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Privacy Policy for EarDirect

Last updated: August 10, 2026

This Privacy Policy describes how 8409668 CANADA INC (doing business as / developed by Guang Zheng; hereinafter referred to as "Company", "we", "us", or "our") collects, uses, processes, and protects your personal data when you use our mobile application, EarDirect (the "App").

Please study this document carefully to understand how your personal data is processed and to learn about your rights regarding data processing.

1. Data Controller & Identity Details

  • App Name: EarDirect

  • Developer Name: Guang Zheng

  • Legal Entity / Controller: 8409668 CANADA INC

  • Data Protection Requests & Inquiries: You may submit any inquiries or requests concerning our data processing via the contact section of our application or website, or by contacting our support channel directly. Replies will be provided without delay and at the latest within 30 days.

  • Data Protection Officer: Pursuant to Article 37(4) of the GDPR, the Controller is not obliged to designate a dedicated Data Protection Officer.

2. Principles & Compliance

We respect all applicable data protection laws, including Regulation (EU) 2016/679 (General Data Protection Regulation / GDPR) and local privacy legislation. We are committed to protecting the privacy of all users who provide personal data to us through EarDirect.

3. Purposes and Legal Grounds of Data Processing

We process personal data for the following specific purposes and legal bases:

  • App Functionality & Order Performance: Processing account, order, or configuration details necessary to provide EarDirect services (GDPR Art. 6(1)(b)).

  • Legal Compliance & Invoicing: Maintaining records and issuing invoices in compliance with accounting obligations (GDPR Art. 6(1)(c)).

  • Customer Support & Partner Contacts: Maintaining communication, responding to inquiries, and ensuring business continuity (GDPR Art. 6(1)(f)).

  • Marketing & Analytics: Optional promotional communications and basic usage statistics, conducted only with your explicit consent (GDPR Art. 6(1)(a)). Consent can be withdrawn at any time.

4. Data Retention

  • Financial & Order Records: Retained for a minimum of 8 years to meet legal accounting obligations.

  • Support & Contact Inquiries: Retained for up to 1 year following the resolution of the request or termination of the customer relationship.

  • Usage & Analytics Data: Retained until consent is withdrawn or up to 26 months maximum.

5. User Rights (GDPR & Data Protection Laws)

As a user of EarDirect, you have the following rights regarding your personal data:

  • Right of Access: Request confirmation of whether your data is being processed and obtain a copy.

  • Right to Rectification: Request prompt updates or corrections to inaccurate data.

  • Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data when it is no longer required or if you withdraw consent.

  • Right to Restriction of Processing: Request temporary restriction of data processing under specified legal conditions.

  • Right to Data Portability: Receive your personal data in a structured, machine-readable format or request transfer to another controller.

  • Right to Object: Object to data processing based on legitimate interest or direct marketing.

  • Right to Lodge a Complaint: Lodge a complaint with your local Data Protection Authority regarding our data processing activities.

6. Third-Party Service Providers

To operate EarDirect effectively, we may engage trusted third-party service providers as data processors. All processors are required to comply with GDPR and applicable security standards.

  • Google Analytics / Cloud Services: Usage statistics and application insights ().

  • Microsoft Azure Services: Hosting applications, secure database storage, and backend support ().

7. Data Security

8409668 CANADA INC implements appropriate technical, organizational, and operational security measures to safeguard your personal data against unauthorized access, loss, alteration, or destruction. Electronic communications and database storage are protected using encryption and access restrictions.

8. Changes to This Privacy Notice

Any material changes to this Privacy Policy will be communicated to users in advance through EarDirect or via email prior to taking effect. Non-substantive changes (e.g., typographical corrections) will take effect immediately upon publication.