T-MINUS MOBILE APPLICATION PRIVACY POLICY

INTRODUCTION

This policy (together with our end-user licence agreement as set out at www.t-minus.info/EULA (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

  • T-Minus mobile application software (App) available on our site and hosted on the Apple App Store distribution platform https://www.apple.com/uk/ios/app-store/ (App Site), once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of our services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites).
  • This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: http://www.t-minus.info/privacypolicy/privacy.pdf

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

11. DESCRIPTION OF CATEGORIES OF PERSONAL DATA

IMPORTANT INFORMATION AND WHO WE ARE

T-TINNITUS LTD trading as T-Minus (collectively referred to as "Company", "we", "us" or "our" in this policy) is the controller and is responsible for your personal data.

Contact details

Our full details are:

  • Full name of legal entity: T-TINNITUS LTD trading as T-Minus.
  • Email address: hello@t-minus.info. 
  • Postal address: 110 – 112 Lancaster Road, New Barnet, Hertfordshire, EN4 8AL.

Persons in the EU have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 11 September 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.  Where you have provided us with your email address, we may also email you the updated version of the policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The following is a list of third party apps or sites that are currently utilised in the app. It is the responsibility of the user to read and agree to the appropriate privacy policy of each individual service if they plan to access that website or service via the app.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of data about you as follows:

  • Content Data.
  • Usage Data.
  • Marketing and Communications Data.
  • If you do not sign up to a Service, the Content Data and Usage Data that we collect will be collected on an aggregated basis and will not be linked to you.

Where you sign up to a Service, we will collect Content Data and Usage Data that may be linked to you.  We will also collect:

  • Identity Data.
  • Contact Data.
  • Profile Data.

We explain these categories of data in detail at the end of this policy.

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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. 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.

Where you use the journal function to record any information about your experience of and/or thoughts and feelings regarding tinnitus, we will be recording your personal health information.  Use of the journal function is entirely voluntary and we will be collecting and processing any information that you choose to record on the basis of your consent.  Please do not use the journal function unless you consent to the collection and processing of this information in accordance with this policy. You can withdraw your consent at any time by deleting such content or by letting us know. Other than that, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We do not track your activity across third-party websites, and we do not knowingly allow other parties to collect personal information about your online activities over time and across third-party websites when you use our Site.

Note that, under California Civil Code Section 1798.83, a California resident with whom we have an established business relationship may request a list of third parties to which we, during the immediately preceding calendar year, have disclosed certain personally identifiable information for direct marketing purposes. We do not share personal information about such individuals with third parties for their own marketing purposes.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Device Data from analytics providers such as Firebase (powered by Google) and Apple;
    • Contact Data from providers of technical, payment and delivery services such as Worldpay;
    • Identity and Contact Data from data brokers or aggregators;
  • (in each case based inside and outside the EU), and
    • Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the EU.
  • Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you, as set out in the EULA.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Please refer to Glossary: Lawful basis to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications via the App and/or by email if we have your consent, unless the law allows otherwise. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity
Contact
Financial
Device

Your consent

To process in-App purchases and deliver Services including managing payments and collecting money owed to us

Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Location

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services

Identity
Contact
Financial
Profile
Marketing and Communications

Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity
Contact
Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content (including but not limited to: sound therapy library, tinnitus related news and links, FAQ articles, and access to our community hub) and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications

Necessary for our legitimate interests (to develop our products and services and grow our business)

(For direct marketing only) Opt-in consent

DISCLOSURES OF YOUR PERSONAL DATA

We will share your personal data with the third parties set out below for the purposes set out in the Purposes for which we will use your personal data table above:

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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.

INTERNATIONAL TRANSFERS

If you are located outside the EEA and have signed up to use our App, your personal information will be transferred to our servers located in the EEA. We will comply with the relevant data protection laws applicable to us, including the General Data Protection Regulation and United Kingdom Data Protection Act 2018, to ensure a sufficient level of protection of your personal information. Please refer to the information set out in the Data security section below.

Our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

DATA RETENTION

Your personal data will be processed for as long as necessary to fulfil the purposes we collected it for (as outlined in the How we use your personal data section above). For example, we will process your personal data for as long as necessary to continue to provide you with the App.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of three years then we will treat the account as expired and your personal data may be deleted.

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer or your personal data
  • Right to withdraw consent

Please refer to Glossary: Your legal rights for further elaboration of these terms.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at hello@t-minus.info.

GLOSSARY

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties

Other companies in the T-Minus group acting as joint controllers or processors and who are based within the EEA and support us in the provision of the App and Services.

External third parties

Professional advisers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.

Relevant organisations and entities providing services (medical or non-medical related) within the tinnitus market, whether of a commercial or non-commercial nature, both within and outside the EEA.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Your legal rights

Persons in the EEA have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data's accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

  • Identity Data: first name, last name, username or similar identifier, title, date of birth, gender.
  • Contact Data: billing address, delivery address, email address and telephone numbers.
  • Transaction Data: includes details about payments to and from you and details of in-App purchases.
  • Device Data: includes the type of mobile device you use, your mobile operating system, the type of mobile browser you use, time zone setting.
  • Content Data: includes information stored on your Device, including the music that you have streamed and/or added to your library.
  • Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
  • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.