Initial Effective Date: April 1, 2020 (GMT)
THIS POLICY DESCRIBES OUR POLICIES AND PROCEDURES FOR COLLECTION, USE, STORAGE, PROCESSING, DISCLOSURE AND PROTECTION OF ANY INFORMATION, INCLUDING, BUT NOT LIMITED TO, PERSONAL INFORMATION PROVIDED BY YOU AS A USER WHILE USING THE SERVICE. USER SHALL MEAN ANY PERSON/ PERSONS, WHO VISITS, USES, DEALS WITH AND/ OR TRANSACTS THROUGH TINNIBOT APP (“PRIVACY POLICY”). PLEASE ALSO READ OUR TERMS OF SERVICE (“AGREEMENT”) WHICH SETS OUT THE TERMS GOVERNING THE SERVICES. THE AGREEMENT, PRIVACY POLICY AND ANY OTHER TERMS AND CONDITIONS AS MAY BE APPLICABLE SHALL HEREINAFTER COLLECTIVELY BE REFERRED TO AS “TERMS AND CONDITIONS”.
If You are having suicidal thoughts or planning to act on suicidal thoughts or if You feel that You may be a danger to Yourself or to others or if You otherwise have any medical or mental health emergency or severe mental health condition or if You are in a crisis or trauma or abuse, please discontinue use of the Service immediately and call the relevant emergency number in Your country and notify the police or emergency medical services. For example, You can find Your country-specific suicide emergency number at: Suicide.org - Suicide Prevention, Awareness, and Support If You are less than 18 years of age, please read through the Tinnibot Privacy Policy and the Tinnibot Terms of Service with Your parent or legal guardian to understand eligibility before use. Tinnibot is not to be used by children under 13 years.
Your interaction with the Tinnibot bot is with an AI chatbot and not a human. The bot is restricted in the means of response and the intended use is for providing evidence-based tools and techniques to manage tinnitus and encourage mental wellbeing. It is not intended for providing diagnosis, treatment or cure of a condition or disease. The bot cannot and will not offer advice on issues it does not recognize.
The Tinnibot Therapist Service is a video-call and text-messaging Service provided by highly trained and qualified mental health and well-being professionals. Your assigned Tinnibot Therapist will use person-centered supportive approach to encourage and motivate You to take control of Your tinnitus and emotional well-being. Tinnibot Therapist will draw on various evidence-based psychological and lifestyle coaching techniques to provide empathetic and non-judgmental support to help You strengthen Your self-esteem and ace through emotional hurdles and current concerns to reach Your goals. Your Therapist will listen to Your worries empathetically, promote positivity and support You in making successful lifestyle changes, so that You can manage your situation better and build emotional resilience. By using the Therapist Service You understand and agree that the Therapist assigned to work with You will be located remotely and not in the country or state where You reside.
Tinnibot Therapist Service is not intended to be a replacement for face-to-face psychotherapy or to provide a diagnosis, prognosis, treatment or cure for a disease/condition/disability or provide any type of state-regulated mental health services.
Tinnibot bot and Tinnibot Therapist cannot and will not offer medical or clinical advice. They can only suggest that User seek advanced (medical) help. Keep Your conversations private and device secure by following the best practices outlined in section 7. d of the Privacy Policy.
We do not use the data collected for the purpose of identifying You. You are not obliged to provide any Personal Information. Please do not share Your personally identifiable Information (such as full name, date of birth, gender, contact numbers, address, financial identifiers, government-provided identifiers) or Your medical-related information or any other sensitive Information (such as Your sexual preferences, religious or political opinions, financial information) when You use the Tinnibot App and Services.
For safety and security reasons, we strongly recommend that You set automatic update of the Tinnibot App in the application manager settings of Your mobile device to get the latest Tinnibot App-based features and any Tinnibot App fixes.
Welcome to Tinnibot App, the mobile and online service of Odio Tech Pty Ltd (hereinafter “Odio Tech”, “Tinnibot”, “We”, “Us”, or “Our”). When you as a user (“You/r”) use Odio Tech’s Services, You trust us with Your Information. This Privacy Policy governs Your use of the mobile based software application (hereinafter the “Tinnibot App” or “Mobile Software”) created by Odio Tech. This Privacy Policy along with Tinnibot Terms of Service constitutes a legal agreement between You and Odio Tech.
This Privacy Policy applies to the Information You provide Us when You Use the Tinnibot App. Information automatically collected from Your mobile device, optional services made available within the Tinnibot App, and other apps that integrate with or work in conjunction with the Tinnibot App (collectively "Apps"), Personal Information You provide Us when You visit Websites maintained by Us relating to our Apps ("Websites"). Our Apps, Websites, or any of Our online and/or mobile services, online Tinnibot Therapist Services through the mobile software and software provided on or in connection with the Services are collectively referred to as the "Service(s)").
Please note that by using the Services, You acknowledge and agree that You have read and understood this Privacy Policy.
