Privacy Policy

Gamma Innovations Global Pty Ltd (ABN 672 305 547) ("we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, share, and protect your information when you use the EchoSphere mobile application ("App"), the EchoSphere administration portal, and any associated websites (collectively, the "Services").

This Privacy Policy complies with the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs), the General Data Protection Regulation (GDPR) for users in the European Economic Area, and applicable data protection laws in the regions where we operate.

By using our Services, you consent to the practices described in this Privacy Policy. If you do not agree with this policy, please do not use our Services.

1. Information We Collect

a. Information You Provide Directly

• Account Information: When you create an account, we collect your name, email address, and display name. Authentication is handled via Microsoft Entra External ID (a third-party identity provider), and we do not store your password directly.
• Preferences: Your selected news categories, preferred languages, preferred countries/regions, preferred voice for audio playback, playback speed, auto-play settings, and notification preferences.
• Payment Information: If you subscribe to EchoSphere Premium, payment is processed by Stripe, Inc. We do not store your full credit card number, CVV, or bank account details. We retain only your Stripe customer identifier, subscription status, and billing period dates.
• Playlists: Names and article selections you save to custom playlists.
• Support Communications: Any information you provide when contacting us for support.

b. Information Collected Automatically

• Usage Data: Articles you listen to, playback history, playback progress and completion rates, saved/bookmarked articles, search queries, and time spent listening.
• Device Information: Device type, operating system and version, unique device identifiers, and mobile network information.
• Push Notification Tokens: If you enable push notifications, we collect your Firebase Cloud Messaging (FCM) device token to deliver notifications to your device.
• Ad Interaction Data: For Free tier users, we collect data about audio and display advertisements served, including ad impressions, completion rates, and skip events.
• Log Data: IP address, access times, pages and screens viewed, app crashes, and diagnostic data collected via Azure Application Insights.
• Location Data: We do not collect precise GPS location. Your general region is inferred from your IP address and your selected country/region preference.

c. Information from Third-Party Sources

• News Content: We aggregate news articles from NewsAPI.org, a third-party news aggregation service. Article metadata (titles, descriptions, source names, publication dates) is cached temporarily in our systems.
• Authentication Provider: Microsoft Entra External ID provides your authenticated identity (user ID, email, display name) when you sign in.

d. Sensitive Information

We do not intentionally collect sensitive information such as health, racial, ethnic, political, religious, or biometric data. If such information appears incidentally in news content you consume, it is not used for profiling or targeting.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Provide Core Services: Convert news articles into audio format using text-to-speech technology (powered by ElevenLabs), deliver personalized news feeds based on your preferences, and enable audio playback with background and lock-screen controls.
• Personalization: Customize your news feed, "Top Stories," "For You," and "Trending" sections based on your selected categories, languages, and regions.
• Subscriptions and Billing: Process Premium subscription payments via Stripe, manage subscription status, and provide ad-free experiences to Premium subscribers.
• Advertisements: Serve audio advertisements between articles and display advertisements within the App for Free tier users. Ad frequency is managed based on your listening patterns.
• Push Notifications: Send you daily "Top Story of the Day" notifications and other relevant updates, subject to your notification preferences and quiet hours settings.
• Playlists and Library: Enable you to create, manage, and play custom playlists of saved articles.
• Analytics and Improvement: Analyze listening patterns, article completion rates, popular categories, and feature usage to improve the App and Services.
• Security: Detect and prevent fraud, unauthorized access, and other security threats.
• Legal Compliance: Comply with applicable laws, regulations, and legal processes.

3. Audio Content and Text-to-Speech

EchoSphere converts written news articles into audio using artificial intelligence-powered text-to-speech technology provided by ElevenLabs, Inc. The text of news articles is transmitted to ElevenLabs' servers for audio synthesis. The resulting audio files are cached in our cloud storage (Microsoft Azure) and delivered to your device for playback. We do not share your personal information with ElevenLabs; only the article text is transmitted for synthesis.

4. Advertising

Free Tier Users

If you use EchoSphere on the Free tier, you will hear audio advertisements inserted between articles and may see display/banner advertisements within the App. Advertisements are served via Google Ad Manager and our own ad management system. We collect ad interaction data (impressions, completions, skips) to manage ad frequency and improve the ad experience.

Premium Tier Users

Premium subscribers enjoy an ad-free experience. No audio or display advertisements are shown, and no ad interaction data is collected for Premium users.

Ad Personalization

In Version 1, advertisements are not individually targeted or personalized based on your profile. Ads are served using basic rotation logic with frequency capping. We do not sell your personal data to advertisers.

