The app (“Fonetti app”), website (“Fonetti website”) and the speech processing services for Fonetti (“speech processing”), and the websites for Auris Tech Limited (“Auris website”), collectively referred to here as “the Services” or “Auris Services” are operated by Auris Tech Limited.
The personal information collected in connection with your or your child’s use of the Fonetti includes the collection of voice recordings that are captured when users proactively turn on the “recording” function in settings or volunteer their time knowingly for the purpose of their voice being recorded while using Fonetti. By design, Fonetti does not record the voices of its users in its default mode, and the “recording” function is not readily accessible without knowing and intentional actions by users to turn it on.
You may also request deletion of user data previously collected by contacting us at firstname.lastname@example.org.
For processing the data of a child, we require consent from an adult with parental authority over that child, such that your consent for us to collect and process data is valid and authorised. By creating an account and accessing the Services, you certify that you possess that authority and that you are in fact providing consent, and are responsible for all activities in the Services.
You can withdraw your consent by contacting us at email@example.com.
1.1. Who is Auris Tech Limited?
Auris Tech Limited (“Auris Tech,”“the Company”, “we”, “our”, “us”) is registered in England and our registered address is at 14 East Bay Lane, Lesney Avenue, London, United Kingdom, E20 3BS
Auris Tech is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our websites, it will only be used in accordance with this privacy statement.
2. Our obligations – data protection principles
We comply with the privacy principles of the GDPR – which states the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
3. Information we collect
We may collect certain user information, including personal information in the following ways:
Information you provide to us
To provide you with the required services, we may collect personal information that you provide voluntarily to us including; over the telephone, by e-mail, face-to-face, when you visit our website(s), for example, when you fill out the contact form, consent form, Data Subject Access Request Form, participate in any interactive features on our website, participate in a survey, promotion, activity or event, apply for a job, request support, or communicate with us via third-party social media sites or direct marketing.
The types of information you provide typically include your name, email address, phone number, age, location, name as well as any contact or other information you choose to provide or financial and bank account/debit/credit card information.
- Registration details, such as your name, email, and year of birth, and your child’s age or year of birth and a name for your child’s reader profile;
- Purchase details when you subscribe to Fonetti for any Auris Services, which can include your name, payment information, mailing address, and telephone number;
- Other information you may volunteer to share publicly in relation to Auris Services on any of its sites or public forums administered by Auris;
- Correspondence with you, if you contact us for any reason, may be kept;
- Audio recordings made knowingly, voluntarily and with consent;
Information we collect automatically
When you access or use the Auris Services, we may automatically collect information about you, including:
- Technical details about the device used, such as type and model, and service use details, such as IP address, location data (if enabled on your device), and other data related to your usage of the Services;
- Service user behaviour details, such as how features in our Services are used, time spent and frequency of sessions using our Services may be collected automatically;
Information we collect from other sources
We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
4. How we use your personal data
- We may use the Personal Data collected for the limited purpose of providing the required services and related functionality for which Auris tech has been engaged. Most commonly, we will use your Personal Data for the following lawful bases for legitimate interests to:
- Share with you valuable feedback of your child’s use of Fonetti, including progress and challenges, with the intention of improving their reading enjoyment and abilities;
- Analyse compiled, aggregated, anonymised user data so that we may better understand how we can improve our Services;
- Provide you with improved features and functions in our Services;
- Announce updates about the Auris Services, including any policy and product updates;
- Communicate with you about your account, including purchase information;
- Verify that our policies and terms are being followed and laws are not being violated in cases of suspicious activity.
- Where we need to comply with a legal or regulatory obligation.
Special categories of personal data
We may need to use more sensitive personal data (known as “special categories of personal data”) about you or others associated with you, for example your family. We will only use this kind of information where:
- we have your explicit consent;
- it is necessary for us to carry out the service(s) for which you have expressed interest and/or explicitly registered for;
- it is necessary for us to use this information to protect your vital interests or those of another person where it is not possible to obtain consent;
- it is necessary for us to do so in connection with the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity; or
- in exceptional circumstances, another of the grounds for processing special categories of personal data are met.
Where you have provided us with explicit consent to use special categories of personal data about you, you may withdraw your consent for us to use this information at any time. Please see right to withdraw your consent for further details.
Please note that if you choose to withdraw your consent for us to use special categories of personal data about you, this may impact our ability to provide legal or support services to you.
Automated decision making
We do not undertake any fully automated decision-making processes.
5. For how long will you use my information?
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any marketing, sales, legal, contractual, accounting, or reporting requirements.
6. Data security and Data Retention
While no service is completely secure, we take reasonable measures to help protect your information loss, theft, unauthorised access, disclosure, alteration and destruction. We also take reasonable measures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Where we store your data and how we do International Transfers
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Where we transfer data to a member of Auris Tech or use third party providers in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.
If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
7. Change of purpose
We will only use your personal information supplied in this website for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for any other reasons and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
8. Sharing and disclosure of information
We will not share personal information about you with any third parties except as described in this Privacy Notice or in connection with the services we provide to you. For example, we may share personal information about you including as follows:
- Compliance with laws or our legitimate interest: We may disclose your information to a third party if:
(a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; or
(b) to enforce our agreements, policies and Terms of Service; or
(c) to protect the security or integrity of our services; or
(d) to protect Auris Tech Limited, our customers or the public from harm or illegal activities; or
(e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or
(f) where it is necessary to administer the working relationship with you, such as for the fulfilment of your order, the processing of your payment details and the provision of support services; or
(g) where we have another legitimate interest in doing so e.g. for marketing or performance of contract; or
(h) to any other third party with your prior consent.
- Business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Aggregated or anonymised data: We may also share aggregated or anonymised information with third parties that does not directly identify you.
9. Third party services
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We ensure that appropriate technical and organizational measures are adopted by us to ensure safekeeping against unauthorised or unlawful processing of personal data and against accidental loss or destruction or damage to the personal data. We will retain information you provide on our website for as long as we need it to provide you or your organization with the services, unless we may need to retain this information as necessary to comply with any legal obligations. If you have submitted information to us and wish to see a copy of the information we hold about you or have it removed from our internal records, please email us at email@example.com
10. Your choices
You may update, correct or delete information about you at any time by emailing firstname.lastname@example.org.
In particular, you can also request for the following
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes that you don’t want.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
Upon request, Auris Tech will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information that we are aware of. To request this information, contact us at email@example.com. We will endeavour to respond to your access request within 30 days.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly excessive, repetitive, or when you request for multiple copies or when your request is unfounded. Alternatively, we may refuse to comply with the request in such unusual or strange circumstances.
11. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
12. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please send us email at firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Promotional and newsletter communications. You may opt out of receiving promotional and newsletter emails from Auris Tech by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing email@example.com with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Auris Tech services or our ongoing business relations.
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent we may post your testimonial along with your name
13. Data Protection / Compliance Team and how to make a complaint
How to make a complaint
Data Privacy Laws are constantly evolving and we endeavour to maintain best practice. However, we recognise that we may not always get it right and where you are not satisfied in the way we handle data or you wish to discuss our processes then we would be grateful to hear from you.
If you have any concerns about your privacy and our compliance with Data Privacy Laws, we would appreciate the chance to deal with your concerns before you approach a Supervisory Authority. Please contact us in the first instance at firstname.lastname@example.org.
However, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
If we are involved in a reorganisation, merger, acquisition or sale of our assets, your information may be transferred as part of the deal. We will notify you of any such deal and outline your choices in that event.
2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
3. We use the following cookies:
3.1 Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
3.2 Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
3.3 Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
3.4 Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
5. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.