1. Introduction

At Hidden Hearing Ltd, we respect and protect the privacy of our users, and we are dedicated to be as transparent as possible regarding the use of your personal data.

This Privacy Notice explains how we collect and use your personal data. In this Privacy Notice, “we”, “us” and “our” means Hidden Hearing Ltd.

We may change this Privacy Notice from time to time, so please check back when you use our services to make sure that you have seen the most recent version.

2. Who We Are

This website is owned and operated by Hidden Hearing Ltd, and Hidden Hearing Ltd is the data controller of the personal data collected through the website and other means.

If you have any questions about this Privacy Notice, or you would like to exercise your rights, you can contact us by using the contact points below.

Hidden Hearing Ltd
3030 Lake Drive
Citywest Business Campus
Dublin 24

Tel: +353 1 5173900
E-mail: info@hiddenhearing.ie      dpo@hiddenhearing.ie

3. Personal Data We Collect and Use

We collect your personal data:

• When you make enquiries or book an appointment through our website online form, purchase products from us through our website, request marketing material or sign up to receive our newsletter.
• When you visit our website and cookies are placed on your computer. Please see our cookie policy for further information.
• When you email, call us or write to us, visit our clinics/visiting sites or provide us with information in any other way, including by interacting with us via social media such as Facebook, Twitter, etc.
• When a relative or friend gives us information about you during discussions about your hearing, or where an individual has indicated that he or she would like you to accompany them to a hearing assessment, hearing aid fitting or service appointment.

We process the following types of personal data:

• Your name, title, postal address, telephone number and email address, and, if you make a purchase with us, credit or debit card details;
• Information about your use of our contact centre and your clinic visits.
• Information you provide to us during communications you have with us, whether by email, post, telephone, in person or through our website, for example comments or queries about the products and services we provide.
• If you register for a hearing test with us, give us information about your hearing or purchase one of our hearing aids you may give us sensitive personal information about your health. This could include for example whether you currently use a hearing aid and if so what type of hearing aid, information about your hearing condition, medication/prescriptions and where appropriate your family history. We will only collect and use sensitive personal information about your health with your explicit consent.

We will do our best to ensure that the personal data and sensitive personal data, we process about you is correct. We will also make sure to update your personal data continuously. As our services depend on your correct and updated personal data, we ask you to inform us, if there are any relevant changes regarding your personal data. You may use our contact information above to notify us of any changes.

4. Why do we collect and use your personal data and what is our legal basis for doing so?

We use your personal data for the following purposes:

• To process and respond to requests, enquiries and complaints received from you, in accordance with our legitimate interest to provide our clients with a responsive service.
• To provide services and products requested and/or purchased by you and to communicate with you about such services and/or products. We do this as necessary to carry out a contract with you and in accordance with our legitimate interest to operate a business, which offers products and services related to hearing health care.
• To update our records and for audit purposes, in accordance with our legitimate interest to do so and/or when required by legislation.
• To prevent or detect fraud and to establish, exercise or in defence of legal claims, in accordance with our legitimate interest to do so.
• Where legally required or where it is in our legitimate interests to do so, to comply with requests from law enforcement and regulatory authorities.
• To analyse trends and profiles, for our legitimate interest to aim to enhance, modify, personalise and improve our services and communications for the benefit of our clients.
• To carry out customer satisfaction research, for our legitimate interest to aim to enhance, modify, personalise and improve our services and communications for the benefit of our clients.
• To recommend products and services we think you will be interested in. We do this in accordance with our legitimate interest to carry out direct marketing to our customers and, where we use your health data or electronic methods such as email, only with your explicit consent.

5. How we share your personal data

We will not rent, sell or otherwise share or disclose your personal data, except as described herein or otherwise stated at the time the data is collected.

We may share your personal data with affiliated companies within the William Demant Group to deliver, enhance and develop our products and services. Please refer to the organisational chart in our latest annual report to see which companies are part of the William Demant Group. You can find our latest annual report at www.demant.com.

We may share your personal data with our service providers for tasks such as:

• assisting us with administering or troubleshooting our website;
• assisting us with the supply or design of our products or with our business administration;
• assisting us with our marketing campaigns;
• operating our contact centre; or
• providing us with electronic or physical storage services or systems.

We will only share your information in these circumstances, if it is necessary for our service providers to perform the service for us. These service providers are not authorised to keep or use your personal data for any other purposes, and they will always be under an obligation to keep your personal data safe and confidential.

We may disclose your personal data to selected third parties such as law enforcement agencies, regulatory authorities and our professional advisors if we are under a duty to do so in order to comply with any legal obligation, or if it is in our legitimate interests, or in order to enforce or apply our website Terms and Conditions or other related contracts with you or your company.

6. How long do we keep your personal data?

We will keep your personal data for as long as we need to for legitimate legal or business reasons, including to comply with any regulatory obligations. We will delete your personal data, when it is no longer required in relation to the purpose for our collection, processing and storage of your personal and sensitive personal data. We will store personal and sensitive personal data that we are obliged to keep in accordance with the law.

If you would like more detailed information about our retention policy, please contact us by using the contact points above.

7. Security

We have put in place appropriate technical and organisational measures to protect your personal and sensitive personal data against unintended loss or amendment, against unauthorised disclosure and against unauthorised persons accessing your personal and sensitive personal data.

Should a breach of security occur, we will inform you as soon as possible, if the breach may result in high risk to your rights e.g., theft of ID, discrimination of you, loss of reputation or other significant inconvenience.

8. Your Privacy Rights

You have the right, at any time, to request information about the personal data we are processing about you, where the data is collected from, and what we are using it for. You also have the right to know how long we will keep your personal and sensitive personal data (if applicable), and who we share your data with. If you request so, we can give you details (and a copy) of the personal data we hold about you. Your access can be restricted to ensure other people’s privacy protection, trade secrets and intellectual property rights. You may also have the right to data portability. If you think the personal data we are processing about you is inaccurate or incomplete, you have the right to request correction. Please contact us and let us know how to rectify your information.

In some instances, we are obliged to delete your personal data. This might be the case if you withdraw your consent. If you believe that your personal data is no longer necessary in accordance to the purpose for which we collected them, you are entitled to request their deletion. You can also contact us if you believe that your personal data is being processed contrary to applicable law or other legal obligations.

We will investigate if the conditions are fulfilled, when you make a request of having your personal data rectified or erased. If so, we will carry out the amendments or deletion as soon as possible.

You have the right to object to our processing of your personal data. You can also object to our use of your personal data for marketing purposes. You can contact us at the contact points outlined at the top of the Privacy Notice if you want to submit an objection. If your objection is justified we will ensure the termination of the processing of your personal data.

9. Right to lodge a complaint

If you have a concern in relation to how we use your data, please let us know, and we will reply to your queries and if necessary, take steps to ensure our practices are consistent with our obligations. If you are still not satisfied with the way we use your data, you have the right to lodge a complaint with the Data Protection Commissioner. You can contact Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, Tel: 761 104800, Email: dataprotection.ie

10. Children’s Privacy

We provide solutions for children but this Website is not intended or designed to collect personal data about children under the age of 13. We do not intentionally collect personal data from any person we know to be under the age of 13.

11. Third Party Websites

This website may contain links to websites of other companies and organisations. This Privacy Notice does not apply to such third-party sites, and we suggest that you contact those third-party sites directly for information on their data collection and distribution policies.

12. Changes to the Privacy Notice

We may update this notice from time to time by publishing a new version on our website. Where relevant, possible and appropriate, you will be notified by email.

This Privacy Notice was updated on January 17, 2019.