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UK privacy notice

If you live in the United Kingdom, the UK GDPR and the Data Protection Act 2018 protect your data. This notice adds what they require to our global privacy policy, and explains how we follow the ICO's Age Appropriate Design Code for children.

Ultimo aggiornamento: 22 ottobre 2026

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  1. 1Who is responsible

    The controller is Omnibus, Ltd., postal address available on request at the email below, registered outside the UK. Our privacy team (and our data protection officer once one is appointed) is at , or use the contact form.

    What we collect and why is explained in full in the privacy policy. The legal bases are the same as under the EU GDPR and are listed in our EU privacy notice; under UK law the same articles of the UK GDPR apply.

  2. 2Our UK representative

    As we have no establishment in the UK, we appoint a representative under Art. 27 UK GDPR. You and the ICO can contact them about anything to do with our processing.

    UK representative: will be named here before we offer the service in the UK; until then, please write to us directly.

  3. 3Health-related data

    Listening levels, sound dose and posture state may count as data concerning health, a special category under Art. 9 UK GDPR. We process it only with explicit consent (Art. 9(2)(a)) — for a child, the consent of the parent who adds them. It is asked for on its own screen, the box is never pre-ticked, and you can withdraw it at any time in the app or in iOS Settings. Under s. 9 of the Data Protection Act 2018, children under 13 need a parent's consent for online services: a child's phone cannot be paired before that consent is recorded. Earbunny is not a medical device and does not diagnose.

  4. 4Transfers outside the UK

    Our servers are in the EU, which the UK recognises as adequate. Where a processor accesses data from another country, we rely on UK adequacy regulations (including the UK Extension to the EU–US Data Privacy Framework for certified US companies) or the International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses, with a transfer risk assessment. Processors are listed in the subprocessor list.

  5. 5Your rights

    You can ask for access, rectification, erasure, restriction, portability, objection and not to be subject to solely automated decisions with legal or similarly significant effects (we make none), and you can withdraw consent at any time. In the app: Settings → Download my data and Delete account. Other requests: . We reply within one month, free of charge, and can extend by two months for complex requests. A parent can act for their child; a child old enough to understand their rights (generally from about 12 in the UK) can also ask us directly.

    Complaints. Please tell us first so we can put it right. Under the Data (Use and Access) Act 2025 you may also complain to us formally and we will acknowledge it within 30 days. You can complain to the Information Commissioner's Office at any time: ico.org.uk, helpline 0303 123 1113.

  6. 6The Children's Code

    The ICO's Age Appropriate Design Code (the Children's Code) sets 15 standards for online services likely to be used by under-18s. Earbunny is made for families, so we apply all of them. Here is how.

    StandardHow we meet it
    1. Best interests of the childThe app exists to protect children's hearing and habits. No ads, no data sale, nothing that earns from a child's attention.
    2. Data protection impact assessmentWe assessed the risks of monitoring children, health-related data and location in a DPIA, and review it every year and before any new data type or purpose.
    3. Age-appropriate applicationThe parent enters a birth year so we know the child's age band. Child screens use short, simple words, and under-13s cannot be paired without parental consent.
    4. TransparencyChildren get a short version in plain words (in the app and in our children's notice), shown when their phone is paired and in Settings at any time.
    5. Detrimental use of dataGoals, stars and streaks reward healthy habits such as safer volume and sitting upright — never more time in the app. Children cannot buy anything: the paywall appears only in the parent's account.
    6. Policies and community standardsWe do what our privacy policy, terms and acceptable use policy say, and enforce them, including for friends and the weekly league.
    7. Default settingsHigh privacy by default: background monitoring is off, friends and the league are off until a parent turns them on, and a child's data is visible only to the child and the linked parents.
    8. Data minimisationNo microphone, no listening content, no contacts, photos or messages, no advertising IDs. Raw motion data stays on the phone; only a posture state is sent.
    9. Data sharingWe share children's data with no one except processors that run the service for us. Schools see only anonymous class averages, with at least 10 students reporting.
    10. GeolocationLocation is off by default and never tracked continuously. With permission, it is recorded only at the moment an earbud drops or is left behind, and deleted after 7 days. Low-accuracy background updates run only if background monitoring is turned on, and iOS then shows its location indicator.
    11. Parental controlsThere is no hidden mode. The child always sees that monitoring is on and who can see their data on the “Who sees me” screen, and gets a reminder every 30 days.
    12. ProfilingNo profiling for advertising, marketing or content recommendations. The only calculations are the ones the features need, such as weekly sound dose.
    13. Nudge techniquesWe never use design tricks to get children (or parents) to share more or switch privacy protections off. “No” is as easy to choose as “yes”, and nothing stops working that doesn't need the permission.
    14. Connected toys and devicesThe app reads earbud and headphone sensors only during listening sessions, explains this at setup, and processes motion on the phone.
    15. Online toolsDownload my data and Delete account are in Settings; parents can delete a child's profile at any time; anyone can write to us through the contact form.

  7. 7This website (PECR)

    Under the Privacy and Electronic Communications Regulations, this site stores only what is strictly necessary and loads cookieless, aggregated analytics only with your consent. See the cookie policy.

  8. 8Everything else

    • Retention, security and recipients: privacy policy.
    • Purposes, legal bases and automated decisions: EU privacy notice, which applies equally under UK law.
    • Changes: we announce material changes in the app and by email before they take effect.