TV Clear App

Privacy Policy Sennheiser TV Clear App (hereinafter called “app”)

Prior to download, installation and use, please carefully read the following notes and
information on how and for what purpose your data is collected and processed.

Further information can be obtained by reading the privacy policy of the platform/app
store from which you download the app. Under the heading of “Data Protection”, “Privacy
Policy” or a similar heading addressing the topic of data protection, this will inform you about which data is directly collected there and how it is processed. As the provider of the app, Sonova Consumer Hearing GmbH, Am Labor 1, 30900 Wedemark, Germany has no influence on data processing by the platform providers.

The responsible party for the processing of personal data is the publisher and operator of the app indicated on the platform/in the app store. 

Further information on your data protection rights (right to information pursuant to Art. 15 GDPR, right to rectification pursuant to Art. 16 GDPR, right to erasure pursuant to Art. 17 GDPR, right to restriction of processing pursuant to Art. 18 GDPR, right to data portability pursuant to Art. 20 GDPR, right to object pursuant to Art. 21 GDPR, right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR) as well as the contact details of our data protection officer can be found in our privacy policy at  https://www.sennheiser-hearing.com/de-DE/privacy/.

If you have any questions regarding the processing of your data, please contact us directly by sending a mail to privacy@sonova.com

Notes on data collection and processing and on
firmware updates

The following information is required to establish a connection to a device: Bluetooth address (for Android), access rights to location information of the device (for Android), BLE UUID (for iOS). This data is required for the operation of the product on your device and is not transferred to us or companies commissioned by us and is not processed.

The use of the app on Android devices mandatorily requires the activation of location services to enable the functioning of the app and the operation of this product. The connection to this product is established using Bluetooth Low Energy Scan (BLE Scan) technology, which requires access to the location services of your device. If you do not enable location services, the app cannot connect to this product. We do not process location information for any other
purpose. 

Using the TV Clear app, you can update the product’s firmware free of charge via an Internet
connection. 

It is possible to register for push notifications (optional opt-in) in the event of newly provided firmware for this product. If this function is used, then a PNS handle (Platform Notification Service) corresponding to the operating system (Android or iOS) is installed on the device. This PNS handle does not contain any personal data. This setting can be revoked at any time.

Updating the firmware requires your consent. If the device on which the app is installed is connected to the Internet, the following data is transferred to our servers and processed there in order to provide and transfer appropriate firmware updates: hardware identifier, hardware revision number, firmware version of the product, operating system type (Android, iOS) and version, version of the app. The data is only used for the purpose of providing and transferring firmware updates (legal basis Art. 6 para. 1 lit. b GDPR) and is not stored permanently.

If you do not want this data to be transferred and processed, do not establish an Internet connection.

Installation and use:

Sonova Consumer Hearing GmbH as the publisher of the app itself does not collect or process any personal usage data. Therefore, there is also no transfer of personal data by Sonova Consumer Hearing GmbH to third parties.

Certain usage data and crash reports are processed using Google Firebase (a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), subject to your consent. Such processing is necessary to provide a continuously improved app and the product and is only done in anonymous form to determine statistical characteristics regarding app and product usage, app distribution and identification of error causes, as well as for the purpose of providing and maintaining the app and the product and improving the features of the app and the product. At no time can a reference be made to a specific person. In particular, the following information is processed:

While using the app, Google Firebase Analytics is used to track general app use. This is done for analytics purposes to understand the application usage and improve its usage performance. Google Firebase Analytics has some events that are automatically collected; examples of these events are:

• Frequency, type and duration of app use
• OS updates and app updates, app 1st open and remove, app exceptions
• Operating system and version number
• Type of device used with the app

For a complete overview of all possible automatically collected events see https://support.google.com/firebase/answer/9234069?visit_id=637852818650424916-729496526&rd=1.

The events relevant to our app are limited only to the first chapter ‘Automatically collected events’, whereby in particular all mentioned events in connection with advertising (ads), in-app purchases (in-app buy), subscriptions (subscriptions) are not relevant as these functions are not supported by the app.

If Google Firebase transfers your data to third countries outside the European Economic Area (“EEA”), the standard data protection clauses issued by the European Commission apply in conjunction with appropriate technical and organizational safeguards.

In addition to the automatically collected events, the app also logs a number of custom events. The following categories of custom events are logged from the mobile app: 

• Screen views
• Button clicks
• Earbud usage
• Configuration changes
• Firmware / Voice Prompt update results
• Usage events

The app also uses the Crashlytics services which anonymously logs error reports in case of an app crash. These logs are used to increase the stability of app and fix issues.

In addition to the above mentioned app analytics, the app also reads event logs & usage statistics from the earbuds and cradle in anonymous form.  with the sole purpose of providing a continuously improved product. 

By selecting the appropriate setting in the “Privacy” section of the app menu, you can consent
to the processing of your anonymized data or prevent it at any time by revoking your consent with future effect. 

If you log in to the TV Clear app using your user account or create a user account in the app,
the following data is processed automatically to provide you with product updates (Art. 6 para. 1 lit. b GDPR):

• Device model 
• User-created profiles and settings such as presets 
• email address
• log-in user name

This data is stored to ensure the alignment of the features on multiple devices and after
reinstallation. You can prevent the storage of this data by not using the app.

Deleting your user account will also delete all associated profiles and settings from our systems.

We use Microsoft Azure (provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA) to store data associated with the user account. In order to maintain the level of data protection granted by the European General Data Protection Regulation (GDPR), we have concluded the standard data protection clauses or “standard contractual clauses” issued by the European Commission in conjunction with appropriate technical and organizational safeguards with the provider. If your country of origin entered during registration belongs to the European Economic Area (“EEA”), your data will be stored in data centers within the EEA. For users from other regions, data center locations will be determined in accordance with relevant data localization requirements.