Version 1.0 Updated: 12 July 2026
Do you have any questions? You’re welcome to write to us.
At TRUE LISTENING, protecting your privacy is an essential part of earning your trust. We follow the principle of data minimisation, meaning we process only the personal data necessary to operate, secure, evaluate and improve the App, to provide the functionality you request, and to communicate with you where you have chosen to receive communications.
The TRUE LISTENING App is designed to be used without creating a personal account. We do not sell personal data, do not use advertising networks, and do not track you across other apps or websites.
This Privacy Policy explains what personal data is processed when you use the TRUE LISTENING App, why it is processed, the legal bases we rely on, the service providers involved, and the rights available to you under applicable data protection laws.
We follow the principle of data minimisation. You can use the TRUE LISTENING App without creating an account. Each installation of the App is assigned a random installation identifier that enables the App to function without directly identifying you.
We process only the categories of information described below.
1.1 Information You Provide
Depending on how you use the App, you may voluntarily provide:
Year of birth; Gender (if you choose to provide it); Responses to the optional Survey; Your name and email address, if you voluntarily subscribe to the TRUE LISTENING newsletter.
Participation in the Survey and subscription to the newsletter are entirely voluntary and are not required to use the App.
1.2 Technical, Survey, and Listening-Related Information
The App is built using Unity. Limited technical information, including the device type, operating system, App version, random installation identifier, general App usage information and approximate country or region derived automatically from the IP address during communication with the App, may be processed to operate, secure and improve the App.
TRUE LISTENING does not collect or store your precise location and does not request location permissions from your device. Crash reporting is currently disabled and the App does not currently collect crash reports. If you choose to participate in the optional Survey or use the hearing exercises, Survey responses, exercise interaction information and listening-related information may be processed solely to: provide an appropriate initial exercise recommendation; evaluate and improve the App; understand how hearing exercises are used and experienced; and further develop TRUE LISTENING’s hearing training methods. We do not use this information for advertising profiling or cross-app tracking.
1.3 Optional Surveys and Segmentation
Participation in the optional Survey is entirely voluntary. If completed, broad user segments may be created within the TRUE LISTENING environment to provide an appropriate initial exercise recommendation and, where you have subscribed to the newsletter, to personalise newsletter content. Segmentation is based solely on your consent and is not used for advertising profiling or for automated decision-making with legal or similarly significant effects.
1.4 No Tracking or Advertising
TRUE LISTENING does not: track users across apps or websites; use advertising networks; create advertising profiles; use personal data for behavioural advertising; or sell personal data to third parties.
We process personal data only for the purposes described in this Privacy Policy.
2.1 Optional Survey
Participation in the Survey is voluntary. If you complete the Survey, your responses are used once to recommend an appropriate starting point for your hearing training. This recommendation is intended solely to support your introduction to the App and does not constitute a hearing test, medical assessment, diagnosis or healthcare advice.
2.2 Exercise Interaction and Product Improvement
Exercise interaction information helps us understand: how users interact with the hearing exercises; how users progress through the training; which exercises are most effective and engaging; and how the overall App experience can be improved. At the current stage of the App, this information is used for evaluation, quality improvement, research and product development. It is not used to continuously personalise or automatically adapt your training.
2.3 Usage and Device Analytics
To operate, secure and improve the App, we process Usage and Device Analytics. This may include: device model; operating system; App version; random installation identifier; general App usage information; session information; and approximate country or region derived automatically from the IP address. This processing is based on our legitimate interests in operating, securing, evaluating and improving the App in accordance with Article 6(1)(f) GDPR. Technical information is associated with the random installation identifier rather than with yourname or email address and is not used for advertising or cross-app tracking.
2.4 Newsletter
If you voluntarily subscribe to the TRUE LISTENING newsletter, we process your name (if provided) and email address to send: TRUE LISTENING news; product updates; hearing training tips; educational content; and information about new exercises and App features. Newsletter processing is based on your consent under Article 6(1)(a) GDPR. You may withdraw your consent at any time by clicking the unsubscribe link included in every newsletter.
To provide more relevant newsletter content, a limited number of labels may be associated with your Mailchimp contact. Some labels are neutral administrative labels, such as how you joined the mailing list. Other labels may reflect information you have voluntarily provided, including gender and general listening preferences. These labels are used solely to personalize newsletter content based on your consent. They are never used for advertising profiling or shared for marketing by third parties.
2.5 Research and Statistical Improvement
We may analyze Usage and Device Analytics, Survey responses and exercise interaction information to evaluate and improve the App and to further develop hearing training methods. Wherever possible, analyses are performed using aggregated or anonymised information. Where information remains associated with a random installation identifier and can still distinguish one installation from another, it is treated as pseudonymised personal data rather than fully anonymous information. Research results, statistics and publications will never identify individual users.
Depending on the purpose of processing, we rely on one or more of the following legal bases:
Article 6(1)(a) GDPR – your consent, where explicit consent is required, newsletter subscription and personalised newsletter content; Article 6(1)(b) GDPR – where processing is necessary to provide App functionality you have requested; Article 6(1)(f) GDPR – our legitimate interests in operating, securing, evaluating and improving the App; and Article 6(1)(c) GDPR – compliance with legal obligations. Where Survey information could be regarded as special-category personal data under applicable law, we rely on your explicit consent where legally required.
