Privacy Policy

Welcome to The Sound Approach. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (iOS and Android) and web application. The Sound Approach is an audio player for bird sound examples in The Sound Approach book series.

The data controller is M Constantine t/as The Sound Approach, a sole trader based in the United Kingdom. We serve users worldwide.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the application.

We use the information we collect to:

• Create and manage your user account
• Authenticate your identity via one-time passwords
• Enable synchronization of your favorites across devices (when signed in)
• Provide customer support and respond to your inquiries
• Investigate optional error reports you submit
• Understand how the apps are used and improve features and content (usage analytics)
• Monitor service health and active usage (including aggregated analytics)
• Manage inactive accounts and send related service emails
• Comply with legal obligations

Where the UK GDPR or EU GDPR applies, we process personal data on the following legal bases:

• Contract (Art. 6(1)(b)): Creating and managing your account, sending OTPs, syncing favorites, providing signed-in features, and delivering the service you request
• Legitimate interests (Art. 6(1)(f)): First-party usage analytics; service health and security monitoring; inactive-account cleanup and related warning emails; investigating optional error reports. Our interests are operating, securing, and improving The Sound Approach in a way that is proportionate and respects your rights
• Legal obligation (Art. 6(1)(c)): Where we must retain or disclose information to comply with applicable law

Where we rely on legitimate interests, you may object as described in Your Data Protection Rights below. We will consider your objection and stop or adjust the processing unless we have compelling legitimate grounds or the processing is needed for legal claims.

We use service providers (data processors or similar) to help us run the apps. They process personal data only as needed to provide their services to us:

We also use infrastructure providers that may process limited technical data in the ordinary course of operating the service, for example:

• Hosting and content delivery: Web hosting and CDN providers that serve the web app and media files (which may process IP addresses and request logs)
• App platforms: Apple and Google, in connection with distributing the mobile apps through their stores (subject to their terms and privacy policies)

We do not sell your personal information, and we do not share it with third parties for their own advertising.

We do not sell, trade, or rent your personal information. We share personal information only:

• With service providers: As described above, to operate authentication, database, email, hosting, and distribution
• Legal requirements: When required by law, court order, or legal process
• Protection of rights: To protect our rights, property, or safety, or that of our users or the public

We are based in the United Kingdom and serve users worldwide. Your information may be transferred to, stored, or processed in countries other than your own, including where our service providers operate.

Where personal data is transferred outside the United Kingdom or the European Economic Area, we rely on applicable legal transfer mechanisms, such as an adequacy decision or appropriate contractual safeguards (for example standard contractual clauses), as relevant to the transfer.

Regardless of where you are located, we take reasonable steps appropriate to the sensitivity of the data to protect personal information during international transfers.

We do not knowingly collect personal information from children under 13. If you are under 13, please do not use this app or provide any information. If we learn we have collected information from a child under 13, we will delete that information promptly.

Where applicable law requires a higher minimum age for information-society services or requires parental consent, those requirements apply. Parents or guardians who believe we may have collected information from a child should contact us immediately at sales@soundapproach.co.uk.

We implement reasonable technical and organizational measures to protect your personal information. However, please note that:

• No method of transmission over the internet is 100% secure
• We cannot guarantee absolute security of your information
• You are responsible for maintaining the confidentiality of access to the email address associated with your account

If the UK GDPR or EU GDPR applies to you, you have the following rights, subject to the conditions and exceptions set out in applicable data protection law:

• Right to Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Request transfer of data you provided to us, where the right applies
• Right to Object: Object to processing based on legitimate interests (including usage analytics)
• Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time (withdrawal does not affect prior lawful processing)

We process usage analytics for signed-in users based on legitimate interests as described above. You may object by contacting us at sales@soundapproach.co.uk. We will assess your objection. If we cannot continue the signed-in service without that processing, we will explain your options, which may include limiting certain features or deleting your account.

To exercise your right to erasure (delete your data), use our Delete Account page or the in-app deletion flow. To exercise your other rights, contact us at sales@soundapproach.co.uk.

If you are located outside the United Kingdom, EEA, or California, you may still contact us to request access to, correction of, or deletion of your personal data. We will respond in accordance with applicable law.

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including:

• Right to know what personal information we collect
• Right to delete your personal information
• Right to opt-out of the sale of personal information (note: we do not sell personal information)
• Right to non-discrimination for exercising your rights

Residents of other US states may have similar rights under applicable state privacy laws. To make a request, contact us at sales@soundapproach.co.uk or use the account deletion tools described above for erasure requests.

We may update this Privacy Policy from time to time. We will notify you of any changes by:

• Updating the "Last Updated" date at the top of this policy
• Providing notice through the app for material changes

Where a change requires a new consent or other action under applicable law, we will ask for that separately. Otherwise, continued use after notice of non-material updates means you acknowledge the updated policy.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact the data controller:

Controller: M Constantine t/as The Sound Approach Country: United Kingdom Email (privacy and legal): sales@soundapproach.co.uk Postal address: Available on request by email for data protection correspondence (we can provide a service address suitable for formal notices).

Please contact us first so we can try to resolve your concern. If you are in the United Kingdom and believe we have not adequately addressed your concerns, you may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

If you are in the EEA, you also have the right to lodge a complaint with your local data protection supervisory authority.