Privacy Policy

Welcome to the Freequency app, which can help you cope with your tinnitus! In this privacy statement, we explain what we do with your personal information.

PURPOSE OF THE FREEQUENCY APP

The app helps you train yourself to experience less discomfort from your tinnitus.

While using the app, we ask for information related to your symptoms, such as tone or noise, how you feel and how you experience your symptoms on the different days you use the app. This information is only stored on your device (your mobile phone or tablet) and you use this information to train yourself to gain more control over your tinnitus. In addition, we ask you to complete the medically recognised TFI questionnaire four times every 100 days. This can also be done anonymously. We use the results of the TFI questionnaires to improve the app and facilitate medical research by our partners. Freequency only processes your personal data if you use the paid version of the app.

Who we are (legal information about the controller)

The Freequency app is owned by Freequency B.V.

Markt 8a, 5581 GK Waalre.

Chamber of Commerce number 90412540

VAT number NL865303084B01 You can also find our contact details on the contact page on the website www.freequency.app.

Why we are permitted to process data (legal basis)

By downloading the Freequency app, you enter into a user agreement with Freequency B.V. and the terms and conditions of use apply. Performance of the user agreement is the legal basis for the processing of your personal data.

In addition, Freequency has a legitimate interest in processing your data for the improvement of the app and for conducting medical research in order to certify the app in accordance with the prescribed legal procedures for medical devices.

Purpose of processing

You provide your personal data to Freequency yourself via the app for the purpose of being able to use the full app.

Personal data that Freequency processes about you:

Your name App Store payment ID Email address Your unique identifier that is created when you complete the TFI questionnaire. Responses to the TFI questionnaire* Data marked with an asterisk (*) is optional, meaning you can use the app anonymously and omit this information while still making full use of the app’s functionalities.

As much user data as possible is stored locally on your device, so that it is not available to the servers of Freequency BV or the App Store. This includes the noise, beep or tone you have set, your play preferences, your diary results and your Avatar. You will therefore encounter this data in the app, but this information is not subject to the processing of personal data by Freequency as intended in the GDPR. It is advisable to secure your device, for example with a password or face ID, to prevent unauthorised persons from viewing this data on your device.

TFI questionnaires

TFI stands for Tinnitus Functional Index. This questionnaire can help measure the impact of tinnitus on your life. The TFI questionnaire works as a self-report.

You can submit the TFI questionnaire either anonymously or by providing your name and email address. We store responses to the TFI questionnaires in a separate database to the one used by the Freequency app. If you enter your name and email address in the questionnaire, your responses from previous questionnaires can be linked. This is useful for seeing what changes you experience in the 100-day cycle used by the Freequency app.

Freequency allows external researchers to analyse the responses from the TFI questionnaires in order to comply with legal requirements for the certification of medical devices and to improve the app. Your name and email address will not be included in the database that the researchers have access to. We create a separate code (pseudonym) for each user, which ensures that the researchers can correctly link the answers to the TFI questionnaires for analysis, but cannot trace them back to your email address.

Special personal data that we process

According to European legislation, data about your health is considered special personal data. That is why, before submitting the TFI questionnaire (non-anonymous option), we ask for separate consent (Article 9(2)(a) GDPR) to process this special data. You may withdraw this consent at any time. By withdrawing this consent, your email address and name will be removed from the TFI database. After that, we will no longer be able to link the questionnaires you previously completed to new TFI questionnaires. If you use the anonymous version, no UUID will be created and we will not be able to link it to your previously completed questionnaire.

You are probably interested in Freequency because you have experience of tinnitus. For some of our users, this involves personal experience or complaints. Freequency does not know whether you are using the app as an interested party, a healthcare professional or a patient, so we make the app available to every user without specific consent under Article 9(2) GDPR.

Partially automated decision-making

The app and its content are configured based on the options you select.

Your app diary, the TFI questionnaire you complete, and the app content provide you with insights and tips. Tips can never replace medical advice. You decide for yourself whether or not to follow the tips provided by the app. Freequency does not make any decisions that affect you, so there is no automated decision-making.

Minimum age of 16

Users who indicate that they are under 16 years of age cannot use the Freequency app. The Freequency app is expressly not intended for use by young people under the age of 16. Freequency also has no intention of collecting data from young people. The age indication follows the general Account Settings in the App Store.

Retention periods

The Freequency app programme ends after completing the cycle of 100 days. After these 100 days, you can repeat the programme or occasionally follow up with additional content and challenges.

