NEBROO MOBILE APPLICATION PRIVACY POLICY
Effective Date: 01st May 2025
GA Trading LLC, located at 1021 E Lincolnway, Suite 7892, Cheyenne, Wyoming 82001, USA (“the Company,” “we,” “us,” or “our”), is responsible for the processing of personal data related to the use of the Nebroo mobile application (the “Application”). This Privacy Policy aims to inform you about the types of personal data we collect, how we process it, and the rights you have when using the Application, which focuses on the Over-The-Counter (OTC) hearing aids industry.
1. SCOPE OF THIS POLICY
This Privacy Policy applies to all users who download, install, or use the Nebroo Application, including any services or features related to it. By using our Application, you acknowledge and agree to the privacy practices outlined herein.
2. INFORMATION WE COLLECT
1. Information Provided Directly by You:
○ Registration Data: Such as your name, email address, phone number, or other details if the Application requires account creation.
○ Preferences and Application Settings: Information that you enter to personalize your experience in the Application.
○ Hearing-Related Information: If the Application offers features like hearing self-tests or assessments, this data may be considered sensitive and will be handled with special care and confidentiality.
2. Information Collected Automatically:
○ Device Information: Including device type, model, operating system, language settings, unique device identifiers or IP address.
○ Usage Data: Such as frequency of use, time spent within the Application, sections visited, features accessed or similar usage metrics.
3. Information from Third Parties:
○ If the Application connects with third-party services or platforms (e.g., social networks or medical systems), we may receive information about you according to those platforms’ privacy policies. We recommend that you review the data handling practices of any such third-party platforms you use in connection with the Application.
3. PURPOSE OF DATA PROCESSING
We use the collected personal data for the following purposes:
1. Provision of Services and Features:
○ To enable the use and functioning of the Application, including personalized hearing features based on the information you provide.
○ To process user registration and maintain your user account, if applicable.
2. Application Improvement:
○ To analyze usage patterns and optimize the interface, features, and performance of the Application.
○ To conduct internal research or testing with anonymized data to improve Nebroo’s technology.
3. Customer Service and Technical Support:
○ To respond to inquiries, requests, or complaints submitted through our available communication channels.
○ To provide support when technical issues arise.
4. Marketing and Communications:
○ To send promotional materials, special offers, or updates related to Nebroo, provided that you have given your consent.
○ To remind users of certain features or services provided by the Application.
5. Legal Compliance:
○ To comply with obligations required by law, court orders, or administrative authorities, or to protect the legitimate interests of the Company as allowed by applicable regulations.
4. LEGAL BASIS FOR PROCESSING
Depending on the applicable jurisdiction, our legal basis for processing your personal data
typically includes:
● Your express consent, especially for sensitive data such as hearing or medical information.
● The necessity to perform a contract to which you are a party (i.e., providing you with the services and features of the Application).
● Compliance with our legal obligations.
● The Company’s legitimate interest in improving its services and ensuring the security of the Application.
5. SHARING YOUR PERSONAL DATA
We may share your personal data with third parties in the following circumstances:
1. Service Providers:
○ Companies we engage to provide services such as data hosting, payment processing, technical support, or Application usage analytics. These providers are contractually obligated to use the data only to perform services on our behalf and to maintain confidentiality.
2. Legal Compliance:
○ If required to disclose information in order to comply with legal obligations, court orders, or requests from competent authorities.
3. Corporate Transactions:
○ In the event of a merger, acquisition, sale of assets, or corporate restructuring, your personal data may be transferred to the acquiring entity or successor, with the obligation to continue safeguarding the data in line with applicable legal requirements.
6. INTERNATIONAL DATA TRANSFERS
Since GA Trading LLC is based in the United States, your data may be transferred and processed outside your country of residence. We will ensure adequate safeguards are in place, as required by applicable law (e.g., Standard Contractual Clauses in the EU, or equivalent frameworks in other jurisdictions), to protect your personal data.
7. INFORMATION SECURITY
We implement technical, organizational, and administrative security measures designed to protect your personal data against unauthorized access, loss, or improper alteration. However, no security system is completely foolproof, and we cannot guarantee absolute protection of your data. You are responsible for maintaining the confidentiality of your credentials and adopting strong passwords on your devices.
8. DATA RETENTION
We retain your personal data only as long as necessary to fulfill the purposes stated in this Privacy Policy or as required by law. Once the data is no longer needed for the stated purposes, it will be securely deleted or anonymized.
