Privacy

EFFECTIVE 1st May 2023

INTRODUCTION

At Hearlogic, we value your business and respect your privacy. We are committed to protecting your privacy rights in accordance with the privacy and data protection laws that may apply to you, including the CCPA and the General Data Protection Regulation (GDPR).

This privacy policy describes your privacy rights related to information that you share with Hearlogic, and how you contact us to exercise those rights. In addition, this privacy policy describes how Hearlogic collects, uses and shares information that can identify you (Personal Information) related to the use of Hearlogic’s Products and Services. Products and Services means our websites, e-store, mobile apps, software applications, hearing devices and hearing care providers. Hearlogic will collect, process and share your Personal Information in accordance with this privacy policy.

WHO WE ARE

In this privacy policy, “Hearlogic”, “we”, “us” and “our” refers to the Hearlogic entity that you are interacting with, or that is providing you with our Products and Services related to which you are sharing your Personal Information.

With respect to your rights under applicable privacy laws, the data controller of your Personal Information is Hearlogic.

You can contact Hearlogic’s Data Protection Officer at:

Hearlogic
William F Austin House
Bramhall Technology Park, Pepper Road, Hazel Grove, Stockport SK7 5BX

WHAT PERSONAL INFORMATION HEARLOGIC COLLECTS AND WHEN

Hearlogic collects the following information, including Personal Information, when you interact with us and use our Products and Services:

Website Information: means information that you enter directly or otherwise provide or disclose, including Personal Information, when you use or access any of our websites. Website Information includes information about the technology that you used to access our website, including the IP address, Internet service provider, browsers, apps and devices. Website Information also includes details of your activities while on our websites, like how long you visited a webpage, the content that you clicked on or accessed and information about other sites that you visited before or after our website. Website Information includes anything that you submitted via the website like a webform to “contact us”, the content of any “chat” communications you have with us through our websites.

Health and Patient Information: means information collected from you when you request an appointment, including your name and contact information, like telephone number or email address, as well as information about your hearing care needs, including health information, and your preferences for how we contact you. 

Communications Information: means information that you provide while communicating with Hearlogic, in any way, for any reason, which may include Personal Information. Communications Information includes the information that you provide over the phone, which may include your name, phone number, address, email address, device serial number as well as the content of any phone calls you have with us.

Your Information Shared by a Third Party Who You Authorised: means your Personal Information that is provided to us by a third party, because you authorised the third party to share it. For example, you may authorise your hearing care provider to share your Personal Information with Hearlogic, which may include your contact information, financial information and health information. We also collect Personal Information about you through websites that we manage for third parties, like a third-party hearing care provider.

Anonymous Information: means information that does not allow you to be identified or otherwise make you identifiable. For example, we collect generic information about the type of mobile device and mobile operating system that you use to access and interact with our Products and Services, as well as generic information about your hearing aid devices, like the make and model, and the firmware used by the hearing aid devices. In some cases, Hearlogic may aggregate and de-identify data to remove all information that could be used to specifically identify you, thereby rendering it anonymous. Anonymous Information is not considered Personal Information in this privacy policy, or by applicable law.

Why we Collect Personal Information

We collect your Personal Information because it is necessary to provide the services, features or functionality of our Products and Services that you have elected to use. Hearlogic also collects your Personal Information for legitimate business purposes, to protect Hearlogic and its customers, and for legal reasons. We only collect and process your Personal Information based on our legitimate interests when we have determined that our legitimate interests are not outweighed by your privacy and data protection rights.

Depending on your interaction with Hearlogic, and your use of our Products and Services, Hearlogic may collect your Personal Information for the following reasons:

providing you with access to and use of our Products and Services, either independently or with the assistance of your healthcare provider;

operating, maintaining and improving our Products and Services;

entering, performing and terminating a contract with you;

scheduling and communicating with you about your appointment;

sending you important administrative notifications or confirmations, as well as technical notices about things like updates and security alerts;

responding to your comments and questions and providing you with customer support;

preventing abuse of our Products and Services, and investigating or prosecuting any potential threat or misuse;

to protect, investigate and deter against fraudulent, unauthorised or illegal activity;

protecting the rights and property of Hearlogic and its customers, including in the event of legal claims

tracking and analysing our advertising and promotional efforts;

sending you marketing or promotional communications that may be based on your behaviour and Personal Information, and that may include social notifications, surveys or other newsletters depending on your settings; and

fulfilling any purpose for which you have given us your consent.

