Privacy Policy (Trial)


Welcome to our privacy policy which applies to the services we provide through our app and headset software.

There may be times when we collect your personal data and when we do we will always respect your privacy and protect your personal data. This is why our policy is to take steps to ensure that your data and privacy rights are protected and to be clear about our personal data practices.

The purpose of this privacy policy is to explain what data we collect, how we use it and how you can control it.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Hearing Diagnostics Limited collects, stores, uses, transfers and shares your personal data through your use of our app and related headset software.

We keep our privacy policy under regular review and reserve the right to update this privacy policy from time to time. If we make any material changes, we will notify you by email (sent to the email address if provided) or by presenting you with a new version of this privacy policy. If permitted by applicable law, your continued use of our services after the effective date of an updated version of the privacy policy will indicate your acceptance of the privacy policy as modified.

Our details

We are a limited company registered in Scotland under company number SC575929 and have our registered office at Suite 2, Ground Floor Orchard Brae House, 30 Queensferry Road, Edinburgh, United Kingdom, EH4 2HS. We are the controller and responsible for your personal data (collectively referred to in this policy as “Hearing Diagnostics”, “we”, “us” or “our”). If you have any questions about this privacy policy or our data practices, you can contact us on the information below:

Email address:

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Personal Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect personal data about you in a variety of ways. Sometimes we collect the personal data directly from you and at times we may receive personal data about you from other sources and third parties. We also collect personal data automatically when you interact with our app and software.

This personal data is being collected through your participation in our research trial and we will be collecting data that we need in order to fulfil our research objectives and enable us to further develop our products prior to making them available to the wider public.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Health Data includes any personal data you choose to provide about your health, physical and mental well-being.
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our app and software.
  • Usage Data includes information about the frequency of use of our services, areas and features that you access, visit or use and engagement with particular features.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Data from external sources. We may receive personal data about you from various third parties, like information to enhance or supplement existing user information or for statistical purposes and analytics.

Children’s Data

The app and software are not intended for children and we do not knowingly collect personal information about children under 13 years old. If you are aware of anyone under the age of 13 using our app and/or software or otherwise providing us with personal data, please contact us and we will take required steps to delete such information.

How we use your personal data

We will not collect and use your personal data without letting you know. Our use of your personal data will primarily be for completing the trial and for research purposes which you have agreed and consented to take part in.

Principles of processing

We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you. We also will not collect any personal data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your approval before we begin that processing.

We will not sell or rent your personal data and will get your consent before giving your personal data to any third party for direct marketing communications.

Purposes for which we will use your personal data

The personal data we collect about you will be used for your participation in our trial for the following purposes:

(1) to provide you with access to our services and fulfil our contract with you; and

(2) as part of our product development for our legitimate interests (to study how customers might use our products/services, to develop them, to grow our business and to inform our marketing strategy).

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties – we will share your personal data with service providers we have appointed to act as our processors, such service providers being based in the UK to provide app and software support services.
  • Where required by law or under any legal order.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Aggregated Data. We may aggregate, anonymize or de-identify your personal data so that it cannot reasonably be used to identify you. Such data is no longer personal data but we will still take care of it. This is done for our legitimate interest as well as the wider societal interest. .

International transfers

We do not transfer your personal data outside the UK or the EEA. If there was any international transfers, we would ensure that a similar degree of protection is afforded to it by having appropriate safeguards in place prior to any international transfer taking place.

Data security

We have put in place reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will limit access to your personal data to those parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Where we have anonymised your personal data (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.

We are committed to providing you with privacy rights in relation to your personal data. Details of the rights you have are set out below. If you wish to exercise any of the rights set out above, please contact us.

Individual Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Your right to be informed: You have the right to understand how we collect and use your data. This privacy policy is our main way of giving you this information but you can also contact us for further information if required.
  • Your right of access: You have the right to ask us for copies of your personal information.
  • Your right of rectification: You have the right to ask us to rectify information you think is inaccurate.
  • Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
  • Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
  • Your right to object to processing: You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.

You can read more about all of these rights at


You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.