Privacy Policy

This notice describes how we collect and use personal information about you, in accordance with the UK General Data Protection Regulation (UK GDPR) 2018 and any other applicable national implementing laws, regulations and secondary legislation as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

This privacy notice sets out the rights and freedoms of “data subjects”, (referred to as “you” or “customer”) and Tinnisoothe Limited (referred to as “we”, “us” or “our”).

This privacy notice was published 12th September 2023. It is effective upon acceptance for new customers immediately and for existing clients from 12th September 2023.

About Us

Tinnisoothe Ltd is a British manufacturer of high-quality sound therapy devices, most commonly used for tinnitus management. Our company was formally established on 30th April 2021. We are registered in England and Wales as a Limited Company. Our registered office is 15 Bowling Green Lane, London, United Kingdom, EC1R 0BD.

This privacy notice is applied to: Tinnisoothe Ltd. Company Registration Number 13369186

What is personal information?

Personal information is information relating to an identifiable natural living person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as name, identification numbers, location, or to one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identify of that natural person.

Personal information we collect

To provide you with your agreed engaged services, we will collect personal information that you provide us. Personal information may include, but is not limited to:

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity.

• Bank account details and payment information.

• Details of any services we provide you along with correspondence and communication with you.

• Information received from other sources such as publicly available information.

• Information from research, surveys and marketing activities.

How we use your personal information

We use the personal information that we collect from you to provide services and ensure you receive relevant targeted communications (advertising and marketing). We also use the information you provide to detect, prevent and mitigate fraudulent or illegal activities.

We process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.

We process your personal data for the purposes of our own legitimate interests, providing that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

If you refuse to provide us with certain information when requested, we may be unable to perform the contract we have entered into with you.

The basis upon which we process your personal information

When you engage us to provide you with a service, you enter into a contract with us for the supply of such goods and services. We use the data gathered in order to perform the contract we are required to process your personal data that we collect, we will:

• Record and store your personal data in paper files and computer systems (including emails, computer hard drives and cloud hosted providers). This information can only be accessed by employees, advisers and consultants of Tinnisoothe Ltd; and only when it is necessary to provide a service to you and to perform administrative tasks associated with or incidental to that service.

• Submit your personal data to government agencies, companies house or HMRC where required to do so, to fulfil either your legal and regulatory obligations or ours.

• Share your personal data with agencies, auditors or supervisory authorities where required to do so, to fulfil either your legal and regulatory obligations or ours.

Your choices about how we use your personal information

You have a right to choose how we use your personal information to communicate with you, to send you marketing information and how we use that information to provide customised and relevant marketing material.

We respect your rights to access, correct, request deletion or request restrictions of our usage of your personal information as required by applicable law. We take steps to ensure that the personal information you provide us is kept up to date. You have a right to:

• Know what personal information we maintain about you and upon request we will provide a copy of this personal information in a commonly used and machine-readable format. This is known as a Data Subject Access request and should you wish the exercise this right you should contact us as outlined at the end of this notice.

• Request that we correct, delete or complete any personal information that we maintain (details as to the extent of which we can do this will be provided at the time of such request).

• Ask us to further explain how we use your personal data.

• Object to processing of your personal information.

• Request that we delete or restrict how we use your personal information; this right may impact the services we provide you.

• Change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent to market to you in its entirety).

• Request the transfer of your personal data to you or another provider or third party (if technically feasible).

How we might share your personal information

During the course of work undertaken by us, we may disclose personal information to third parties where required to do so under the obligations of applicable law. This includes providing information to governing bodies or HMRC to fulfil your legal obligations. We attempt to minimise the information we disclose to what is directly relevant and necessary to accomplish the specified purpose.

Under no circumstances do we sell, rent or otherwise disclose your personal information to third parties for their marketing and or advertising purposes without your explicit consent.

We may use third-party providers for the following activities; IT and Cloud services, professional advisory services, administration services, marketing and banking services. All our third-party service providers are required to take commercially responsible and appropriate security measures to protect your data. Our providers are only permitted to process your personal information in accordance with our instructions.

How long we keep your personal information

We retain your personal information for as long as necessary to provide the services for which you engage us, or for other essential purposes as complying with our legal obligations, resolving disputes or enforcing our rights. In most cases we retain the data for a minimum of six years, but certain instances may require us to retain records indefinitely.

When assessing what retention period is appropriate for your personal information, we take into consideration:

• the requirements of our business and services provided;

• any statutory or legal obligations;

• the purposes for which we originally collected the personal information;

• the lawful grounds on which we based our processing;

• the types of personal information we have collected;

• the amount and categories of your personal information; and

• whether the purpose of the processing could reasonably be fulfilled by other means.

How do we protect your personal information?

We protect your personal information using technical and organisational security measures; in an effort to reduce the risk of loss, misuse, unauthorised access, disclosure or alteration. Some of the safeguards include the use of firewalls and data encryption, physical access controls and authentication controls. We also offer services for transferring data between both parties using secure methods and advise against sending us confidential information using unprotected means.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where legally required to do so.

Exercising your rights

If you have any queries or concerns regarding our use of your personal information or you would like to exercise any of your rights as outlined in this notice, you should contact us by emailing hello@tinnisoothe.com

Privacy Notice Updates

Further updates to this Privacy Notice will be published at www.tinnisoothe.com/privacy

*Please Note* phone calls may be recorded for training purposes.