This privacy policy (“Policy” or “Privacy Policy”) has been drafted in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, including (but not limited to) requirements within HIPAA (Health Insurance Portability and Accountability Act) and General Data Protection Regulation (GDPR) (EU) 2016/679 regulation (collectively referred to as "Data Protection Law").
This Privacy Policy describes the steps that We will take to comply with the Data Protection Law to ensure the processing of Your Personal Information. For the purposes of Data Protection Law, the Data Controller for Tinnibot App is Odio Tech Pty Ltd (A.C.N. 620 664 039), a private limited company, incorporated and existing under the laws of Australia.
This Privacy Policy is meant to help You understand what data We collect, why We collect it, what We do with it, how You can manage and control the Use of Your Information and the rights You have to access and control Your Personal Information. Please read the definitions in the next section to understand the terminology used in this Privacy Policy. Our mission is very simple. We want to help You care for Yourself better, and help You access tools that can help with your tinnitus to build healthier behaviour, both physically and mentally.
We will always respect and protect Your privacy, and this forms a part of Our guiding principles. We have policies and procedures in place to protect the privacy and security of Your Personal Information. Your trust means a lot to Us. Tinnibot does not request nor process Your Personal Information. Please do not share any Personal Information at any time in Your Use of Our Service such as while in conversation with the Tinnibot App or Tinnibot Therapist Service. We will always tell You of any Personal Information that We collect, and will take Your permission before asking You to share it with Us. We will clearly identify why We need this Personal Information. We will collect only the minimum Personal Information necessary to provide Our Services to You. For example, We don’t ask for Your full name, phone number, email address, country specific social security number, Your gender, Your date of birth or Your address. We don’t have to have it, hence We don’t ask for it. If We collect it at any time, We will Use and protect Your Personal Information in accordance with the terms of this Privacy Policy. We respect Your privacy and will protect it with strong encryption during transmission, plus strict policies that govern how all data is stored and handled. We will keep Your Information only as long as necessary.
Your use of the Tinnibot App will be governed by this Privacy Policy as applicable to the Tinnibot App together with all policies, notices, guidelines, disclaimers that are published and shared with You from time to time which are incorporated herein by way of reference including but not limited to Tinnibot Terms of Service. This Privacy Policy shall be enforceable against You in the same manner as any other written agreement.
Users may request additional Services from Odio Tech or Odio Tech affiliates. Because the needs and choices of each User may vary, We may provide separate privacy policies or addendums to this Privacy Policy for certain additional Services. Any applicable separate privacy policies and addendums will explain the types of Information We collect, their purposes of Use and other policies that may apply to that service. When You choose to Use an additional service, You may be informed of the applicable privacy policy or addendum which applies in addition to, and may modify this Privacy Policy, before You can access the additional service.
Odio Tech reserves the right to make changes to this Privacy Policy and to make such changes effective for all Information We may already have collected from You. You must periodically review the policy for the latest information on our privacy practices.
Personal Information or personal data or personal identifiable information (PII) means information relating to an identified or identifiable natural person who can be directly or indirectly identified by reference to an identifier such as full name, identification numbers, location address, online identifier and other identifiers within the definitions of The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 and General Data Protection Regulation (GDPR) (EU) 2016/679 regulation.
Non-Personal Information means any information that does not reveal Your specific identity either directly or indirectly. This includes information that is anonymized so that it does not allow easy identification of a specific individual.
Information under this Privacy Policy means both Personal and Non-Personal Information.
A Cookie is a small amount of data generated by a website and saved by your web browser. Cookies are used to store user preferences for a specific site. Use of cookies makes web-surfing easier. You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies.
Encryption is the process of transforming information into unreadable text so that it is only eligible to those possessing an encryption key. The process of making encrypted information readable again is referred to as decryption. Web Browser is a software program that allows user to access, retrieve and view information on the World Wide Web. Examples of browsers include Internet Explorer, Firefox, Google Chrome and Safari.
The Tinnibot App is a virtual AI chatbot (“Bot” or “Tinnibot bot”) that You can chat with, including upon Your choice, the ability to subscribe and to message or video-call with a highly trained and qualified mental health and well-being professional (“Tinnibot Therapist” or “Therapist”), to be able to use institutional support mechanism integrated within the Tinnibot App, and through a conversational interface get access to tools and techniques to manage Your tinnitus, emotional wellness and to encourage You in building resilience. The Tinnibot App is primarily available for both iOS and Android mobile systems. Your Interaction with the Bot is with an AI chatbot and not a human. The Bot is restricted in the means of response and the intended usage of Tinnibot App is providing evidence-based tools and techniques to manage emotions and encourage mental wellbeing as an early intervention tool. The Bot cannot and will not offer advice on issues it does not recognize. Tinnibot App and Service is not intended for use in crisis such as abuse or complex or severe mental health conditions that causes ideation of suicide, harm to self and others, and any medical emergencies. Tinnibot App and Service cannot and will not offer medical or clinical advice. It can only suggest that user seeks advanced (medical) help.
