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Nura Privacy Policy

Nura Privacy Policy

Last updated: 25 May 2018

As part of the Nura community, you and your privacy are of high importance to us. Making the world's first headphones that automatically know how you hear is no easy feat. To achieve our vision of providing perfect sound for every person in any place, Nura products collect and analyse your hearing data to create your personalised hearing profile.

We also know that an amazing experience isn’t just about having a revolutionary product - it’s also about getting help when you need and making sure the process of ordering, receiving and using your Nuraphones is as easy as possible.

We want to make sure that you always know what information we collect and how we collect, use and share it. We have created this Privacy Policy to be transparent about our information practices and to keep you informed.

This Privacy Policy explains how information about you is collected, used and disclosed by Nura Operations PTY, LTD. This Privacy Policy applies to information obtained from or in relation to Nura products (“Products”), our mobile applications (“Apps”), and our websites (www.nuraphone.com and sub-websites) (collectively, the “Sites”, and collectively with the Apps, the “Services”).

Because we’re always looking for new and innovative ways to help you achieve your perfect sound, this Privacy Policy may change over time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Products or Services to stay informed about our information practices and the ways you can help protect your privacy.

Remember, we’re here to help! If you have any questions about this Privacy Policy, just reach out to [email protected]


What data does Nura collect?

When you buy a product

When you purchase a Product, we collect transaction information, such as information about the Products you purchase, shipping and delivery information and information related to returns, refunds and cancellations.

When you create a Nura account

When you access the Nura App to calibrate your Product to your hearing, you will need to create a Nura account. When you create your Nura account, you’ll be prompted to enter personal information, including your name, email address, country, password, age, gender and any other information you provide. We use age and gender information to analyse hearing measurement trends, and as described in this Privacy Policy.

You may also have the option to create your Nura account using your credentials from certain social media accounts, such as your Facebook or Google+ accounts. If you choose to do so, we may have access to basic information about you from that account, like your name, profile picture, and friend list, in accordance with your privacy settings on that service.

When you calibrate a Nura product

Calibration of Nura Products involves collecting signals from your ear, including frequency responses and a measurement called Otoacoustic Emissions (OAE). Nura analyses your hearing data -- the OAE and frequency responses-- to create calibration data that provides you with a personalised sound experience. The calibration data is stored locally on the Product so you can experience personalised sound day-to-day, without using the App. This hearing data is also sent to Nura and used to optimize and develop Nura products and services.

When you sync your Nura product

Whenever your Product is connected to your device, and your device has a network connection, usage data is transferred from your Nura Products to our servers. Usage data is information about how you use the Product, such as the duration of a listening session and the volume of the sound during that session.

When you use our services

Whenever anyone visits the nura Sites or Apps, we will collect standard log data, such as: the page that they were referred from, the actions they performed, their browser type, App version, their operating system and the pages viewed. We also collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

When you refer your friends

Great music should be shared with great friends! This is why Nura lets you invite friends to receive a discount off their very own Nura Products, while rewarding you too. When you invite your friends, you’ll be asked to provide details such as their name and email address. By providing such information, you represent that you have their permission to share their information with Nura.

When you interact with Nura and the Nura community

In your pursuit for perfect sound, we encourage you to be active in the Nura community. When communicating with the Nura community in public areas or social media sites such as Facebook and Twitter, any information you provide may become public information. At times Nura will also collect and store this information to help improve your experience, learn more about your tastes as a Nura community member, and for marketing purposes.

We encourage you to take care when providing information in public forums, especially information that may pertain to your identity or health. Please also note that the content created by members of the Nura community may include the advice and opinions of the general public - as these are not posted by Nura, they do not represent the advice or opinions of Nura and Nura does not necessarily support or validate this content.

Nura uses cookies and other similar technologies.

Cookies are small data files stored on your hard drive or in device memory that help us improve our Products and Services, improve your experience, see which areas and features of our Services are popular, and to count visits. We use this data to learn more about your experience using the Services, so that we can constantly improve and personalise your Nura experience. Such technologies are also used to help you move seamlessly between the Nura App and Site without logging in. This may also be helpful when you are ordering more Nura Products or contacting the Nura team, as your information may be pre-filled. For more information about cookies, and how to disable them, please see "Your Choices" below.

