GN respects your privacy and is committed to protect your personal data. This privacy policy gives you information about how GN collects and processes your personal data if you use our applications governed by this privacy policy (“apps” or “services”).
Please note that other privacy policies may apply to certain specific solutions or services provided by us. We kindly refer you to read the privacy policy for the information related to the specific solutions or services you are using. This privacy policy may supplement such other policies and is not intended to replace them.
If you are directed to a GN or a third-party website from the app, we refer you to the privacy policy of the website you visit. We do not control third-party websites and we are not responsible for their privacy policies and their use of your data.
The terminology used in this privacy policy, for example controller, processor, processing, personal data, recipient, third party, consent, have the meaning given in the EU General Data Protection Regulation (2016/679) unless other data protection laws apply, in which case, the terms will be interpreted in light of the closest term of the applicable data protection laws.
The legal entity who is controller and responsible for processing your personal data is:
GN Hearing A/S, Lautrupbjerg 7, DK-2750 Ballerup, Denmark, registration number 55082715. Telephone number 45750000, email: info@gn.com (the Company”)
How to contact our Data Protection Officer about our use of personal data
For general questions concerning personal data you may contact our Data Protection Officer on (click on the link): GN Data Privacy Inquiry Site
For specific request concerning your personal data you may contact our Data Protection Officer on (click on the link): GN Data Privacy Request Site
The Data Protection Officer can also be contacted on telephone +45 4575 0000.
The Company and the GN Group
The Company is part of an international group of companies which is engaged in different activities: production and marketing of for example hearing instruments, headsets, speakerphones, webcams, accessories and other services and products.
These products and services are marketed under a variety of brands such as Resound, Beltone, Interton, Jabra, Steelseries, Kontrolfreek, Blueparrott, Falcom, a.m.
When referred to “GN”, “we” or “us” it includes the Company and/or any other relevant affiliated company whose involvement is necessary to achieve the purposes as described in this privacy policy. You can find more information about the companies in the GN Group here: www.gn.com
The GN companies may act as independent controllers or processors in relation to each other. The GN companies may also act as joint controllers when processing your data. In such case we jointly determine the purposes and means of processing personal data. We have determined how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations.
GN Store Nord, Lautrupbjerg 7, 2750 Ballerup, Denmark (“GNSN”) is an affiliated company to the Company. GNSN is at your disposal as your central point in case of any questions in relation to our use of personal data, and GNSN can be contacted using the contact information above. You are also free to assert your rights by contacting any of the involved companies. In case you do so and if necessary, GNSN and the company in question will coordinate in order to respond to your inquiry and to preserve your rights as a data subject.
We collect your data in different scenarios and from different sources, such as directly from you, through third parties and/or through automated means, such as:
We have set out below, a description of how we may use your personal data. This is a generic description, and the specific use may differ in various apps.
We collect information from you in connection with your use of the app(s) as described in this section.
Information you provide to us directly in the App: we may collect information, such as your name, address, email, telephone number, age, password, any communications between you and us, and any other information you provide directly to us while using our App.
Using the support services in the App: Please note that when you contact our support function you will be directed to a form on our website or the website of a third-party engaged by us where we collect and use your name, email, telephone number, country/region in order for us to contact you concerning your inquiry. Please also refer to our privacy policy on jabra.com
Automatically collected Information
We collect certain automatically collected information, subject to your privacy choice, where required, to provide you with the full functionality of our app, e.g. to allow you to manage the settings of your headset/other products and to update firmware to the app and your headset/other products, and also for us to understand your use of our app, mobile and headset/other products in combination, in order for us to provide you with the best possible service and support, and in general to improve and develop our products and services.
The automatically collected information includes:
Registration for Marketing Information.
You can provide us with your consent to receive marketing information from us. In such case we use your name and e-mail and certain automatically collected information, e.g. your app key, app version, headset type, firmware version and IP address etc.
Your registration is voluntary, and your app will be able to work without your registration.
You can withdraw your consent by opting out again in your app or unsubscribing by clicking the link in the bottom of any marketing emails received.
Rating of the app
If you choose to rate the app – you will be directed to Jabra.com, where we collect and use your review to understand how you regard the app in general and your email to contact you concerning your ratings. In relation to the rating, we also collect your IP-address, app version, app name, firmware version and headset or other product type. We may use your rating and review data to improve the functions of our products and services. We may also use your ratings and reviews data to assist you when you require customer support or to follow up or guide you through our customer support process.