You may use the Service only if You are a natural/legal person and can form a binding contract with Tinnibot, and only in compliance with the Agreement and all applicable local, state, national, and international laws, rules and regulations.
The customer assures that he has been treated by an ear, nose and throat specialist before using the app and that the necessary diagnostics have been completed (in particular ear microscopy, hearing test and exclusion of a neurological cause). He also assures that he does not suffer from serious mental illness.
The customer is aware that the therapy program can not provide individual diagnoses. Therefore, Odio Tech Pty Ltd assumes no responsibility for incorrect or incomplete diagnoses of the treating physicians.
To provide You Our Service, Odio Tech will collect, store and use the following Information provided by You. The lawful basis for processing all Your Information is for the performance of this Contractual Agreement and as agreed by You:
USER PROVIDED PERSONAL INFORMATION
Tinnibot does not request nor require Your Personal Information. We do not use the Information collected for the purpose of identifying You either directly or indirectly. You are not obliged to provide any Personal Information. Please do not share any Personal Information at any time in Your use of Our Service such as while in conversation with the Tinnibot App or Tinnibot Therapist Service or when You contact Us with inquiries or send Us feedback. By voluntarily providing Us with Your Personal information, You are consenting to Our collection and use of it in accordance with this Privacy Policy. If You provide Personal Information, You acknowledge and agree that such Personal Information may be transferred from Your current location to the globally-located secure cloud servers of Our authorized third party data processor or to Our own secure server locations.
If You accidently provided personal information and/or submitted media files (such as videos, images, etc.) containing personal information during Your conversation with the Tinnibot App or the Tinnibot Therapist Service and want to rectify or delete that information, kindly write to us at the contact provided in section 7.b. at the earliest.
At present, when You download and setup Tinnibot App in Your mobile device, You do not need to go through a registration or sign-up process or share Personal Information before using the Service.
USER PROVIDED NON-PERSONAL INFORMATION
To provide You Our Service, Odio Tech will collect, store and use the following non-personal Information provided by You:
How do We handle Your conversation messages?
When You use the Service, all the conversation messages You have with the Tinnibot App are private. You provide Your messages by way of choosing pre-formatted responses or by way of free-text. Each submitted message gets processed in real-time by the Tinnibot App’s proprietary algorithms, and directed appropriately to subsequent context-based conversation based on a proprietary rule-based content management process. At no point during Your conversation with the Tinnibot App does another natural person have access to, or gets to monitor or respond to Your messages except at the time of using the Tinnibot Therapist Service. The Tinnibot App’s proprietary algorithms also process all Your messages for positive and negative sentiments and for any self-harm or suicidal tendencies. This is done to enable the Tinnibot App to empathetically converse with You, and personalize Your conversation. There is no solely automated processing done by the Tinnibot App to determine what You should do - You are always asked to verify whether the Tinnibot App has understood Your conversation or sentiment or emotions or feelings correctly, before proceeding down a conversational path.
Your messages are not processed to send You unwanted content. Your submitted messages or app usage habits or Website browsing habits are not used to sell to advertisers. We do not ‘monetize’ the messages or the Information You submit to Us. The messages You send and receive are encrypted and stored securely. You can read more about the security provided in section 6 of this Privacy Policy.
You can also, at any point of time, clear all Your past conversations from Your mobile device by using the “reset my data” feature available in the Tinnibot App. Refer to “Reset my data” in the other optional information of this Policy for more details. DO NOTE THAT RESET MY DATA RESETS YOUR APP-BASED PROFILE BY REMOVING ASSOCIATION WITH ALL YOUR SUBMITTED INFORMATION INCLUDING PAST CONVERSATIONS, REMINDERS, ASSESSMENT RESPONSES AND ENABLED SETTINGS. POST RESET, YOU WILL NOT BE ABLE TO ACCESS YOUR PAST INFORMATION AND YOU WILL BE CONSIDERED AS A NEW USER. HENCE, THIS FEATURE IS TO BE USED BY YOU AT YOUR OWN DISCRETION.
A limited set of Your conversation messages gets anonymized before being processed for internal operations and for research and statistical analysis purposes. This is done only to improve Your future experience when using Our Service.
From time to time a new version of the Tinnibot App is published in the Play Store or App Store. ALWAYS EXIT THE TINNIBOT APP VERSION IN YOUR MOBILE DEVICE BY USING THE BACK BUTTON BEFORE UPGRADING TO A NEWER VERSION TO PREVENT LOSS OF ONGOING OR PREVIOUS CONVERSATIONS.
Do We need to know Your full name?
When You use the Service, We will not ask for and will not require Your full name at any point of time during the conversation. After sign up, We take You through a one time on-boarding process. Here We ask for only Your nickname to help personalize Our conversation with You. PLEASE DO NOT SHARE YOUR FULL NAME TO MAINTAIN COMPLETE ANONYMITY. You can change the nickname once provided to the Tinnibot App by typing #help and choosing “Change Name” from the slider displayed.
Why do We ask about Your thoughts, feelings (emotions), mood, major event or life changes, goals and energy levels?
