Privacy Policy

hearOS — Tinnitus Awareness & Personalized Sound Routines

Effective date: June 02, 2025 Last updated: June 02, 2025

1. Who We Are

hearOS is developed and operated by ICI Tech Teknoloji A.Ş. ("Company", "we", "us", or "our"), a technology company registered in Turkey.

We process personal data in compliance with the Turkish Personal Data Protection Law No. 6698 (KVKK).

Medical Disclaimer: hearOS is a consumer wellness and self-management support tool. It is not a medical device, regulated health app, telehealth service, or substitute for professional diagnosis, treatment, or clinical care. Descriptions and routines within the app are optional self-tracking ideas only — not individualized medical advice. Experiences vary; consult qualified clinicians for medical decisions.

2. Scope of This Policy

This Privacy Policy applies to:

• The hearOS iOS app (distributed via the Apple App Store)
• The hearOS Android app (distributed via Google Play)
• The hearOS website at https://hearos.app/
• Any related support, marketing, or communication channels operated by us

EEA and UK users: Please also read our GDPR Privacy Notice, which applies to you in addition to this Policy and contains additional rights and protections under the General Data Protection Regulation.

3. Data We Collect

3.1 Account Information

An account is required to use hearOS. We collect:

• Email address
• Password (stored as a one-way hash — we never see your plain-text password)
• Optional: display name, profile photo

3.2 Tinnitus Profile Data

• Guided frequency matching results (estimated perceived tinnitus pitch in Hz)
• Sound profile preferences derived from matching sessions
• Session history and adjustments over time

This data is health-related and is processed only with your explicit consent.

3.3 Hearing Self-Check Data

• Results from the in-app hearing self-check, inspired by common screening formats
• Self-check history and trends

This data is health-related, for personal awareness and tracking only — not a diagnostic audiogram. Processed only with your explicit consent.

3.4 Symptom Diary Data

• Self-reported daily entries for: tinnitus intensity, pain, pressure, dizziness, sound sensitivity, and hearing
• Weekly trend summaries derived from your entries

This data is health-related and is processed only with your explicit consent.

3.5 Sound Therapy Session Data

• Sound content played, session duration, volume preferences
• Completion records, favorites, and listening patterns
• Relief Studio and sleep session history

3.6 Progress and Tracking Data

• Daily relief scores and streak records
• Goals, reminders, and milestone achievements
• App engagement patterns (session frequency, feature usage)

3.7 Microphone / Ambient Noise Data

• Ambient sound level measurements captured when the environment noise monitoring feature is active
• Processed in real time on your device to display noise levels and inform session recommendations

Ambient audio is not recorded, stored, or transmitted to our servers. Microphone access is used only for real-time noise level measurement.

3.8 Subscription and Purchase Data

• Subscription tier and status (active, trial, expired, cancelled)
• Purchase date, renewal date, transaction ID
• Platform of purchase (App Store or Google Play)
• RevenueCat pseudonymous customer ID

We never receive your payment card details. All payment processing is handled by Apple or Google.

3.9 Device and Technical Data

• Device type and model, OS version, app version
• IP address (truncated where possible), time zone and locale
• App session timestamps, crash logs, and error reports

3.10 Push Notification Data

• Device push token (if you grant notification permission)
• Notification delivery and open events

3.11 Communications Data

• Email address and message content when you contact us for support or feedback

3.12 Legal and Compliance Data

• Records required by applicable Turkish law, regulatory correspondence, legal proceedings

4. How We Collect Your Data

5. Legal Bases for Processing

6. How We Use Your Data

Core App Functionality

• Authenticating your account and syncing your data across devices
• Generating your tinnitus frequency profile and personalizing sound routines
• Tracking daily progress, relief scores, and symptom trends
• Displaying ambient noise levels and adjusting session recommendations
• Managing your subscription and unlocking Premium features

App Quality and Safety

• Diagnosing crashes and fixing bugs
• Security monitoring and fraud prevention
• Aggregated usage analysis to improve features

Communications

• Transactional messages (subscription receipts, password resets)
• Recovery reminders and milestone notifications (with your permission)
• Marketing messages (with your explicit consent only)

