GN Hearing Privacy Policy

References in this privacy policy to “GN Hearing”, “we”, “us” or “our” mean GN Hearing A/S (a company registered in Denmark and the owner of the Resound, Beltone and Interton brands). Being a data controller means GN Hearing will make sure your data is collected and used in compliance with applicable European data protection legislation.

We are part of a corporate group of companies (“our Group”), which includes entities in several countries as shown on our websites www.resound.com, www.beltone.com, www.interton.com., www.danavox.com

Our contact info is:
GN Hearing A/S
Lautrupbjerg 7
DK-2750 Ballerup
Denmark
Reg. no. 55082715
Telephone number +45 45 75 11 11

If you have questions or concerns in relation to data protection, you are always welcome to contact our Data Protection Officer (DPO) via this form or by phone +45 45 75 00 00

When using the term “personal data” in this policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we possess. Your personal data may include for example your name, your contact details, information relating to purchases or information on how you use our websites and apps or how you interact with us. We collect personal data from you, for example when you use our websites or apps, use our services or contact us

We may collect and process the following categories of information about you:

1. Contact details
   When you take an online hearing test or wish to find a hearing care professional close to you we may ask for your name, telephone number and email address to be able to contact you. If you create an account on our website / when you purchase our products we will also ask for your address, to be able to send the products to you.
2. Hearing tests
   In order to perform hearing tests, contacting you by means of any communication methods (including phone, email, direct mail etc.), to discuss test results, hearing care, surveys and scheduling a hearing test, we will ask for your consent to collect and process contact details about you and the result from your hearing test. It will also include a right to share the data with your local hearing care professional.
3. Manufacture, delivery and repair of hearing aids
   In order to manufacture, deliver and repair hearing aids we may register information such as serial number, fittings, audiograms and contact information about you if provided by you or hearing care professionals.
4. User IDs and Passwords
   Provides you with access to your profile areas on our web shops or other digital applications (on websites).
5. The communications you exchange with us, e.g. emails, letters, calls, messages or our online chat service
   Used to raise and respond to issues and inquiries of all types. Also used to distribute information about GN Hearing’s products and services.
6. Information about payments
   When purchasing products at GN Hearing’s websites, we cooperate with third party payment providers. We will not have access to your payment details. We refer you to the payment providers privacy policies.
7. GN Hearing Internet Protocol Reporting
   GN Hearing uses your IP (Internet Protocol) address to monitor web site traffic and to help diagnose problems with our server. We do not use IP addresses to personally identify users.
8. Use of data cookies
   We kindly refer you to our Cookie policy. You can find the Cookie policy on our websites.
9. Apps
   When you download the app and use the app, GN Hearing may collect information about device specific information such as your mobile device unique device id, the type of mobile device you use, the ip address of your mobile device, bluetooth name, bluetooth mac address and your mobile operating system.
   
   Apps for use with wireless hearing aids:
   In general, GN Hearing collects aggregated, non-personally identifiable data across all the active app users by analyzing how the application features are used in general. This could be information about how extensively a feature is used and when the feature is typically activated. Also, we can tell if the volume bar is used by a majority of all users but we are not tracking your individual use of the volume bar.
   
   Some of our apps will allow you to receive firmware updates, remote fine tuning services and receiving customer services, to get the most out of your hearing instrument. If this is the case, we will be asking for your acceptance when installing the app. Use of the app is optional and gives you the added benefit and flexibility of being able to receive firmware updates etc., but as a result of this, some of your personal information will need to be processed in the manner described below. By using the app, you will be allowing us to access and process the information below about you and your use of the app: The hearing instrument’s serial number, hardware identification number and software version, hearing instrument settings, the length of time you use your hearing instrument, device type information and technical log information and the location (when you have accepted the GPS-enabled services).
   
   To receive remote fine tuning services you have to contact your hearing care professional, and sign a consent. We kindly refer you to the privacy notice that you received when you consented to the remote fine tuning services.
   
   If you withdraw your consent you will not be able to receive firmware updates for your hearing instrument via the app. If you withdraw your consent to receive remote fine tuning services you will not be able to use this service. If you are using the location service, you are free to switch off the location and GPS function on your mobile device at any time and prevent the collection and processing of this information.
   
   Some of our apps have features that require you to take pictures of yourself and your hearing aids. These features rely on facial and object recognition technologies and are used with the purpose of ensuring a good quality fitting and sound experience for you. The pictures are only stored locally in the app and are not accessed or used by GN Hearing nor shared with any third parties. The pictures can be deleted directly in the app or simply through uninstalling the app from your phone.
   
   Apps for use without a need of hearing aids:
   Some of our apps allow you to subscribe to functionality, for example, to create your own plan for managing tinnitus. No personal data beyond what is mentioned above in this section I (device specific information) will be processed in this regard.
   
   Payment for subscription management apps is handled either through Apple Appstore and your iTunes account or through your Google Play Store account, GN Hearing will not have access to your payment information. We refer you to the payment service providers personal data policies.


10. Additional personal data we collect about you as hearing care professional or business partner
    In addition to the above we collect information from business related interactions that we plan to have or have had with you as a hearing care professional or a business partner. We collect and process only the information necessary to be able to contact and/or follow up with you to maintain the professional relationship and to deliver the agreed customer service level.
    
    We may collect and process the following categories of information about you as a heath care professional or business partner:
    
    
    1. Customer Relations and Service Management
       To professionally manage our customer and partner relations, we record the date, contact data, purpose and agreed outcomes of meetings and events with customers and partners. In addition, we store information about GN Hearing product’s service provided to customers based on enquires from customers and partners when related to GN Hearing product quality and product application.
    
