About our privacy policy
This Privacy Statement of Tinzo BV ("we", "us" or "our") describes how and why we process your personal data when you use our Services. By this we mean downloading and using our mobile application Tinzo, or any other contact you have with us in connection with marketing activities or events.
Tinzo BV cares deeply about your privacy. We therefore only process data that we need for (improving) our services, and we handle the information we have collected about you and your use of our services with care. We never make your data available to third parties for commercial purposes. Our employees have signed an agreement to handle your data with care and will not distribute or disclose it other than for this purpose.
This privacy policy applies to the use of the Tinzo application and the services of Tinzo BV made available through it. This Privacy Policy describes which data about you we collect, what this data is used for, and for what purposes and under which conditions this data may be shared with third parties. We also explain how we store your data, how we protect your data against misuse, and which rights you have with regard to the personal data you provide to us.
If you have questions about our privacy policy, you can contact our contact person for privacy matters; you will find the contact details at the end of this document.
About the data processing
Below you can read how we process your data, where we store it (or have it stored), which security techniques we use and why this information is accessible to certain parties.
Which personal data do we process?
Personal data that depends on the way you use our Services and the choices you make in the application. We may process privacy-sensitive data such as:
- Name, address and payment details
- Health data.
We only process this data with your explicit consent. We collect personal data that you voluntarily provide to us when registering for the Services, expressing interest in our products or services, participating in activities through the Services, or otherwise contacting us.
Personal data provided by you may include:
- Names, email addresses, usernames and passwords
- Health data: collected only with your explicit consent
- Payment details: processed and stored by Apple App Store, Google Play and RevenueCat. We do not store your full payment details ourselves. Please consult the respective privacy statements of these parties: Apple, Google and RevenueCat.
- Social media account login details (if you register via Sign in with Apple or Sign in with Google).
How do we process your personal data?
We process your personal data for various purposes, depending on the way you use our Services, including:
- Facilitating account registration and authentication
- Executing and managing orders and payments
- Identifying usage trends and improving our Services
- Measuring the effectiveness of our marketing campaigns
- Protecting a vital interest of the data subject or of third parties
- Moderating and safeguarding the quality of the Tinzo Community, including assessing reports of inappropriate content and enforcing the rules of conduct
- Facilitating the connection between users and specialists via Tinzo Pro, including processing intake data and scheduling sessions via Cal.com
We use your data exclusively for the purpose of our services: this means that the purpose of the processing is always directly related to the Tinzo application you download and use. We do not use your data for (targeted) marketing.
User-generated content (Tinzo Community)
If you use the Tinzo Community, we process the content you post or share through the Community. This data is visible to other users of the Services. This concerns:
- Posts, comments and replies you post within the Community
- Profile data you make public, including your username, profile photo, banner photo and activity statistics (number of posts, likes and comments)
- Group participation and interactions with other users
- Images you upload as part of posts or your profile.
We expressly point out that content and profile data you post are visible to other registered users of our Services. We advise you not to publicly share special categories of personal data, such as detailed medical information, through the Community.
How do we secure your personal data?
We have taken appropriate technical and organizational security measures to protect the personal data we process. Despite our efforts, no electronic transmission over the internet or information storage technology can be completely secure. We therefore recommend always using our Services in a secure environment.
We do not collect personal data through third parties
If you share data with us and we use this data to contact you at a later moment other than at your request, we will ask for your explicit consent.
Your data is not shared with third parties, other than to comply with accounting and other administrative obligations. These third parties are all bound to confidentiality by agreement, in line with the legal obligations (GDPR).
Retention periods
We keep your data for as long as you are our customer. This means that we keep your customer profile until you indicate that you no longer wish to use our services. If you indicate this to us, we will also treat it as a request to be forgotten.
- Under applicable administrative obligations we are required to keep invoices containing your (personal) data; we will therefore keep this data for as long as the applicable period runs. The retention periods for data depend on the laws and regulations that Tinzo BV must comply with.
- For medical devices (our Tinzo application complies with the CE mark for medical software) this is regulated in a European regulation, the Medical Device Regulation (MDR 2017/745), with a retention period of 10 years.
Your rights
Under Dutch and European law, you as a data subject have certain rights with regard to the personal data processed by or on behalf of us. Below we explain which rights these are and how you can invoke them. In principle, to prevent misuse, we only send transcripts and copies of your data to the email address already known to us. If you wish to receive data at a different email address or, for example, by post, we will ask you to identify yourself. We keep a record of handled requests; in the case of a request to be forgotten, we keep anonymized records. You will receive all transcripts and copies of data in the machine-readable data format we use within our systems. You have the right to access, rectification, erasure, restriction of use and data portability, as regulated in the GDPR.
Right of access
You have the right to access the personal data Tinzo BV holds about you and information about what the personal data is used for. If you wish to see this data, you can submit a request via info@tinzo.nl. Via this email address you can indicate which data you wish to see. When requesting access, you must identify yourself. You can do this by enclosing a copy of your passport or identity document, stating the category under which we have stored this data. Tinzo BV will respond to your request within 30 business days and make the data available to you for inspection.
Right to rectification
Does Tinzo BV hold data about you that is (no longer) correct or incomplete? You can report this to us via info@tinzo.nl. You will receive a response to your request within 30 days. If your request is granted, we will send a confirmation to the email address known to us that the data has been amended.
