Sembo Hearing Aid App — Privacy Policy

Shenzhen Shenbo Intelligent Manufacturing Co., Ltd. (“we,” “us,” or the “Operator”) understands the importance of personal information and will protect your personal information in accordance with applicable laws by taking appropriate security measures.

This Privacy Policy (the “Policy”) explains how we collect, use, store, share, transfer, disclose, and protect your personal information when you download, install, or use “Sembo Hearing Aid App” (Chinese name: 声博助听器; English name: Sembo; package name: com.semboems.hearingaid; the “App”) through Google Play and other channels.

Please read and understand this Policy before using the App. By tapping “Agree” or using the App, you acknowledge that you have read and agreed to this Policy. If you do not agree, stop using the App and uninstall it.

This Policy and the Terms of Service together govern your use of the App. If they conflict on personal information protection, this Policy prevails.

1. How We Collect and Use Your Personal Information

We follow the principles of lawfulness, legitimacy, necessity, and good faith, and collect and use your information only as needed for App functions.

(1) No registration required

The current version focuses on local features. You can use core functions such as Bluetooth connection and fitting adjustment without registering an account. We do not require your name, mobile number, ID number, or similar identity information solely because you use the App.

(2) Information necessary for core functions

A. Bluetooth device information

To search for, connect to, and manage compatible hearing aid devices, we process:

This information is mainly obtained via BLE interaction with your device and is stored locally on your mobile device by default. It is not uploaded to our own business servers (the business API host is not configured/enabled in the current version).

B. Fitting and hearing-related data (sensitive personal information)

When you use audiogram input, channel compensation, fitting adjustment, etc., data you enter or generate may include:

• Hearing thresholds by frequency (dB HL);
• Left/right ear selection and fitting scheme parameters;
• WDRC/compensation parameters written to the device.

Purpose: fitting assistance and sending parameters to Compatible Devices. Processing: mainly on your phone locally and via Bluetooth to the device; we do not use this data for unrelated marketing.

Notice: Hearing-related data is sensitive and may reflect your health. Enter it carefully and safeguard your device. We process it only as necessary for the above functions.

C. Environment assessment (microphone)

When you actively use “Environment Assessment,” the App requests microphone (record audio) permission, captures ambient sound, and calculates noise level in decibels to assess whether the environment is suitable for fitting.

• Audio is processed locally in real time for dB calculation and is not used to identify you;
• Per current implementation, results are logged locally and not uploaded to our servers;
• If you deny microphone permission, this feature is unavailable; other features are unaffected.

Note: Some permissions are merged/trimmed in AndroidManifest; environment assessment still requests microphone at runtime when needed. If your OS or dependencies merge additional permissions, follow the prompts on your device.

D. App settings

(3) Device permissions and features

You can manage permissions in system Settings. Disabling them may limit related features.

(4) Automatically collected technical information

The current version does not integrate a standalone crash analytics SDK and does not actively upload device model, OS version, network type, IP address, or device identifiers to third parties for App business purposes.

2. Cookies and Similar Technologies

The App is a native Android application and does not use browser cookies. We may use local storage (SharedPreferences, etc.) for device lists, language settings, and configuration so you do not need to reset them each time.

3. Sharing, Transfer, and Public Disclosure

(1) Sharing

We do not sell your personal information. We may share necessary information only when:

1. You give explicit consent;

2. Required by law, litigation, arbitration, or government authorities;

3. Necessary for third-party SDKs (Section 4);

4. Reasonably necessary to protect our, your, or other users’ lawful rights.

(2) Transfer

We do not transfer your personal information to any company, organization, or individual except:

1. With your explicit consent;

2. In mergers, acquisitions, or asset transfers—we will require the recipient to remain bound by this Policy or obtain your consent again.

(3) Public disclosure

We do not publicly disclose your personal information unless:

1. You give explicit consent; or

2. Required by law or mandatory administrative/judicial requirements.

4. Third-Party SDK List

The App may integrate or configure the following third-party components. They may collect information independently under their own privacy policies. We recommend reviewing the linked policies.

(1) Other configured but not actively used components

• Amap API Key: configured in AndroidManifest; no active Amap location/map calls in current code. If enabled in a future version, we will update this Policy and obtain consent as required.
• Umeng analytics: configuration placeholders exist; Umeng SDK is not integrated in current dependencies—no collection.

(2) App distribution and system services

When downloading/updating via Google Play, Google may process information per its privacy policy: https://policies.google.com/privacy

5. Storage of Information

(1) Location

1. Local data: device list, EQ parameters, language, howling suppression, etc., on your mobile device.

2. The current version does not integrate third-party SDKs that upload personal data to third-party servers for translation or voice services.

(2) Retention

1. Local data: until you uninstall, clear app data, or delete device records.

2. As required by law otherwise.

(3) Android backup

allowBackup="true" in AndroidManifest—some app data may be backed up to your Google account or device backup per system settings. Manage backup in system Settings.

6. How We Protect Your Personal Information

We use industry-standard measures including:

1. HTTPS/encrypted communication where third-party SDKs require it;

2. Processing fitting parameters mainly locally and over Bluetooth to reduce unnecessary uploads;

3. Limiting employee access to personal information;

4. Security incident response procedures.

No method of transmission or storage is 100% secure. Please safeguard your device against unauthorized use.

7. Your Rights

Under applicable law, you may have the right to:

1. Access and copy: view saved Bluetooth devices in “My Devices” and similar screens;

2. Correct/supplement: readjust parameters or audiogram input;

3. Delete: delete saved devices in the App, or clear app data/uninstall to remove all local data;

4. Withdraw consent: disable permissions in Settings (related features will stop);

5. Account deletion: not applicable—no account system in current version;

6. Complaints: contact us below.

We will respond within a reasonable period after verifying your identity, except where law requires otherwise.

If you are in the EU, UK, California, or similar jurisdictions, you may also have rights to data portability, objection, restriction, etc.—contact us to exercise them.

8. Protection of Minors

The App is mainly for adults using hearing devices. If you are under 18, read this Policy with a guardian and use the App only with guardian consent.

If a guardian believes a minor provided personal information without consent, contact us and we will delete it promptly.

9. Special Notice on Sensitive Personal Information

Sensitive information we process includes:

1. Hearing thresholds, fitting parameters, and related health information;

2. Microphone audio during environment assessment (for dB calculation, not long-term storage).

We will notify you in context and obtain separate consent when you use related features (e.g., permission dialogs).

10. Updates to This Policy

We may revise this Policy and notify you via in-app notice, app store listing, or other reasonable means. Material changes will receive more prominent notice.

Continued use after an update means you accept the revised Policy. If you disagree, stop using the App and uninstall.

11. Scope and Governing Law

This Policy is governed by the laws of mainland China (excluding conflict-of-law rules). If you access the App from outside China, your information may be transferred to overseas third-party servers; we will inform you and obtain consent as required by law.

12. Contact Us

For questions, comments, suggestions, or complaints about this Policy or our processing of personal information:

Operator: Shenzhen Shenbo Intelligent Manufacturing Co., Ltd.

Registered Address: 301, Building F2, North Industrial Park, Yanchuan Community, Yanluo Street, Baoan District, Shenzhen, Guangdong, China

Contact Email: sales@semboems.com

We will reply within 15 business days of receiving your request, unless law requires otherwise.

— End of Policy —

Appendix: Third-Party Privacy Policy Links

• Google Play: https://policies.google.com/privacy