As part of our shared values of innovation, engagement and responsibility, at the Sonova Group; that is, Sonova Holding AG and all of its affiliates and subsidiaries and employees, officers and agents (“Sonova” or “We”), We respect the privacy of all persons who have entrusted us with their Personal Data, including visitors to our websites, and users of our applications etc. This Data Protection Statement (“Statement”) sets out the steps we have taken to meet data protection requirements under Swiss, EU and other applicable laws which regulate the collection, storage, use transfer and disclosure (“process/processing”) of Personal Data.
We consider this to be Personal Data: any information from which someone can or could find out your identity, such as:
- your name, your address, email address, serial number of a device, social security number and the like;
- information about your circumstances including employment status and history, cultural and linguistic background, health and welfare, disabilities and family circumstances;
- information about your family and other related persons such as partners, children and carers; and
- information about you to verify your identity and administer records including healthcare identifiers and tax file numbers.
This Statement describes the ways in which we process the Personal Data we obtain from you through a website or application that is owned or operated by Sonova. This Statement applies to Personal Data collected by Sonova, such as through a website, in clinic, through e-mail and other online tools and applications.
Please note that the information or services provided here by Sonova are directed at adults only and not at children under the age of 16. We do not knowingly collect Personal Data from anyone under the age of 16. Any person who provides their Personal Data to us represents that they are 16 years of age or older. If you learn that your child has provided us with Personal Data without your consent, you may alert us as described in the “How to contact us” section below. If we learn that we have collected any Personal Data from children under the age of 16, we will promptly take steps to delete such information and delete the child’s profile.
Consent to Collection etc.
We generally collect and process your Personal Data to be able to provide you with the services, products and information you request, to perform actions in connection with a contract we have with you, or because of our legitimate interest to conduct certain analyses and statistics, such as to improve our products and services and the content of our websites and applications and for administrative purposes.
In some instances, we may additionally ask for and will need your specific consent for collecting and using your Personal Data, especially in connection with sending you marketing materials or newsletters regarding our products and services.
Use of Our Online Portal
As part of your service offering, we offer an online portal that contains several hearing and related tests which you can complete (Online Tests). You will also be able to view your results from the Online Tests you complete and other Personal Data within the online portal.
We collect, store and use your Personal Data in order to provide you the services you elect to receive from us and for the other purposes set out in this Policy.
If you refuse to grant us consent to collect and use your Personal Data
If you do not provide the personal information requested:
- we may not be able to provide you with our services or products; and
- the quality of the services or products provided to you may be lesser than if you had provided all of the information requested; and
- the risk of adverse consequences from our provision of services and goods may be increased. We are not liable to you for any adverse consequences resulting from your failure to provide accurate personal and health information.
Update to this Statement
We may from time to time decide to update this Statement as necessary. In this case, we will post updated versions of this Statement on this page. A revised Statement will apply only to data collected subsequent to its effective date. We encourage you periodically to review this page for the latest information on our privacy practices. Your continued use of our services following the posting of changes to the Statement will mean you accept those changes.
What Personal Data do we collect about you?
How do we use your Personal Data?
We may use your Personal Data only as described in this Statement, to provide you with our services, to respond to your requests and to the extent as otherwise permitted or required by applicable laws, or in support of any legal or criminal investigation. We may further anonymise or pseudonymise and aggregate data collected for statistical purposes to help us improve our products and services. If you do not want to provide us with this information, please do not utilise these features on our websites or applications.
With whom do we share your Personal Data?
We only share, or otherwise disclose, your Personal Data to our subsidiaries, affiliated companies or other trusted business partners providing services on our behalf, such as for technical support, to evaluate the usefulness of our websites and applications, for marketing purposes (if we have your consent), or for other types of service delivery. We further may share your Personal Data via cookies with advertising networks, to the extent we have your consent. We have contracts in place with these parties to ensure that Personal Data are processed based on our instructions and in compliance with this Statement and any other appropriate confidentiality and security measures.
We will usually disclose your personal information to other entities in the following circumstances:
- to health care providers involved in the provision of health services to you;
- to our suppliers (who are located overseas in Switzerland, Vietnam and China but may be located elsewhere from time to time) if you order a product from us; and
- to government authorities in relation to government programs, such as the Hearing Services Program.
We only share your Personal Data with these parties and other third parties mentioned above, including governmental authorities, as far as necessary to provide any services that you have requested or authorised, to protect your, our, or others’ rights, property or safety, to maintain the security of our services or if we are required to do so because of applicable laws, court or other governmental regulations, or if such disclosure is otherwise necessary in support of any legal or criminal investigation or legal proceedings.
Please note that the above-mentioned Sonova affiliates and subsidiaries, as well as authorities, customers and suppliers to whom we may disclose your Personal Data, may be located outside of your country of domicile, potentially including countries such as the United States, whose data protection laws may differ from those in the country in which you are located. In such cases, we will ensure that appropriate safeguards are in place to protect your Personal Data by implementing appropriate legal mechanisms, such as EU Standard Contractual Clauses.