Right to restriction of processing
You can ask Tinzo BV to (temporarily) stop using your personal data. To do so, please contact us by emailing info@tinzo.nl. Please note that this may affect the services Tinzo BV performs for you. If Tinzo BV has used your personal data solely with your consent, you may withdraw this consent at any time. You can submit a request to that effect to our contact person for privacy matters. You will then receive a response to your request within 30 days. If your request is granted, we will send a confirmation to the email address known to us that the data will no longer be processed until you lift the restriction.
Right to data portability
You have the right to receive your personal data from Tinzo BV in a structured, commonly used and machine-readable format, for example an Excel or Word file. You can submit a request to that effect to our contact person for privacy matters. You will then receive a response to your request within 30 days.
If your request is granted, we will send transcripts or copies of all data about you that we have processed, or that has been processed on our behalf by other processors or third parties, to the email address known to us.
Right to erasure
You can ask Tinzo BV to erase the personal data we hold about you. Unfortunately, this is not always possible. As long as you purchase and use our Tinzo application, we need your data.
Right to object and other rights
Where applicable, you have the right to object. Upon your objection, we will immediately suspend the data processing pending the handling of your objection.
If your objection is well-founded, we will make transcripts and/or copies of the data we process (or have processed) available to you and then permanently cease the processing.
Which cookies does Tinzo BV place?
Tinzo BV currently does not place analytics or marketing cookies on the website. We do not use Google Analytics or similar tracking tools.
Changes to the privacy policy
We reserve the right to change our Privacy Policy at any time.
However, you will always find the most recent version on this page. If the new Privacy Policy affects the way we process data already collected about you, we will inform you by email.
Complaints
If you believe that we are processing your personal data unlawfully, you have the right to file a complaint with our data protection officer (fg@tinzo.nl).
If you are not satisfied with the handling of your complaint, you can turn to the competent supervisory authority. As a Dutch company, our supervisory authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP), website: www.autoriteitpersoonsgegevens.nl, tel: +31 70 888 85 00.
Our contact details: via www.tinzo.nl/contact or by contacting us at info@tinzo.nl.
Appendix 1: Types of data
Application data
If you use our mobile application, we may, depending on the permissions you have granted, also collect the following data:
- Location data
- Access to device features (camera, storage)
- Device data (device ID, model, operating system, IP address)
- Push notifications.
Automatically collected data
When you visit, use or navigate through our Services, we automatically collect certain data. This data does not reveal your specific identity, but may include device and usage information, such as:
- Log and usage data: IP address, browser type, activity timestamps and features used
- Device data: device type, operating system and configuration
- Location data: based on IP address or GPS, to the extent permitted by your device settings.
Google API
The use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
Account data
You can view or change your account data at any time by logging into your account.
If you request that your account be terminated, we will deactivate your account and remove your data from our active databases. Please note that certain data may be retained to the extent necessary for fraud prevention, compliance with legal obligations or the resolution of disputes.
Data of minors
We do not collect personal data from children under 13 and do not direct our marketing at them. Users between 13 and 17 years of age must have the consent of, and be supervised by, a parent or legal representative, who agrees to this Privacy Statement on their behalf. By using our Services, you declare that you are older than 13. If we nevertheless receive data from a child younger than 13 without the required consent, we will deactivate the account in question and delete the data as soon as possible. Please report this via info@tinzo.nl.
Data processed in the context of Tinzo Pro
If you use Tinzo Pro, we process additional data necessary to facilitate the connection between you and a specialist. This data is collected via a one-time intake form at the start of your use of Tinzo Pro and includes:
- Data about your tinnitus situation, background and treatment goals; this data qualifies as special categories of personal data (health data) and is processed only with your explicit consent.
- Session data, including booked time slots, the name of the chosen specialist and participation in video sessions.
- In addition, specialists' profile data (name, professional background, specializations and rate) is visible to you as part of the booking process. This data is managed by the specialists themselves and falls outside the direct processing responsibility of Tinzo B.V.
Appendix 2: Processors and service providers
We may share your data with the following categories of external service providers that support us in delivering the Services. Data processing agreements have been concluded with all processors, and they may only process your personal data on our instructions:
- Supabase (database, authentication and file storage): supabase.com/privacy
- Railway (backend infrastructure and API hosting): railway.app/legal/privacy
- RevenueCat (subscription and payment management): revenuecat.com/privacy
- Brevo (email marketing and transactional email): brevo.com/legal/privacypolicy
- Apple App Store (app distribution and payment processing): apple.com/legal/privacy
- Google Play (app distribution and payment processing): policies.google.com/privacy
- Cal.com (scheduling and video infrastructure for Tinzo Pro): cal.com/privacy
Tracking and do-not-track settings
Tinzo is primarily a mobile application. You can manage tracking and data collection settings via your device settings:
- iOS: go to Settings > Privacy & Security to manage app permissions, including location, notifications and tracking.
- Android: go to Settings > Privacy to manage app permissions and ad personalization.
We currently do not respond to browser Do-Not-Track (DNT) signals, because no uniform standard for handling such signals has been established. If such a standard is introduced in the future, we will update this Privacy Statement accordingly.
How do we handle social media login details?
You can register and log in via your existing Apple or Google account ("Sign in with Apple" or "Sign in with Google"). If you choose to do so, we receive certain profile data from Apple or Google, including your name and email address. If you hide your email address with Apple, we receive a private relay address. We use this information only for managing your account. Apple and Google determine themselves how they use your data; please consult their privacy statements:
- Apple: apple.com/legal/privacy
- Google: policies.google.com/privacy