PRIVACY POLICY - HEAREN
Last updated: 2 September 2026
1. Data Controller
HEAREN LAB LIMITED is the controller of the personal data processed in connection with the use of the Hearen application and associated services.
HEAREN LAB LIMITED
Private company limited by shares incorporated in England and Wales
Company Number: 17006631
Registered office: 72 Halliwick Road, London, England N10 1AB, United Kingdom
Email: contact@hearen.io
Representative in the European Union under Article 27 GDPR
Didier Marchand
France
Email: support@hearen.io
In this Privacy Policy, “Hearen”, “we”, “our” or “us” means HEAREN LAB LIMITED.
2. Personal Data We Process
2.1 Hearen Account Data
When you create and use a Hearen account, we process the information necessary to create, authenticate and manage your account, including your email address and technical information associated with your account.
2.2 Hearing and Sound Personalisation Data
Hearen may process information relating to your hearing profile in order to personalise certain sound experiences.
This information may come from the hearing test carried out in Hearen or, when you choose to use this feature and grant the necessary permissions, from audiogram data accessible through Apple Health and HealthKit.
Hearen may also use audiometric information that you enter manually in the application.
This information is used to adapt certain characteristics of the Hearen sound experience. It is not used by Hearen to make a medical diagnosis or to carry out a medical assessment of your hearing.
2.3 Data Relating to Your Use of Hearen
When you use Hearen, certain information relating to your use of the Service may be processed in order to enable the features you use to function and to retain the elements necessary for your experience in the application.
This may include your preferences and settings, the features you use, and information necessary to track certain activities or your progress in Hearen.
This information is used to provide the Service, maintain continuity in your experience and enable the corresponding features to function.
2.4 Subscription and Purchase Data
When you purchase a Hearen subscription through the App Store, payment is processed by Apple in accordance with the applicable App Store terms.
HEAREN LAB LIMITED does not receive or store your payment card details or other payment information that you provide directly to Apple.
Hearen may process the information necessary to determine and maintain your access rights to the Service, including information used to verify the existence and status of an eligible subscription or purchase and to restore your purchases.
Billing, renewal, cancellation and, where applicable, refunds for transactions made through the App Store are managed through the mechanisms provided by Apple.
2.5 Data You Provide When Contacting Hearen
When you contact HEAREN LAB LIMITED, including to request assistance, report a problem or exercise one of your rights, we process the information you choose to provide and the information necessary to respond to your request.
This information may include your email address, the content of your message and, where necessary to resolve your request, relevant information relating to your account or the issue concerned.
We use this information only to the extent necessary to handle your request, provide the corresponding follow-up and, where necessary, protect our rights or comply with our legal obligations.
2.6 Technical Data and Data Relating to the Operation of the Service
Hearen may process certain technical information and certain information relating to the use of specific features in order to operate the Service, assess how it functions and improve the experience provided.
Certain features may record events relating to the display or selection of suggestions and to certain personalisation steps. These events may be accompanied by contextual information such as the personalisation stage, the variant presented, the number of sessions, the number of days since installation, the time of day and the date of the event.
When you are signed in to your Hearen account, some of these events may be associated with your internal account identifier.
Certain information may also be stored temporarily on your device to enable the operation or diagnosis of the relevant features.
This information is used to understand how these features operate, assess their use and improve the Service.
3. Why We Use Your Data
We use your personal data only to the extent necessary to provide, secure, maintain and improve Hearen.
Depending on the features you use, we may process your data to:
create, authenticate and manage your Hearen account;
provide the features and services you choose to use;
personalise certain sound experiences using your hearing profile or audiometric data;
manage your access rights to the Service and recognise your subscription status;
maintain continuity in your experience and retain your preferences and progress;
respond to your requests and provide assistance;
understand how certain features operate and are used in order to maintain and improve them;
ensure the security of the Service, prevent misuse and resolve technical problems;
comply with our legal obligations and protect our rights.
4. Legal Bases for Processing
HEAREN LAB LIMITED processes your personal data only where there is a legal basis permitting the processing.
Depending on the nature of the data and the relevant purpose, we rely in particular on the following legal bases:
performance of a contract or steps taken at your request, where processing is necessary to create and manage your account, provide the Hearen features you choose to use, retain the elements necessary for your experience or manage your access rights to the Service;
the legitimate interests of HEAREN LAB LIMITED, where processing is necessary to ensure the security and proper operation of the Service, resolve technical problems, understand how certain features operate and improve Hearen, provided that these interests do not disproportionately affect your rights and freedoms;
compliance with a legal obligation, where HEAREN LAB LIMITED must process or retain certain information in order to comply with an obligation imposed by law.
Certain information relating to your hearing or audiogram may constitute health data and, as such, may benefit from enhanced protection.