In order to provide you with the highest level of service, we may share your Personal Data, including data collected in the course of your completion of any Online Tests, with our clinical or other staff. This may include accessing, downloading or transferring your Online Test information and results to a member of our staff so that they may deliver any of our services to you.
Sonova is committed to contributing to continuously improving understanding of hearing healthcare and hearing aids, and improving our products and services. To this end, Sonova performs internal research and is involved in research with universities and other third-party organisations or individuals (Research Organisations). Information related to you (but always fully de-identified) may be used by Sonova for these purposes.
This research involves the collation and analysis of (de-identified and non-personal) data collected from our clinics, centres and online (including our online portal). For example, this may include data collected during assessments performed by our clinical staff or from your participation in Online Tests. The research may be presented in journals, conferences, patents or other publications.
Sonova only discloses such de-identified and non-personal data to Research Organisations or in publications. You will not be able to be identified from that data. We and the Research Organisations are bound by confidentiality and privacy laws. Our contracts with Research Organisations contain legally binding provisions to protect your privacy.
How do we protect your Personal Data?
We have implemented a variety of security measures to protect your Personal Data from unauthorised access, use and disclosure. These follow technical and organisational measures generally accepted as appropriate security standards in the industry, including access controls, password, encryption, regular security assessments, and the like.
How long do we store your Personal Data?
We will store your Personal Data as long as required to fulfill the purposes outlined in this Statement, unless a longer or shorter retention period is required or permitted by applicable law.
When no longer required, We archive Personal Data in a secure manner.
How may you access control or delete your Personal Data?
You have the right to know and inquire what Personal Data We hold about you and to request the correction or deletion of your Personal Data held by us or by a third party with whom We conduct business. In addition, you have the right to object to or to request the restriction of the processing of your Personal Data and you may contact your local data protection authority and file a complaint regarding the processing of your Personal Data.
You may also contact us if you need to update your Personal Data. Our contact details are below.
If you would like to make such a request, please contact us as described in the section “How to contact us” below. After you have provided satisfactory proof of identity, We will respond within a reasonable time.
Cookies and Usage Tracking
Cookies allow us to store information, such as your domain name, your internet service provider, your operating system, the date and time of access, the pages you visit or the types of searches you perform. We collect such data, for example, to conduct system administration and report aggregated information to affiliates, business partners and/or vendors who conduct website and application analyses and website performance reviews on our behalf.
We use this information to store your preferences and settings, help improve the contents of our websites or applications, to enable you to register to websites and applications and to compile aggregated statistics to evaluate visitors’ use of our website or website activity, and for internal and market research purposes.
We apply cookies on our Website. Cookies are small files stored by most internet browsers to track visitor information and enable Sonova to make its web-offering more relevant to you. This happens by Cookies providing information on your browser settings, location, type of device used to access the website, etc. Also Cookies can provide insight into which other websites you may have visited, which again can be beneficial to refine the content you can see on a Sonova website. Through Cookies Sonova may also learn about your browsing preferences, and also which products you are interested in. Whilst Cookies in principle do not directly identify you, Sonova may be able to associate your previous website behavior once you register with your details on a Sonova website.
If you are not interested in the advantages of our Cookies, the ‘Help’ function of your browser can provide instructions on how to prevent Cookies or delete existing Cookies. Also, you can learn how to block all new Cookies on your browser and which configuration steps are required to receive a notification about new Cookies. Very helpful information on Cookies in general can be accessed on http://www.allaboutcookies.org/.
Social Media Plugins
Social media plugins are a part of certain webpages of Sonova and exist for social media providers (“Provider”) such as Facebook, Instagram, Twitter, LinkedIn, Google+, and Youtube. When you visit a page by clicking such a plugin your browser will connect to the respective social media server. At the same time the Provider will know that you visited our website prior to landing on the social media site. If you are registered and have logged in with the Provider concerned, your visit can also be linked to your user account. The Providers in general do not provide specific information about which data is transmitted in the use of their social plugins. We therefore have no definitive ability to verify the content and scope of the transmitted data or its use by such Providers, for further information about this please consult the data protection stipulations of the relevant Provider. If you do not wish a Provider to collect data on you through our website, please deactivate the plugins in your web browser. If you wish to avoid a link to any existing user account, you must log out of the social media webpage before your visit to our website.
On some of our websites or applications, We offer interactive features, such as blogs, messages board, or newsfeeds. If you make any contributions to such features, please be aware that these contributions may be viewed by others and that these contributions will be neither private nor confidential.
If you wish to complain about how we’ve handled your Personal Data, please contact us as per the below.
We will use the information from your feedback to investigate and resolve individual issues and to provide feedback to our staff or business areas. Your information will be stored and uses to help us improve the delivery of our services.
If We do not resolve your complaint to your satisfaction, you may contact the Office of the Australian Information Commissioner. The OAIC is independent from us.
How to Contact Us
If you have any questions, comments, or concerns about this Statement, or want to request access to your Personal Data or exercise your privacy rights, please contact us using the contact information below. You may also reach out to our Data Protection Officer at firstname.lastname@example.org.
Thank you for your interest in Sonova!
8712 Stäfa, Switzerland
Phone: +41 58 928 0101