Hidden Hearing Data Protection Statement

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. 
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 

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. 


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. 

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.

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.

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.   
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.
 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
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. 
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.

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. 

Privacy Notice for Hidden Hearing Ltd processing of personal data on social media platforms


1. INTRODUCTION
At Hidden Hearing Ltd, 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 ("Privacy Notice") explains how Hidden Hearing Ltd processes your personal data in connection with your interaction with Hidden Hearing Ltd as a data controller by use of different social media platforms, such as Facebook, Instagram, Twitter, YouTube and LinkedIn.

 In this Privacy Notice, "we", "us" and "our" mean 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

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 Park
Dublin 24
Email: privacy@demant.com 

3. PERSONAL DATA WE COLLECT AND USE

We may process the following types of personal data:
Information about you, such as your name, email, age, gender, country, job title, current and former employer, education background, profile picture, interests, your friend list/connections/followers etc., and other publicly available information, provided that you have published all this information on your social media profile or posted it on one of Hidden Hearing Ltd social media pages. 
Other information you provide to us by posting on Hidden Hearing Ltd social media page, including your comments and/or likes to our posts and pictures or direct messages you send to us via Hidden Hearing Ltd social media platforms. 
 

In addition to the above, the different social media platforms collect personal data concerning you through your use of these social media platforms and through the use of cookies and similar technologies, including cookies collected via the social media tools, such as Facebook Insights, Facebook Pixel, Facebook Custom Audience, Facebook Lookalike Audience, Twitter Pixel, LinkedIn Insight Tag and LinkedIn sponsored InMail, etc. 
In some cases, for instance, in relation to our Facebook page, Hidden Hearing Ltd acts as joint controller together with Facebook in relation to the processing of your personal data. Thus, we recommend that you read Facebook's privacy notice to understand how Facebook processes your personal data. 
We generally refer to the different social media platforms' privacy notices for more information about their processing of your personal data. Below you will find a listing of the social media platforms that Hidden Hearing Ltd uses and a reference to their privacy notices. 
Link to Facebook's data policy: https://www.facebook.com/privacy/explanation 
Link to LinkedIn's privacy notice: https://www.linkedin.com/legal/privacy-policy
Link to Instagram's privacy policy: https://help.instagram.com/402411646841720 
Link to Twitter's privacy policy: https://twitter.com/en/privacy 
Link to YouTube's privacy policy provided by Google: https://support.google.com/youtube/topic/9386940?hl=en&ref_topic=2803240 
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 understand the audience to our social media channels by getting to know the demographic, preferences and interests which enables us to provide relevant information. 
To analyse trends and profiles to enhance, modify, personalise and improve our services and communications for the benefit of our audience.
To process and respond to requests and enquiries received from you.
To carry out market surveys to enhance, modify, personalise and improve our services and communications for the benefit of our users through Hidden Hearing Ltd social media pages on Facebook, Instagram, Twitter and YouTube.
To recommend products and services we think you will be interested in. We do to carry out direct marketing to our customers and/or potential customers. However, if we use electronic methods, such as email or direct messaging through our social media pages, for instance, via Facebook and/or Instagram, to send direct marketing to you, we will only do so if it is permitted under the applicable rules on direct marketing. 

The legal basis for collecting and processing your personal data via Hidden Hearing Ltd different social media pages is our legitimate interest as described above in accordance with EU General Data Protection Regulation (“GDPR”) art. 6(1)(f). Our legitimate interests are under these circumstances regarded to override your interests. 

5. HOW WE SHARE YOUR PERSONAL DATA
We will not pass, sell or otherwise share or disclose your personal data, except as described herein or otherwise stated at the time the personal data is collected. 

As mentioned under section 3, we may act as joint data controller in relation to the processing of your personal data via our social media pages together with the specific provider of the social media, for instance, Facebook Inc. or Facebook Ireland Ltd. This means that we are jointly responsibly for processing of your personal data. We have inserted a reference to Facebook’s privacy notice in section 3.

We may share your personal data with affiliated companies within the Demant Group 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 form part of the Demant Group. You can find our latest annual report at www.demant.com.  
We may share your personal data with our service providers for a variety of 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, for instance, via Facebook Custom Audiences and Facebook Lookalikes;
providing us with electronic or physical storage services or systems.
We will only share your information under these circumstances, if it is necessary in order for our service providers to perform the specific 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 the Demant Group located outside the EU/EEA and non-affiliated companies, such as service providers or business partners located outside the EU/EEA provided this is considered necessary in relation to a particular data processing activity or performance of the service.
If your personal data are transferred 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. Where necessary, we have entered into the EU Commission’s standard contractual clauses with the recipient of the personal data. The EU Commission finds these clauses to 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 necessary and/or as prescribed 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 also store personal data that we are obliged to keep in accordance with the law.
If you have commented on any of our posts on social media platforms, such comments will be deleted at the time when the post in question is deleted. We may, however, choose to delete specific comments at an earlier point in time. You may also at any time choose to delete your own comment.
Information that is collected via social media platforms for a specific purpose, for instance, a targeted marketing campaign, will be deleted 1 year after the specific processing activity is carried out. Certain data may be retained up to 2 years after the specific campaign for documentation purposes.
If you would like more detailed information about our retention policy, please contact us by using the contact points in section 2 above.

8. YOUR PRIVACY RIGHTS
Pursuant to the GDPR, as a result of our processing of your personal data, you may exercise a number of rights. They are: 

The right to access to your personal data 
The right to have us rectify (correct) your personal data
The right to have us delete your personal data
The right to restrict our processing of your personal data
The right to data portability 
The right to object to our processing

These rights may, however, be subject to conditions and/or exemptions, e.g. to ensure other people’s privacy, trade secrets, intellectual property rights or to comply with a legal obligation.

If you would like to exercise one or more of your rights, please contact us by using the contact points in section 2 above.

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 relevant national data protection authority. In Ireland, the relevant data protection authority is The Data Protection Commission. You can contact The Data Protection Commission at 21 Fitzwilliam Square, South Dublin 2, D02 RD28, e-mail: dataprotection.ie 
10. CHILDREN’S PRIVACY
We provide solutions for children but our social media pages on Facebook, Instagram, Twitter, YouTube and LinkedIn are not intended or designed to collect personal data about children under the age of 16. We do not intentionally collect personal data from any person we know to be under the age of 16. 
11. THIRD PARTY LINKS
Hidden Hearing Ltd social media pages on Facebook, Instagram, Twitter, YouTube and/or LinkedIn 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 Privacy Notice from time to time by publishing a new version on our website hiddenhearing.ie and different social media pages on Facebook, Instagram, Twitter, YouTube and LinkedIn.

This Privacy Notice was updated on December 18, 2019.



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