When You use the Service, We may periodically ask You about Your tinnitus, thoughts, feelings or emotions, mood, major events / changes in life, Your resilience goals and Your energy levels. Your response is processed by Tinnibot solely to provide You access to tools and techniques to manage Your tinnitus, emotional wellness and to encourage You in building resilience.
Your Information is encrypted during transmission and is securely stored. YOUR INFORMATION IS NEVER SHARED WITH A THIRD PARTY WITHOUT YOUR EXPLICIT CONSENT. How do we handle Your responses to health related questions?
When You use the Service, You will be asked to respond to health related questions. Response is voluntary and You can opt to not report to any of these questions. Tinnibot App currently uses four validated assessment scales for understanding Your tinnitus and emotional well-being, namely the Tinnitus Functional Index (TFI) to self-report tinnitus intrusiveness, the Patient Health Questionnaire (PHQ9)- to self-report any depression symptoms, the Generalized Anxiety Disorder Assessment (GAD7) - to self-report any anxiety symptoms and the Subjective Units of Distress Scale (SUDS)- to self-report the intensity of disturbance or distress currently experienced. Other assessment scales may be introduced in the future. You will also be asked to share how You cope with day to day activities as part of the health questions. Health related questions are a proven way to baseline and track progress of Your symptoms. Your response is used solely for the purpose of providing You with feedback on Your well-being and to provide You access to validated and curated tools and techniques to manage Your tinnitus, emotional wellness and to encourage You in building resilience.
YOUR RESPONSES TO THESE ASSESSMENT QUESTIONS ARE NOT PROCESSED TO FORM A DIAGNOSTIC OPINION NOR PROCESSED FOR ANY MEDICAL PURPOSES. We DO NOT ask for nor process Your medical information or Protected Health Information (PHI), defined under the US law that can be linked to You or Identify You. We use Your anonymized assessment scores for population-level research and statistical purposes as per Our legitimate interest (Section 6.a of this Policy).
Your response is encrypted during transmission and is securely stored. YOUR INFORMATION IS NEVER SHARED WITH A THIRD PARTY WITHOUT YOUR EXPLICIT CONSENT.
What do We collect when You book a session with a Tinnibot Therapist?
When You use the Tinnibot Therapist Service, You can schedule or reschedule a real-time video-call session with Your Tinnibot Therapist. We collect Your chosen session dates and time to book sessions with Your Tinnibot Therapist. At times, Tinnibot App may get your local time wrong which could affect the session scheduling. PLEASE ALWAYS VERIFY YOUR LOCAL TIME DISPLAYED BY TINNIBOT APP IN THE SESSION SCHEDULING SCREEN BEFORE PROCEEDING WITH BOOKING OF A SESSION. IF YOU NOTICE AN ERROR IN YOUR LOCAL TIME DISPLAYED, GO TO THE BOT MESSAGING INTERFACE AND TYPE #TIME TO CHANGE YOUR TIME. If you face any challenge changing Your local time or booking a session with Your Tinnibot Therapist, kindly write to us at the contact provided in section 7.b.
If You choose to use Apple’s SIRI to invoke the Tinnibot Bot Service, You get the opportunity to talk to Tinnibot Bot for a limited number of messages using Apple’s voice based Service after which You are directed to the Tinnibot App to continue the conversation. No Personal Information gets asked or collected during use of this Service. Please do not share Your Personal Information at any time during use of this Service. When You use SIRI, Apple may collect some Identifiers and Information from You to provide their service for which You are subject to Apple’s terms and conditions and privacy policy. You can read Apple’s privacy policy here. We do not access, receive or collect any identifiers and information that is collected by Apple.
-->AUTOMATICALLY COLLECTED NON-PERSONAL INFORMATION
To provide You Our Service, Tinnibot App will automatically collect, store and use the following Non-Personal Information:
Why do We collect Device Information and access logs when You use Our Service?
When You use the Service, We may also collect Non-Personal Information through the use of commonly-used information-gathering tools such as cookies, log files and web beacons. Such information may include standard information collected from Your mobile device (such as mobile application identifier, operating system, OS version, time zone, manufacturer, model and brand name) or from Our Website (such as browser type, browser language, Operating System, browser information including type and language settings) along with the actions You take on Our Website (such as the web pages viewed and the links clicked).
We use this information to detect and deter unauthorized or fraudulent use of or abuse of the Service, and to optimize Your experience for e.g. to make sure the Tinnibot App is displayed correctly on Your phone, or Your usage settings are applied.
Do We collect Passive Sensing Information from Your mobile device?
When You use the Service, the Tinnibot App does not passively collect nor process any information from Your mobile device sensors, such as accelerometer, ambient light readings and screen on/off readings, including location (GPS) and call logs.
How do We use any Third Party Software?
