Privacy Policy

Last updated: 2 November 2026  ·  privacy@ebbchart.com

EbbChart handles sensitive information about your hearing. This page explains, in plain terms, what we collect, why, who can see it, and the control you have over it.

Who we are

EbbChart is a hearing-tracking application operated by David McAvinue, an individual based in Cork, Ireland. For the purposes of the EU General Data Protection Regulation (GDPR), we are the data controller for the information described below.

If you have any question about your data or this policy, contact us at privacy@ebbchart.com.

What this policy covers

This policy applies to the EbbChart iOS application and to the website at ebbchart.com. It does not cover the App Store or TestFlight themselves, which are operated by Apple under Apple's own privacy terms.

What we collect

Account information

When you create an account, we collect your email address and authentication details so you can sign in and so your data is kept private to you.

Health information you enter

This is the core of what EbbChart does, and it is treated as special-category health data under GDPR. It includes:

• The results of hearing checks you take in the app, recorded over time
• Symptom logs, notes, and any triggers or observations you choose to record

Apple Health (HealthKit)

With your permission, EbbChart reads hearing-test (audiogram) data from Apple Health. This data originates from Apple Health and any devices connected to it, is imported into EbbChart only when you grant access, and is stored on our servers (Amazon Web Services, in the European Union) so the app can show you your hearing trends over time.

You control this access at any time in iOS Settings → Health → Data Access & Devices, and within EbbChart. We use Apple Health data only to provide EbbChart's hearing-tracking features. We never use it for advertising, and we never sell it.

Technical and usage information

To keep the service working and secure, we process basic technical information such as app version, device type, timestamps of activity, a count of how many times you export your data (kept for up to 36 months), and your display preferences (such as which Insights layout you use on a phone or a tablet).

Website analytics

The ebbchart.com website uses Statcounter to understand aggregate visitor numbers and which pages are viewed. This is separate from the app and is not linked to your hearing data or your account.

Why we use your data, and our legal basis

• To provide the app — storing your hearing checks and showing you how they change over time. Legal basis: performance of our agreement with you.
• To process your health information — recording and summarising the sensitive data above. Legal basis: your explicit consent, which you give separately from accepting the Terms, by ticking a box on the screen shown when you set up EbbChart (and, for accounts created before that screen existed, on first opening the app after it was added). It is not pre-ticked, and EbbChart cannot be used without it, because the app cannot work without processing health information. You can withdraw it at any time (see "Your rights").
• To keep the service secure and reliable — diagnosing problems and preventing misuse. Legal basis: our legitimate interest in running a safe service.

We do not use your data for advertising, and we do not sell it. We never use your health information for advertising or marketing purposes.

Research participation

EbbChart lets you choose, if you wish, to support research into the conditions the app helps you track. This is entirely optional and off by default. Choosing to take part, or choosing not to, has no effect on your use of EbbChart.

If you turn on Research Participation, we record only your choice and the version of the consent information you agreed to, together with the dates you gave or withdrew that choice. Turning it on does not, by itself, share any of your data. As of the date of this policy, no data is shared with any third party for research and no research partnerships are active.

Should research use begin in future, we will first remove identifying details — your name, email address, and account identifiers — from the data used for research, so that it is not linked to your identity. Such research may include externally funded studies; this does not change that commitment. The legal basis for any such processing, and the safeguards required under the General Data Protection Regulation and Ireland's Health Research Regulations 2018, will be in place before any research use begins. If the purpose or manner of use changes materially, we will ask for your consent again rather than rely on a previous choice.

You can withdraw at any time from Profile → Research Participation. Withdrawing is as straightforward as giving consent and stops any future use of your data for research. Your consent record is retained as a record of the choices you made, including any withdrawal.

To ask about this, or to exercise your data protection rights, contact privacy@ebbchart.com.

How we use AI

AI processing of audiogram photos

If you choose to add an audiogram by taking or uploading a photo, EbbChart uses artificial intelligence to read the values from that image so you can check and save them. This is the only place EbbChart's own features use AI.

This processing is carried out using Amazon Bedrock, an AI service run within our own cloud environment in the European Union (Ireland). The photo is sent only when you submit it, is used only to read the values, and is not stored by EbbChart after the values are returned to you. Your data is not used to train AI models, and it is not shared with the underlying model provider for their own purposes.

The values it reads can be wrong. Always check them against your original audiogram before saving. They are not medical advice.

Connecting EbbChart to an AI assistant

EbbChart can be connected to third-party AI assistants — currently Claude, made by Anthropic, and ChatGPT, made by OpenAI — so you can ask questions about your own hearing data in conversation. This is entirely optional and off by default. Nothing is shared with any AI assistant unless you deliberately connect one.

What connecting does

When you connect an AI assistant, you authorise it to read data from your EbbChart account on your behalf. You do this from inside the EbbChart app — go to Profile → Connected AI assistants and turn it on. Before enabling, you will see exactly what data will be shared and who receives it.

What can be read

A connected assistant has read-only access. It can retrieve:

• Hearing test records — your audiogram thresholds by date and frequency, for both ears, including whether each came from an in-app test, Apple Health, or a clinic
• Symptom logs — the daily entries you have recorded, including any free-text notes
• Medication courses — medication names, doses, how often you take them, and start and end dates (medication courses are available to Claude only)
• Profile information — your condition, affected ear, year of diagnosis, country, and when your account was created

What cannot be done

A connected assistant cannot:

• Create, change, or delete anything in your EbbChart account
• Access your email address, password, or authentication credentials
• Access your payment details
• Access other EbbChart users' data

The connection grants a single read-only permission scope. There is no write access of any kind.

Who receives your data, and what happens to it there

When you use a connected assistant, the data it retrieves is transmitted to that assistant's provider — Anthropic if you use Claude, or OpenAI if you use ChatGPT — and processed on their systems in order to answer your questions.

