1. Who We Are
Burotec Limited (“Burotec”, “we”, “us”, “our”) is a UK-based app development company specialising in accessibility and wellness applications for iOS. Our registered address is 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
We are the data controller for personal data collected through our website and apps. For data protection enquiries, contact us at privacy@burotec.co.uk.
Data Protection Officer: We are not required to appoint a DPO under UK data protection law. However, we take data protection seriously and have designated a contact point for privacy matters at
privacy@burotec.co.uk.
2. Apps Covered by This Policy
This policy applies to the following Burotec apps and any future apps we publish:
HearingUS — Hearing Aid App (Hear Boost)
HearingPal — Deaf Transcriber
Tinnitus Masker
Sleep Fan Noises
Future Burotec apps
Future apps will reference this policy unless a separate policy is provided.
3. What Data We Collect and How
3.1 Our Website (burotec.co.uk)
When you visit our website we may collect:
- Analytics data via Google Analytics — including pages visited, session duration, browser type, and approximate location derived from IP address. This data is aggregated and does not directly identify you. It is only collected if you provide consent via our cookie banner.
- Your email address if you subscribe to our newsletter. We use this only to send you app updates and accessibility news from Burotec.
3.2 HearingUS and HearingPal — Microphone Access
These apps require access to your device’s microphone in order to function:
- HearingUS uses your microphone to amplify ambient sound in real time. Audio is processed entirely on your device. It is not recorded, stored, or transmitted to us or any third party.
- HearingPal uses your microphone to perform real-time speech-to-text transcription. All processing is performed on-device using Apple’s on-device speech frameworks. No audio or transcription data is sent to our servers or to any third party.
We do not collect, store, or have access to any audio recorded by these apps. All audio processing is performed entirely on your device.
3.3 Tinnitus Masker and Sleep Fan Noises
These apps do not access your microphone. They do not collect any personal data beyond what Apple may collect as part of App Store operations and any analytics data described in section 3.4.
3.4 App Analytics
Our apps may use Apple’s built-in analytics framework to collect anonymised and aggregated usage data, subject to your App Store privacy settings and ATT consent where applicable. This data does not identify you personally.
3.5 In-App Purchases and Subscriptions
Some apps offer optional in-app purchases processed through Apple’s StoreKit or Google Play Billing. We do not receive or store your payment details. All payment processing is handled by Apple or Google. We receive only a confirmation of whether a purchase or subscription is active.
3.6 Data We Do Not Collect
- Your name, address, or date of birth through our apps
- Health data, diagnosis information, or audiological data
- Location data
- Device identifiers for advertising purposes
- Any data from children — our apps are not directed at children under 13
4. Lawful Basis for Processing
Under the UK GDPR and Data Protection Act 2018, we rely on the following lawful bases:
- Consent — for newsletter subscriptions and any analytics that require your consent under PECR or ATT.
- Legitimate interests — for website analytics and occasional use of contact information to reach similar audiences through advertising platforms.
- Contract performance — to process subscription purchases and provide app functionality you have requested.
- Legal obligation — where we are required to retain data by law (e.g. financial records for HMRC purposes).
5. How We Use Your Data
- Provide and improve our apps and website
- Send you app updates and news if you have subscribed to our newsletter
- Understand how our apps and website are used through aggregated analytics
- Process and manage in-app subscriptions
- Occasionally create lookalike audiences on advertising platforms to reach new users similar to our existing audience — using hashed data only
- Comply with our legal obligations
We do not sell your data to third parties. We do not use your data for automated decision-making or profiling beyond standard advertising platform functionality.
6. Third-Party Services
- Google Analytics — used on burotec.co.uk to analyse website traffic. See Google’s privacy policy.
- Apple App Store / StoreKit — handles in-app purchases and subscriptions on iOS.
- Google Play Billing — handles in-app purchases and subscriptions on Android.
- Apple Speech Frameworks — HearingPal uses on-device Apple APIs for speech recognition. All processing is on-device; no data leaves your device.
- Meta (Facebook) — we may use hashed contact information to create lookalike audiences for advertising on Meta platforms.
7. International Data Transfers
Google Analytics may transfer data to the United States. Google participates in the EU–US Data Privacy Framework and maintains appropriate safeguards. Where we transfer data outside the UK, we ensure appropriate protections are in place in accordance with UK GDPR Chapter 5.
8. How Long We Keep Your Data
| Data type | Retention period |
|---|
| Newsletter email addresses | Until you unsubscribe; deleted within 30 days |
| Website analytics (Google Analytics) | 26 months (Google default); we hold no separate copy |
| Subscription records | 7 years (HMRC financial record-keeping) |
| Privacy correspondence | 3 years |
| App audio & transcription data | Never stored — processed in real time on-device only |
9. Your Rights
Under UK GDPR you have the following rights regarding your personal data:
Right of accessRequest a copy of the personal data we hold about you.
Right to rectificationAsk us to correct inaccurate or incomplete data.
Right to erasureAsk us to delete your data where there is no longer a lawful basis to hold it.
Right to restrict processingAsk us to pause processing of your data in certain circumstances.
Right to data portabilityAsk us to provide your data in a portable format.
Right to objectObject to processing based on legitimate interests or for direct marketing.
Right to withdraw consentWithdraw consent at any time without affecting prior lawful processing.
To exercise any of these rights, contact us at privacy@burotec.co.uk. We will respond within one calendar month.
10. Complaints
If you have a concern about how we handle your personal data, please contact us first at privacy@burotec.co.uk. If you are not satisfied with our response, you have the right to complain to the UK Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint.
11. Cookies
Our website uses two categories of cookies:
- Strictly necessary cookies — required for the website to function correctly. These cannot be disabled.
- Analytics cookies — Google Analytics cookies set only if you choose ‘Accept All’ on our cookie banner.
You can change your cookie preference at any time by clearing your browser cookies and revisiting the site. Our apps do not use cookies.
12. Children’s Privacy
Our apps and website are not directed at children under the age of 13, and we do not knowingly collect personal data from children under 13. If you believe a child under 13 has provided personal data to us, please contact privacy@burotec.co.uk and we will delete it promptly.
13. Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. Our website is served over HTTPS.
Audio data processed by HearingUS and HearingPal never leaves your device. Because audio processing occurs entirely on-device, sensitive audio data is never transmitted over the internet.
14. Changes to This Policy
We review this policy regularly and will update it when our practices change or when required by law. The ‘Last updated’ date at the top of this page reflects the most recent revision. Where changes are material, we will notify newsletter subscribers by email.