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Who we are and purpose of this privacy notice
[Sonova Singapore, 8 Kallang Avenue #13-08 Aperia Tower 1, 339509
Tel: +65 6895 2666
Enquiry.singapore@phonak.com, ] (“we”), as a Controller, respects your privacy and are committed to protecting your personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, or the General Data Protection Regulation (hereafter “Applicable Law”).
Please read this privacy notice to understand how we collect, use and protect the personal data that you provide to us in the context of using our online hearing test services.
What are the data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect Health Data about you, which are considered as sensitive data, and which are necessary for using our online hearing screener services. The processing of those data is possible only if you consent to. You may withdraw your consent at any time, or exercise one of your legal rights as mentioned in the section “Your legal rights”.
How your personal data are collected
We use different methods to collect data from and about you:
Direct interactions: You may give us your identity and contact information by filling in forms. This includes personal data you provide when you:
Automated technologies or interactions: As you use our service, we will automatically collect technical data about your equipment, browsing actions and patterns, in order to ensure the proper functioning and security of the website. We collect this personal data by using cookies and server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources: We will receive data from Google Analytics. We gather information to analyze user actions in the application and to improve the product. All data are anonymized/aggregated.
Why we use your personal data
We use your personal data for the following purposes:
Disclosure of your personal data
We may share your personal data with third parties in case they need access to perform tasks on our behalf. Such parties are obligated not to disclose or use your data for any other purpose than those set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with Applicable Law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In addition, we may transfer your personal data in a de-identified form to our partners with the aim to improve services and products offered to you. The processing of personal data for these purposes will be done in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, or it will be anonymized.
The third parties to which we can disclose your personal data are the following:
International transfers
In the event your personal data are transferred outside the European Union/ European Economic Area to countries not considered as providing an adequate level of protection according to the European Commission, we commit to:
Depending on the importing third country, we undertake to adopt supplementary measures such as completing a data transfer adequacy assessment if, after evaluation of the circumstances of the transfer and after evaluation of the legislation of the third country, it is necessary for the protection of the transferred personal data.
Data security
We have adopted appropriate security measures according to Applicable Law to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We also have adopted procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so.
In addition, we limit access of your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. In some circumstances we will de-identify your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
According to Applicable Law, you have the right of access, rectification, restriction of processing, data portability, objection of the processing of your personal data, erasure of your personal data, and withdrawal of your consent. Please note that the exercise of such rights is not absolute and is subject to the limitations provided by Applicable Law.
If you wish to exercise one of these legal rights, we may need to request specific information from you to help us confirm your identity and ensure your request is lawful. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Please know that If you consider that the processing of your personal data constitutes a violation of the Applicable Law, you can lodge a complaint with the competent supervisory authority.
Important information
00Minors’ personal data: This website and our service are not intended for children and we do not knowingly collect data relating to children.
Third-party links: This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.
Change of purpose: We will only use your personal data for the purposes for which we collected them as set out above. Before we change the purpose of processing your personal data, we will notify you and will explain the legal basis which allows us to do so. You have the right to reject to the processing for a different purpose at any time, and we will change or delete your data according to your request according to Applicable Law.
How to contact us
If you wish to exercise any of the rights set out above, or for any other questions, information or remarks about this privacy notice or our privacy practices, please contact us at [Sonova Singapore, 8 Kallang Avenue #13-08 Aperia Tower 1, 339509, Tel: +65 6895 2666, Enquiry.singapore@phonak.com].