PRIVACY POLICY

Last updated: Sep. 6, 2024

Singular Hearing Inc. ("Singular", "we" or "us") is committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy policy is to inform you about our privacy practices, including how we collect, use and disclose your personal information.

This privacy policy relates to all of our activities, unless we have provided you with a separate privacy policy for a particular product, service, or activity.

Please review this privacy policy carefully. By submitting your personal information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us, you consent to our collecting, using, and disclosing your personal information as set out in this privacy policy, as revised from time to time.

WHAT'S IN THIS PRIVACY POLICY?

You can click on a section heading below to go directly to that section.

Meaning of personal information
Your consent to collection, use and disclosure
Personal information we collect
Audio recordings
How we use your personal information
How we share your personal information
Opting out of communications
Retention of personal information
Information security
Accessing and updating your personal information
International transfer and storage of information
Third-party websites and services
Children's information
Privacy policy updates
Contact us

Meaning of personal information

"Personal information" means information about an identifiable individual. This information may include, but is not limited to, your name, mailing address, email address, telephone number, and HeardThat audio logs.

Personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work electronic address.

Personal information also does not include information that has been anonymized or aggregated in such a way that it is reasonably foreseeable in the circumstances that it irreversibly no longer allows the person to be identified directly or indirectly.

Your consent to collection, use and disclosure

We collect, use and disclose your personal information with your consent or as permitted or required by law. How we obtain your consent (i.e. the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy policy.

Typically, we will seek your consent at the time your personal information is collected. For example, we will seek your express consent before you upload any audio logs while using the HeardThat application. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the "Contact Us" section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

We may collect your email address if you contact us for technical support. We do not require users to create accounts to use our services.

Personal information we collect

The personal information we collect is generally in one or more of the following categories.

• Information you provide to us: We may collect your email address if you contact us for technical support. We do not require users to create accounts to use our services.
• Information we automatically collect: we collect log data and usage information relating to your use of our products and services.
• Audio recordings. You can choose to record the audio of a session always, never, or on-demand. These recordings are stored on your device and can be reviewed, deleted, or shared at your discretion. You have the option to share these recordings with other services (such as cloud storage providers), other people (via email or messaging apps), or with us for technical support purposes. We only have access to recordings you explicitly choose to share with us.
• Website. For individuals who visit our website located at https://heardthat.ai or any of our related websites (collectively, "our website"), we may collect certain technical and device information about your use of our website. Such information may include your Internet protocol address, information about your device, browser and operating system, and the date and time of your visit.
• We may also use "cookies" or enlist third-party services which use cookies to track your preferences and activities on our website. Cookies are small data files transferred to your computer's hard-drive by a website. They keep a record of your preferences, making your subsequent visits to the site more efficient. Cookies may store a variety of information, including the number of times that you access a site, and the number of times that you view a particular page or other item on the site. The use of cookies is a common practice adopted by most major sites to better serve their users. Most browsers are designed to accept cookies, but they can be modified to block cookies. See your browser's help files for more information. You should note, however, that without cookies some of our website's functions may not be available.
• Other Interactions. For individuals who otherwise interact with us, whether in person, by phone or email, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, or who respond to surveys and questionnaires, we may collect information that you provide to us during these interactions. This information may include your name, email address and other contact information.

We do not collect payment card information. If you make an online payment using a payment card, such as a credit card or debit card, you are connected directly to our online payment processing service provider and your payment card information is collected and processed by that service provider.

Audio recordings

Our app provides the ability to record audio during your sessions. This feature is designed to enhance your experience and provide additional functionality. Here's what you need to know about audio recordings:

• Recording Options: You can choose to record audio always, never, or on-demand. This setting can be adjusted in the app's preferences at any time.
• Storage: All recordings are stored locally on your device. We do not automatically upload or store your recordings on our servers.
• User Control: You have full control over your recordings. You can review, play back, delete, or share them at your discretion through the app interface.
• Sharing Options: You can choose to share your recordings with other services (such as cloud storage providers) or other people (via email or messaging apps). This sharing is entirely under your control.
• Technical Support: You have the option to share recordings with us for technical support purposes. We only gain access to recordings you explicitly choose to share with us in this context.
• Use of Shared Recordings: If you choose to share recordings with us for technical support:
• We use these to analyze and resolve technical issues, conduct regression testing, and improve our services.
• We may use portions containing only ambient noise (not speech) to train our noise reduction models.
• We retain anonymized versions of these recordings indefinitely to support ongoing product improvement, unless you request their deletion.
• Security of Shared Recordings: We implement appropriate technical and organizational measures to protect any recordings shared with us and limit access to authorized personnel only.
• Deletion of Shared Recordings: You can request the deletion of any recordings you've shared with us for technical support. To do so, please contact us using the information in the "Contact Us" section of this policy.
• Consent: By sharing recordings with us, you consent to the uses described above. If you're uncomfortable with this, you can seek technical support without sharing recordings or request their deletion after your issue is resolved.

We are committed to transparency in our handling of your audio recordings and to providing you with control over your data. If you have any questions or concerns about our audio recording practices, please don't hesitate to contact us.

