Privacy Policy
The short version
- The app has no accounts. It never asks for your name, email or phone number.
- Your test results, journal, questionnaires and check-ins are stored on your iPhone. There is no server of ours holding a copy.
- To improve the app, it sends usage statistics and crash reports to Google Firebase: which screens and features are used, the numeric results of tests, questionnaires and daily check-ins, and technical crash details. They are tied to a random device identifier that survives reinstalling the app (pseudonymous, not anonymous), but never to a name, email, journal text, notes or audio.
- You can switch both off at any time in Settings → Privacy & Data. No ads, no advertising identifier (IDFA), no identifier for vendors (IDFV), and we never sell your data.
- Guided recordings are downloaded the first time you play them; the server hosting them sees your IP address, as with any download.
- You can erase everything for good from the same screen, free for everyone. With Premium you can also export it. Anyone can ask us, free of charge, for a copy or the deletion of the usage data we hold (section 10).
This policy explains, in plain language, what happens to information when you use Tinnitus Haven. It is written to meet the transparency requirements of the EU General Data Protection Regulation (GDPR, Articles 13 and 14), Turkey's Personal Data Protection Law No. 6698 (KVKK) and Apple's App Store requirements.
1. Who is responsible
Tinnitus Haven is made and operated by an independent developer based in Türkiye, who is the controller for any personal data covered by this policy.
Contact: info@tinnitushaven.com. We answer emails ourselves. The feedback form inside the app is read too, but it cannot be answered individually. If you need a reply, please email us.
We have not appointed an EU representative under Article 27 GDPR. The only data that reaches us from the app is the pseudonymous usage statistics and crash reports described in section 4; we regard this as occasional, low-risk processing within the exemption in Article 27(2)(a), and will revisit it if the app's data handling changes. We have not appointed a data protection officer either; the criteria in Article 37 GDPR are not met.
In practice there is little for a controller to do here, because the app sends us nothing that directly identifies you: no name, email or account. Sections 3 to 6 explain exactly what it does send, and what it does not.
2. What this policy covers
It covers two things: the Tinnitus Haven iOS app (bundle identifier com.tinnitushaven.tinnitus, iOS 18 and later), and this website. Where the two differ, we say so.
3. What the app keeps on your device
Everything below is created on your device, stored on your device by iOS, and read only by the app on your device. The records themselves are never uploaded, not to us and not to anyone else. What does leave the device is the usage statistics and crash reports described in section 4, which include some of the numbers below (for example test thresholds and check-in scores) unless you switch them off.
| What | Why | Where it is kept | Who can see it |
|---|---|---|---|
| Hearing and tinnitus self-test results (thresholds, pitch and loudness matches) | To show your results and tailor the sound therapy | On the device, in Apple's SwiftData store | Only you; the numeric results are also part of the usage statistics in section 4 unless you switch them off |
| Sound therapy settings and presets, mindfulness and CBT-programme progress | To remember where you left off | On the device, in Apple's SwiftData store | Only you |
| Journal entries, anxiety-questionnaire results, daily check-ins | To let you track how you are doing over time | On the device, in a separate, file-protected store, encrypted at rest by iOS Data Protection and readable by the app once you have unlocked the device after it starts | Only you; questionnaire and check-in scores (never journal text or notes) are also part of the usage statistics in section 4 unless you switch them off |
| Your privacy choices (“Help improve the app”, “Send crash reports”) and other preferences | To remember what you chose | On the device, in the app's preferences. What each switch controls is explained in section 4. | Only you |
| Reminders and check-in notifications | To remind you at the times you choose | Scheduled locally by iOS on your device; their content never leaves it | Only you |
| Microphone input | Only to measure how loud the room is while you set up a hearing test, so the app can warn you that it is too noisy | Nowhere. The level is measured live; audio is never recorded, never saved and never transmitted | Nobody |
| Subscription status | To unlock paid features | Determined on the device by Apple's StoreKit, from your Apple account. See section 7. | You and Apple |
Like most apps, Tinnitus Haven also writes an ordinary diagnostic log to the device's own system log (Apple's unified logging) to help with troubleshooting. That log stays on the device. If you have chosen to share device analytics with Apple, iOS may include system-log data in the diagnostics it sends to Apple under Apple's own privacy policy; that channel is Apple's, not ours, and we receive nothing from it.