When You use the Service, Tinnibot App usage and system generated event Information gets sent to third-party analytics software such as Firebase and Google Analytics via their secure API integrated within the Tinnibot App. These events do not contain any Information provided by You during Your use of the Service such as Your nickname, Your conversations, Your assessment responses or any sensitive Information voluntarily provided by You. These events are analysed only to help monitor and improve Our Apps performance and Service.
Apart from the App-pushed events, the third party software APIs also may automatically collect some non-personal events. Firebase automatically collected events can be found here. Google Analytics automatically collected events can be found here.
The use of Firebase is governed by Firebase Terms of Service, Use Policy and Crashlytics Terms of Service.
The use of Facebook Analytics is governed by Google Data Policy and Terms of Service.
Our website is hosted on Heroku and Amazon Web Services (AWS), third party web management platforms. Heroku and AWS help Us collect Your website visit and Usage information for the purposes of analytics and improve your experience on our website. The use of Heroku is governed by AWS’ and Heroku’s Terms of Service, Privacy and Cookie Policy and GDPR Compliance Statement.
NO PERSONAL INFORMATION OR IDENTIFIERS ARE PUSHED BY THE TINNIBOT APP TO THESE THIRD PARTY SOFTWARE.
You use the Zendesk Chat customer support software, when You chat with Our Customer Support from within the Tinnibot App. The Customer Support will only answer questions that You may have about Your purchase of the Tinnibot Therapist Service. It is not intended for use in crisis such as abuse or complex or severe mental health conditions that causes ideation of suicide, harm to self and others, and any medical emergencies. The Customer Support cannot and will not offer therapy, counselling, life coaching, medical or clinical advice. They can only suggest that You seek advanced (medical) help. All Your conversation with Customer Support will be stored in Zendesk servers and not in Our Servers. Your use of Zendesk Chat is governed by Zendesk policies, Zendesk privacy and data protection. Kindly go through these notices to understand how Your data will be protected by Zendesk. We do not ask any Personal Information during Your chat with Our Customer Support. Please do not voluntarily share any of Your personally identifiable Information or Your medical-related Information or any other sensitive Information (such as Your sexual preferences, religious or political opinions, financial Information) when You talk with the Customer Support. If You accidently provide any Personal Information You can write to us requesting to rectify, erase the specific identifier at tinnibot@hearingpower.co. We may retain Your messages even after Your account is closed if retention is reasonably necessary. These could be in situations where We need to comply with applicable Data Protection Law, regulations or legal obligations, provide and complete Customer Support, resolve disputes between or with Odio Tech users, or to detect and deter unauthorized or fraudulent use of or abuse of the Service. If You have any query about the Therapist Service post-purchase or have any other questions, please write to Us at tinnibot@hearingpower.co. We may at times be unable to address all Your requests, if We are unable to correctly identify You.
OTHER OPTIONAL INFORMATION
To improve Your experience, We provide optional features in the Tinnibot App. If You choose to use such features, We may ask You for additional Information:
OPTIONAL: Your feedback and ratings
When You use the Service, We ask You for Your feedback and Your rating of Tinnibot App. You can also provide feedback using the Feedback feature provided in the Tinnibot App “more” section. You can use this feature to email Us Your feedback. This feedback and rating is used by Us to improve the product and Your product experience.
AS A BEST PRACTICE, IT IS ADVISED THAT YOU TAKE ADEQUATE PRECAUTIONS TO NOT SHARE YOUR HEALTH OR PERSONAL INFORMATION WHILE GIVING FEEDBACK OVER EMAIL NETWORKS.
OPTIONAL: Your Saved Sessions
When You use the Service, You have the option to view Your conversation sessions using the “Journey” feature in the Tinnibot App. You also have the ability to delete your saved sessions from the Tinnibot App anytime You choose. This feature is solely for Your convenience and to help You play back Your earlier conversations with the Bot. If You reset Your data, You will not be able to access Your earlier conversation sessions.
OPTIONAL: Manage Notifications or reminders
When You use the Service, You have the option to manage app-based notifications or reminders. The Tinnibot App will ask Your preference for the time of day to receive notifications and will confirm Your local time to ensure reminders get sent as per Your preference. You can change or delete notifications at any time by invoking help function (type #help) or from more > settings of Your Tinnibot App. You also have the option and convenience to save Tinnibot Therapist Session reminders to Your local calendar management software in Your mobile device. WE DO NOT SEND ANY MARKETING NOTIFICATIONS TO YOU WITHOUT YOUR EXPLICIT PERMISSION.
OPTIONAL: Connecting Your Fitness App
When You use the service, You have the option to connect Google Fit or Apple Health app with the Tinnibot App. You can connect using the Connect Fit feature available in the Tinnibot App more > settings. This allows the app to collect and process Your activity data from the fitness app to understand Your activity levels and provide Your activity reports. You can disconnect this feature at any time by going to Your fitness app settings and by disconnecting “Tinnibot”.
OPTIONAL: Authorize and Unauthorize Tinnibot Therapist
When You use the Tinnibot Therapist Service, You have the option to either share or stop sharing access to Your provided information including sleep, activity, mood, health related responses, alerts and tool usage with the Tinnibot Therapist. This feature can be activated or deactivated at any time during Your conversation by using the “Authorize/Unauthorize Therapist” feature in the Tinnibot App more > settings.
