Privacy Policy & Terms of Use

Privacy Policy

It is the policy of NRTHRNLIGHTS to respect your privacy, and the privacy of all users of our applications. This Privacy Policy (the “Policy”) has been established to help you understand our commitment to protecting your privacy, and the steps we take to ensure it. This Policy was last modified on January 8, 2026. NRTHRNLIGHTS reserves the right, at any time and without prior notice, to modify the Policy.

Your privacy is very important to us and we want you to know everything we do and don’t do with the information you provide. Our guiding principle is that any information we collect from you will be treated with the utmost care and respect, and every effort will be made to ensure the information is kept private.

For purposes of the Policy, “Application” refers to TwinSleep or TwinSleep AI cloud service, as the case may be. Application also includes any Application updates and upgrades that NRTHRNLIGHTS may provide to you or make available to you, or that you obtain after the date you obtain your initial copy of the Application, to the extent that such items are not accompanied by a separate Privacy Policy.

For purposes of the Policy, “Service” refers to the TwinSleep AI cloud service.

Where the present Policy refers to TwinSleep, it may refer to the Application or NRTHRNLIGHTS or both, depending on the context.

BY INSTALLING, USING OR ACCESSING THE APPLICATION, YOU HEREBY ACCEPT THE POLICY WITHOUT QUALIFICATION. You have also explicitly accepted the Terms and Privacy Policy following your installation of the Application and launch of the Application for the first time. If you do not agree to this Policy, do not use or access the Application, and delete it from the device on which the Application was installed (the “Device”).

If you have any questions about the Policy, please contact:

Kevin Kolasinski
kevin@nrthrnlights.com

TwinSleep does not gather any of your personal information while you are using the Application, except as provided for in this Policy. The app may collect non-identifying information through Google Analytics, such as settings, the version of the app, information about firmware and other non-personal information. It is necessary to enhance the product.

Information We Collect

As a Visitor, you can browse our Website to find out more about our Website and use our Application. You are not required to provide us with any personal information as a Visitor.

We collect your personal information when you register with us via the Application, when you express an interest in obtaining information about us or our products and services (such as email list sign-up), when you participate in activities on our Website (such as commenting on our blog), or otherwise contacting us.

The personal information that we collect depends on the context of your interaction with us and the Application, the choices you make and the products and features you use. The Application has a number of means of creating user-generated data, such as baby information, schedules, and chat messages – we refer to that information as “Content”. We also collect and receive the following types of information:

Name, Email Address and Contact Data.
Payment Information:
If you choose to purchase a subscription via our website, we collect payment information through our payment processor. All payment information is securely stored by our payment processor and we do not have access to your sensitive information, such as credit card number or security code.
Usage Data:
We collect and log data on how you and others access and use the Application, for example, the act of updating schedule information or sending chat messages.
Device Information:
We collect information about the number and type of devices you use to connect to the Application, as well as information about the operating systems on those devices (e.g., iOS, Android, Windows).

We also may link your subscriber information with data we receive from our partners and other third parties to help understand your needs and provide you with a better experience. For example, if you create or log into a Service account using your Google Apps credentials via single sign-on, we will have access to certain information such as your name and email address as authorized in your Google Apps profile settings.

What does TwinSleep do with my information?

We are committed to protecting the privacy of your information. Below, we describe the ways in which we use the information we collect and receive to provide, maintain, and improve the Service; to provide troubleshooting and customer support; to protect the Application for all our users; to contact you; and to administer Service accounts.

To provide accurate results, the Application requires your baby’s exact birthdate—and weeks premature, if applicable. We also suggest using nicknames for your children when referring to them in the Application. This information is stored only on your device and never shared. If you opt to have the app send baby information to the chatbot, only your child’s nickname and adjusted age will be shared, in a format like “6 months, 1 week”.

To provide troubleshooting and customer support, our Customer Support team may need to access your information, such as your account email address and information about the Application you are using, subject to the protections described below.

To prevent against fraud and unauthorized access.

Would someone at TwinSleep ever view my Content?

If you contact our Customer Support team for help with a specific issue with the Application, we may ask for your temporary permission to look at your Content. This permission terminates when the issue is resolved.