How we use your personal information

We may use your personal information and other information for purposes such as:

• to provide you with our products and services and to support your use of our products and services;
• to contact you relating to our products and services;
• to monitor and improve our products and services, and to develop new products and services;
• to analyze the needs and activities of our customers to help us better serve them, using aggregated and non-personal information;
• to conduct research and analysis related to our business, products and services, using aggregated and non-personal information;
• to respond to inquiries and other requests;
• to collect opinions and comments in regard to our products and services;
• to provide you with information that we think may interest you, including in regards to our products and services;
• to investigate legal claims;
• to provide the recording functionality as selected by you, including storage and management of audio recordings on your device;
• to provide technical support, which may include analyzing audio recordings that you choose to share with us. These shared recordings help us diagnose issues, improve our services, and provide more effective support. We only access and analyze recordings that you explicitly share with us for this purpose;
• to process and respond to specific requests or questions you submit to us, which may involve using information from shared recordings if relevant to your request.

We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

We do not use the information we collect to provide advertising of third-party products and services or targeted advertising of Singular products and services across third-party websites or service offerings.

How we share your personal information

We rely on third-party services providers to perform a variety of services on our behalf, such as e-commerce providers, payment card processors, telephone and technical support providers, hosting, data storage and processing service providers, and research and analytics providers.

If we provide your information to service providers, then we require that the service providers maintain the confidentiality of your personal information and keep your personal information secure. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information in the "Contact Us" section below.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

We use Google Play Services whose privacy policy is here.

We use Crashlytics, a service offered by Fabric which is a company owned by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Crashlytics provides us information about crashes and malfunctions in our application. In case of a crash or malfunction, we send the following information to Crashlytics:

• information about the phone, such as device ID, model and device type, name and version of the operating system, settings, and language of the device.
• version and functionality of the application
• time of failure

Data transmitted to Crashlytics is neither stored or transmitted to other services or resources, nor associated with other data available to Google. Further information about Crashlytics and data privacy can be found here.

For audio recordings that you choose to share with us for technical support purposes:

• These recordings are stored securely on our servers with access limited to authorized personnel only.
• We use these recordings to analyze and resolve technical issues, conduct regression testing, and improve our services.
• We may retain these recordings indefinitely to support ongoing product improvement and quality assurance.
• Upon your request, we will delete specific recordings that you have shared with us. To request deletion, please contact us using the information provided in the "Contact Us" section of this policy.
• We do not share these recordings with third parties, except as may be necessary to provide technical support or as required by law.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

Opting out of communications

If you no longer want to receive emails from us, including marketing messages, news updates, and special offers, you may opt-out by clicking the "unsubscribe" link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the "Contact Us" section below.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that even if you opt-out from receiving these types of communications, we may still need to send you important administrative messages about your use of our products or services, or other matters.

Retention of personal information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.

Audio recordings are stored on your device and retained according to your preferences. You have full control to review, delete, or share these recordings at any time through the app interface.

For recordings that you choose to share with us for technical support purposes:

• We retain anonymized versions of these shared recordings indefinitely to assist with ongoing product improvement and quality assurance.
• These recordings are used for analyzing and resolving technical issues, regression testing to prevent recurrence of past problems, and may be used to improve our services.
• Portions of shared recordings that contain only ambient noise (and not speech) may be used to train and improve our noise reduction models.
• We implement appropriate technical and organizational measures to protect these shared recordings and limit access to authorized personnel only.
• Upon your request, we will delete specific recordings that you have shared with us for technical support. To request deletion, please contact us using the information provided in the "Contact Us" section of this policy.

By sharing recordings with us for technical support, you consent to this retention and use. If you have concerns about this practice, please consider not sharing audio recordings when seeking technical support, or request deletion after the support issue has been resolved.

Information security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business 'need-to-know' or whose duties reasonably require such information.

For audio recordings that you choose to share with us for technical support purposes, we implement additional security measures:

• Shared recordings are stored on secure servers with restricted access.
• Access to these recordings is limited to authorized personnel only, typically those directly involved in providing technical support or product improvement.
• We use encryption for data in transit to protect the confidentiality of shared recordings during transmission.
• We regularly review and update our security practices to enhance the protection of shared recordings.

Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the "Contact Us" section below.

Accessing and updating your personal information

We will take steps to ensure that your personal information is kept as accurate, complete and up-to-date as reasonably necessary. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with updates to your personal information, when required.

You may make a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose.

International transfer and storage of information

Your personal information, including any audio recordings you choose to share with us, may be transferred to, and stored in, servers located in the United States and Canada. This means that your personal information may be processed in countries other than your country of residence, where privacy laws may be different.

Specifically:

• If you reside outside of the United States and Canada, when you use our app or share recordings with us, your data will be transferred to and stored on servers in the United States and/or Canada.
• Data, including shared recordings, may be transferred between our servers in the United States and Canada as part of our normal operations.

By submitting your personal information or using our services, you consent to this transfer, storing or processing of your personal information in the United States and Canada. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this privacy policy.

Third-party websites and services

This privacy policy applies only to our products and services. This privacy policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third-party websites or products or services.

Children's information

Our products and services are not intended for children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. Children under the age of 16 should not use our products and services and should not provide us with their personal information.

Privacy policy updates

This privacy policy is current as of the "updated" date which appears at the top of this page. We may modify this privacy policy from time to time. When changes are made to this privacy policy they will become immediately effective when published in a revised privacy policy posted on our website unless otherwise noted. We may also communicate the changes through our services or by other means. By submitting your personal information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this privacy policy, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy policy.

Contact us

All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be sent to our Privacy Officer as follows:

Address:	Attention: Privacy Officer 16479 92A Ave Surrey, BC V4N 5N1 Canada
By email:	privacy@singularhearing.com