eargym Privacy Policy

Effective: 25th July 2024

Introduction
 

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your sensitive information and how we will deal with it. For the purposes of the Data Protection Act (‘the DPA’) and the EU General Data Protection Regulation (‘the GDPR’), sensitive information includes what is defined as your ‘personal data’

 

By visiting https://www.eargym.world (the ‘Website’) you accept and consent to the practices described in this Privacy Notice including the processing of your personal data under this lawful basis. In this Privacy Notice, we seek to abide by the letter and spirit of the guidelines laid out by the UK Information Commissioner’s Office in the document ‘Accountability Framework'.

 

Who We Are

 

eargym Ltd (Company Number 12589955) is a digital hearing health company located at 63-66 Hatton Garden, London, EC1N 8LE, UK. For the purposes of the DPA and in-line with the GDPR, eargym is the Data Controller.

 

How to Contact Our Data Protection Officer (DPO)

 

eargym has assigned Andrew Shanks, CTO, as our data protection officer in charge of protecting your data. If you have any concerns about the way we use your information or any questions about this Privacy Notice, please let us know. You can contact the eargym DPO on DPO(at)eargym.world.

 

How to Report When An Individual Below 16 is Using the eargym App

 

If you are concerned that an individual below 16 years old is using the eargym app or providing personal data, you can report that to the Data Protection Officer on the address above and we will investigate and address appropriately and permanently delete all their data within 15 working days. Please include as much detail as possible including the identity of the individual below 16 years old and their parents, your relationship to the individual and what email address has been used to create their account if known.

 

What we do with your information

 

We will use your information to:

 

• Send our newsletter to you and to send you information about the services that we offer and other related topics;

• Collect feedback from you about our services and our website;

• Deliver our services to you and to improve our service offering and your user experience;

• Provide commercial services to our customers based on anonymous and aggregated data created by people; and

• Contact you with information about the services we provide by other agreed means.

 

We compile statistics about user trends on our website and app, which are used by third-party organisations to understand how users interact with businesses, brands and one another online and to advise about these things. These statistics are drawn from a dataset which does not contain any information from which you can be identified.

 

If you pay to access our commercial services then your data will be processed on the legal basis of the performance of a contract.

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Information we collect from you

 

We will collect and process the following information about you:

 

Information you give us

This is information about you that you give us by interacting with our app, filling in forms on our website by corresponding with us by phone, email or otherwise. We only request from you the minimum data required for you to use our service. The information we require from you to sign up to our mailing list may include your email address, full name, town, job role and company.

 

Information we collect about you

Whenever you visit our website we will automatically collect the following information:

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- Technical information - including the Internet protocol (IP) address used to connect your computer to the  Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

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- Information about your visit - this includes the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), pages you have visited, page response times, download errors, length of visits to certain page and page interaction information (such as scrolling, clicks, and mouse-overs).

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App usage information

Whenever you use our app we will automatically collect information about your usage such as when you used the app, which features you used and for how long. We also save the information generated by your engagement with the app, personal information about you, the hearing checks and training so we can provide you with a personal experience on the app.

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Data sharing policy

 

We are driven by our mission to contribute data to clinical, academic and industry research into the correlation between hearing loss, social isolation, Mild Cognitive Impairment (MCI) and dementia. To do that we will be working with our academic partners to conduct research into the effectiveness of hearing training and sharing anonymous data with those partners about the efficacy of using our services. All data we provide to our academic partners is anonymised - we will never share your personally identifiable information. We will never share your personally identifiable data with anyone outside of the eargym organisation without your consent, this includes your employer if they are paying for eargym for you. We will share anonymised data with our academic partners to contribute to key research into the correlation between hearing loss and dementia as well as the efficacy of hearing training. You cannot opt out of this sharing because it is an essential practise to enable us to deliver the best hearing health service possible and ensure the future of the business. 

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Where we hold and what we do with your information 

 

The information and content held on our website is deployed geographically to maximise user experience. All information that could identify individuals within the European Union is stored exclusively within the European Union.  We will never share your user information with third parties for promotional purposes.

