Privacy Notice for Oticon Medical A/S 

1. INTRODUCTION
At Oticon Medical A/S, we respect and protect the privacy of our users, and we are dedicated to being 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” mean Oticon Medical A/S.

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 Oticon Medical, and Oticon Medical 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. 

Oticon Medical A/S
Kongebakken 9
DK-2765 Smørum
Denmark
E-mail: privacy@demant.com

3. PERSONAL DATA WE COLLECT AND USE
We collect your personal data:

• When you make enquiries or book an appointment through our website form, take our online hearing test, purchase products from us through our website, register for an account on 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 or write to us, visit our branches or provide us with information in any other way, including by interacting with us via social media such as Facebook and Twitter.

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 call centres and your branch 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 might give us sensitive 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 and, where appropriate, your family history. We will only collect and use sensitive information about your health with your explicit consent.

We will do our best to ensure that the personal data we process about you is correct. We will also make sure to update your personal data continually. As our services depend on your correct and updated personal data, we kindly 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 customers 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 in order 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 defend 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 customers.
• 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 customers.
• 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 Demant in order 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 Demant. 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 call centres; or
• providing us with electronic or physical storage services or systems.

We will share your information in these circumstances only if it is necessary in order 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 of Use or other related contracts with you or your company.

6. TRANSFER OF DATA TO THIRD COUNTRIES 
In order to deliver our products and services to you, we may share your personal data with affiliated companies in Demant located outside the EU/EEA.

If we process your personal data outside the EU/EEA, we will implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of the relevant Data Protection laws, including ensuring the protection of the rights of the data subject. The transfer of personal data is based on the EU Commission’s standard contractual clauses, which the EU Commission finds provide adequate guarantees for the protection of privacy, basic rights and liberties, as well as for exercising the associated rights. 

7. 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 data. We will store 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.

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

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, for example identity theft, discrimination of you, loss of reputation or other significant inconvenience.   

9. 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 data and who we share your data with. If you request, 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 our retention of your personal data is no longer necessary in accordance to the purpose for which we collected it, you are entitled to request its deletion. You can also contact us if you believe that your personal data is being processed contrary to applicable law or other legal obligations.    
When you make a request to have your personal data rectified or erase, we will investigate whether the conditions are fulfilled. 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.

10. 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 relevant national data protection authority. 

11. 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. 

12. 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.

13. 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 03 August 2018.