Last modified: 3rd March 2020
Respect for your privacy is of our utmost concern. Since we started HearClear, we’ve aspired to build our Services with a set of strong privacy principles in mind.
Your Services are provided by Desifa Ltd (“Desifa”), which is also the data controller responsible for your information when you use our Services.
Please also read HearClear’s Terms of Service (“Terms”), which describes the terms under which you use our Services.
Information We Collect
HearClear must receive or collect some information to operate, provide, improve, understand, customize, support, and market our Services, including when you install, access, or use our Services. The types of information we receive and collect depend on how you use our Services.
Information You Provide
- Your Account Information. You provide your mobile phone number, email address and basic information (including a profile name) to create a HearClear account. You provide us, all in accordance with applicable laws, the phone numbers in your mobile address book on a regular basis, including those of both the users of our Services and your other contacts. You may also add other information to your account, such as a profile picture and about information.
- Your Messages. We retain your messages for a limited time period, which are all fully encrypted in the ordinary course of providing our Services to you. Once your messages (including your chats, photos, videos, voice messages, files, and share location information) are delivered, they are deleted from our servers within a short period of time. Your messages are stored on your own device. If a message cannot be delivered immediately (for example, if you are offline), we may keep it on our servers for up to 30 days as we try to deliver it. If a message is still undelivered after 30 days, we delete it. To improve performance and deliver media messages more efficiently, such as when many people are sharing a popular photo or video, we may retain that content on our servers for a longer period of time. We also offer end-to-end encryption for our Services, which is on by default, when you and the people with whom you message use a version of our app released after March 1, 2020. End-to-end encryption means that your messages are encrypted to protect against us and third parties from reading them.
- Your Connections. To help you organize how you communicate with others, we may help you identify your contacts who also use HearClear, and you can create, join, or get added to groups and broadcast lists, and such groups and lists get associated with your account information. You give your groups a name. You may choose to provide a group profile picture or description.
- Customer Support. You may provide us with information related to your use of our Services, including copies of your messages, and how to contact you so we can provide you customer support. For example, you may send us an email with information relating to our app performance or other issues.
Automatically Collected Information
- Usage And Log Information. We collect information about your activity on our Services, like service-related, diagnostic, and performance information. This includes information about your activity (including how you use our Services, your Services settings, how you interact with others using our Services, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our Services, the features you use like our messaging, calling, Status, or groups features, profile photo, about information, whether you are online, when you last used our Services (your “last seen”), and when you last updated your about information.
- Device And Connection Information. We collect device and connection-specific information when you install, access, or use our Services. This includes information like hardware model, operating system information, battery level, signal strength, app version, browser information, and mobile network, connection information including phone number, mobile operator or ISP, language and time zone, and IP, device operations information, and identifiers like device identifiers.
- Location Information. We collect device location information if you use our location features, like when you choose to share your location with your contacts, view locations nearby or those others have shared with you, and the like, and for diagnostics and troubleshooting purposes such as if you are having trouble with our app’s location features. We use various technologies to determine location, including IP, GPS, Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
- Information Others Provide About You. We receive information about you from other users and businesses. For example, when other users or businesses you know use our Services, they may provide your phone number, name, and other information (like information from their mobile address book or in the case of businesses, additional information about you such as unique identifiers), just as you may provide theirs, or they may send you a message, send messages to groups to which you belong, or call you. We require each of these users and businesses to have lawful rights to collect, use, and share your information before providing any information to us.
- Businesses On HearClear. Businesses you interact with using HearClear may provide us information about their interactions with you. A business on HearClear may also use another company to assist it in storing, reading, and responding to your messages on behalf of and in support of that business. Please note that when businesses use third-party services, their own terms and privacy policies will govern your use of those services and their use of your information on those services.
- Third-Party Service Providers. We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. For example, we work with companies to distribute our apps, provide our infrastructure, delivery, and other systems, supply location, map, and places information, process payments, help us understand how people use our Services, market our Services, help you connect with businesses using our Services, conduct surveys and research for us, and help with customer service. These companies may provide us information about you in certain circumstances; for example, app stores may provide us reports to help us diagnose and fix service issues.
- Third-Party Services. We allow you to use our Services in connection with third-party services. If you use our Services with such third-party services, we may receive information about you from them; for example, if you choose to access our Services through a mobile carrier’s or device provider’s promotion of our Services. Please note that when you use third-party services, their own terms and privacy policies will govern those services.
