Privacy Policy

Fresh ‘n Rebel B.V. (trading under the brand name 'Fresh 'n Rebel')  ("we," "our," or "us") is committed to protecting your privacy and ensuring your personal data is secure. This privacy policy outlines how we collect, use, and safeguard your information when using Fresh ‘n Rebel My Sound App. We comply with the General Data Protection Regulation (GDPR) and other relevant regulations.

Please read this Privacy Policy carefully before downloading or using this app.

1. Data Controller Information

· Data Controller: Fresh ‘n Rebel B.V.

· Address: Linatebaan 101, 3045 AH Rotterdam, The Netherlands.

· Website: www.freshnrebel.com 

· Contact: privacy@freshnrebel.com 

2. Data We Process

The app collects and processes the following data to enhance your user experience:

· Device and System Information: Through an integrated third-party exception reporting plugin, we collect:

o Phone model, phone brand

o Android OS version, API level, manufacturer’s OS version

o CPU architecture type, root status, disk space usage, SD card space usage, memory usage

o Network type, application’s current process name, and PID

This information is used solely to analyze and address technical issues. No personally identifiable information is transmitted to external servers.

· Bluetooth Device Information: To facilitate a seamless connection with your headphones, the app may access Bluetooth MAC addresses. This data is used only for local processing and is not shared or uploaded.

· Device's approximate location with Android devices: Our app may use approximate location data solely to detect nearby headphone devices for connection purposes. We do not collect or upload any personal location data.

3. Legal Basis for Processing

The processing of data is based on the following legal grounds:

· User Consent: we rely on your consent, which you provide when using the app.

· Legitimate Interests: Device and system information is processed to ensure app stability, compatibility, and technical support, which aligns with our legitimate interests to provide a reliable user experience.

4. Data Retention Period

All data is stored locally on your device and will not be transferred or uploaded to external servers. Data is retained on your device as long as you continue to use the app. You may delete this data by uninstalling the app.

5. Data Security

We are committed to ensuring the security of your data. Data remains local on your device, and we employ encryption and other technical safeguards to protect your data from unauthorized access.

6. Data Subject Rights

Under GDPR, you have the following rights:

· The right to access, correct, or delete your personal data

· The right to restrict or object to our processing of your data

· The right to data portability

· The right to withdraw consent at any time

· The right to lodge a complaint with a supervisory authority

7. Third party software used by Audiodo software

Aspen library

· cpp_httplib, https://github.com/yhirose/cpp-httplib/blob/master/LICENSE, used only if upload of hearing profiles is done, which is off for this customer.

· howardhinnant_date, https://github.com/HowardHinnant/date/blob/master/LICENSE.txt/, used for working with dates.

· nlohmann_json, https://json.nlohmann.me/home/license/, used for working with json file formats.

· openssl_openssl, https://github.com/openssl/openssl/blob/master/LICENSE.txt, used for encryption/decryption of files and http traffic if that is used.

Reference app - Android

· Gson, https://github.com/google/gson/blob/main/LICENSE, used to work with json.

· AboutLibraries, https://github.com/mikepenz/AboutLibraries/blob/develop/LICENSE, used to find dependencies and list all licenses in the app, probably not used in the same way by customers.

Reference app - iOS

· CoreBluetoothMock, https://github.com/NordicSemiconductor/IOS-CoreBluetooth-Mock/blob/main/LICENSE, used to be able to mock headphone device behaviour, not used by customers.

8. Updates to the Privacy Policy

We may update this privacy policy to reflect changes in legal requirements or our services. Any updates will be communicated to you through the app.

9. Questions or Concerns

If you have any questions or concerns about the use of your data or about this privacy statement, please contact Fresh ‘n Rebel B.V..