4. Usage statistics and crash reports
To learn which features are actually used and to find and fix bugs, the app uses two services from Google LLC: Firebase Analytics and Firebase Crashlytics. Apart from downloading guided recordings (section 6), this is the only data that leaves your device because of the app, so we describe it in full.
What is collected: usage statistics (“Help improve the app”)
- which screens you open and which buttons you tap;
- the steps you take through the hearing test, sound therapy, mindfulness and CBT features (for example started, completed or skipped);
- the numeric results of hearing and tinnitus tests and questionnaires: per-ear hearing thresholds, the matched tinnitus frequency and loudness, questionnaire item scores and the anxiety-questionnaire (GAD-7) total, as numbers only, never any note or text you write;
- the severity and impact scores of your daily check-ins, again as numbers only, never the note;
- settings you change, such as the app language or a therapy preset;
- whether the subscription screen was shown and whether a subscription was bought and, for a completed purchase, the product, its price and its currency. Never any card or other payment details: payment is handled entirely by Apple;
- when the app is opened and closed, together with general technical facts: app version, iOS version, device model, language and an approximate country or region, which Google derives from your IP address (the app never asks for your location).
What is collected: crash reports (“Send crash reports”)
- if the app crashes or freezes: a technical report of where in the code it happened, the app and iOS version, device model, orientation, available memory and storage, and what the app was doing in the moments before;
- related performance diagnostics, such as unusually slow starts.
What is never collected
- your name, email address, phone number or any account (there is none);
- journal entries, check-in notes, or anything else you type;
- audio, microphone input or your precise location;
- the advertising identifier (IDFA) or the identifier for vendors (IDFV). The app never shows Apple's App Tracking Transparency prompt because it does not track you across other companies' apps or websites, and the data is not used for advertising.
The device identifier
The only identifier attached to this data is a random code that the app generates the first time it runs and stores in your device's Keychain. It is sent as the user ID with both the usage statistics and the crash reports, so everything sent from one device is linked to that code. It is not your name, email, Apple ID, phone number, advertising identifier (IDFA) or identifier for vendors (IDFV), and neither we nor Google can tell from it who you are. The data is therefore pseudonymous, not anonymous, and we declare it as “Linked to you” in Apple's App Privacy label. It is not used to track you across other companies' apps or websites.
Because it is kept in the Keychain, the identifier survives reinstalling the app, and “Delete all data” does not remove it. Switching off “Help improve the app” and “Send crash reports” stops it from being sent.
Who processes it
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, processes this data on our behalf as a processor under Google's data-processing terms. We use it only to improve the app; it is not sold, and it is not used for advertising. How Firebase handles data is described at firebase.google.com/support/privacy.
Legal basis
Our legitimate interest in understanding how the app is used and in keeping it stable (GDPR Art. 6(1)(f); KVKK Art. 5(2)(f)). We weighed this against your interests: the data is minimal, carries no name or contact details, is never used for advertising or profiling, and you can stop it at any time with one switch. The test and check-in figures are numbers attached only to the random device identifier; we declare them as “Health” data “Linked to you” in Apple's App Privacy label, to be transparent about their nature.
How long it is kept
Google Analytics event data is kept for up to 14 months, after which only aggregated statistics remain. Crash reports are kept for 90 days.
Where it is processed
Google may process this data on servers in the United States and elsewhere outside the EU/EEA and Türkiye. The transfer is covered by the EU Standard Contractual Clauses incorporated in Google's data-processing terms; see section 12.
How to switch it off
Open Settings → Privacy & Data in the app. Help improve the app controls the usage statistics; turning it off stops every event immediately, including Firebase's own automatic events such as session starts. Send crash reports controls crash reporting. Both are on by default, and nothing else in the app changes when they are off. Data already sent is tied only to the random device identifier, which the app does not show and we cannot link to your name or email. It expires as described above; section 10 explains how to ask us for a copy or for its deletion before then.
