Privacy Notice For Customers

PRIVACY NOTICE

Last updated: 01/10/2024

The processing of your personal data complies, according to your country, with local data protection requirements, including the revised Swiss Federal Data Protection Act (“FDPA”), the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR"), and / or, as may be applicable, the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") for your personal data qualified as Protected Health Information.

This Privacy Notice may be updated from time to time. In this case, we will inform you that this Privacy Notice has been modified and the “last updated” date on top of this document will be modified. We recommend that you periodically review the latest version of this Privacy Notice.

1. Who we are

Depending on your country of residence, the local affiliate of Sonova Consumer Hearing (“Sonova”) and the local distributor from whom you are purchasing the product or service may act as either independent Data Controllers or Joint Controllers.

2. Personal data we collect from you and why

Sonova and your local distributor act as joint controllers for the following processing of personal data:

1. To fulfill your purchase request and complete your order. This activity is conducted in accordance with our terms and conditions and is based on the legal basis of performance of the contract.
2. To provide customer service support and address your inquiries or issues. This processing activity is based on the performance of the contract in response to your request and our legitimate interest in effectively supporting our customers.
3. To prevent fraudulent activity and improve security. Depending on applicable laws, this activity may be based on a legal obligation or on our legitimate interest to maintain trust and the integrity of our services and products.

Sonova will act as independent Data Controller if you choose to create an account and provide your consent to receive marketing communications and newsletters. For details on this processing of personal data, please refer to the relevant privacy notice provided when creating an account or giving consent.

For activities not performed or managed by Sonova, your local distributor may act as an independent Data Controller and is solely responsible for the processing of personal data in accordance with its own privacy notice.

3. How we share your personal data

We may share your personal data based on your consent and/or on a relevant legal basis, with the following third parties:

• Business partners providing services on our behalf, such as for technical support, for marketing purposes or for other types of services delivery .
• Governmental authorities and public authorities, as far as this is necessary to provide any services that have been requested or authorized, to protect Data Subjects’ 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 Laws, court or other governmental regulations, or if such disclosure is otherwise necessary in support of any legal or criminal investigation or legal proceeding.
• Individuals authorized by the Data Subject or by Applicable Laws to participate in the Data Subject’s care, including family, close friends or others.

Depending on Applicable Laws, we implement contracts with some third parties to ensure that Personal Data is processed based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.

Before we disclose any personal data to other third parties than those listed above, we will explicitly ask you for your consent. However, if we are obliged to disclose personal data without your consent, we will only disclose personal data that are strictly necessary for that purpose to fulfil our legal obligations.

4. International personal data transfers

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.

5. How long we keep your 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, we may retain personal data longer if required by any applicable laws to protect or exercise our rights, to the extent permitted.

At the end of the retention period, we may also need to archive personal data, to comply with applicable laws, for a limited period of time and with limited access.

These retention periods may vary depending on the country where you reside and in accordance with applicable laws.

6. Your legal rights

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. According to your country, you may have other rights such as providing instructions for how your personal data should be processed posthumously. Under HIPAA you may also have the right to request an accounting of disclosures of your personal data, and the right to receive a paper copy of this notice upon written request.

Please note that the exercise of such rights is subject to the limitations provided by applicable law.

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.

7. How to contact us

In the event of questions about this Privacy Notice, or the processing of your Personal Data, please contact our Data Privacy Team at privacy@sonova.com and the distributor privacy team at privacysennheiser@imsindo.co.id.