When you contact the Nura team

There’s nothing more annoying than having to repeat yourself, so when you contact us, we collect personal information such as your name, email address, and any other information you provide. We keep a record of this information, along with the nature of your requests over time. This helps us learn more about your experience using Nura Products, your preferences, and how we are best placed to help you. Storing and analysing this data, also helps us identify how to optimise and improve the Nura experience for everyone. We may also monitor, record and retain your communications with us for security, dispute resolution and training purposes.

When you assist Nura’s research

From time to time, the Nura team will reach out to you for your advice and opinions on our Products and Services, for Nura’s research purposes to improve our current Products and Services and develop new ones. Such surveys will only be sent by Nura and authorised research affiliates - they will be clearly marked as for use by Nura only, unless stated otherwise. Surveys may collect both anonymous and identifiable information.

When you activate location features

Subject to your consent, we may collect information about the location of your device each time you access or use our App, or when you otherwise consent to the collection of this information. For more details, please see "Your Choices" below.

How does Nura use and disclose data?

We may use and disclose personal information for various purposes related to the running of the Nura business, including to:

  • Provide, maintain and improve our Products and Services;

  • Develop new Products and Services;

  • Personalize the Products and Services, such as by providing content or features likely to interest you;

  • Provide and deliver the Products and Services you request, by processing transactions and sending you related information, including confirmations and invoices;

  • Send you technical notices, updates, security alerts and support and administrative messages;

  • Respond to your comments, questions and requests and provide customer service;

  • Communicate with you on an ongoing basis about Products, Services, offers, promotions, rewards, and events offered by Nura and others, and provide news and information we think will be of interest to you;

  • Monitor and analyze trends, usage and activities in connection with our Products and Services;

  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Nura and others;

  • To serve you with advertisements we think are likely to interest you, off of our website

  • Facilitate contests, sweepstakes and promotions; and deliver entries and rewards;

  • Link or combine with information we get from others to help understand your interests; and

  • Carry out any other purpose described to you at the time the information was collected.

Special deals and promotions

With your consent, we’ll keep you in the loop about special Nura deals and promotions. These might include opportunities to refer a friend, access discounts, attend events and win prizes. To do this, we will need to use your information to contact you and offer you the most relevant promotions. We may also provide you with information we think may be of interest to you, including promotional messages.

If you no longer wish to receive promotional emails from Nura, please see "Your Choices" below.

When does Nura share collected information?

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants, professional advisors and other service providers including IT providers, delivery companies, advertising and marketing organisations and others who need access to such information to carry out work on our behalf;

  • Payment system operators and financial institutions providing services to us;

  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;

  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Nura or others;

  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

  • Between and among Nura and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and

  • With your consent or at your direction.

Advertising and analytics services provided by others

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Nura and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioural advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Security

Nura takes reasonable measures designed to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Data retention

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

Social sharing features

The Services may offer social sharing features and other integrated tools (such as the Facebook "Like" button), which let you share actions you take on our Services with other media platforms, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please review your privacy settings and the privacy policies of the entities that provide these features.

Data transfer

We and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. We will request your consent to this transfer where required by law.

EEA residents

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

Legal basis for processing

If you are a resident of the EEA, when we process your personal data we will only do so in the following situations :

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the Product you have requested.)

  • We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Products and Services, and to provide, secure, and improve our Products and Services.

  • When you consent.

  • When we are required by law.

Data subject requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at [email protected].

Questions or complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Other considerations

There are many facets to managing your privacy and maintaining data security. The following should be taken into consideration, when seeking to understand aspects of your privacy when using Nura Products and Services.

Your choices

You may update, correct or delete information about you at any time by sending an email request to [email protected], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Mobile device settings

When you first launch any of our Apps that collect location information, you will be asked to consent to sharing your location. Similarly, if the App would like to access your camera, you will be asked to consent to allowing that functionality. If you initially consent to sharing location information and/or camera function, you can subsequently withdraw these consents at any time by changing the preferences on your mobile device. If you do so, our App, or some of its features, may no longer function.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional communications

You may opt out of receiving promotional emails from Nura by following the instructions in those emails or by contacting us at [email protected]. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile push notifications/alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Third party websites

At times, the Nura website and app may contain links to third party websites. As these websites are not part of Nura Services, they are not governed by this Privacy Policy.

Contacting Nura

We want to help you stay informed about your privacy when you use Nura products and services. If you have any questions about this Privacy Policy, please contact us via [email protected] or write to us at:
NURA OPERATIONS PTY. LTD., PO Box 95, Brunswick, 3056, VICTORIA, AUSTRALIA

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