5. Legal basis
For the data stored only on your device, we have no way to reach it and do not process it as a controller in the ordinary sense. To the extent that operating the app counts as processing:
- GDPR Art. 6(1)(b): performance of the contract, since the app cannot show you your results without storing them on your device.
- GDPR Art. 9(2)(a): your explicit consent for the health-related content you choose to enter (hearing results, symptoms, journal, questionnaires). You provide it by choosing to enter that content; you can withdraw it at any time by deleting the data (section 9).
- KVKK Art. 5(2)(c) for data directly related to performing the contract, and KVKK Art. 6(3) (explicit consent, açık rıza) for the health-related data stored on your device.
- GDPR Art. 6(1)(f) and KVKK Art. 5(2)(f): our legitimate interest, for the pseudonymous usage statistics and crash reports in section 4, which you can object to at any time by switching them off.
There is no processing for marketing or profiling, and no advertising of any kind.
6. Who we share data with
One processor: Google LLC, which receives the usage statistics and crash reports described in section 4 (including the numeric test and check-in figures listed there) and processes them on our instructions.
The host of the guided recordings. Mindfulness sessions and CBT audio lessons are not bundled with the app; each one is downloaded from a static file host the first time you play it, and then kept on the device. Like any server, that host necessarily receives your device's IP address, the file requested and the time of the request when a file is downloaded. No other data is sent with the download.
Nobody receives your journal, notes or the records stored on your device. Specifically, the app contains:
- no advertising, ad networks, advertising identifier (IDFA) or identifier for vendors (IDFV);
- no social-media or attribution SDKs;
- no cookies or similar technologies.
Apple's App Tracking Transparency prompt does not appear, because the app does not track you across other companies' apps or websites, which is what that prompt is about.
7. Purchases and Apple's role
Subscriptions are sold, billed, renewed, refunded and cancelled entirely through your Apple account. We never see, receive or handle your payment details, billing address or Apple ID. Apple acts as an independent controller for that transaction under its own privacy policy.
Like every developer, we can see the aggregate, anonymous sales and usage reports Apple provides in App Store Connect, for example how many subscriptions were active in a country in a month. These reports are statistical, come from Apple rather than from the app, and cannot identify you.
8. This website
These pages are plain HTML. They set no cookies and contain no tracking pixels, no advertising and no external fonts.
To see how many people visit and where they come from, we use Cloudflare Web Analytics, a privacy-first statistics service from our hosting provider. It loads one small script from Cloudflare, sets no cookies, does not use your IP address to identify you and does not follow you across websites. We only see totals: page views, the page you came from, country, browser and device type, and how fast pages load. Nothing you do here is linked to you or to the app. The legal basis is our legitimate interest in understanding, in aggregate, how the site is used (GDPR Art. 6(1)(f)).
As with any website, our hosting provider, Cloudflare, Inc., processes the technical data needed to deliver a page to you (your IP address, the time of the request, the page requested and your browser's user-agent string) and keeps it briefly for security and to keep the service running. The legal basis is our legitimate interest in serving the site securely (GDPR Art. 6(1)(f)).
9. How long data is kept, and how to erase it
Data on your device stays there until you remove it. There is no copy anywhere else and no automatic expiry. You have two ways to erase everything:
- In the app: Settings → Privacy & Data. Deletion is permanent and cannot be undone, so the app asks you to type DELETE to confirm.
- Delete the app from your iPhone. iOS removes its container, and everything in it, with it.
With Premium, the same screen also lets you export your data first, so you can keep a copy.
Usage statistics and crash reports already sent are kept by Google for the periods in section 4 and then expire. Deleting your data in the app does not remove them, and it does not reset the random device identifier, which stays in the Keychain even if you delete or reinstall the app. Switch off “Help improve the app” and “Send crash reports” if you want nothing further to be sent.
Deleting the app does not cancel a subscription. See the FAQ for how to cancel.
10. Your rights
Under the GDPR and the KVKK you have the right to access your data, to have it corrected, to have it erased, to receive it in a portable format, to restrict processing, and to object to processing. Here is the honest, practical answer to how you exercise them:
- Access and portability: the records the app keeps are already yours and already on your device. You can see all of them in the app, and there is no other copy. With Premium you can also export them as a file (JSON) in Settings → Privacy & Data. Your rights never depend on a subscription: anyone can ask us, free of charge, for a copy of the data we hold (the usage statistics and crash reports tied to the random device identifier; see section 4) or for its deletion, as described below.
