We are committed to protecting your privacy. This privacy policy applies to all the web pages related to this website, the dbTrack mobile application and the dbTrack web-portal. All information gathered on the website is used to personally identify users that subscribe to this service. The information will not be used for anything other that which is stated in the Terms & Conditions of use for this service. None of the information will be sold or made available to anyone. The website may collect certain information about your visit, such as the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet; the date and time you access the website,; the pages that you access while at the website and the Internet address of the website from which you linked directly to this website. This information is used to help improve our Service, analyze trends, and administer the Site. We may need to change this policy from time to time in order to address new issues and reflect changes. We will post those changes here so that you will always know what information we gather, how we might use that information, and whether we will disclose that information to anyone. Please refer back to this policy regularly. If you have any questions or concerns about our privacy policy or send us an E-mail.

By using this website, you signify your acceptance of our Privacy Policy. If you do not agree to this policy, please do not use our site. Your continued use of the website following the posting of changes to these terms will mean that you accept those changes.

This dbTrack mobile application collects some Personal Data as well as listening behaviour data and hearing screening data, considered as Usage Data and geolocation data from its users.

Personal Data and Usage Data collected for the following purposes and using the following services:

1. Access to third party services’ accounts

1.1 Access to the Facebook account
If login is permitted via Facebook, the permissions include: Email, Name, Surname, user device id , device type and device operating platform.

1.2 Access to the Google account
If login is permitted via Google, the permissions include: Email, Name, Surname, user device id , device type and device operating platform.

2. Analytics

2.1 Google Firebase Analytics and Analytics collected directly
Personal Data and Usage data

3. Hosting and backend infrastructure

3.1 Amazon Web Services
Personal Data: various types of Data as specified in the privacy policy of the service Usage Data: listening behaviour and hearing screening data

4. Infrastructure monitoring

4.1 Crashlytics
Personal Data: various types of Data as specified in the privacy policy of the service

5. Usage and Location-based

5.1 Geolocation and Non-continuous geolocation
Personal Data: geographic position limited to city/town Usage Data: listening behaviour data

6. Registration and authentication

6.1 Facebook Authentication
Personal Data: various types of Data as specified in the privacy policy of the service.
6.2 Direct registration
Personal Data: email address, first name, last name, gender, city / town of residence.
6.3 Gmail registration
Personal Data: email address, first name, last name, gender, city / town of residence.

7. Contact information

Data owner
hearX SA Pty (Ltd)
Owner contact email info@hearxgroup.com

1. Data Controller and Owner

hearX SA Pty (Ltd)
Owner contact email: info@hearXgroup.com

2. Types of Data collected

2.1 Users
Among the types of Personal Data that this Application collects, by itself or through third parties, are: first name, last name, gender, email address, geographic position up to city/town level and country, hearing loss status, if this is known to the User.
Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User, or collected automatically when using this Application. Any use of tracking tools by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for this Application to provide its services. Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner. The Usage data that this Application collects are: listening behaviour data which is the sampling of the sound played inside the ear canal to determine the loudness level measured by the earphones, anonymised hearing test results, geographic position up to city/town level and country if the permission for this information was granted by the User.

2.2 Minor Users
Personal Data: When creating an account for your child, personal information like their first name, last name, year of birth, gender and if they have a known hearing loss problem are collected.
The Usage data that this Application collects for minor users are: listening behaviour data which is the sampling of the sound played inside the ear canal to determine the loudness level measured by the earphones, anonymised hearing test results, geographic position up to city/town level and country if the permission for this information has been granted.

3. Mode and place of processing the Data

3.1 Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
Usage Data is anonymised and stored separately from Personal Data of users.. Anonymised Usage Data may also be used for research or other types of analysis or processing by the Owner or an approved third party.

3.2 Place
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

3.3 Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document (including the retention of anonymised testing data for research purposes). The User can request that the Data Controller suspend or remove any identifiable or unprocessed data.

3.4 The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, and for the following purposes: Access to third party services’ accounts, Analytics, Contacting the User, Hosting and backend infrastructure, Infrastructure monitoring, Interaction with external social networks and platforms, Location-based interactions, Managing support and contact requests, Registration and authentication, Social features, anonymised data processing, analysis and research, as well as User database management.
The Personal Data used for each purpose is outlined in the specific sections of this document.

4. Facebook permissions asked by this Application

This Application may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:

4.1 Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their location. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

4.2 Contact email
Access the User’s contact email address.

4.3 Email
Provides access to the User’s primary email address.

5. Detailed information on the processing of Personal Data
6. Additional information about Data collection and processing

6.1 Legal action
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

6.2 Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

6.3 System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).

7. Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

8. The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services used honour the “Do Not Track” requests, please read their privacy policies.

9. Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

10. Information about this privacy policy

The Data Controller is responsible for this privacy policy

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number or test results.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Minor User

The individual, not of legal age, using this Application, with the permission from a parent/legal guardian that accepted the Terms of Use on behalf of the Minor User, and to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware and software tool by which the Personal Data of the User is collected.

This privacy policy relates solely to this Application. dbTrack is intended as a listening behaviour tracking application with additional hearing ability screening tool to provide listening behaviour history data and hearing status to Users.