Where Hearen processes such data in order to provide a personalisation feature that you have chosen to use, the processing is based on providing the requested service and, where required by applicable law for this particular category of data, on your explicit consent.
You may withdraw your consent where consent is the condition permitting the processing of this data. Withdrawal does not affect the lawfulness of processing carried out before your consent was withdrawn.
5. Recipients and Service Providers
HEAREN LAB LIMITED does not sell your personal data.
Your data may be accessible, only where necessary, to technical service providers that help us provide, host, secure or operate Hearen.
Depending on the features you use, these service providers may include:
Apple, including for subscriptions and purchases made through the App Store and, where you choose to use this feature, for access to audiogram data available in Apple Health and HealthKit;
our hosting and infrastructure providers, used to operate the Hearen backend, host certain application data and distribute content necessary for the Service;
our transactional messaging providers, used to send messages necessary for the operation of the Service, including account recovery and support requests.
Where we use a service provider acting on our behalf, it may process the relevant data only to the extent necessary to provide the corresponding service and in accordance with applicable contractual and legal obligations.
We may also disclose certain information where required by law, where requested by a competent authority acting within its lawful powers, or where necessary to protect our rights, the security of the Service or the rights of others.
6. International Data Transfers
HEAREN LAB LIMITED is established in the United Kingdom. Depending on where you live and the technical service providers used to provide the Service, your personal data may be processed in countries other than the country in which you reside.
Where personal data is transferred to a country outside the United Kingdom or, where European data protection law applies, outside the European Economic Area, HEAREN LAB LIMITED ensures that the transfer is based on a mechanism recognised under applicable law.
This may include a decision recognising an adequate level of protection in the relevant country or appropriate safeguards provided for under applicable law.
Where such safeguards are required, we take appropriate measures to ensure that the personal data concerned continues to benefit from a level of protection consistent with applicable data protection requirements.
7. Data Retention
HEAREN LAB LIMITED retains your personal data only for as long as necessary for the purposes for which it is processed.
Data relating to your account and your use of Hearen is, in principle, retained for the lifetime of your account. When you delete your Hearen account, personal data associated with the account is deleted, subject to information that may need to be retained temporarily to comply with a legal obligation, protect our rights or maintain the integrity and security of our systems and backups.
Certain data may have a shorter retention period where it is needed only for a particular feature. Information used to reset a password, for example, is subject to a limited validity period.
When data is no longer necessary for the purposes for which it was collected, it is deleted or anonymised, unless longer retention is required or permitted by applicable law.
8. Your Rights
Depending on applicable law and the circumstances of the relevant processing, you may have the following rights:
right of access: to obtain confirmation as to whether or not we process personal data concerning you and, where we do, to access that data and the information required by applicable law;
right to rectification: to request correction of inaccurate personal data or completion of incomplete data;
right to erasure: to request deletion of certain personal data where the conditions provided by applicable law are met;
right to restriction of processing: in certain circumstances, to request that the use of certain data be temporarily restricted;
right to object: in the circumstances provided by applicable law, to object to certain processing based in particular on the legitimate interests of HEAREN LAB LIMITED;
right to data portability: to receive certain personal data that you have provided to us in a structured, commonly used and machine-readable format, where this right applies;
right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
Where the processing of your data is based on the legitimate interests of HEAREN LAB LIMITED, you have the right to object to that processing in accordance with the conditions provided by applicable law.
You may exercise your rights by contacting HEAREN LAB LIMITED at: support@hearen.io.
To protect your data and your account, we may ask you to provide information reasonably necessary to verify your identity before acting on a request.
We respond to requests concerning your rights within the time limits provided by applicable law.
You also have the right to lodge a complaint with the competent data protection authority. For HEAREN LAB LIMITED in the United Kingdom, this authority is the Information Commissioner’s Office (ICO). Where the law of another country applies to you, you may also have the right to lodge a complaint with the competent supervisory authority in that country.
9. Data Security
HEAREN LAB LIMITED implements appropriate technical and organisational measures to protect personal data against unauthorised access, use, alteration or disclosure, and against accidental loss, destruction or alteration.
These measures are appropriate to the nature of the data processed, the features concerned and the risks that may affect individuals’ rights and freedoms.
We also seek to ensure that the technical service providers we use implement appropriate security measures for processing carried out on our behalf.
No method of electronic transmission or storage can guarantee absolute security. We therefore reassess the measures implemented where necessary in order to maintain a level of protection appropriate to the risks.
10. Changes to this Privacy Policy
HEAREN LAB LIMITED may update this Privacy Policy to reflect, in particular, changes to Hearen, our data processing practices or applicable legal and regulatory requirements.
The applicable version is the version made available in Hearen or through the associated services, together with its date of update.
Where changes are material and significantly affect how your personal data is processed or your rights, we will inform you by an appropriate means before they take effect where required by applicable law.
Last updated: 2 September 2026