- Rectification: edit or re-run anything directly in the app.
- Erasure and withdrawal of consent: delete all data in the app (free for everyone), or delete the app.
- Objection and restriction: turn off “Help improve the app” and “Send crash reports” in Settings → Privacy & Data, or stop using a feature.
You are welcome to write to info@tinnitushaven.com with any request; it costs nothing. We hold no copy of the records stored on your device, so we cannot send, correct or delete those on your behalf; they are under your control in the app. The only data we hold is the usage statistics and crash reports described in section 4. If you ask for a copy of them or for their deletion, we will do it free of charge. Because the app does not show the random device identifier and we cannot link it to your name or email, we will first help you identify the data that comes from your device. If you send us personal details in an email, we use them only to answer you and delete the correspondence when it is no longer needed.
11. Complaints
If you think your data-protection rights have been breached, you can complain to a supervisory authority: in the EU/EEA, the data protection authority of the country where you live, work or where the issue arose (the list is published by the European Data Protection Board); in Turkey, the Personal Data Protection Board (Kişisel Verileri Koruma Kurumu). We would appreciate the chance to sort it out first, but you do not have to contact us before complaining.
12. International transfers
The records in section 3 (your journal, notes and history) are not uploaded, so no transfer of them takes place. The usage statistics and crash reports in section 4, including the numeric figures listed there, are processed by Google, which may use servers in the United States and other countries outside the EU/EEA and Türkiye. That transfer relies on the EU Standard Contractual Clauses that form part of Google's data-processing terms, together with Google's technical and organisational safeguards; for users in Türkiye it takes place under Article 9 KVKK. This website is delivered by a content-delivery network, so the technical request data in section 8 may be handled on servers outside your country; no content of yours is involved. The same applies to the host of the guided recordings in section 6.
13. Children
The app is rated 16+ on the App Store because it regularly provides health and treatment information about tinnitus; it is not designed for or directed at children, and it is not a substitute for a paediatric hearing assessment. We do not knowingly collect personal data from children; the statistics in section 4 carry no name or contact details, and a parent or guardian can switch them off. If a child uses the app, everything they enter is stored on the device, and a parent or guardian can erase it as described in section 9.
14. Security
Your data is protected by iOS itself: each app is sandboxed, and the app's stores (including the separate one for your journal, questionnaire results and check-ins) are encrypted at rest by iOS Data Protection. They become readable to the app once you have unlocked the device after it starts. Please use a device passcode and keep iOS up to date. Because there is no server of ours and no account, there is no database of users to breach and no password of yours to steal. The statistics and crash reports in section 4 are sent to Google over an encrypted connection.
15. Not a medical service
Tinnitus Haven is a wellness app. It is not a medical device, it does not diagnose or treat anything, and its self-test is a screening aid, not a clinical hearing test. See the Terms of Use and the FAQ.
16. Changes to this policy
If we change how information is handled (for example, if a future version adds optional accounts, cloud sync, or collects anything beyond what section 4 describes), we will update this page, raise the version number and the “Last updated” date, and describe the change inside the app before it takes effect. Material changes that need your consent will ask for it.
Version 1.3 (23 October 2026) states that for a completed purchase the product, price and currency are included in the usage statistics (never payment details), and that the approximate country or region is derived by Google from the IP address.
Version 1.2 (12 October 2026) describes the device identifier more precisely (pseudonymous, linked to you in Apple's label, kept across reinstalls), lists the check-in and questionnaire scores included in the usage statistics, adds the host of the guided recordings as a recipient, and corrects the description of on-device encryption. It also states that exporting your data in the app is part of Premium while deletion stays free for everyone, and explains how anyone can ask us, free of charge, for a copy or the deletion of the usage data we hold.
Version 1.1 (26 September 2026) added section 4: usage statistics and crash reports via Google Firebase, both switchable off in Settings.
17. Contact
Questions about privacy: info@tinnitushaven.com. We answer in English, Turkish and German.