Location Services
In general, when you opt-in to location services we collect and process information about your actual location, like gps signals sent by your mobile device and we may also use various other technologies to determine location, such as sensor data from your device that may provide information of nearby wi-fi access points and cell towers. Further when you use location services this would typically also mean that we would need to collect your mobile device identification (e.g. Android ID), mobile device brand, model and operating system, and the applied IP-address. The information collected will be shared with a third-party provider of geolocation services to provide you with the requested service.
Find my Jabra is an example of a location service. If you choose to activate “Find My Jabra” as a service, your phone will store the latest location where your headset was in contact with your mobile device. The information will stay on your phone until you ask the app to locate the latest contact with your headset. When you make such a request in the app, your data (as mentioned above) will be shared with a third-party provider of geolocation services to help you locate your headset.
Fitness services
If you opt-in to use the workout performance service in our sports app, you share the following information with us: performed workouts; heart rate over time, geographical coordinates (gps) over time, calories consumption over time, speed (pace) over time, date and time of workout, (activity) type of workout, total duration of workout, total distance, total calories consumed, snapshot (image) of map and path taken during the workout with heart rate zone color information (if applicable), average heart rate, average speed (pace), test result - heart rate, vo2 score, resting heart rate stress feedback. We use third-party analytics providers to provide you with statistics of your training. In some Jabra apps you can share information about your fitness on social media or in another e.g. third-party sports application. If you choose to do so, we refer you to the privacy policy of such social media or third-party sports application. To use such features, the app will need your credentials which is stored on your device. You may have the option to create a publicly visible Jabra account, which include your name and photo.
Subscription on app stores
Subscription for apps on third-party app stores. For subscription of apps through various third-party app stores, GN refers you to privacy policies available within these services;
Social Media
To communicate with current and potential customers, to market, improve and develop our products and services and to inform about various activities, we use social media platforms cf. also the section on social media platforms below;
Prevention of fraud
To prevent or detect fraud and to establish, exercise or in defence of legal claims, we use your contact info such as name, address, email, phone number and the information we have registered about your requests and inquiries;
Compliance with applicable law.
To comply with applicable legislation and/or requests from law enforcement agencies, we use and share with such law enforcement agencies and regulatory authorities information such as name, address, email, phone number to the extent required;
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for an additional purpose which is compatible with the original purpose. If we were to consider using your personal information for a new purpose, we will inform you or, as required, collect your consent.
Applicable personal data legislation may require us to outline the legal basis on which we collect and use your personal data. This is for example a requirement under the EU General Data Protection Regulation and similar national legislation.
Below we have outlined the legal basis we rely on to collect and use your data. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data.
We will use your personal data based on the following legal bases:
To the extent use of your personal data is governed by national regulation requiring explicit or deemed consent for the use we only do this based on your consent. Consent may be required when we for example send you newsletters.
We will only use and transfer your personal data when applicable law allows us to.
Where we need to collect personal data by law, or under the terms of a contract we have with you or your company and you fail to provide us with the data when requested, or choose to withdraw a former given consent, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you or your organization have with us; but we will duly notify you about this, if relevant.
This section describes how we process your personal data in connection with your interaction with us as a data controller by use of different social media platforms and online search platforms, such as Facebook, Instagram, X, YouTube, LinkedIn, Google and more.
We use social media platforms to get in contact with current and potential customers, to improve, develop and market our products and services and to inform about various activities, i.e. we use the social media platforms:
We may use information about you, such as your name, email, age, gender, country, job title, current and former employer, education background, profile picture, interests, your friend list/connections/followers, and other publicly available information, provided that you have published all or parts of this information on your social media profile, posted it on one of our social media pages or sent it directly to us via our social media platforms.
In some cases, for instance, in relation to our certain social media platforms we may act as joint controller together with a social media platform in relation to the processing of your personal data.
We generally refer to the different social media platforms' privacy policies and cookie policies for more information about their processing of your personal data, including any information on when our use is considered joint use with the social media platform in question. Below you will find a listing of the social media platforms that we use and a reference to their privacy policies.