Legal and Compliance

• Meeting obligations under Turkish law
• Responding to lawful regulatory or court requests
• Protecting our legal rights in disputes

7. What We Do Not Do

• We do not sell your personal data to any third party.
• We do not share your tinnitus data, hearing self-check results, symptom diary entries, or frequency profile with Meta, TikTok, Google Ads, or any advertising network.
• We do not use your health-related data for ad targeting or behavioural profiling.
• We do not record, store, or transmit microphone audio. Ambient noise monitoring is real-time and on-device only.
• We do not use advertising identifiers (IDFA on iOS, GAID on Android).
• We do not knowingly collect personal data from children under 18.

Where marketing measurement tools are used on our website, they are limited to consent-based, generic signals — never health or tinnitus inferences.

8. Subscriptions and Billing

hearOS Premium is an auto-renewing subscription available through the Apple App Store (iOS) and Google Play (Android).

We use RevenueCat to manage subscription state. RevenueCat receives a pseudonymous customer ID and your subscription status only — not your name, email, payment details, or any health data. RevenueCat privacy policy: https://www.revenuecat.com/privacy

We never receive or store your payment card details. All payment processing is handled by Apple or Google.

To manage or cancel your subscription:

• iOS: Settings → [your name] → Subscriptions → hearOS
• Android: Google Play → Profile → Payments & subscriptions → Subscriptions → hearOS

9. Third-Party Services

We do not integrate advertising SDKs or behavioural analytics platforms into the hearOS app.

10. Data Sharing and Disclosure

We never share tinnitus profile data, hearing self-check results, or symptom diary entries with advertising or analytics partners.

11. International Data Transfers

ICI Tech Teknoloji A.Ş. is based in Turkey. Some service providers operate internationally. For all international transfers, we apply appropriate safeguards as required by KVKK Article 9, including standard contractual clauses.

12. Data Retention

Account deletion: We will delete or irreversibly anonymize your data within 30 days of account deletion, except where a longer period is required by law.

13. Security

• TLS 1.2+ encryption for all data in transit
• Encryption at rest for server-stored data
• Health-related data (tinnitus profile, symptom diary, hearing results) is treated with elevated access controls
• Microphone data is never stored or transmitted
• Optional biometric or passcode lock within the app
• Regular security assessments and penetration testing
• Data breach response plan in place; breach notifications per KVKK requirements

14. Push Notifications

Manage in Settings → Notifications within the app or through your device settings.

15. Children's Privacy

hearOS is intended for users aged 18 and older. We do not knowingly collect data from minors. If you believe a child has submitted data, contact us at app@icitech.com.tr and we will delete it promptly.

16. Your Privacy Rights

We respond to all privacy requests within 30 days, free of charge.

17. Cookies and Tracking Technologies

Our website (https://hearos.app/) uses cookies. A consent banner is shown on your first visit.

We do not use cookies to infer tinnitus status, hearing status, or any health information. The hearOS app does not use advertising identifiers or advertising SDKs.

18. EEA and UK Users

If you are located in the EEA or UK, the GDPR applies to your data. Please read our full GDPR Privacy Notice, which covers:

• GDPR article-level legal bases for each processing activity
• Your rights under GDPR Articles 15–22 (including data portability)
• Standard Contractual Clauses for international transfers
• Our EU Representative status (Article 27)
• How to lodge a complaint with your local supervisory authority (CNIL, BfDI, AEPD, ICO, etc.)
• 72-hour breach notification obligations

19. Changes to This Policy

For material changes, we will notify you via in-app notice or email at least 14 days before changes take effect. The current version is always at https://hearos.app/en/privacy/.

20. Contact Us

We acknowledge all privacy enquiries within 5 business days.

21. Governing Law

This Privacy Policy is governed by the laws of the Republic of Turkey, including KVKK No. 6698 and the Electronic Commerce Law No. 6563. Disputes are subject to the jurisdiction of Turkish courts.

*hearOS is a wellness companion — not medical care. Nothing in this app constitutes medical advice or guarantees any outcome.*