 

We hold our data with Firebase, Wix, Typeform, MailChimp, and MixPanel who are contracted by us for the provision of technical services. We remain responsible at all times for the security of your information

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We store our documents and certain customer information in our password encrypted Google Suite. You can learn more about Google and how they handle personal data here. 

 

We deliver our emails to you using MailChimp and Wix. You can learn more about MailChimp and how they handle your personal data by visiting their website here.

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What we do to ensure the security of your personal information

 

We take the security of your personal data very seriously. Our approach to information security is constantly evolving and continually reviewed.

 

We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business;  your personally identifiable information such as name and email address are kept separate from your other hearing data using pseudonymisation. ​ eargym has Cyber Essentials Plus certification which demonstrates our high level of commitment to cybersecurity; this certification ensures that eargym has robust measures in place to protect sensitive data and systems from cyber threats

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Sensitive information security policy

 

Any sensitive user data is stored in Google’s Firebase database. Firebase uses Pseudonymisation to separate personally identifiable data and high standard encryption services. Firebase services encrypt data in transit using HTTPS, logically isolate customer data and also encrypt data at rest. More information here:

https://firebase.google.com/support/privacy 

Firebase meets these standards - ISO 27001 ISO 27017 ISO 27018 SOC 1 SOC 2 SOC 3

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Your rights regarding your personal information

 

We may contact you via email with updates about the services that we offer or any changes that we have made to our Website. You can opt in or out at any time by clicking the ‘Unsubscribe’ link in our emails.

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Your rights

 

You have the right to find out about what information we hold about you. You can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days. To make a request for information please contact privacy(at)eargym.world and a member of our team will be in touch.

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If your personal data is incorrect then you have the right to rectify this information and ensure that it is accurate and up to date.  If your data is incorrect then please contact us at the email address above and a member of the team will rectify this on your behalf.

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You have the right ‘to be forgotten’ and to have your personal identifiable information permanently deleted from our systems.  Again, if you would like to exercise this right then please contact us at DPO(at)eargym.world.

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There will be no charge made for reasonable electronic access to your information, your right to rectification or for your right to be forgotten from our systems.

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How long we hold your information for

 

We will keep your personal data indefinitely while you are a customer and will delete it 24 months after you stop being a customer in case you want to come back and renew our services and access your hearing health record.  Of course, you have the right to be forgotten at any point and can find out more about this in the ‘Access to Information’ section above. Research participants data will be stored indefinitely, and if applicable identifiable data will be deleted as soon as it is no longer required for the study.​

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Changes to this Privacy Notice

 

Any changes we may make to our Privacy Notice in the future will be posted on this page. The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of our services.​

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Our Cookie Policy

 

If you’d like to manage your use of cookies or completely turn off cookies then you can find out how to do so by using the link here.  Please note that if you do limit or block cookie use on our Website the functionality of both the website and our services will be affected.

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Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site.  By continuing to browse the website, you agree and consent to our use of cookies.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
 

As part of our overall approach to privacy and transparency, this section describes what cookies are in the context of our web and mobile interfaces, and what their use means to you. At the end, we've included some links to help you research cookies and their impact, and how you can use your web browser to control the way it manages cookies.

 

We use the following types of cookies:

 

Strictly necessary cookies - these are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-payment system.

 

Analytical/performance cookies - these allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

 

Functionality cookies - these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

 

Targeting cookies - these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but these cookies will contain no information capable of identifying you personally to us.

 

You can find more information about the individual cookies we use and the purposes for which we use below:​

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Google Analytics

We use Google Analytics to understand general trends about our website and app content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the amount of visits we receive.
 

Google's statement about privacy can be found here.

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X button

The X button allows our users to share our platform and services with their followers more easily.

X's privacy policy states they use cookies "to collect additional website usage data and to improve our services" – You can read the policy in full here.

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Facebook button

We use the Facebook button to allow you to share out site with your friends and other Facebook users.

Facebook's statement about privacy relating to their Connect feature is here and also here.

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More information about cookies

Still don’t know what cookies are?  Then why not follow the link conveniently located here which provides more information about what they are and how they work.

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Contact the Information Commissioner if there is a problem

If you consider we have not addressed your problem, you can contact the UK Information Commissioner’s Office for assistance. Further information can be found here.