Privacy Policy

Last updated: 20 August 2026

1. Introduction and Who We Are

Welcome to Hearo's Privacy and Data Protection Policy (Privacy Policy). Hearo (trading name of LUX GLOBAL LTD, we, us, or our) is committed to protecting and respecting your privacy and personal data, and to acting in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable UK data protection law.

Hearo is a multilingual survey and form platform used by two types of people:

Creators, who sign up for a Hearo account to build, publish, and analyse surveys.
Participants, who answer a survey shared with them, without creating a Hearo account.

This Privacy Policy explains how we collect, use, and protect personal data for both groups, and — because these two roles are treated differently under data protection law — is organised to make clear which parts apply to you.

2. Two Different Roles: Please Read This Section First

If you are a Creator (you have a Hearo account): Hearo is the data controller for your account data (name, email, password, admin language, and similar account information). See Sections 3–8 below.

If you are a Participant (you are answering someone else's survey): the organisation or individual that created the survey (the Creator) is generally the data controller for the responses you submit — Hearo processes that data as a data processor, on the Creator's instructions, to provide the survey and translation service. This means:

Questions about how your survey responses will be used, stored, or shared should be directed to the Creator of that specific survey — the survey's introduction or consent text is the right place to look for this information.
Hearo processes your response data (including any personal data you choose to include in free-text answers) only to deliver the survey, generate translations, and provide the Creator with the response data they requested.
Section 9 below explains how Hearo handles Participant data as a processor.

3. Your Data Controller (for Creator Accounts)

Hearo is the data controller responsible for your Creator account data. We are not required to, and have not currently, appointed a Data Protection Officer. For any questions or requests regarding your data, contact us at [email protected] or by post at:

One Suffolk Way, Sevenoaks, Kent, TN13 1YL, United Kingdom

You always have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk. We would appreciate the chance to address your concerns before you contact the ICO, so please contact us first if you're able to.

4. Data We Collect

4.1 Account data (Creators). When you sign up, we collect your first name, last name, email address, and a hashed password. If you update your profile, we also hold your chosen admin language.

4.2 Survey content (Creators). The questions, answer options, instructions, consent text, and other content you enter into the survey builder, and your selected source and participant languages.

4.3 Response data (Participants). Answers submitted to a survey, including free-text responses, the language a response was given in, and metadata such as start/end time, duration, and completion status. If a survey asks for personal information (e.g. an email question, or a free-text question requesting a name), that information is collected as part of the response.

4.4 Translation feedback. If a Participant flags a translation issue, we collect the issue type, any optional details provided, and the question and language it relates to.

4.5 Technical and usage data. We use a browser cookie to let a Participant resume an incomplete response to a specific survey link, and we may collect standard technical data (such as browser type and IP address) to operate and secure the Services.

4.6 Special category data. We do not deliberately collect special category data (data revealing racial or ethnic origin, religious or philosophical beliefs, health information, sexual orientation, and similar) about Creators through the account sign-up process. Where a survey a Creator builds requests this type of information from Participants (for example, a wellbeing or needs-assessment survey), the Creator — as data controller for that survey — is responsible for ensuring an appropriate lawful basis is in place.

5. Legal Basis for Processing

We rely on the following legal bases:

Contract — to create and manage your account and provide the Services you've signed up for.
Legitimate interests — to maintain and improve the Services, keep them secure, and communicate with you about your account, provided this doesn't override your rights and freedoms.
Consent — where you've opted in to something specific, such as marketing communications.
Legal obligation — where we're required to retain or disclose data by law.

Where Hearo processes Participant response data as a processor on behalf of a Creator, the Creator is responsible for establishing the lawful basis for collecting that data from Participants.

6. How We Use Your Data

We use Creator account data to provide and maintain your account, operate the survey builder and dashboard, communicate with you about your account or the Services, and respond to support requests. We use AI translation tools to translate survey content and free-text responses; see Section 9 for how these tools are used with Participant data specifically. We do not use Customer Content or Participant response data to train AI models.

