HEARBOX MOBILE APP PRIVACY POLICY

I. GLOSSARY OF TERMS

The terms used in this Privacy Policy have the meanings given to them in the Regulations.

1. Application - software in the form of a mobile application called Hearbox Mobile, intended for installation by the End User on the Device, available for download in the Google Play and Apple App Store.
2. Account - a subpage of the Hearbox Mobile Application, a set of permissions made available by the Service Provider to the End User after registration, individualizing the User and enabling access to the Application's functionalities (e.g. results history).
3. Mentee - a natural person without full legal capacity (e.g. a minor) who uses or intends to use the Application Services under the supervision of the End User and whose personal data are entered into the Application by the End User who is his/her legal guardian or with the consent of his/her legal guardian.
4. System (Central System) - the Service Provider's IT infrastructure, enabling the collection and processing of data from the Application (including anonymized data for scientific purposes).
5. Hearing screening test - a preventive functionality of the Application, intended for a preliminary hearing assessment, the result of which does not constitute a medical diagnosis.
6. Service Provider (Data Controller) - INSTITUTE OF PHYSIOLOGY AND PATHOLOGY OF HEARING with its registered office in Warsaw at ul. Mochnackiego 10, 02-042 Warsaw.
7. End User - a natural person with full legal capacity who uses or intends to use the Application Services.

II. PERSONAL DATA CONTROLLER AND DATA PROTECTION OFFICER

1. The controller of the personal data of End Users and Mentees processed for the purpose of providing the Services via the Application is the Service Provider, i.e. the Institute of Physiology and Pathology of Hearing.
2. You can contact the Controller electronically at the following e-mail address: hearbox.mobile@ifps.org.pl.
3. The Institute of Physiology and Pathology of Hearing has appointed a Data Protection Officer (DPO). End Users may contact the DPO with any questions or comments regarding the processing of End Users' personal data and their rights under data protection law.
4. The contact details of the Data Protection Officer are: tel. (22) 35-60-468, e-mail: iod@ifps.org.pl.
5. Information for patients about the processing of personal data by the Service Provider is also available on the website: https://hearboxmobile.ifps.org.pl/.

III. SCOPE OF PROCESSED PERSONAL DATA

1. The Controller processes only the data necessary to achieve the processing purposes, applying the principle of „data minimization".
2. In order to ensure the proper functioning of the Application, the Controller processes the following categories of data:
   1. User Data: e-mail address, username, gender, date of birth.
   2. Sub-account (Mentee) data entered by the User: username, gender, year of birth.
   3. Information regarding screening tests performed: date, results and metadata of tests performed by the User or Sub-Account, stored and processed in the System.
   4. Technical data regarding the Device and connection: phone model and manufacturer, operating system (name and version), IP address used during connection to the Application server, technical data of the device necessary for test calibration.
   5. Information about Account activity: date of account creation, password change, login and logout.
3. The End User who creates a Sub-Account for a Mentee represents that they are the Mentee's legal guardian and have full authority to act on their behalf. The End User is solely responsible for the accuracy and completeness of the Mentee's data entered and for having the necessary authorizations to process it.
4. Due to the fact that information regarding the Application account is sent to the email address provided by the End User, including information that may reveal the End User's personal data and information about services provided, the Service Provider does not recommend providing an email address shared by the End User with third parties. The End User is solely responsible for the use of the email address provided by the End User.

IV. PURPOSES AND LEGAL BASIS FOR PERSONAL DATA PROCESSING

The Controller may process personal data of End Users and Mentees collected via the Application for the following purposes and on the following basis:

1. Provision of services by electronic means (maintaining the Account and operating the Application) - pursuant to Article 6(1)(b) of the GDPR (necessity for the performance of a contract to which the User is a party - acceptance of the Regulations).
2. Health purposes - hearing prevention (performing a screening test) - pursuant to Article 9(2)(h) of the GDPR (processing is necessary for the purposes of preventive health care) in conjunction with Article 3(1) of the Act on Medical Activity. Test results are collected, stored, and processed in the Institute's System.
3. Implementation of the Institute's statutory research tasks - pursuant to Article 6(1)(e) of the GDPR (performance of a task carried out in the public interest) in conjunction with Article 9(2)(j) of the GDPR (processing necessary for scientific research purposes). Test results (in anonymized form) may be used for statistical analyses and the development of medical knowledge, which constitutes the implementation of the Institute's public mission.
4. Establishing, pursuing or defending claims - pursuant to Article 6(1)(f) of the GDPR (legitimate interest of the Controller).
5. Performing a hearing screening test as part of access without logging in to the Application (guest mode), in the scope of data collected temporarily (including test results) - based on the voluntary and informed consent of the End User (Article 6(1)(a) and Article 9(2)(a) of the GDPR). Data processing for this purpose takes place only during the period of use of a given test session and to enable the User to decide whether to save or delete the data.

V. DATA RECIPIENTS AND DATA TRANSFER

1. The personal data of the End User and the Mentee may be made available to entities processing data on behalf of the Controller (e.g. IT service providers, Application service providers, server providers) only on the basis of appropriate agreements.
2. App store operators (Google Play, Apple App Store) are separate controllers of the User's data in the scope of the process of downloading the Application and maintaining the account in the store.
3. The personal data of End Users and Mentees will not be transferred to third countries (outside the European Economic Area) or to international organizations.

VI. DATA STORAGE PERIOD (RETENTION)

1. Data related to the Account are processed for the duration of the service provision (the period of having an Account).
2. Regardless of the deletion of the Account, health data (test results) are stored in accordance with the retention periods adopted for preventive purposes or until an effective objection is filed (in the case of scientific purposes), but not shorter than the limitation period for any claims (maximum 6 years from the end of cooperation).
3. Deleting an Account at the User's request is tantamount to terminating the agreement for the provision of electronic services. This request is tantamount to requesting the permanent deletion of all personal data of the End User and the data of the Sub-Accounts collected from the Service Provider's servers, provided that health data (test results) and data necessary to fulfill the Institute's statutory scientific and research tasks are still stored, in accordance with the retention periods specified in Part V, paragraph 8 of the Regulations. The process of permanent deletion of the Account and all other data not covered by the above exception will be finalized by the Service Provider within 30 days of the date of termination.

VII. END USER RIGHTS

1. The End User (and the legal guardian acting on his/her behalf in the case of Mentees) has the right to:
   1. Access their data and receive a copy of it.
   2. Rectification (correction) of incorrect data and supplementation of incomplete data.
   3. Deletion of data („right to be forgotten") - in cases provided for by law (e.g. when the data is no longer necessary for the purposes for which it was collected).
   4. Restriction of data processing.
   5. Data portability (receiving data in a structured format).
   6. Withdrawal of consent - where processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
2. The User has the right to object at any time to data processing based on a public interest task (scientific purposes) or legitimate interest.
3. The End User and - on behalf of the Mentee - his or her legal guardian have the right to lodge a complaint with the President of the Personal Data Protection Office if he or she considers that the processing of his or her personal data violates the provisions of the GDPR.
4. End Users and Mentees will not be subject to automated decision-making (without human involvement). End Users' or Mentees' personal data will also not be used for profiling.

VIII. VOLUNTARY PROVISION OF PERSONAL DATA

1. Providing personal data in the Application is completely voluntary.
2. It is possible to use the Application and complete the test without providing any personal data (including date of birth or email address).
3. If used without providing personal data (guest mode), test results may not meet age-appropriate medical standards, and the test result history will not be permanently saved. Technical data and test results are collected temporarily, based on consent, solely for the duration of a given test session, to enable the User to decide whether to save or delete the data.
4. Providing an email address is only necessary if you wish to create an Account, which allows you to save your results history and access them on other devices.

IX. APPLICATION ACCESS TO DEVICE RESOURCES

1. The Application requires access to the Device's microphone solely for the purpose of measuring ambient sound levels. No audio data is recorded, saved, or stored.
2. Internet access is necessary for the operation of the Application, including data synchronization, storing the results of services performed, maintaining user accounts and communicating with the server.