To improve our Application, TwinSleep may review conversations to improve AI performance. Conversations are anonymized.

If you send TwinSleep an error report and choose to attach application activity logs, please note that such logs may contain Content (for example, chat messages). You may edit Content out of your activity logs before you send them to us.

If we become aware of a potential violation of our Terms of Service, we may suspend or close your account until the problematic material is removed. Under such a circumstance, we would only look at the Content in your account if you give us consent or if necessary to comply with our legal obligations, including to protect the safety of you or any other person.

To test and improve our product offerings for our users, we use aggregated data that does not contain any personal information, does not identify any person, and cannot be connected to any specific user. This policy is not intended to apply to such anonymized/de-identified data.

How does TwinSleep share or disclose my information?

TwinSleep is not in the business of selling or renting your information. Here are instances when we may disclose your information — and then only the minimum information necessary:

We share your information with Service Providers who process data on our behalf, such as credit card processors and customer management systems. For example, these Service Providers help us:
- Operate, develop, and improve the features and functionality of the Application
- Complete your payment transactions
- Fulfill your sales and support requests
- Communicate with you as described elsewhere in this policy
We require these providers to agree to strict data protection requirements in keeping with our privacy policy standards, the European Union’s General Data Protection Regulation (“GDPR”), and our commitments under our EU-US Privacy Shield and Swiss-US Privacy Shield certifications as discussed below.
We do not share your information with any third parties for their own advertising purposes.
In the event of a merger, sale, or reorganization of all or part of our business, information covered by this policy may be transferred in connection with that deal.

How does TwinSleep respond to legal requests for my information?

We vigilantly protect the privacy of your account. We will not disclose your information to law enforcement or other governmental authorities unless we believe it is required to comply with warrants, court orders, subpoenas, or other lawful government requests. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards of due process.

We narrowly interpret all information requests, and we only disclose Content in your account that is specifically responsive to a government warrant or where you have provided your explicit consent. We will notify you if we believe we are compelled to comply with a third party’s legal demand for your information, and we routinely push back on government orders to delay user notice that we view as overly broad.

In addition, in rare cases, we may share your information as necessary to investigate or take action regarding illegal activities, suspected fraud, or potential threats against persons, property or the systems on which we operate the Service, or as otherwise necessary to comply with our legal obligations.

How can I manage my information stored in TwinSleep?

Your data is yours—in most cases, you can manage your information simply by logging into your account and editing your information directly within the Application.

However, if you prefer, you can contact us at kevin@nrthrnlights.com to ask us to provide access to, correct, update, or delete your personal information. Please note that we may ask you for proof of account ownership and/or identity before fulfilling your request. We will comply with such requests to the extent required by applicable law or the US-Swiss Privacy Shield and US-EU Privacy Shield.

How can I delete my account?

You can delete your account at any time directly from the app. From the Support tab, select your user icon (sign in if not already signed in), then tap “Delete Account”.

A Note for our European Users about our Data Processing Grounds and Data Access Rights

The European Union’s GDPR requires that we provide notice in a specific way to our European users about their privacy rights. We process Account Holder or End User personal information on one of three grounds, depending on the circumstances: (i) your affirmative consent, in which case you will have the right to withdraw consent at any time; (ii) contractual necessity; or (iii) our legitimate interest in providing the Service. In addition, we are required to list the data access right available to all users in a specific way.

How long does TwinSleep store my information?

Logged chat messages are automatically deleted after 30 days. Other account data, including device information, is stored until the account is deleted.

The Service’s backup systems may retain residual copies of your deleted Content due to the nature of those systems’ operations.

What happens if I want to stop using TwinSleep?

As described above, you can delete your account at any time, and you can stop using the Application or Service at any time.

Where does TwinSleep store my information?

When you use the Application on your computing device, such as by using one of our downloadable applications, some of your data will be stored locally on that device.

When you sync your computing device with the Service, that data will be replicated on servers maintained in the United States. This means that if you store information in or submit data to the Service, you acknowledge your personal information will be transmitted to, hosted, and accessed in the United States.

Data privacy laws or regulations in your home country may differ from, or be more protective than, those in the United States. We will collect, store, and use your personal information in accordance with this Privacy Policy and applicable laws, wherever it is processed.

