Privacy Policy

Last Updated April 2022

This Privacy Policy explains how We use your personal data used in the Jabra device and the mobile app (together referred to as the “Jabra Enhance” or the “Jabra Enhance Services”).

The purpose of this Privacy Policy is to help you understand our privacy practices when you use our Jabra Enhance, including the information and personal data we collect, why we collect it and what we do with it and your individual rights.

We reserve the right to amend or update this Privacy Policy from time to time. When We update this Privacy Policy. We will update the Last Updated date at the top of this Privacy Policy. If changes are made to any part requiring your consent you will be asked to restate or change your consent(s). If changes are made to any part not requiring your consent, the Privacy Policy is considered applicable upon publication. We will notify you of any such changes. In this case by continuing to access or make use of our services after having been informed of the changes to the Privacy Policy, you acknowledge the updated Privacy Policy.

1. Who is collecting and is responsible for the proper, safe and joint use of your personal data?

The company responsible for the processing of your personal data, i.e., the data controller is:

GN Hearing A/S, (Danish) company reg. no 55082715, Lautrupbjerg 7, 2750 Ballerup, Denmark, Telephone number: +45 45 75 00 00.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

For general questions concerning this Privacy Policy (click on the link): GN Data Privacy Inquiry Site

For specific request concerning your legal rights (click on the link: GN Data Privacy Request Site

You are also free to contact the DPO at

Lautrupbjerg 7, 2750 Ballerup, Denmark

telephone +45 45 75 00 00

When referred to “GN”, “the Company”, “We” or “Us” in this Privacy Policy it may include GN Hearing A/S and/or any other GN Group company involved in the processing of your data. You can see more about the use by other GN Group companies below under section 8 (Joint use in the GN Group). The involved GN Group companies are jointly responsible as joint controllers. GN Store Nord A/S is at your disposal as your central point in case of any questions in relation to the use of personal data, and GN Store Nord A/S can be contacted by using the contact links above.

You are also free to assert your rights by contacting any of the involved GN Group Companies listed in section 8 (Joint use by the GN Group). In case you do so, GN Store Nord A/S and the company in question will coordinate in order to respond to your inquiry and to guarantee your rights as a data subject.

With regard to the joint processes, We jointly determine the purposes and means of processing personal data. In an agreement on joint controllership the involved GN Group companies have determined how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations. In particular We have determined how an appropriate level of security and your rights as a data subject can be ensured, how the information duties under data protection law can be fulfilled jointly and how potential data protection incidents can be monitored. This also includes ensuring that reporting and notification obligations are fulfilled.

2. The Jabra Enhance and this Privacy Policy.

By activating and using the Jabra Enhance, you will be allowing Us to access and use your personal data, incl. personal data related to your hearing enhancement via the mobile App.

This Privacy Policy explains what personal data will be collected, how it is used and why.

3. The data We use and why We use it.

Depending on your privacy choices, We collect and use your personal data for the purposes as stated below.

For the purposes as stated below, We may collect your sensitive personal data, i.e. health data. We protect your personal data in accordance with applicable security requirements. However, in the event that your personal data despite all reasonable efforts would be exposed to disclosure or misuse, this may lead to e.g. mental stress which deserve your special attention prior to providing Us with your consent to process your personal data.

We will acquire and handle your personal data only to the extent necessary for the achievement of the purposes of use specified in advance and in accordance with applicable data protection principles.

A. Basic Functionality Services

We use the following data in order for Us to be able to deliver the Jabra Enhance and to provide you with customer services (shipping and communication about such matters as support, repair, software updates, software updates and legal/technical information, etc.) and to allow you to operate the Jabra Enhance:

· Your name, email and physical address; (to the extent provided by you)

· Your personalization profile used in Jabra Enhance, i.e. your hearing enhancement data;

· Your age and gender (Jabra Enhance may be used without you providing your gender).

· Jabra device and app information, such as the serial number, device identification number, settings and software version of the app;

· Information about mobile device used, such as settings, type of operation system, browser settings and browser language, internet protocol;

· Technical system activity information about the use of Jabra Enhance features, e.g. details of the use, settings, events (crashes and similar), capacity and performance of the app and the device;

· Information about the level of noise in your sound environment (noise, quiet, speech in noise).

We only use your personal data for the Basic Functionality Services when applicable national data protection legislation allows us to.

To the extent use of your personal data is governed by European Union or equivalent national law you are hereby informed that the legal basis for use of information such as your contact data and technical information for the Basic Functionality Services is our legitimate interest (Article 6.1. (f) of the General Data Protection Regulation (EU) 2016/679 (GDPR). It is in our legitimate interest to process data as specified above for the purposes of providing you with a high-quality experience. We minimise your data to the extent feasible and we need to use the data to allow for the Jabra Enhance to function efficiently and to provide you with customer services.