How We Use Information
We use the information we have (subject to choices you make) to operate, provide, improve, understand, customize, support, and market our Services. Here’s how:
- Our Services. We use the information we have to operate and provide our Services, including providing customer support, and improving, fixing, and customizing our Services. We understand how people use our Services and analyse and use the information we have to evaluate and improve our Services, research, develop, and test new services and features, and conduct troubleshooting activities. We also use your information to respond to you when you contact us.
- Safety And Security. We verify accounts and activity, and promote safety and security on and off our Services, such as by investigating suspicious activity or violations of our Terms, and to ensure our Services are being used legally.
- Communications About Our Services. We use the information we have to communicate with you about our Services and features and let you know about our terms and policies and other important updates. We may provide you marketing for our Services.
- No Third-Party Banner Ads. We do not allow third-party banner ads on HearClear. We have no intention to introduce them, but if we ever do, we will update this policy.
- Commercial Messaging. We will allow you and third parties, like businesses, to communicate with each other using HearClear, such as through order, transaction, and appointment information, delivery and shipping notifications, product and service updates, and marketing. For example, you may receive flight status information for upcoming travel, a receipt for something you purchased, or a notification when a delivery will be made. Messages you may receive containing marketing could include an offer for something that might interest you. We do not want you to have a spammy experience; as with all of your messages, you can manage these communications, and we will honour the choices you make.
- Measurement, Analytics, And Other Business Services. We help businesses who use HearClear measure the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
Information You And We Share
You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our Services.
- Send Your Information To Those You Choose To Communicate With. You share your information (including messages) as you use and communicate through our Services.
- Account Information. Your phone number, profile information, about information, last seen information, and receipts may be available to anyone who uses our Services, although you can configure your Services settings to manage certain information available to other users and businesses with whom you communicate.
- Your Contacts And Others. Users and businesses with whom you communicate may store or reshare your information (including your phone number or messages) with others on and off our Services. You can use your Services settings and the block feature in our Services to manage the users of our Services with whom you communicate and certain information you share.
- Businesses On HearClear. We help businesses who use HearClear measure the effectiveness and distribution of their services and messages, and understand how people interact with them on our Services.
- Third-Party Service Providers. We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms.
- Third-Party Services. When you use third-party services that are integrated with our Services, they may receive information about what you share with them. If you interact with a third-party service linked through our Services, you may be providing information directly to such third party. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.
Assignment, Change Of Control, And Transfer
How The General Data Protection Regulation Applies To Our European Region Users
Our Legal Bases For Processing Information
We collect, use, and share the information we have as described above:
- as necessary to fulfill our Terms;
- consistent with your consent, which you can revoke at any time;
- as necessary to comply with our legal obligations;
- occasionally to protect your vital interests, or those of others;
- as necessary in the public interest; and
- as necessary for our (or others’) legitimate interests, including our interests in providing an innovative, relevant, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
How You Exercise Your Rights
Under the General Data Protection Regulation or other applicable local laws, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information. This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.. You can access tools to rectify, update, and erase your information directly in-app. If we process your information based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. You can also object to our processing of your information.
Managing And Deleting Your Information
We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.
If you would like to manage, change, limit, or delete your information, we allow you to do that through the following tools:
- Services Settings. You can change your Services settings to manage certain information available to other users. You can manage your contacts, groups, and broadcast lists, or use our block feature to manage the users with whom you communicate.
- Changing Your Mobile Phone Number, Profile Name And Picture, And About Information. You must change your mobile phone number using our in-app change number feature and transfer your account to your new mobile phone number. You can also change your profile name, profile picture, and about information at any time.
- Deleting Your HearClear Account. You may delete your HearClear account at any time (including if you want to revoke your consent to our use of your information) using our in-app delete my account feature. When you delete your HearClear account, your undelivered messages are deleted from our servers as well as any of your other information we no longer need to operate and provide our Services. Be mindful that if you only delete our Services from your device without using our in-app delete my account feature, your information may be stored with us for a longer period. Please remember that when you delete your account, it does not affect the information other users have relating to you, such as their copy of the messages you sent them.
Law And Protection
We collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to:
- respond pursuant to applicable law or regulations, to legal process, or to government requests;
- enforce our Terms and any other applicable terms and policies, including for investigations of potential violations;
- detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues;
- protect the rights, property, and safety of our users, Desifa , or others, including to prevent death or imminent bodily harm.
Our Global Operations
Updates To Our Policy
The Data Protection Officer for Desifa can be contacted at the address below
15 Victoria Road