Information Regarding Your Data Protection Rights Under General Data Protection Regulation (GDPR)

For the purpose of this Privacy Policy, we are a Data Controller of your personal information.

If you are from the European Economic Area (EEA), our legal basis for collecting and using your personal information, as described in this Privacy Policy, depends on the information we collect and the specific context in which we collect it. We may process your personal information because:

We need to perform a contract with you, such as when you create Content with us
You have given us permission to do so
The processing is in our legitimate interests and it’s not overridden by your rights
For payment processing purposes
To comply with the law

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the personal information we have on you
The right of rectification
The right to object
The right of restriction
The right to data portability
The right to withdraw consent

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Protecting Your Child’s Privacy

Our Application is not designed for use by anyone under the age of 13 (“Child”), though we realize we may have a Child attempt to make purchases through our Application or register for our service. We do not verify the age of our Users nor do we have any liability for verifying a User’s age. If you are a Child, please seek the permission of a parent or guardian before using our Application or Service. If you are a parent or guardian and believe your Child is using our Application or Service, please contact us to remove your Child’s account; we reserve the right to ask you for verification of your relationship to the Child before we honor such a request. If we discover that a Child has created an account on our Service, we will immediately delete the account as soon as we discover it, we will not use the information for any purpose, and we will not disclose the information to third parties. However, as parent of such a Child, you understand that you are legally liable for any transactions created by the Child.

Links to Third-Party Websites

Our Website may contain links to other websites that are not under our direct control. These websites may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. You access such linked Websites at your own risk. These websites are not subject to this Privacy Policy. You should check the privacy policies, if any, of those individual websites to see how the operators of such websites will utilize your personal information.

In addition, these websites may contain a link to websites of our affiliates. The websites of our affiliates are not subject to this Privacy Policy, and you should check their individual privacy policies to see how the operators of such websites will utilize your personal information.

Updates to Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we choose is at our sole discretion. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.

Contact Us

If you have any questions about our Privacy Practices or this Policy, please contact us.

Terms of Use

The software is provided “AS IS” without any representations or warranties, express or implied.

You accept full responsibility for the use of the software. The developer isn’t responsible for any actions made by you.

The developer does not assume responsibility for loss of data or any other losses that result from any use of the software.

Using the software you must not break the law of the country you live.

The information/advice provided throughout this Application is NOT medical advice. All advice is meant for healthy children, with common sleep difficulties, that are unrelated to any medical conditions. No advice in this call is to substitute medical advice, nor is any information/advice intended to be a substitution for medical advice. Please ALWAYS contact your physician with questions regarding health/feeding concerns, medical conditions, and the general welfare of your child. You agree to consult with and receive approval from your pediatrician before following the advice and/or using techniques in this plan.

All guidance is based on average developmental patterns and may not suit every baby. Sleep training is not for some babies.

In no event will NRTHRNLIGHTS, LLC be liable to you for any claims, losses, injury, or damages occurring due to the use of any information or advice provided during or after using this app. Although attempts have been made to verify all information provided is accurate, we do not assume any responsibility for errors, omissions, or contrary interpretation of subject matter. Reliance on any advice from this app is at your own risk.

TwinSleep AI Terms of Use:

You Won’t Use TwinSleep AI for Anything Illegal or Promote Illegal Activities.
You Won’t Send Messages that are Irrelevant or Lack A Legitimate Purpose.
You Won’t Violate Our Users’ Rights.
You Won’t Annoy or Scam Our Users.
You Won’t Violate IP Rights.
You Won’t Mess With Our Service.
You Won’t Attempt to Copy or Resell Our Service.
You Won’t Pretend to Be Someone You’re Not.
You Won’t Exceed the Scope of Your Authorized Use.
You Won’t Share Objectionable Content.

Adherence with these terms is at the full discretion of the developer. While we hope that all users of the TwinSleep AI service comply with these Guidelines, we must caution you that, notwithstanding these Guidelines and the requirements in our Terms of Service, you may be exposed to offensive, indecent or objectionable content when using the Service. We expect that you understand this and, accordingly, you use the Service at your own risk.