We do not intentionally collect personal data from children without the explicit consent of a parent or guardian. If we learn that we have collected personal data from children without the explicit consent of a parent or guardian, we will delete that personal data as soon as possible. If you believe that we may have collected personal data related to a child without the explicit consent of a parent or guardian, please submit a request through this DSAR form.
We will not share or disclose your personal data, except as described herein or otherwise stated at the time the personal data is collected. We will generally limit sharing of your personal data and always only share to the extent necessary.
However, we might share your personal information with:
In some cases, we will transfer personal data to recipients mentioned above which may be located in countries outside of your jurisdiction. Such transfers will be conducted in strict accordance with applicable laws, and where required we will provide appropriate safeguards for such transfers.
When transferring personal data out of the European Union or other jurisdictions requiring similar appropriate safeguards, we will use either the standard contractual clauses as approved by the European Commission or equivalent national bodies, or any other contractual agreement approved by the competent authorities as a basis for the transfer and where necessary, implement additional supplementary safeguards to ensure an adequate level of protection.
Your personal data will be stored in your jurisdiction if the applicable law requires so. Please contact us by using the contact details in section 2 above, if you would like further information on the specific mechanism used by us when transferring your personal data out of the European Union and/or other jurisdictions requiring appropriate safeguards.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, such as accounting, tax or other reporting requirements.
To determine the appropriate retention period for personal data, we consider the nature, the sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available upon request. Please use the contact information outlined in section 2 above.
Data protection law gives you a range of rights in connection with our use of your personal data. In this regard you have the right to request access to the personal data concerning you that we use. You may request that we rectify or delete your personal data or restrict the use of your personal data, if you think the data is inaccurate. You may have the right for data portability. We are required to assess and act on your request.
Your rights may be subject to conditions or restrictions. Accordingly, there is no certainty that you will be entitled to for example data portability in the specific situation; it will depend on the circumstances of the use.
If our use of your personal data is based on your consent, you may withdraw your consent at any time. However, please note that this does not affect our use of your personal data prior to withdrawal of your consent.
If you wish to contact us about our processing of your personal data, feel free to contact our Data Protection Officer as specified above in section 2.
You have the right to be free from unlawful discrimination for exercising your rights under this privacy policy. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to a 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 expedite your request more efficiently.
We try to respond to all legitimate requests within one month and shorter where required. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please be aware that you may also have the right to lodge a complaint with the Danish Data Protection Agency and with your national data protection authority or other public authority governing the protection of your personal data comprised by this privacy policy. We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection authority or other public authority, so please contact us in the first instance. The contact information of the Danish Data Protection Agency can be found at www.datatilsynet.dk
We provide you with the opportunity to unsubscribe to communication from us if you receive newsletters etc. via e-mail, text (SMS) or other direct message channels. At the end of each message, instructions on how to unsubscribe are included.
If one of our corporate affiliates or a third party has acquired our business, specific assets or the business of one of our operating divisions (such as part of a sale, merger, reorganization, or similar event), your personal data will become owned by that company, unless otherwise provided for by local legislation. In that event, the acquiring company's use of your personal data will be subject to the governing privacy policy, and the privacy preferences you have expressed to us prior to any merger.
Personal data is used in accordance with applicable data protection legislation. We take steps to ensure that the information we process is dealt with in accordance with this privacy notice and in accordance with applicable laws. When required or appropriate, we shall obtain written assurances from third parties that may access your data that they will protect the data with equivalent safeguards to those adopted by us. To protect the privacy of your information we maintain both technical and organizational safeguards, and we regularly update and test our security measures.
GN may in some situations act as a data processor based on agreements entered into with partners or customers etc. The partners/customers are in these cases considered data controllers. In such case your personal data is processed by GN on the basis of the instructions provided by the controller. For more information about how your personal data is used we refer to the privacy policies of the relevant controller.
This privacy policy will be updated on a regular basis and when necessary due to changes in applicable law. The updated privacy policy will always be posted on our websites and include information on the effective date of the latest version. We recommend that you regularly check this page to keep yourself updated on our privacy practices.
For California residents this section 18 applies in addition to the preceding sections:
You are free to request and obtain from us once a year, free of charge, information about the personal information, (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.
Please be informed, that we do not sell and have not sold personal information in the preceding 12 months. We do not sell the personal information of minors.