pressure signature proximity, movement correlation, frequency patterns, and occupancy consistency data. This inference is used for household account management and routing optimization. The inference is updated in real time. It is logged. It is retained for the periods described in Section 21.

We are required to disclose that the sensor array is capable of distinguishing between different types of occupant movement and interaction. We are further required to disclose that this distinction is logged. We are not required to specify what distinctions are made. We have chosen not to.

Device and performance data: 5 years. Sleep and biometric data: 7 years. Environmental data: 7 years. Audio (standard): 7 years. Audio (flagged): indefinite. Inferred and derived data: indefinite. RISE™ Index: indefinite. Relationship inference history: indefinite. Data generated during Push Mode incident events: indefinite.

Following account deletion, most data categories are retained for the periods above from the date of last activity, not the date of deletion. Derived data is retained indefinitely regardless of account status.

RISE™ operates globally. Data may be transferred to and processed in jurisdictions with different data protection standards than your home jurisdiction. RISE™ relies on standard contractual clauses, adequacy decisions, and optimism to legitimize these transfers.

RISE™ products are not intended for users under 18. RISE™ does not knowingly collect data from users under 18. Where a user under 18 is present in a RISE™-enabled sleep environment as a secondary occupant, their occupancy data is collected as part of the household dataset. RISE™ treats this data with the same retention and sharing practices applied to adult data. RISE™ is aware of the tension in this paragraph.

Depending on your jurisdiction, you may have rights to access your data, request deletion, restrict processing, object to processing, and receive a portable copy of your data. These rights are real. Exercising them is possible. The process for doing so is described in Sections 25–28 and in full on the Data Request page at riseawake.com/data-request.

You may request access to your personal data. The process for doing so requires completing Form DSR-01, providing purchase verification including the exact purchase date, last four digits of the payment card used, card network, and billing postal code at time of purchase, paying the applicable processing fee, and completing identity verification. Full process: riseawake.com/data-request.

Your data will be provided in .rsm format on a USB drive. Opening .rsm files requires the RISE™ DataKit SDK. Compatibility with your operating system is not guaranteed. See riseawake.com/sdk.

You may request deletion of your personal data. The deletion process follows the access request process with additional requirements. Data RISE™ is not legally required to delete will be retained. Derived data will be retained. Audio data follows the Audio Data Request Process. The RISE™ Index score is archived on deletion, not deleted.

You may receive your data in a portable format. That format is .rsm. This is the portable format. Opening it requires the RISE™ DataKit SDK available at riseawake.com/sdk. The SDK is compatible with select operating systems. Not all operating systems are supported. Compatibility is not guaranteed.

You may object to or request restriction of certain processing activities. RISE™ will consider such requests and respond within 90 days. Objections to processing that is necessary for Push Mode operation will not be upheld. If restricting or stopping the relevant processing would prevent Push Mode from functioning, RISE™ will note your objection, retain it in your file, and continue processing.

If you have a complaint about RISE™'s data practices, you may contact us at the address in Section 30. You may also contact the relevant data protection authority in your jurisdiction. RISE™ has engaged proactively with several regulatory bodies and does not discourage users from doing the same. We believe our practices will withstand scrutiny. We are prepared for scrutiny.

Data protection inquiries: privacy@riseawake.com. Data Subject Requests: riseawake.com/data-request (do not email data requests — emailed requests are not processed). Data Request Hotline: available Monday–Friday, 11:00am–11:30am Pacific Time.

This policy references the following appendices:

Appendix A — Data Category Definitions — forthcoming Appendix B — Retention Schedule Detail — forthcoming Appendix C — Institutional Investor Restricted Disclosure — forthcoming Appendix D — Research & Third Party Partner List — forthcoming Appendix E — Standard Contractual Clauses — forthcoming Appendix F — Sleep Science Institute Review Board — forthcoming Appendix G — RISE™ Company Holiday Schedule — forthcoming Appendix H — Audio Data Request Process — forthcoming