Privacy Policy

Last Updated: November 18, 2025

1. Introduction

BearMinds ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the HearBook mobile and desktop application ("the App").

Please read this Privacy Policy carefully. By using HearBook, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use the App.

2. Information We Collect

2.1 Information You Provide

Local Device Storage

HearBook stores the following data locally on your device:

• Audiobook Files: Audio files you import into the App (MP3, M4A, M4B, FLAC, OGG, WAV, AAC)
• Metadata: Book titles, authors, duration, chapter information, cover art, and other metadata extracted from audio files
• User Preferences: Playback speed, theme settings, language preferences
• Playback Progress: Current playback position, completion status, bookmarks
• User Categories: Custom categories you create to organize your audiobooks
• Archive Status: Which books you've marked as archived

Important: All this data is stored exclusively on your device using SQLDelight database. We do not have access to your audiobook files, and this data is never transmitted to our servers or any third-party servers.

2.2 Automatically Collected Information

Analytics Data

We use Firebase Analytics to collect anonymous usage statistics to improve the App. This may include:

• Device Information: Device model, operating system version, unique device identifiers
• App Usage: Features used, screens viewed, session duration, crash reports
• Technical Data: App version, language settings, performance metrics

This data is collected anonymously and cannot be used to personally identify you.

No Personal Information Collected

HearBook does not require or collect:

• ❌ Name, email address, or phone number
• ❌ Account credentials (no login required)
• ❌ Location data (GPS or precise location)
• ❌ Contacts or address book information
• ❌ Camera or photo library access (except when you explicitly choose cover images)
• ❌ Microphone access

2.3 Subscription Information

If you purchase a premium subscription on Android or iOS:

• Payment processing is handled entirely by Google Play Store or Apple App Store
• RevenueCat (our payment processor) may collect transaction data including purchase date, subscription status, and anonymized user identifiers
• We do not collect or store your credit card information, billing address, or payment details

3. How We Use Your Information

3.1 Local Data (Stored on Your Device)

• Provide core audiobook player functionality
• Remember your playback position and bookmarks
• Organize your library with custom categories
• Save your preferences and settings
• Enable archive and restore features

3.2 Analytics Data

• Understand how users interact with the App
• Identify and fix bugs and crashes
• Improve App performance and user experience
• Develop new features based on usage patterns
• Generate anonymous, aggregated statistics

3.3 Subscription Data

• Process and manage premium subscriptions
• Verify subscription status and entitlements
• Prevent fraud and unauthorized access
• Provide customer support for billing issues

4. Data Sharing and Disclosure

4.1 Third-Party Service Providers

We share limited data with the following third-party services:

Firebase Analytics (Google LLC)

• Purpose: Anonymous usage analytics and crash reporting
• Data Shared: Device information, app usage patterns, technical metrics
• Privacy Policy: https://firebase.google.com/support/privacy
• Location: United States (see Section 10 regarding international transfers)

RevenueCat (RevenueCat, Inc.)

• Purpose: Subscription and payment processing (Android/iOS only)
• Data Shared: Anonymous user identifiers, subscription status, transaction data
• Privacy Policy: https://www.revenuecat.com/privacy
• Location: United States

Google Play Store / Apple App Store

• Purpose: App distribution and payment processing
• Data Shared: As required by the respective app stores
• Policies:
  • Google Play: https://policies.google.com/privacy
  • Apple: https://www.apple.com/legal/privacy/

4.2 No Sale of Data

We do not sell, trade, or rent your personal information to third parties for marketing purposes.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, government requests) to:

• Comply with legal obligations
• Protect and defend our rights or property
• Prevent or investigate possible wrongdoing
• Protect the personal safety of users or the public
• Protect against legal liability

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change and any choices you may have regarding your information.

5. Data Security

5.1 Local Data Protection

• All audiobook files and user data are stored locally on your device in an encrypted SQLDelight database
• Your device's operating system security protects this data
• We do not transmit your audiobook files or playback data to external servers

5.2 Security Measures

We implement appropriate technical and organizational measures to protect your information, including:

• Secure data transmission using HTTPS/TLS when communicating with Firebase and RevenueCat
• Regular security updates and patches
• Limited data collection (we only collect what is necessary)
• Anonymous analytics (no personally identifiable information)

5.3 No Absolute Security

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

6. Your Data Protection Rights (GDPR)

If you are a resident of the European Economic Area (EEA) or European Union (EU), you have certain data protection rights under the General Data Protection Regulation (GDPR):

6.1 Right of Access

You have the right to request copies of your personal data. Since most data is stored locally on your device, you already have direct access to it.

6.2 Right to Rectification

You have the right to request correction of inaccurate information. You can edit metadata and preferences directly within the App.