The use of Jabra Enhance, especially your personalisation profile may reflect health data. Our legal basis for using your health data is your consent. To the extent use of your personal data is governed by European Union or equivalent national law, you are hereby informed that the legal basis for use of your health data is your consent (Article 9.2.(a) of GDPR.

Your consent for the Basic Functionality is mandatory. The Basic Functionality is not able to function without your consent and if you choose to withdraw the consent at a later stage, you will not be able to use the Jabra Enhance Services.

B. Personalised Notification Services

If you choose to activate the Personalised Notification Services, your personal data is matched with models based on use patterns in order to provide you with various personalised notifications. The personalised notifications will be provided to you through messages in the app. Based on your usage of the Jabra Enhance it could be recommendations on how to use your Jabra Enhance, to contact professionals concerning your hearing enhancement, advantages or offerings in other products and services from the Company. In more detail We use data such as:

· Your name (if provided by you);

· The serial number, identification number of the device for identification;

· Age and gender (gender only if provided by you);

· Your Personalization profile used in Jabra Enhance, i.e. your hearing enhancement data;

· Service and support requests and history;

· Jabra device and app information, such as the serial number, device identification number, settings and software version of the app;

· Information about mobile device used, such as settings, type of operation system, browser settings and browser language, internet protocol;

· Technical system activity information about the use of Jabra Enhance features, e.g. details of the use, settings, events (crashes and similar), capacity and performance of the app and the device;

· Information about the level of noise in your sound environment (noise, quiet, speech in noise).

We only use your personal data for the Personalised Notification Services when applicable national data protection law allows us to.

To the extent use of your personal data is governed by European Union or equivalent national law you are hereby informed that the legal basis for use of information such as your contact data and technical information for the Personalised Notification Services is our legitimate interest (Article 6.1. (f) of the GDPR). It is in our legitimate interest to process data as specified above for the purposes of providing you with a high-quality experience. We minimise your data to the extent feasible and the used data is necessary to provide the Personalised Notification Services.

The use of Jabra Enhance, especially your personalisation profile may reflect health data. Our legal basis for using your health data is your consent. To the extent use of your personal data is governed by European Union or equivalent national personal data regulation you are hereby informed that the legal basis for use of health data is your consent (Article 9.2.(a) of the GDPR).

Your consent for the Personalised Notifications is NOT required in order for the Jabra Enhance to function. Your consent is completely voluntary, and you can still use the Jabra Enhance without accepting this.

C. Marketing Information Services

If you choose to activate our Marketing Information Services We use your name and email to send you newsletters and other marketing information through messages in your app and on email. The marketing information will be about products and services from the GN Group. See more above about the GN Group here www.gn.com

Our legal basis under the Marketing Information Services is your consent. To the extent use of your personal data is governed by European Union or equivalent national law you are hereby informed that the legal basis for such use for the Marketing Information Services is your explicit consent (Article 6.1.(a) of GDPR).

Your consent for the Marketing Information Services is NOT required in order for the Jabra Enhance to function. Your consent is completely voluntary, and you can still use the Jabra Enhance without accepting this.

D. Improving products and services

We use all data collected to improve our services and/or goods where permitted under applicable law.

We may process the data We collect from your ratings and reviews to respond to your comments and questions to understand how you regard the Jabra Enhance in general. We may use your ratings and reviews data to improve the functions of our product and the app. We can only see your app store username, ratings, comments and anything you choose to share with Us or make public. We do not link the ratings and reviews data to your account. However, We may 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. We may collect personal data including your basic public profile (name, gender, profile image and profile address) and email for authentication purposes.

To the extent use of your personal data is governed by European Union or equivalent national personal data law you are hereby informed that the legal basis for such use of ratings, reviews or improvement of services is based on our legitimate interest (Article 6.1. (f) of the GDPR). We minimise your data to the extent feasible and We need the data to allow Us to better understand how our products and services are perceived by our customers.

Further a copy of the personal data we collect about you under A-D above is executed by Us and anonymised. The anonymisation is carried out in accordance with acknowledged techniques and standards for anonymization. Once the data has gone through the anonymisation process, the data is no longer considered personally identifiable. Such anonymised data is used by Us to understand the use of the Jabra Enhance, the market and to develop and improve our products and services.

E. Other

We carry out works related to the purposes of A through D above as permitted by applicable laws and regulations.

Otherwise, the personal data specified above will be processed and used solely for the purposes included herein and only to the extent necessary to fulfil these purposes, except where required or permitted by applicable legislation, regulations, public authorities, court orders.

4. Settings on your mobile device

The Jabra Enhance requires you to permit connection from your Jabra device to the app. You can block this connection through settings on your mobile device at any time. If you block your connection your Jabra Enhance will still be able to be fully functionable in case the personalisation process has been completed. If you block your connection before having completed your personalisation process the Jabra Enhance will not be able to function.

The Jabra Enhance encourages you to permit notifications to receive notifications about firmware updates etc. You can block this through settings on your mobile device at any time.