    
    2. Training
       To enable professional use of GN Hearing products and deliver training qualified by third party as merited continued medical education, we store customer’s contact name, date and content of training provided.

We collect your personal data from the following source(s):

1. Directly from you, such as the information you enter the app or other forms or information you provide to GN Hearing through our websites or oral communication;
2. Directly from the apps and the use of the websites;
3. From hearing care professionals

GN Hearing limits its collection, storing and processing of personal data to situations where a specific purpose exists. With reference to the EU General Data Protection Regulation (GDPR), we have listed the most relevant purposes and some of our activities associated with the purposes. We process your personal data on the following legal bases:

1. Article 6.1.a (Consent): E.g. when you have accepted to receive newsletters from us, using location service in an app or accept firmware updates of an app.
2. Article 6.1.b (Necessary for the performance of the contract between you and GN Hearing): E.g. when it is necessary for GN Hearing to process your personal data to be able to sell and send products to you.
3. Article 6.1.f (Necessary for the pursuit of legitimate purposes of GN Hearing): E.g. when GN Hearing stores some of your personal data with the purpose of administration resources on various projects. Any collected application usage data is an important part of ensuring that we always provide, maintain, protect and improve the services, GN Hearing offers. Further, it enables us to identify the need to improve existing functionality and develop new apps.
4. Article 9.2.a (explicit consent): E.g. Health data when GN Hearing stores data regarding remote fitting, or online hearing test (including your consent to share the hearing test result with a local hearing care professional).

GN Hearing will generally limit sharing your personal data and always only to the extent necessary. However, we might share your personal information with:

• Hearing Care Professionals, suppliers, business partners and vendors that we work with to assist our business (meaning service providers, technical support, payment services, webshop providers, analytics providers, supply services, and financial institutions);
• Other collaborators (such as internet providers);
• Group entities;
• Public authorities

Certain business partners and vendors process personal information on behalf of GN Hearing and may only process your personal data in accordance with the instructions given by GN Hearing and in compliance with this privacy policy and any other appropriate confidentiality and security measures. These third parties may not process your personal data for their own purposes. To the extent GN Hearing disclose or transfer your personal data to these third parties who may use your personal data for their own purposes, such disclosure or transfer will only take place if it is in accordance with applicable law or with prior consent obtained from you. From time to time authorized third parties may need access to some of your personal information. For example, if GN Hearing ships something to you, it is necessary to provide your name and address to a shipping company. We strictly limit third party access and use of your personal information. We may share aggregated information publicly and with companies, organizations or individuals outside of GN Hearing or with our partners, which could be publishers, advertisers or connected sites. For example, we may share aggregated information publicly to display trends about the general use of our applications. If GN Hearing is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of the mobile application information and give affected users notice before information is transferred or becomes subject to a different privacy policy.

To the extent possible, GN Hearing will refrain from sending personally data to countries outside the EU/EEA. However, in some cases it might be necessary. We may transfer personal data to countries outside the EU/EEA. Such transfers will only take place for the specific purposes mentioned above, and we will always ensure that appropriate safeguards are in place for such transfer as set out below, either:

1. If the country/countries has/have been deemed by the Commission of the European Union to have an adequate level of protection of personal data, or using EU US-Privacy Shield; or
2. If the country/countries has/have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data, we will provide appropriate safeguards for the transfer, either through the use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities. You may obtain more information about the contract/agreement by contacting us.

Your personal information will be stored for as long as it is necessary in order to fulfil the purposes described above and comply with minimum retention periods under applicable law.

We hereby inform you, that when the processing 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 GN Hearing's processing of your personal data prior to withdrawal of your consent. You may withdraw your consent here. In some apps, you can also notify us within the app.

We provide users the opportunity to opt out of receiving any further communications from GN Hearing when they receive distributions via e-mail. At the end of each email message, instructions on how to unsubscribe and be removed from the mailing list database are included. GN Hearing also gives users the option of contacting GN Hearing at any time to remove their information from our database or to stop receiving future electronic distributions. You can stop all collection of information by the app easily by uninstalling the app. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. If you uninstall the app all future collection of information by GN Hearing will stop through the app.

As the data subject we would like to inform that GN Hearing has taken all necessary and adequate steps in order to protect your personal data and ensure your rights. Please note, that there may be more conditions or limitations to these rights than stated below.

Right of access You have the right to request access to any personal data which we have processed about you and additional information in relation to the processing.

Right to rectification You have the right to get inaccurate personal data that we have stored about you rectified. That includes completion of incomplete personal data.

Right to erasure (right to be forgotten) Under certain circumstances, you have the right to erasure, which means that upon your request, we will erase stored personal data about you.

Right to object Under certain circumstances, you have the right to object at any time to our processing of personal data about you. In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.

Right to restriction Under certain circumstances you have the right to restrict our processing of personal data about you.

Right to data portability Under certain circumstances, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format, and the right to have your personal data transferred to another data controller.

Exercising your rights You may take steps to exercise your rights here.

• We encrypt data communication using strong encryption (128 or 256-bit SSL).
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to your personal information to GN Hearing employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Danish Data Protection Agency (Datatilsynet)
Borgergade 28, 5
DK-1300 Copenhagen K
Telephone number: +45 33 19 32 00
Email address: dt@datatilsynet.dk
Website: www.datatilsynet.dk