Freequency applies the following retention periods:

We store your name and App Store payment ID for as long as the app is active on the device. [current configuration option] We store the email address provided in the non-anonymous version of the TFI questionnaires for as long as the app is active for linking the questionnaires [end of current configuration option]. Responses to the TFI questionnaire are only stored anonymously after the 100-day cycle for scientific research, improving the Freequency app and sharing anonymous group reports with our partners. Sharing personal data with third parties

Suppliers

Freequency uses suppliers to support the app itself and to process the TFI questionnaire. Insofar as these suppliers have access to the personal data of Freequency users, processing agreements are concluded between Freequency BV and these processors.

Researchers

Freequency does not sell your data to third parties. However, responses to the TFI questionnaires are shared with researchers. No data that constitutes personal data for the receiving researcher is provided. Only pseudonymous or even anonymous data is used for scientific research.

App store

You can only use the Freequency app if you download it to a device such as a phone or tablet. Depending on your device, the terms and conditions and privacy policy of either the Apple App Store (iOS) or the Google Play Store (Android) always apply to the app.

Legal obligation

Freequency may provide data to third parties in order to comply with a legal obligation, such as keeping records and filing tax returns.

Transfer outside Europe [only applies to people residing in countries within the EU]

Freequency app does not share any data it receives from you outside Europe. Freequency exclusively uses European suppliers and researchers. Both Apple and Google App Stores share data with America in accordance with your device settings and the App Store terms and conditions. Freequency is not officially responsible for this form of data sharing from the App Store.

Viewing, modifying, correcting or deleting data

You have the right to view, correct or delete your personal data. You can do this yourself in the app at any time.

You also have the right to withdraw any consent you may have given for data processing or to object to the processing of your special personal data by Freequency. You can do this in the Freequency app by deleting your email address.

We cannot reproduce your answers to the TFI questionnaires for you because this data is protected for privacy reasons.

You can also delete all your data by removing the app from your device and from your App Store account. Please note that if you delete the app, your subscription will expire, even if you have already paid for it. You do not need to send a request to Freequency to delete your data; you can do this yourself at any time.

If you download the app, we can send you push notifications. You can unsubscribe from push notifications at any time by turning off notifications in the app.

Complaints procedure and supervision

If you are dissatisfied with the way Freequency handles your personal data, please let us know immediately by sending a message in the app or an email to [email protected].

Within Europe

You have the right to report complaints about our handling of your privacy-sensitive data to the Dutch Data Protection Authority.

During the pilot phase in the USA, users in that country can contact ***

Freequency applies terms of use. You can find these terms of use on our website at www.freequency.app/userterms, where you can also download them.

Disclaimer

Information about tinnitus is available on the Freequency app the public freequency.app website. Tinnitus is a medical condition with various causes and solutions. The Freequency app is based on exposure therapy, which means that you are consciously exposed to the tinnitus symptoms you experience. More information about Freequency B.V., the company behind this app, can be found at freequency.app. There you can read about Freequency’s developments and all its products. The information on the websites and in the Freequency app is general in nature and is not intended as medical advice.

If you have any doubts about using the app, contact your general practitioner or hearing specialist. You can also ask us any questions you may have about the Freequency app. Send your question to [email protected] or via the comments section in the app store. We will forward your question to the relevant specialist, who may be a developer or a therapist. Freequency will never give personal advice, but depending on the information you provide in your question, we can check whether the Freequency app can be used normally in your case. Please do not include any personal details in the comments section of the App Store.

Using the app can never replace professional advice. If you have any complaints or questions about your health, always contact a specialist. Freequency accepts no liability for the consequences of using the app, the information on the website or the content provided in the app.

Functional cookies are used on the Freequency app web page, for example to display the information in the correct language and to make it suitable for your screen. We also use statistical cookies to see how much the website is used. Statistical cookies do not process personal data. The marketing cookies we use give us insight into how you use the website, how long you visit the page and what information you read. You will not be tracked once you end the session.

The information on our websites, in the Freequency app and on Freequency’s social media channels is subject to the copyright of Freequency B.V. If you wish to publish information about Freequency, you must request permission from Freequency in advance via [email protected]. Each publication must include at least a reference to www.freequency.app. Freequency may refuse to grant permission for publication.

Version 1.2 privacy policy

The privacy policy of the Freequency app is reviewed from time to time. This is partly to continue to comply with legal obligations and also to keep you well informed about Freequency’s working methods, which are subject to change.

Changes to the privacy policy are always published on the Freequency website.

This privacy policy was drawn up on 1 February 2025 and last amended on 15 January 2026.

Published by Dian van Horrik