7. Cookies

We use a small number of cookies:

Essential cookies, including a session cookie that lets a Participant resume an incomplete survey response on the same device and browser.
Account session cookies, to keep Creators signed in to the workspace.

We do not currently use non-essential tracking or advertising cookies. If this changes, we will update this policy and, where required, request your consent.

8. Your Rights (Creator Accounts)

Subject to certain exceptions, you have the right to:

Be informed about how we use your data (this policy).
Access a copy of the personal data we hold about you.
Rectify inaccurate or incomplete data.
Erasure — ask us to delete your data in certain circumstances.
Object to processing based on legitimate interests.
Restrict processing in certain circumstances.
Data portability — receive your data in a structured, machine-readable format, where processing is based on consent or contract and carried out by automated means.

To exercise any of these rights, contact [email protected]. We won't charge a fee, except where a request is manifestly unfounded or excessive. We may need to verify your identity before responding.

9. Participant Data: How Hearo Acts as a Processor

When a Creator publishes a survey and a Participant responds, Hearo:

Stores the response data in the Creator's account, associated with that specific survey.
Uses AI translation tools to translate free-text responses back into the Creator's admin language, and to translate survey content into the Participant's chosen language.
Makes response data available to the Creator via the dashboard and CSV export.
Retains the original, untranslated response alongside any translation, so the Creator can always view what a Participant actually wrote.

Hearo does not sell Participant data, use it for advertising, or use it to train AI models. Where a Creator closes their account or deletes a survey, associated response data is deleted in line with our data retention practices (Section 11), except where we are required to retain it by law.

If you are a Participant and want to know more about how a specific organisation is using your response, please contact that organisation directly — Hearo does not control what a given Creator's survey is used for.

We share personal data with:

AI translation providers, to generate translations of survey content and responses.
Hosting and infrastructure providers, to store and operate the Services.
Email providers, to send account confirmation, password reset, and service-related emails.

We require these providers to only process data on our instructions and to keep it secure. We may also disclose personal data if Hearo is involved in a merger, acquisition, or sale of assets; if this happens, we will ensure the receiving party is bound by equivalent privacy protections, or we will notify you before your data is transferred and becomes subject to a different privacy policy. We may also disclose data where required by law.

11. How Long We Keep Your Data

We retain Creator account data for as long as you have an active account, and Participant response data for as long as the Creator's account remains active and the survey/response is not deleted. We may retain data for longer where we reasonably believe there is a prospect of litigation, or where required by law.

12. International Data Transfers

Our infrastructure and AI translation providers may process data outside the UK. Where this happens, we take steps to ensure an adequate level of protection is in place, such as the UK's International Data Transfer Addendum or adequacy regulations, before data is transferred.

13. Children

Hearo accounts are intended for use by individuals aged 18 and over. Hearo itself does not knowingly collect account data from children.

However, because Hearo is used by organisations such as schools to run surveys, a specific survey may be directed at, or completed by, a minor (for example, a pupil wellbeing survey). In these cases, the Creator organisation — not Hearo — is the data controller responsible for ensuring appropriate consent, safeguarding, and data protection measures are in place for that survey, in line with applicable law (including, where relevant, additional protections for children's data).

14. Security

We limit access to personal data to employees and processors who need it to operate the Services, and require them to keep it confidential. No transmission over the internet is completely secure, and while we take reasonable steps to protect your data, we cannot guarantee the security of data transmitted to us; any such transmission is at your own risk. If you believe your account or data may have been compromised, contact us immediately.

15. Changes to This Policy

We review this Privacy Policy periodically and will post updates here. Continuing to use the Services after changes take effect means you accept the updated policy.

16. Contact and Company Details

Hearo (trading name of LUX GLOBAL LTD)
Company Number: 13566067
27 Old Gloucester St,
Holborn,
London,
WC1N 3AX,
United Kingdom

Data protection queries & general support: [email protected]