5. How do I withdraw my consent(s)?

You can withdraw your consent(s) free of charge, at any time. You can withdraw your consents to the Basic Functionality Services and the Personalised Notification Services by going to “Privacy policy/consents” in the “About” section in the app to notify us. You can withdraw your consent to the Marketing Information Services, by clicking the “unsubscribe”-link at the bottom of the emails you receive from Us. Alternatively, you can contact our DPO by using the contact information under section 1 above. We will apply your preferences once we receive your notification, but please note that this will not affect the lawfulness of any processing that has taken place prior to us receiving such notice.

If you withdraw your consent for the Basic Functionality Services, the Jabra Enhance will reset the information on your devices and in your App, i.e. the Jabra Enhance will cease to function from the time the consent has been withdrawn, and we will no longer receive or process your personal data as outlined in this Privacy Policy.

If you withdraw your consent provided in relation to our Personalised Notifications, we will stop processing the specific personal data for the purposes covered by the consent as set out in the part describing the Personalised Notification Services from the time the consent has been withdrawn, but the Jabra Enhance will otherwise continue unaffected.

If you withdraw your consent provided in relation to our Marketing Information Services, we will stop processing the specific personal data for the purposes covered by the consent as set out in the part describing the Marketing Information Services from the time the consent has been withdrawn, but the Jabra Enhance will otherwise continue unaffected.

6. What if I just uninstall the app?

If you just uninstall the app, this will stop all future collection of personal data by us through the app, but We may still process personal data that was already collected via the app. If you wish to withdraw your consent to us doing this, please follow the steps set out in the paragraph above. You may uninstall the app by using the standard uninstall processes available on your mobile device or via the mobile app marketplace or network.

7. What other rights do I have?

In the European Union and equivalent national personal data law, depending on the circumstances, you may have certain other rights over your personal data.

You may have the right to request access to the personal data held by us. This includes requesting details of the relevant personal data and the purposes and potential recipients. In addition, you may request to have such personal data rectified, deleted or the processing thereof restricted; or you may object to the processing of your personal data, or request a copy of your personal data in a standardised format so that it can be provided to another app provider. You also have a right to receive a copy of this privacy policy.

We will verify and respond to your request in a manner consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as email address, mailing address, or telephone number in order to verify your identity and protect against fraudulent requests.

To exercise these rights, where they apply to you, please contact us using the contact information provided in section 1above.

Please be aware that you may also have the right to lodge a complaint 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.

8. Joint Use by the GN Group

GN Hearing A/S is a 100% owned subsidiary of GN Store Nord A/S and is a part the GN Group. In order for Us to provide the Jabra Enhance Services and fulfil the purposes specified above, we share personal information with relevant companies within the GN Group. The GN Group's solutions are marketed under the brands ReSound, Beltone, Interton, Jabra, BlueParrott and FalCom. The GN Group markets – besides the Jabra Enhance - products such as: Smart hearing aids, headsets and speaker and video devices. You can find more information about the GN Group here: www.gn.com

We use the following categories of the personal data among the following joint controllers within the GN Group for the listed purposes:

9. Which third parties will have access to my personal data?

In order for us to provide the Jabra Enhance and fulfil the purposes specified above, We share your personal information with certain suppliers.

Some of these suppliers such as IT and cloud provides providing e.g. hosting and back up services are only processing personal data behalf of GN and may only process your personal data in accordance with the instructions given by GN and in compliance with this privacy policy and 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 third parties who may use your personal data for their own purposes, such disclosure or transfer will only take place if it is done in accordance with applicable law and/or with prior consent obtained from you. If you have purchased your product on our website we share your contact information and product specification with (a) packaging and shipping companies for packaging, shipping and receipt of returned products and (b) with payment handling companies for processing your payment.

By using the Jabra Enhance and by providing your consent you acknowledge that your personal information is shared as described here.

In case we provide your personal information to a third party and are legally obligated to create a record of such provision to a third party, we will comply with such obligation.

10. International transfers

In some cases We will be transferring personal data to recipients identified 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 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 1 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.

By using the Jabra Enhance and by providing your consent you acknowledge that your personal information is transferred as described here.

11. How long will you store my personal data?

Your personal data will be stored by Us for as long as necessary in order to fulfil the purposes described above in this form and comply with minimum retention periods under applicable data protection laws. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised 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, regulatory, tax, accounting or other requirements.

12. What if I’m under the age of 18?

By using the Jabra Enhance Services you confirm that you are, at a minimum, 18 years old.

13. Cookies

In case you make use of our customer support and thus are directed to our website or in any other ways navigate to our websites, we will collect cookies about you in accordance with your cookie choices. Reference is made to our cookie banners and cookie policies available on our websites.

14. Additional information for California Residents.

In addition to the information stated above the following information also applies to you If you are a California resident. California Civil Code Section 1798.83 permits you to request and obtain from Us once a year, free of charge, information about the personal data (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

We do not sell and have not sold personal information in the preceding 12 months. We do not sell the personal data of minors.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.