OPTIONAL: Your Age Information
When You use the Service, You have the option to provide Your age information in the form of an age range (Under 18, 20-30, 30-45, Above 45). This information is processed by the Tinnibot App to understand the age profile of Our users and to help provide them access to tools and techniques or provide other operational information relevant to their age range.
WE DO NOT ASK, COLLECT OR PROCESS YOUR SPECIFIC AGE OR DATE OF BIRTH AT ANY TIME DURING YOUR USE OF THE SERVICE.
OPTIONAL: Reset My Data
When You use the Service, You have the option to reset all the Information in the Tinnibot App by using the “Reset my data” feature in the Tinnibot App more > settings. Reset my data resets the entire App, clears all Your conversation messages, clears Your saved sessions, clears Your completed tools, clears reminders or any enabled settings or activities and health-related responses. YOU CANNOT REVERSE OR RECOVER YOUR PAST INFORMATION AFTER A RESET. Please note that reset my data will remove all Your Information from visibility on Tinnibot App but may still remain on our servers but completely de-identified. This means that We will never be able to trace the Information back to You. To request complete removal of Information, kindly write to Us at the contact provided in section 7.b. When You write to Us, provide Us with a description of the nickname used, last use of the Service, and any other information we may require in order to identify and consider Your request. Please note that removal of Information does not ensure complete or comprehensive removal of the Information posted on the Online Services by You.
If You no longer wish to use the Service or if You no longer wish for the Tinnibot App to use or collect Your Information, You may choose to delete Your entire account directly by uninstalling the Tinnibot App. We will take reasonable measures to delete your Information collected.
OPTIONAL: Location Information
To use the apps, You are not required to provide Your location information (“geolocation”). Tinnibot App does not collect Your Geolocation information. We do however check Your device clock and collect Your date-time settings to help us offer a safe and improved experience.
If We collect or use Your geolocation data as an additional separate service, We will make sure that We provide notice and/or obtain Your consent. You can always turn off location sharing at any time using Your phone settings.
OPTIONAL: Contact Information for customer support
There may be occasions where You wish to contact Us to seek support. If You contact Us via Our website or by other means, We may need some Information from You, which You may choose to provide. This includes Your name, contact info such as your email address, phone number, as well as information about Your mobile device or personal computer such as device type, and OS type. We will use this Information to address and investigate the issues You have forwarded to Us, to provide You support and to improve Our customer support service. We process this Information for our legitimate interests.
OPTIONAL: Contact Information for promotional events and customer surveys
If You choose to participate in promotional events or surveys that Odio Tech may offer from time to time, We may ask your contact details (e.g., name, location, phone number, email address, gender and date of birth) to administer the event, such as to confirm participation eligibility for the event, to enable You to fill out a questionnaire, to conduct to deliver the prizes to You. NO PROMOTIONAL EVENT NOTIFICATIONS WILL BE SENT WITHOUT YOUR EXPLICIT PERMISSION TO RECEIVE MARKETING NOTIFICATIONS.
If You choose to participate in any programmes or promotional events, You would be asked to opt-in to complete a survey questionnaire. Your voluntary submissions including Your personal Information such as email address will be processed only for the following purposes - to send You additional Information about the programme, to enroll or on-board You to the programme and to correspond with You on programme related matters. Your survey submission will never be linked to Your Tinnibot app account and hence Your Tinnibot App conversations and activities will never identify You. Your submissions will reside in a secure and private storage area operated within the Tinnibot G-suite account and managed by Google Forms (G-Suite security can be read here. The Tinnibot G-Suite account is also protected by a two-factor secure authentication system. You can opt out at anytime by sending a request to tinnibot@hearingpower.co to delete Your personal Information or to discontinue receiving any further communication on this matter. On receipt of Your email, We will verify and remove only the specific identifiable Information as requested by You, within 72 hours of receiving the request. YOUR SUBMISSIONS WILL NEVER BE SHARED WITH A THIRD PARTY WITHOUT YOUR EXPLICIT CONSENT.
OPTIONAL: Payment Information
If You choose to purchase or use a fee-based service and pay for such service by means of in-app purchases via iTunes or Google Play, we will not collect, retain and store Your personal, financial and credit/debit card information. This is because Your card settlements including card and personal details will be handled by appropriate third-party payment agencies.
OPTIONAL: Follow on Instagram
You have the option to follow Us in Instagram using Your Instagram account by going to more > settings. You can setup an Instagram account, if you do not own one and follow us at @hearingpower WE DO NOT ASSOCIATE YOUR INSTAGRAM ACCOUNT WITH YOUR TINNIBOT APP ACCOUNT.
What Information will be processed by Us for purposes of legitimate interests?
By using the Service, You hereby agree to the use of Your Information for the above mentioned purposes.