6.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your data:

• Local Data: Uninstall the App to delete all locally stored data
• Analytics Data: Contact us at support@bearminds.com to request deletion of analytics data (note: this data is anonymous and not linked to your identity)

6.4 Right to Restrict Processing

You have the right to request restriction of processing:

• Disable analytics by turning off analytics in your device settings or contacting us
• Stop using the App

6.5 Right to Data Portability

You have the right to request transfer of your data:

• Your audiobook files remain in their original locations on your device
• Database files can be exported manually from your device storage

6.6 Right to Object

You have the right to object to our processing of your data:

• Object to analytics by disabling Firebase Analytics (contact us for assistance)
• Stop using the App to cease all data collection

6.7 Right to Withdraw Consent

You can withdraw consent at any time by:

• Uninstalling the App
• Disabling analytics features
• Canceling your subscription (for subscription data)

6.8 Right to Lodge a Complaint

You have the right to file a complaint with your local data protection authority. In Poland, this is:

• Urząd Ochrony Danych Osobowych (UODO)
• Website: https://uodo.gov.pl/

To exercise any of these rights, contact us at support@bearminds.com.

7. Data Retention

7.1 Local Data

• Stored on your device indefinitely until you delete the App or manually delete content
• Deleted when you uninstall the App (depending on your device's operating system)

7.2 Analytics Data

• Firebase Analytics retains data according to Google's retention policies (typically 14-26 months)
• Aggregated, anonymized data may be retained indefinitely

7.3 Subscription Data

• RevenueCat retains subscription data as long as necessary to provide services and comply with legal obligations
• Transaction records may be retained for tax and accounting purposes as required by law

8. Children's Privacy

HearBook does not knowingly collect personal information from children under 13 years of age. The App is intended for general audiences.

• No account creation or personal information is required to use the App
• If you are under 13, please obtain parental consent before using the App
• If you are a parent and believe your child has provided us with personal information, contact us at support@bearminds.com

If we discover we have inadvertently collected information from children under 13, we will delete it immediately.

9. California Privacy Rights (CCPA)

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

9.1 Right to Know

You have the right to know what personal information we collect, use, and disclose (see Section 2 of this policy).

9.2 Right to Delete

You have the right to request deletion of your personal information (see Section 6.3).

9.3 Right to Opt-Out

We do not sell your personal information, so there is nothing to opt out of regarding data sales.

9.4 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at support@bearminds.com.

10. International Data Transfers

BearMinds is located in Poland (European Union). However, our third-party service providers (Firebase, RevenueCat) may process data in the United States and other countries.

10.1 Legal Basis for Transfers

Data transfers to countries outside the EEA are based on:

• Standard Contractual Clauses (SCCs): Google and RevenueCat use EU-approved SCCs for data transfers
• Adequacy Decisions: Where applicable, reliance on EU Commission adequacy decisions
• Your Consent: By using the App, you consent to these transfers

10.2 Safeguards

Our service providers implement appropriate safeguards including:

• Encryption in transit and at rest
• Access controls and authentication
• Regular security audits
• Compliance with EU-US and Swiss-US Privacy Shield frameworks (where applicable)

11. Cookies and Tracking Technologies

HearBook does not use cookies in the traditional web sense since it is a native mobile/desktop application. However:

11.1 Analytics SDKs

Firebase Analytics uses similar tracking technologies to collect usage data. These operate within the App and do not track you across websites or other apps.

11.2 Advertising

We do not use advertising SDKs or display ads in HearBook. There are no third-party advertising trackers.

11.3 Do Not Track

Since we don't track users across websites, Do Not Track browser signals are not applicable to this App.

12. Platform-Specific Privacy Information

12.1 Android

• Permissions Required:
  • WAKE_LOCK: Keeps device awake during background audio playback
  • Storage access: To read audiobook files you select
• Google Play Services: Firebase Analytics requires Google Play Services
• Android ID: May be collected by Firebase Analytics for analytics purposes

12.2 iOS

• Permissions Required:
  • Storage/Files access: To read audiobook files you select
  • Media Library access: Only if you explicitly choose to import from iTunes/Music
• Apple IDFA: We do not collect or use the Identifier for Advertisers (IDFA)
• App Tracking Transparency: We do not track you across apps or websites

12.3 Desktop (JVM)

• File System Access: Limited to directories you explicitly grant access to
• No Platform Accounts: Desktop version does not integrate with platform accounts
• No Subscriptions: Desktop versions do not support in-app purchases or subscriptions

13. Third-Party Links

The App does not contain links to third-party websites or services, except for:

• Links in the Settings screen (e.g., to this Privacy Policy, Terms and Conditions)
• Payment processing through app stores

We are not responsible for the privacy practices of third-party websites or services.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons.

14.1 Notification of Changes

When we make changes:

• The "Last Updated" date at the top will be revised
• For material changes affecting your rights, we will notify you through the App or via other reasonable means
• We may display an in-app notification highlighting key changes

14.2 Your Continued Use

Your continued use of HearBook after any changes to this Privacy Policy constitutes acceptance of those changes. We encourage you to review this policy periodically.

15. Contact Us

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

We will respond to your inquiry within 30 days (or sooner as required by applicable law).

16. Your Consent

By using HearBook, you consent to:

• This Privacy Policy
• Collection and use of information as described herein
• Transfer of data to third-party service providers (Firebase, RevenueCat, app stores)
• International data transfers as described in Section 10

If you do not agree with this Privacy Policy, please do not use the App.

---

Last Updated: November 18, 2025