Once your data reaches the AI assistant, it is governed by that provider's privacy policy and terms, not by this one. We do not control how Anthropic or OpenAI store, retain, or process data within your Claude or ChatGPT account, and we have no access to your conversations there. Depending on your plan and settings, a provider may keep conversations or use them to develop its services; those choices are controlled in your account with the provider, not in EbbChart. Please read Anthropic's privacy policy at https://www.anthropic.com/privacy and, if you connect ChatGPT, OpenAI's privacy policy (https://openai.com/policies/privacy-policy/; for people in the European Economic Area, OpenAI Ireland Limited is the provider and its EU policy applies: https://openai.com/policies/eu-privacy-policy/) before connecting.

This may involve your data being transferred outside the European Economic Area, including to the United States. You are making that disclosure yourself, to a service you have your own account and relationship with, by choosing to connect it.

Health data and your consent

The data described above includes information about your health, which is a special category of personal data under the UK and EU GDPR.

Your consent to process your health data. When you set up EbbChart you are asked to consent to us processing your hearing and health data as described in this policy. This is a separate choice from accepting the Terms of Service. We keep a record of when you gave it and which version of the consent wording you agreed to, so we can show the consent we hold and ask again if the wording or our use of your data materially changes. If you decline, you cannot use EbbChart and are signed out; nothing is processed.

We disclose it to a connected AI assistant only on your explicit instruction — turning on the Connected AI assistants toggle in Profile. That explicit consent is the lawful basis for this disclosure. You do not have to connect an assistant, and no EbbChart feature is withheld if you do not.

You can withdraw that consent at any time (see below). Withdrawal stops any further disclosure but does not affect disclosures already made, and does not delete data already held by the assistant's provider — for that, use the provider's own controls.

What we log

When a connected assistant reads your data, our servers record the request for security and operational purposes: the time, the account it relates to, and which type of data was requested. We do not log the content returned, and we do not log or have any access to your conversations with the AI assistant.

These operational logs are retained for a limited period and are deleted when you delete your account.

Rate limits

To protect the service, connected assistants are limited in how many requests they may make per day. This limit is technical and applies to all users.

How to disconnect

You can revoke access at any time, in any of three ways:

• In the EbbChart app — Profile → Connected AI assistants, turn it off. Takes effect immediately.
• In the AI assistant — remove the EbbChart connector from your connector or integration settings.
• By deleting your EbbChart account — Profile → Delete Account. This removes all of your data from our systems, including access tokens, and immediately invalidates any connection.

Revoking access takes effect immediately. No further data can be read.

Contact

Questions about connected assistants, or about your data generally: privacy@ebbchart.com

Who we share data with

We share data only with the service providers needed to run EbbChart. These act on our instructions and are bound to protect your data:

• Amazon Web Services (AWS) — hosting, database, authentication, and AI processing, in the EU (Ireland) region.
• Anthropic (via Amazon Bedrock) — the AI model that reads the values from audiogram photos you choose to upload. Anthropic's model processes the image our system sends it; this occurs within AWS infrastructure in the European Union. Your data is not used to train Anthropic's models.
• Statcounter — website analytics only (not app or health data).
• Apple — distribution of the app through the App Store and TestFlight.
• AI assistants you choose to connect — Anthropic (Claude) or OpenAI (ChatGPT) receive your data only if you connect them yourself; see Connecting EbbChart to an AI assistant.

We do not sell your personal data to anyone, and we do not share your health information with third parties for their own purposes.

Where your data is stored

Your account and health data are stored within the European Union (Ireland). Where a provider such as Apple necessarily processes limited information outside the EU, that transfer is governed by the safeguards those providers put in place, such as Standard Contractual Clauses.

How long we keep it

We keep your data for as long as you have an account. If you delete your account, we permanently delete your hearing checks, logs, notes, and account record. Deletion is irreversible and cannot be undone. The record of when you gave your consent to the Terms and to health-data processing, and which versions you agreed to, is part of your account record and is deleted with it.

The former in-app AI Guide. EbbChart used to include an in-app AI Guide. It was withdrawn in October 2026. The conversations, memory and usage records it created, and any feedback you gave on its answers, were deleted from our live database on 26 October 2026. Copies held in our encrypted database backups are removed automatically within 35 days.

Your rights

Under GDPR you have the right to:

• Access the data we hold about you
• Correct data that is inaccurate
• Delete your data — you can do this yourself at any time from the app's profile screen, which removes your account and all associated data
• Restrict or object to certain processing
• Receive your data in a portable format
• Withdraw your consent at any time, without affecting processing that already took place. In the app, deleting your account (Profile → Delete account) withdraws it and permanently deletes your data; you can also write to privacy@ebbchart.com.

To exercise any of these rights, contact privacy@ebbchart.com. You also have the right to lodge a complaint with the Irish Data Protection Commission (dataprotection.ie) or your local supervisory authority.

How we protect your data

Data is encrypted in transit and at rest, access is restricted to your authenticated account, and infrastructure is hosted on secure cloud services. No system is perfectly secure, but we take reasonable steps to protect your information.

Children

EbbChart is intended for adults and is not directed at anyone under 18. We do not knowingly collect data from children.

A note on what EbbChart is

EbbChart is a personal tracking tool. It is not a medical device, is not a substitute for professional audiometry, and has not been clinically validated. It does not diagnose or treat any condition. Always consult a qualified clinician before making decisions about your health, and seek care promptly for any sudden change in your hearing.

Changes to this policy

We may update this policy as EbbChart develops. If we make a significant change, we will update the date at the top of this page and, where appropriate, let you know in the app.

Contact

Questions about your privacy or this policy: privacy@ebbchart.com.