To fulfil Our commitment to respecting and protecting Your privacy and the confidentiality of Your Personal Information, Odio Tech has implemented industry-standard safeguards to prevent unauthorized access or disclosure, misuse, alteration or destruction of Your information. More specifically, We will comply with all applicable data protection and security laws in order to assure security, availability, processing integrity, confidentiality and privacy of data. All Information between the Tinnibot App and server is encrypted and transmitted via Secure Socket Layer (SSL). Information You provide to Us is stored on secure servers, which are owned and operated by Amazon Web Services (AWS). AWS are industry leaders in the provision of hosting services. You can find out more about AWS security policies here AWS Cloud Security. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords.
Because no method of electronic transmission or method of data storage is perfect or impenetrable, We cannot guarantee that Your Information will be absolutely safe from intrusion during transmission or while stored in Our systems.
To help protect Your privacy and confidentiality of Your Information, We also need to ask for Your cooperation regarding the following: Please do not copy and transmit Your chat conversations, health data and/or Personal Information with other people. Also, please notify at the contact information provided in Section 7.b, in the event You suspect any unauthorized use of Your account or any other breach of security via Our contact information.
To provide the Service in a reliable and responsible manner, Odio Tech processes and stores Your Information on secure Virtual Private Cloud servers which may be physically located in different countries around the world, including countries outside Australia.
By continuing to use the Service, You agree that your Information may be internationally transferred and that Odio Tech can process and store Your Information in a country other than where You submitted it.
Our Services are global and Your information (including any voluntarily provided Personal Information) may be stored and processed in any country where We have operations or where We engage with partner/s, and We may transfer information to countries outside of Your country of residence, to countries which may have Data Protection Law that are different from those of Your country. However, We will take adequate safeguards and steps reasonably necessary to ensure that any such transfers protect Your privacy, fundamental rights and freedoms, and the exercise of Your rights, in accordance with this Privacy Policy and in compliance with Data Protection Law.
Odio Tech retains any Information You provide or automatically collected while Your account is in existence, for the length of time needed to fulfil any of the applicable purposes of use described in this Privacy Policy, or to comply with applicable Data Protection Law.
We may retain Your Information even after Your account is closed if retention is reasonably necessary. These could be in situations where We need to comply with applicable Data Protection Law, regulations or legal obligations, provide and complete customer support service, resolve disputes between or with Odio Tech users, or to detect and deter unauthorized or fraudulent use of or abuse of the Service.
To facilitate and provide You with the Service, it sometimes is necessary for Odio Tech to request third party partner service providers or agents to help Us process and/or store your Information. We strictly evaluate the partner service providers and agents, and We make every effort to ensure that they have established appropriate and secure information administration and organizational control systems, and We strictly require that they comply with confidentiality obligations and applicable laws and regulations including Data Protection Law as relevant. We also require that they access Your Information only to the extent necessary to perform tasks on Our behalf.
Other than as described in this Privacy Policy and, where relevant, other applicable privacy policies or addendums, Odio Tech will never provide Your Information to any third parties without Your explicit consent, unless We believe in good faith that We are required or permitted to do so under applicable contracts and laws, or to protect and defend Odio Tech’s rights and/or property.
As required by Data Protection Law and as per the agreements executed with business associates, third-party health coaches and partners must protect the privacy of data Tinnibot will share with them and they are required to keep Your Information private and secure.
We may be involved in the transaction of a merger, acquisition, sale of assets, business re-organization, bankruptcy etc. During such a process, We may sell, transfer or otherwise share some or all of Our assets which may include Your Information. However, in such an event of sale or transfer, We shall reasonably ensure that Your Information collected and stored by the Us is stored and used by the transferee in a manner that is consistent with this Privacy Policy. Any such third party to whom We transfer or sell shall have the right to continue to use the Information that You provide to Us or collected by Us immediately prior to such transfer or sale. On completion of the sale or transfer, the privacy policy of the third party shall apply with respect to Your Information. To stay updated about such business transactions, please read this Privacy Policy from time to time.
Odio Tech uses third party advertising agencies to place advertisements on the internet or in other media. To measure the effectiveness of the advertisements to determine how much to pay to the advertising agencies, We may install third-party modules within the Tinnibot app. We may also install other third-party modules within the Tinnibot App in order to deliver the Service and help Us understand how the Service is used.
You have certain rights under the Data Protection Law in relation to the Personal Information that You share with Us. We have tried to make it as easy as possible for You to have control over Your Personal Information. To exercise any of Your rights, please email a request at the contact Information provided in section 7.b. Please note that We will require You to verify Your identity before responding to any requests to exercise Your rights. We may also limit Your individual rights requests (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other's privacy; (c) to protect our rights and properties; or (d) where the request is unjustified or excessive.
If You have provided and We process Your Personal Information based on this contract, You can always send Us a written email request at the contact Information provided in section 7.b at any time to check, rectify, erase, or restrict processing of Your Personal Information. Upon verification of Your identity, We will respond to Your request within one month and in accordance with relevant Data Protection Law. Odio Tech will provide You with a request form that You will need to fill and submit back to Us via email. We will verify and erase only the specific identifiable Information as requested by You, within 72 hours of receiving the filled request form.