9. FOR RESIDENCE IN CALIFORNIA
● 《Act of consumer privacy in California》（CCPA）requires us provide to California residence how we handle their personal data’s specific information.
1.Classification of CCPA personal data.
Nebroo collect the personal data according to the following classification assured by CCPA:
1)Identifier
2)Customer record
3)Biology statics information
4)Internet or net activity
5)Geographic Location
6)Sensor information
7)Occupation or employment
8)Inference
● As further detailed described in this privacy policy, NEBROO will collect those data when you visit our website or purchase and use our product and service. We collect your personal data, because they are necessity for providing, operating, maintaining and supporting our product and service, as well as managing and promoting our business. Please refer to and read other parts of our privacy policy, including “the purpose of collecting data by App” and “how to collect your personal data”.
2.Exert your rights
○ California Residence has right to submit the following requirements(at most twice each year)：
1)Has the rights to ask for obtaining your specific personal data collected by NEBROO.
2)Has the rights to require that NEBROO reveal what personal data is collected, used, revealed or sold by us.
3)Has the rights require NEBROO to delete personal data about you which has been collected (Except some exceptional situation)
4)Has the rights to choose not to sell your personal data.
○ You can exert the rights of visiting and deleting data by the following ways:Send email to us, or give a call to us to contact with our data protection officer. This section does not involve or be applicable to the handle of protected health data by constraint of HIPAA or 《Act of Medical information in California》， including any data collected from your hearing device or NEBROO app by us or any other personal data which obtained exemption according to No.1798.145(c)-(f) clause in CCPA.
○ We will not share any data which NEBROO collect or transfer by App with attached or none-attached third party who need those information for direct marketing purpose. If you are residence in California,then you can require us to gain the related information about revealed personal data to third party for direct marketing purpose. If you want to submit those request, please use the above mentioned data listed by “contact data” to contact with us. You must write “your privacy rights of California state” in the subject field. For the notice letter with incorrect stick label, incorrect sending or incomplete data, we will not be responsible for it.
10. FOR FRANCE RESIDENCE
● You have the rights at any time to release the relative instruction how do handle your personal data after you die.
11. CHILDREN’S PRIVACY
Our Application is not directed at minors, and we do not knowingly collect data from children without parental or guardian consent. If you are a parent or legal guardian and believe that a minor has provided personal information without your consent, please contact us. We will take steps to remove such information as required by law.
12. PRODUCT, SERVICE AND WEBSITE OF THIRD PARTY
● To ensure fluent browsing experience, You may receive the contents or web link from the third party outside of NEBROO AND ITS cooperator (hereinafter to be referred as “the third party “) . NEBROO has no control right to those third parties. You can choose whether or not visit the link, contents, product and service provided by the third party.
● Please notice that the visit to any third party website,software app or other product or service through NEBROO’s website, product or service link are all restrained by the using terms and privacy policy of the third party. You should check carefully the using terms and privacy policy of the third party before you use the third product or service.
● Umeng Statistics SDK
Usage purpose: Collects statistics on user usage habits
Data type: Device information, location information, network information
Privacy policy links: https://www.umeng.com/page/policy
● FCM(Firebase Cloud Messaging) SDK
Usage purpose: Online and offline message push
Data type: Device information(IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM卡IMSI/ICCID), location information, network information
13. YOUR RIGHTS
Depending on the applicable data protection laws (e.g., the European Union’s General Data Protection Regulation (GDPR) or state privacy laws in the United States), you may have the right to:
● Access your personal data and request a copy.
● Request rectification of inaccurate or incomplete information.
● Request erasure of your data when it is no longer necessary for the purposes described.
● Restrict or limit processing of your data under certain circumstances.
● Object to the processing of your data for reasons related to your particular situation.
● Request data portability to another service provider or entity, where technically feasible.
● Withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us using the information provided in the section below.
14. CONTACT INFORMATION
If you have questions, concerns, or wish to exercise your data protection rights, you can reach us at:
GA Trading LLC
Address: 1021 E Lincolnway, Suite 7892, Cheyenne, Wyoming 82001, USA
Email: info@nebroo.com
Phone: +1 512-645-1495
15. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time. If we make any material changes, we will notify you via a notice in the Application or through other appropriate means.
We encourage you to review this Policy periodically to stay informed about how we protect your personal data.
By using the Nebroo Application, you acknowledge that you have read and understood the terms of this Privacy Policy and agree to the practices set forth herein.