5. Sharing Your Information

We may share your information with the following categories of recipients:

• Cloud Infrastructure Providers: Microsoft Azure (hosting, database, storage, serverless compute, application monitoring). Your data is stored in Azure data centres in Central India.
• Authentication Provider: Microsoft Entra External ID handles user authentication. Your sign-in credentials are managed by Microsoft's identity platform.
• Payment Processor: Stripe, Inc. processes Premium subscription payments. Stripe's privacy policy governs how payment data is handled.
• Text-to-Speech Provider: ElevenLabs, Inc. processes article text to generate audio. No personal data is shared with ElevenLabs.
• News Content Provider: NewsAPI.org provides news article data. Your personal information is not shared with NewsAPI.
• Push Notification Service: Google Firebase Cloud Messaging delivers push notifications to your device.
• Advertising Partners: Google Ad Manager serves advertisements to Free tier users.
• Legal Authorities: When required by law, court order, or governmental regulation, or to protect the rights, safety, or property of Gamma Innovations, our users, or the public.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity.

We will never sell your personal information to third parties for their marketing purposes.

6. Guest Access

You may use certain features of the App without creating an account ("Guest Mode"). In Guest Mode, we collect only non-personal device and usage data. Guest users cannot save articles, create playlists, sync playback history, or receive personalized recommendations. To access these features, you must create an account.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with our Services. Specific retention periods include:

• Account data: Retained until you delete your account or request erasure.
• Playback history: Retained for 12 months from the date of playback, then automatically deleted.
• Notification logs: Automatically deleted after 2 days.
• Cached news articles: Automatically deleted after 24 hours.
• Audio files: Cached audio files are retained for service performance; they contain no personal data.
• Ad analytics: Retained for 12 months for service improvement, then aggregated and anonymized.
• Payment records: Retained as required by applicable tax and financial regulations.

Upon account deletion, we will delete or anonymize your personal data within 30 days, except where retention is required by law.

8. Your Rights

Under Australian Privacy Principles (APPs)

You have the right to:

• Access your personal information held by us.
• Correct inaccurate or outdated personal information.
• Complain to the Office of the Australian Information Commissioner (OAIC) if you believe your privacy has been breached.

Under the General Data Protection Regulation (GDPR)

If you are located in the European Economic Area, you additionally have the right to:

• Erasure: Request deletion of your personal data ("right to be forgotten").
• Data Portability: Receive your personal data in a structured, machine-readable format.
• Restriction: Request restriction of processing of your personal data.
• Objection: Object to processing of your personal data for certain purposes, including direct marketing.
• Withdraw Consent: Withdraw your consent at any time where processing is based on consent.

How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@gammainnovations.com.au. We will respond to your request within 30 days. We may require verification of your identity before processing your request.

Managing Preferences In-App

You can manage the following directly within the App:

• Notification preferences (enable/disable, quiet hours, frequency)
• News category, language, and region preferences
• Playback settings (speed, auto-play, preferred voice)
• Account deletion (via Profile settings or by contacting us)

9. Data Security

We implement industry-standard technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS/HTTPS) and at rest.
• Secure secret management via Azure Key Vault.
• Role-based access controls for administrative systems.
• Session-based authentication with secure, HttpOnly cookies for the administration portal.
• Regular security reviews and code audits.
• Managed identity and federated authentication for cloud service access (no stored credentials in deployment pipelines).

While we take all reasonable precautions, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.

10. International Data Transfers

Your data is primarily stored and processed in Microsoft Azure data centres located in Central India. If your data is transferred to service providers located outside Australia or the European Economic Area (including the United States for services such as Stripe, ElevenLabs, Google, and Firebase), we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Compliance with the Australian Privacy Principles for cross-border disclosures.
• Vendor security assessments and data processing agreements.

11. Children's Privacy

EchoSphere is not directed at children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal data from a child under 13, we will take steps to delete such data promptly. If you believe a child has provided us with personal data, please contact us at privacy@gammainnovations.com.au.

12. Third-Party Links and Content

The App may display news articles with links to third-party websites and original article sources. We are not responsible for the privacy practices, content, or security of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Cookies and Similar Technologies

The EchoSphere administration portal may use cookies and similar technologies for session management and authentication. The mobile App uses local storage (AsyncStorage) to store your authentication tokens and preferences on your device. We use Azure Application Insights for performance monitoring and crash reporting.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated policy within the App and on our website.
• Updating the "Effective Date" at the top of this document.
• Sending a push notification or email for significant changes (where applicable).

Your continued use of the Services after changes are posted constitutes your acceptance of the revised Privacy Policy.

15. Contact Us

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

Gamma Innovations Global Pty Ltd
Homebush, NSW, Australia
Email: privacy@gammainnovations.com.au
General enquiries: info@gammainnovations.com.au

For complaints regarding your privacy, you may also contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.