Some features of our websites allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via email. The email response or confirmation may include your Personal Information, including your name and contact information. We cannot guarantee that our emails to you will be secure from unauthorised interception.

When required by law, we will obtain your consent before sending you certain marketing communications. You can withdraw consent at any time by contacting our Data Protection Officer. See the Who We Are section of this privacy policy for details. You may also opt-out of receiving future marketing information, like marketing emails, at any time, by using the instructions provided in marketing communications.

HOW Hearlogic COLLECTS INFORMATION

You Give Hearlogic Information Indirectly (Collected Using Technology like Cookies)
We use tracking technology like cookies to collect information about how you use our Products and Services, and to provide you with essential services, functionality and personalisation of our Products and Services. The purpose of this section is to provide you with the necessary information regarding our use of cookies, and the storage of such cookies on your device when you access our websites, to enable you to choose whether to allow cookies to be placed on your device.

If you are located in the European Economic Area, please review our Cookie Policy for further information on how we use cookies and other related types of tracking technology.

Cookies are small text files that can be stored on your computer by a website that you visit. Cookies are widely used to make websites work, or work more efficiently, as well as to provide web services and functionalities for users.

Cookies may be either “persistent” or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser until its set expiry date (unless deleted by the user before the expiry date). A session cookie, or temporary cookie, will expire at the end of the user session, when the web browser is closed.

Web beacons are small files (also called “pixels”, “image tags” or “script tags”) that may be loaded on our websites, applications and tools, which may work in concert with cookies to identify our users and provide anonymised data about their activity.

Privacy laws in some jurisdictions require that we obtain your consent before cookies may be stored or accessed on your equipment, except that we do not need consent for cookies that are strictly necessary to provide our Products and Services.

Essential Cookies are necessary to provide you with core website functionality, personalisation and browsing history. For example, a preference cookie is required to maintain a record of your consent or non-consent preferences so that we may respect them for future visits. These can only be disabled by changing your browser preferences. Hearlogic does not share this information with third parties.

Functionality Cookies help us to customise our website content based on your preferences, to provide you with a more personal experience on our websites. The information that these cookies collect may be anonymised and does not include browsing activity on third-party websites.

Analytics Cookies are used to collect information about traffic to our websites and user activity on our websites. The information is aggregated and anonymous and does not identify any individual visitor. It includes the number of visitors to our websites, the pages visited and other similar information. We use this information to help operate, maintain and improve our websites.

Social Media Cookies. We allow users to share links to our websites on social media sites like Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work.

Disabling Cookies. Most web browsers allow the control of cookies through the browser settings. By adjusting your web browser, you may avoid receiving cookies. However, this might result in the website not functioning optimally. The method used to block cookies will depend on the web browser used. Consult the “Help” or corresponding menu in your web browser for instructions.

To find out more about cookies, including how to see which cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics visit tools.google.com/dlpage/gaoptout. We do not currently respond to Do Not Track signals sent by the browser.

You Authorise a Third Party to Give Hearlogic Your Information
You may authorise a third party, like your hearing care provider, to give Hearlogic information about you. For example, you may authorise your hearing care provider to provide your Personal Information to Hearlogic, which may include your contact information, financial information and health information. We also collect Personal Information about you through websites that we manage for third parties, like hearing care providers.

INTERNATIONAL DATA TRANSFER

Where allowed by applicable law, Hearlogic’s Products and Services may be delivered using servers and other technical resources in various countries, including the United States. Therefore, your Personal Information may be transferred and processed outside of the country you are located in, including outside of the European Economic Area (EEA). If we transfer Personal Information outside the country or region you are located in, we will take steps to protect and safeguard your Personal Information, in general, by making the transfer subject to the Standard Contractual Clauses approved by the European Commission, to ensure that your data is treated securely and in accordance with this privacy policy. For further details, please contact our Data Protection Officer.

