The Purpose for collecting and using your personal data, including health information, is to carry out your hearing healthcare treatment and to provide you with our services, support and products.
2.1. When you give us your explicit consent[1], we will process the categories of personal data set out below, including your health information, to:
- Administer our relationship with you. This includes contacting you regarding appointments, responding to your enquiries and following up on your treatment. In some situations, we may also be required by law to register and maintain client records with information that is relevant for your treatment. This includes, for example, traceability requirements pursuant to the EU/UK Medical Device Regulation.
For this purpose, we will process your name, title, address, telephone number, email, date of birth, customer URN, information about your hearing and technical information about your hearing device. This includes test results/audiograms, electronic media of tympanic membrane (eardrum) and ear canal treatment plans, health insurance details, records of your visits to our clinics and the support and services you have received from us, unique serial number and fitting settings.
- Provide support and repair services. This includes troubleshooting and monitoring how your hearing device is performing (typically in the form of error logs) and to update the software and firmware of your hearing device.
For this, we will process your name, title, address, telephone number, email, date of birth, information about your hearing and technical information about your hearing device. This includes test results/audiograms, electronic media of tympanic membrane (eardrum) and ear canal, treatment plans, records of your visits to our clinics and the support and services you have received from us, unique serial number, fitting settings and possible error logs detailing your personal user experience of the errors.
- Provide you with marketing communication. If you have expressed an interest in receiving marketing communication, we will send you newsletters or recommend products and services we think you will be interested in via email, text message (SMS), telephone and/or physical mail. For electronic means, we will only do this if you have given your consent to this, or if it is otherwise permitted under the applicable direct marketing rules in your country.
We also check your contact information against lists which we receive from third party service providers, or from public sources such as the electoral roll, to make sure that we have recorded your contact details correctly. This helps us to keep our records up to date and ensure that we can provide you with relevant information and services.
For this, we will process your name, email, telephone number and/or postal address.
- Improve our products and services. This includes, for example, analysis of your use of our products and services, together with specific feedback, based on which we can improve and develop new products and services. In some situations, this may be carried out using aggregated/anonymised information.
For this, we will process your title, address, date of birth, information about your hearing and technical information about your hearing device. This includes test results/audiograms, electronic media of tympanic membrane (eardrum) and ear canal, treatment plans, records of your visits to our clinics and the support and services you have received from us, unique serial number, fitting settings and possible error logs detailing your personal user experience of the errors.
- Your consent to the above is voluntary, and you can withdraw your consent at any time by contacting us at the contact point listed above. If you withdraw your consent, this may affect our ability to provide you with our hearing healthcare products and services. Withdrawal of consent will only have a future effect and our use of your personal data before you withdraw your consent will not be affected.
2.2. When you place an order for one of our hearing device products, we will need to process your personal data on the basis of our contractual relationship with you[2] in order to:
- Provide you with hearing device products. This includes delivering hearing devices and accessories, and shipping, order and payment processing as well as related invoicing.
For this, we will process your name, title, address, telephone number, email and payment details and purchase history.
2.3. In the legitimate interest of ensuring and improving the user experience of our customers, we will process your personal data to:
- Analyse trends and profiles and target marketing activities. This includes modifying, personalising and improving our services and communications for the benefit of our customers, including target marketing activities. We use social media and advertising tools provided by social media providers to find relevant audiences. We target our advertising activities on social media to social media users that we regard as previous, current or future prospects and customers, including social media users that, based on our knowledge on customer trends, likely correspond to our potential, relevant audiences.
For this, we will process your name, title, address, telephone number, email, date of birth, purchase history and information about your preferences.
[1] GDPR Art. 6(1) (a)
[2] GDPR Art. 6(1) (b)