You have the right to object to the processing of Your Personal Information that is based on legitimate interests for the purposes explicitly mentioned in section 6.a by sending Us a written email request at the contact Information provided in section 7.b.
You can always save Your sessions or check Journey to view Your old conversations within the Tinnibot App. You have the right of data portability to receive digital copy of Your Information in a machine readable format. You can send Us a written email request at the contact Information provided in section 7.b. Upon verification of Your identity, We will respond to Your request within one month and in accordance with relevant Data Protection Law. We may charge You a small fee for this service. We do not ask any Personal Information during Your use of Service. We may at times be unable to address Your request, if We are unable to correctly identify You.
PLEASE NOTE:
IF YOU HAD “RESET YOUR DATA”, ONLY THE CONVERSATION MESSAGES POST THE LAST RESET WILL BE AVAILABLE FOR ACCESS.
IF YOU HAVE CANCELLED OR UNSUBSCRIBED FROM THE SERVICE OR HAVE UNINSTALLED THE TINNIBOT APP PRIOR TO MAKING A REQUEST FOR ACCESS, THEN WE WILL BE UNABLE TO PROVIDE YOU ACCESS TO YOUR CONVERSATION MESSAGES.
If You are not happy about any aspect of the way We collect, share or Use Your Personal Information, please let Us know at the contact Information provided in section 7.b. You have the right to complain to a Data Protection supervisory authority in Your state of residence. Contact details for Data Protection Authorities in the EU are available at ec.europa.eu. Do California residents have specific privacy rights?
California law permits Users who are California residents to request and obtain from Us once a year, free of charge, a list of the third parties to whom We have disclosed their Personal Information (if any) for direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Please note that Tinnibot does not share Personal Information with third parties for Their own marketing purposes.
Do Not Track (“DNT”) is a privacy preference that Users can set in certain web browsers, some mobile operating systems and mobile applications. We do not respond to DNT signals or any other similar mechanisms that automatically communicates Your choice to not be tracked online. We will inform You If a standard for online tracking is adopted in an updated Privacy Policy.
The Tinnibot App is intended for a general audience and is not directed to or intended to be used by children under the age of thirteen (18) years. We understand the special necessity to protect children's privacy on Tinnibot App, and We do not knowingly collect any Personal Information from children. If, however, You believe We have collected any Personal Information from children, then please send Us a written request. Refer to Section 7.b for Our contact details. If We learn that We have inadvertently collected Personal Information from children, We will deactivate the relevant account(s) upon identification and will take reasonable measures to promptly delete such Personal Information from Our records.
You are responsible for any use of Your credit/debit card or other payment instrument used by minors to make an in-app purchase.
If You have any questions, comments, concerns, grievances about this Privacy Policy or our other privacy policies or practices, please contact Dr. Fabrice Bardy at tinnibot@hearingpower.co or by writing to:
For any technical issues, please contact us at tinnibot@hearingpower.co with Your questions
The Tinnibot App has been built and is currently provided only for English language users.
To ensure wider reach, Odio Tech will, in the near future, launch Tinnibot in other international languages. We will keep You updated on this development.
You are also responsible for helping to protect the security of your Personal Information. You are responsible for maintaining the security of any personal computing device on which You utilize the Services. Never leave Your device unattended.
US Federal Trade Commission (FTC) publishes information for users on how to secure your personal information and devices. These can be found at the following public link. FTC - How to Keep Your Personal Information Secure
Odio Tech strongly believes in security and safety of Information in Your mobile device. As a responsible service provider, We therefore like to share important device based security information for Your attention. These have been sourced from US FTC best practices and guidelines. Always refer back to the US FTC link provided above for more details and future security updates.
We may modify Our Privacy Policy from time to time for various reasons including to improve Our privacy practices, to reflect changes to Our Service, and to comply with relevant laws. If and when this policy is changed, We will post this information on our Website and provide You with a copy of the revised notice upon Your request or as otherwise required by law. It is Your responsibility to check Our Website and the apps periodically for updates or changes to Our policy. We encourage You to review changes carefully. If You agree to the changes, then please continue to use Our Service. If You, however, do not agree to any of the changes and You no longer wish to use Our service, You may choose to unsubscribe service or close Your account. Continuing to use Our Service after a notice of change has been communicated to You or published on Our Service constitutes Your acceptance of changes and consent to the modified Privacy Policy.
We have taken every effort to ensure that this Privacy Policy adheres with the applicable laws, including Data Protection Law.. The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any Information other than the Information collected by Odio Tech while providing the Services.
This Privacy Policy shall be governed by and construed in accordance with the laws of Australia. The courts of New South Wales, Australia shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Privacy Policy.
Odio Tech is a company based in Australia. By browsing/using the Services, You hereby acknowledge that Odio Tech is not responsible or liable in any manner to comply with any local laws of Your territory except Australia.