HOW Hearlogic SHARES PERSONAL INFORMATION

External Processing. We may share your Personal Information with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure, email delivery and other similar services. We require that our third-party service providers use your Personal Information only to provide the services that we’ve requested based on our instructions and in compliance with our privacy policies and any other required confidentiality and security measures.

For Legal Reasons. We may share your Personal Information as we believe necessary or appropriate (a) to comply with applicable laws; (b) on reasonable request by a law enforcement or regulatory authority, body or agency; (c) in the conduct or defence of legal claims; (d) when obtaining professional advice (including legal advice) in relation to audits and our business and consider this in our legitimate interests in managing our business; (e) to enforce our agreements; and (f) to protect our rights, privacy, safety or property, or that of you or others. We will not delete Personal Information if it is relevant to an investigation or a dispute; relevant information will be stored until such issues are fully resolved.

New Owner of Our Business. We may share your Personal Information with a third party (new owner) in the case of a merger, acquisition, dissolution or sale of one or more of our business entities. In that case, we would also be sharing your Personal Information with that third-party’s advisors related to the transaction.

Affiliates. We may share your Personal Information with other companies owned by Hearlogic (Affiliates). Our Affiliates are bound to protect Personal Information in accordance with applicable privacy and data protection laws.

HOW HEARLOGIC SECURES INFORMATION WE COLLECT

Hearlogic works to secure the information that we collect, including by employing administrative and technical security measures to protect information from unauthorised access, loss, misuse, corruption, alteration and destruction. Hearlogic uses commercially accepted means to secure your Personal Information, including encryption, but we cannot guarantee its absolute security.

Please contact our Data Protection Officer immediately if you have reason to believe that your Personal Information or any of our Products and Services are not secure or have been accessed without authorisation. If you receive a communication that purports to be from Hearlogic that you believe is suspicious, do not open or respond to it, and please contact our Data Protection Officer.

YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are located in the European Economic Area, you have certain data protection rights under the GDPR. Depending on your interaction with Hearlogic and your use of our Products and Services, Hearlogic collects and processes your Personal Information on the following legal bases:

As necessary to enter into, perform or terminate a contract with you, and to provide you with, and facilitate your use of, our Products and Services.

Because you have provided consent.

As necessary to operate our business and pursue our legitimate business interests, where our interests are not overridden by your privacy and data protection rights.

To comply with the law.

Hearlogic takes reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information.

Opt-out. You can contact us any time to opt out of (a) promotional and marketing communications; (b) any new processing of your Personal Information that we may carry out beyond the original purpose; or (c) the cross-border transfer of your Personal Information. Please note that your use of some features of our Products and Services may be affected upon opt-out.

Object. You can ask us to stop using your Personal Information where we no longer need it to provide our Products and Services or for other legitimate reasons.

Access. You can ask us to confirm if we are processing your Personal Information and you can ask at any time to access the Personal Information that we have collected from you by contacting us directly.

Update. You can ask us to correct your Personal Information if it is wrong.

Move. You can request to move your Personal Information to other companies. You may ask that we provide your Personal Information in an easily readable format.

Erase and forget. In certain situations, you can ask us to stop using your Personal Information or delete your information, including where we no longer need it to provide our services to you.

If you wish to exercise any of these rights, please contact us at:

Hearlogic
Attn: Data Protection Officer
Bramhall Technology Park, Pepper Road, Hazel Grove, Stockport SK7 5BX

In your request, please clearly state (a) what Personal Information is concerned, and (b) which of the above rights you would like to enforce. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request, usually within a month, and we will tell you if we need additional time.

Please note that, under applicable law, these rights may be qualified, for example, where your information is being used in legal proceedings. We may need to retain certain information for record-keeping purposes or to complete any transactions that you began before requesting the change or deletion, unless a longer retention period is required or permitted by law (for example, for regulatory purposes).

When you receive promotional emails from us, you can also unsubscribe or opt out by clicking the link provided in the emails.