Privacy Notice For Customers
Sonova Consumer Hearing GmbH - Privacy Notice For Customers
A. GENERAL INFORMATION
This Privacy Notice describes how Sonova Consumer Hearing GmbH (hereinafter referred to as "Sonova"), acting as Data Controller processes the personal data of its customers.
Sonova is subject to the provisions of the European General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), the German Telemedia Act (TMG) and the German Telecommunications Telemedia Data Protection Act (TTDSG) and has taken appropriate technical and organizational measures to ensure that the regulations on data protection are observed.
B. PERSONAL DATA COLLECTED
The Company may process the following Personal Data:
- Identity data: last name, first name, nationality and date of birth
- Contact details data: postal address, private phone number, private email address
- Social security reference number and insurance company
- Financial data: means of payment, financial institution, IBAN
- Data relating to the service provided
- Data relating to the feedback the customer provides on our products and services: comments and notes
C. PURPOSES OF PROCESSING PERSONAL DATA
The following legal bases constitute the foundation on which the Company relies to carry out the processing of Personal Data. Other legal bases may be used depending on where the Data Subject resides and the relevant Applicable Law.
C.1 PROCESSING BASED ON CONSENT
Some processing of Personal Data may be based on your free consent of Data Subjects. The processing of Personal Data for this purpose may involve:
Profiling to send updates on services designed and tailored by us for you, based on your experience, interests or preferences.
C.2 PROCESSING BASED ON A CONTRACT
The processing of Personal Data that the Company carries out may also be based on the execution of a contract. The processing of Personal Data for this purpose may involve:
- To advise and interact with you when you contact us
- Fulfillment of our contractual obligations towards Data Subjects
- Provision of after-sales service after the purchase of a product by a customer
- Claims management
C.3 PROCESSING BASED ON LEGITIMATE INTEREST
The Company may also process Personal Data based on its legitimate interest, in particular in order to improve our products and services, customer experience and internal processes. The processing of Personal Data for this purpose may involve:
- Marketing purposes such as sending newsletters and information about products and services, promotional propositions offered by the Company
- Conducting statistical/usage analysis
- Performing internal administrative functions
- Prevent fraudulent activity and improve security
- Evaluation of the relevance of our products and services
C.4 PROCESSING BASED ON OTHER BASES
The Company may also process Personal Data in order to respond to legal requirements. Processing based on legal requirement depends on the Applicable law.
D. RETENTION OF PERSONAL DATA
Personal Data will not be kept longer than necessary for the above-mentioned purposes. This means that Personal Data will be deleted as soon as the purpose of the processing of Personal Data has been achieved. However, the Company may retain Personal Data longer if necessary to comply with Applicable Law, or if necessary to protect or exercise our rights, to the extent permitted by applicable data protection law.
At the end of the retention period, the Company may also need to archive Personal Data, to comply with Applicable Law, for a limited period of time and with limited access.
These retention periods may vary depending on the country where the Data Subjects reside and in accordance with Applicable Law.
E. DISCLOSURE OF PERSONAL DATA
The Company may share Personal Data, subject to your consent or other relevant legal basis, with the following third-parties:
- Other companies of our group such as subsidiaries and affiliated companies
- Trusted business partners providing services on our behalf, such as for technical support, for marketing purposes or for other types of service delivery
- Governmental authorities and public authorities, as far as this is necessary to provide any services that have been requested or authorized, to protect customers, contractor and partners’ rights, or 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 Law, court or other governmental regulations, or if such disclosure is otherwise necessary in support of any legal or criminal investigation or legal proceeding
Depending on Applicable Law, we implement contracts with some third-parties to ensure that Personal Data are processed based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
F. TRANSFERS OF PERSONAL DATA
Please note that some of the above-mentioned third parties can be located outside your country. Therefore, your personal data may be transferred to countries that do not provide the same level of protection of personal data as your own country. In such cases, we will implement adequate measures including appropriate organizational, technical and legal safeguards in order to govern the relevant transfer and to ensure the necessary level of protection is established under applicable law.
G. PRIVACY RIGHTS RELATED TO PERSONAL DATA
As per applicable law, you may have the right to request access, rectification, erasure of your personal data, or restriction of processing. In addition, you may object to the processing, request data portability and withdraw your consent at any time.
You can exercise your rights by contacting us at firstname.lastname@example.org.
Please note that the exercise of such rights is subject to the limitations provided by applicable law.
In addition, if you consider that the processing of your personal data infringes applicable law then you may also lodge a complaint with the local supervisory authority or the competent regulator. The contact details are:
The State Commissioner for Data Protection Lower Saxony
Prinzenstrasse 5, 30159 Hanover
Telephone + 49 (0) 511 120 4500
I. HOW TO CONTACT US
Sonova's data protection officer:
Laubisruetistrasse 2, CH-8712 Stäfa, Schweiz