Do you have any questions? You’re welcome to write to us.
Your privacy is important to us. This Privacy Policy explains what personal data we collect in the App, how we use it, and what rights you have. We follow a principle of data minimisation and transparency. Optional features such as surveys or newsletters are voluntary and not required to use the App.
1.1 Personal Data (Account Creation)
Name (if provided)
Email address
Year of birth
Place / City
Postal code
This information is processed only for the purposes described in this Privacy Policy and in
accordance with applicable law.
1.2 Technical, Survey, and Listening-Related Information
The App is built using Unity. Limited technical data such as device type, operating system, app version, and anonymous crash reports may be processed. Survey responses and listening-related information may be processed solely to provide personalized training experiences and improve app functionality. We do not use this information for advertising profiling or cross-app tracking.
We follow a principle of data minimisation. Account creation is required to use the App. During registration, we collect only the personal data necessary to create and manage your account and provide access to the App’s core features.
1.3 Optional Surveys and Segmentation
Participation in optional surveys is voluntary. If completed, broad user segments may be created inside the App environment to improve in-app recommendations or personalize newsletter content. Segmentation is based solely on consent and is not used for advertising profiling or automated decisions with legal or similarly significant effects. Segment labels shared with email delivery tools are neutral identifiers and do not contain listening-related or personal information.
1.4 No Tracking or Advertising
We do not track users across apps or websites. We do not use advertising networks. We do not profile users for marketing purposes.
Create and manage user accounts; provide access to the App; provide support; send important account- or service-related communication; ensure technical stability and security. No personal data is used for automated decision-making or advertising.
2.1 Newsletter and Optional Email Updates
If you subscribe to our newsletter, we process your email address based on consent (Art. 6(1)(a) GDPR). You may unsubscribe at any time using the unsubscribe link included in every email.
2.2 Research and Statistical Improvement
We do not sell personal data. For newsletter and optional email communications, email addresses and neutral segment labels may be processed by Mailchimp, a third-party email delivery provider acting as a data processor on our behalf. Segment labels are abstract identifiers and do not contain listening-related, survey, or personal information. Processing is carried out solely for the purpose of sending communications that users have consented to receive. Apple App Store and Google Play may process data independently for distribution and billing.
Processing is based on contract performance, legal obligations, legitimate interests, or consent where required.
We do not sell personal data. For newsletter and optional email communications, email addresses and neutral segment labels may be processed by Mailchimp, a third-party email delivery provider acting as a data processor on our behalf. Segment labels are abstract identifiers and do not contain listening-related, survey, or personal information. Processing is carried out solely for the purpose of sending communications that users have consented to receive. Apple App Store and Google Play may process data independently for distribution and billing.
Where applicable, EU Standard Contractual Clauses or equivalent safeguards apply.
We implement appropriate technical and organisational measures to protect data.
Personal data is retained only as long as necessary or required by law.
Access, correction, deletion, objection, withdrawal of consent, and complaint rights apply.
8.1 How to Exercise Your Rights
Contact: info@true-listening.com. We respond within legally required timeframes.
Unity; Apple iOS / App Store; Google Android / Google Play.
True Listening complies with Apple App Store and Google Play Developer Policies.
Not directed at children under 13.
Data provided unintentionally will be deleted without delay.
We may update this Privacy Policy occasionally.
Circle of Values Communication GmbH
Oelsnerring 83
22609 Hamburg
Germany
Email: info@true-listening.com
German law applies. Jurisdiction: Hamburg, Germany.
14.1 Applicable Legal Texts and Language
German versions of applicable EU and German data protection laws prevail.