We do not sell or rent personal data. Personal data is shared only where necessary to operate the App or provide services you have requested.
We currently use the following service providers:
Unity – technical infrastructure, secure storage, random installation identifiers, Usage and Device Analytics and App functionality; Mailchimp – newsletter subscriptions, newsletter delivery and consent-based newsletter personalisation; and Apple App Store and Google Play – App distribution, downloads, billing and platform security under their respective privacy policies.
Our service providers process personal data only on our behalf and under appropriate contractual, technical and organisational safeguards in accordance with applicable data protection laws. Apple and Google process personal data for App distribution, downloads, billing and platform security independently, under their respective privacy policies.
Some of our service providers may process personal data outside the European Economic Area (EEA). Where required by applicable law, we implement appropriate safeguards for such transfers, including: adequacy decisions adopted by the European Commission; the EU Standard Contractual Clauses (SCCs); and additional technical and organisational measures where appropriate. We take reasonable steps to ensure that personal data transferred internationally remains protected in accordance with applicable data protection laws.
We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or misuse. These measures include, among others: data minimisation; separation of identity data from App usage data; restricted access to authorised personnel; secure transmission of data where appropriate; appropriate contractual safeguards with service providers; and regular review of our security measures. While no method of electronic transmission or storage can be guaranteed to be completely secure, we continually work to protect the personal data entrusted to us.
We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy or where required by applicable law.
In particular: newsletter information is retained until you unsubscribe or withdraw your consent, subject to limited records required to demonstrate consent or comply with legal obligations; Survey responses, exercise interaction information and Usage and Device Analytics are retained only for the period necessary to operate, evaluate and improve the App; aggregated or anonymised statistical information that no longer identifies an individual may be retained for longer periods for research, statistical evaluation and product improvement.
Where personal data is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with applicable legal requirements.
Subject to applicable data protection law, you may have the following rights regarding your personal data:
to request access to the personal data we process about you;
to request correction of inaccurate or incomplete personal data;
to request deletion of your personal data where legal requirements are met;
to request restriction of processing in certain circumstances;
to object to processing based on our legitimate interests;
to receive personal data you have provided to us in a portable format where applicable;
to withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before the withdrawal;
and to lodge a complaint with a competent data protection supervisory authority.
8.1 How to Exercise Your Rights
To exercise any of your rights, please contact us using the contact details provided in Section 13. To help us identify the relevant information, please provide sufficient details, such as your newsletter email address or, where applicable, information that enables us to identify the relevant App installation. We will respond within the timeframes required by applicable law.
The TRUE LISTENING App uses selected third-party platforms and service providers that are necessary to operate the App and provide its functionality.
These currently include: Unity – application framework, technical infrastructure, secure storage, random installation identifiers, Usage and Device Analytics and App functionality; Mailchimp – newsletter subscription management, newsletter delivery and consent-based newsletter personalisation; Apple App Store – App distribution, downloads, billing and platform security; and Google Play – App distribution, downloads, billing and platform security.
Each provider processes personal data only to the extent necessary for the services it provides and in accordance with its own privacy obligations and applicable data protection laws. For further information about how personal data is processed by these providers, please refer to their respective privacy policies.
TRUE LISTENING is designed to comply with the Apple App Store Review Guidelines and the Google Play Developer Program Policies.
The App does not use advertising identifiers for behavioural advertising; does not track users across third-party apps or websites; does not sell personal data; requests only the personal data necessary to provide, operate and improve the App; requests consent where required by applicable law; and provides users with transparent information about how their personal data is processed.
Where Apple or Google process personal data for App distribution, downloads, billing or platform security, such processing is governed by the respective privacy policies of Apple and Google.
The TRUE LISTENING App is not directed to children under the age of 13. We do not knowingly collect personal data from children under the age of 13. If we become aware that personal data has been provided unintentionally by or on behalf of a child under 13, we will take appropriate steps to delete that information without undue delay. Parents or legal guardians who believe that a child has provided personal data may contact us using the details provided in Section 13.
We may update this Privacy Policy from time to time to reflect changes to the App, our data processing practices, applicable legal requirements or regulatory guidance. The current version of this Privacy Policy will always be made available within the App and, where applicable, through our associated website. The “Last updated” date at the beginning of this Privacy Policy indicates when this version became effective.
Circle of Values Communication GmbH
Oelsnerring 83
22609 Hamburg Germany
Email: in**@************ng.com
If you have any questions about this Privacy Policy, the processing of your personal data, or your rights under applicable data protection law, please contact us using the details above.
This Privacy Policy is governed by the laws of the Federal Republic of Germany, without limiting any mandatory rights available to you under applicable data protection legislation. Where legally permissible, the courts of Hamburg, Germany, shall have jurisdiction.
14.1 Applicable Legal Texts and Language
References in this Privacy Policy to the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and other applicable legislation refer to those laws as amended from time to time. In the event of any inconsistency between language versions, the German version shall prevail unless mandatory law requires otherwise.
