Widex REMOTE CARE App Privacy Notice

1. INTRODUCTION
    1.1 This Privacy Notice is intended to provide you with information on how Widex A/S, (hereinafter "Widex", "we", "us", "our") collect and process your personal data when you use the Widex REMOTE CARE App (hereinafter the “App”).

    1.2 This Privacy Notice explains how and for which purposes we process your personal data. We will only process your personal data in accordance with this Privacy Notice and applicable law to which we are subject, in particular the General Data Protection Regulation (EU 2016/679) (hereinafter the "GDPR").

    1.3 Widex is data controller in relation to your personal data. You can contact us by using the contact information in Section 9.

2. THE DATA WE COLLECT, THE PURPOSE AND THE LEGAL BASIS FOR PROCESSING
DATA RELATED TO YOUR REMOTE CARE SESSION
    2.1 When you use the App we will process personal data about you for the purpose of transmitting such personal data to your Hearing Care Professional and to allow the Hearing Care Professional to perform remote fitting of your hearing aids. The categories of personal data we process are:

      2.1.1 your audiogram, first and last name, date of birth, gender, and level of experience in hearing aid use, as well as each hearing aid’s type, serial number, and unique configuration. We will also process the content of the video streaming, including images and sound, between your Hearing Care Professional and you during the remote care session. Please be aware that the video streaming will not be recorded.

      2.1.2 The processing of this information is necessary to enable the remote care session between you and your Hearing Care Professional. The legal basis for our processing is your consent (article 6 (1)(a) and 9(2)(a) in the GDPR).  
      You should contact your Hearing Care Professional directly if you have any questions about how they use information that they receive through the use of the App as such use by the Heath Care Professional is not covered by this Privacy Notice.  

TECHNICAL DATA COLLECTED BY THE APP
    2.2 When you use the App we will collect technical data about your device such as device ID, operating system used as well as how and where the App is used. This may be information on the country you use the App in or how much you use a specific function. The information will be aggregated, and we will not use it to identify you. 

      2.2.1 The processing of this information is necessary to pursue our legitimate interest in maintaining, troubleshooting and perform improvements to the App and in general to improve the services offered by Widex (article 6 (1)(f) in the GDPR). 
     
3. HOW IS YOUR PERSONAL DATA COLLECTED
    3.1 We will collect your personal data from you, the App, your Hearing Care Professional and your hearing aids.

4. DISCLOSURE OF YOUR PERSONAL DATA
    4.1 In addition to the transmission of your personal data to your Hearing Care Professional during the remote care session, your personal data may also be shared with third parties who process data on our behalf, e.g. IT service providers. Contractual arrangements are established to ensure that such data processors are only allowed to process data in accordance with our instructions and for our purposes, as explained in this notice, and to require such data processors to establish adequate organisational and technical security measures.

5. TRANSFER OF YOUR PERSONAL DATA TO THIRD COUNTRIES (OUTSIDE THE EU)
    5.1 One of our data processors, Vidyo, is established in US. Vidyo provides the video streaming of your remote fitting session on behalf of us. The appropriate safeguards to transfer personal data to US are the EU Commissions Standard Contract Clauses.

6. YOUR RIGHTS
    6.1 Under certain circumstances, you have one or more of the following rights:

      6.1.1 You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (art. 15 in the GDPR).

      6.1.2 You have the right to request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected (art. 16 in the GDPR).

      6.1.3 You may have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. To the extent that continued processing of your personal data is necessary, for example in order for us to comply with our legal obligations or for legal requirements to be established, enforced or defended, we are not required to delete your personal data (art. 17 in the GDPR).

      6.1.4 You have the right to object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground (art. 21 in the GDPR). 

      6.1.5 You may have the right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it (art. 18 in the GDPR).

      6.1.6 You may have the right to request the transfer of your personal data to another party (also known as data portability) (art. 20 in the GDPR).

      6.1.7 You are entitled to withdraw your consent at any time. If you wish to withdraw your consent simply uninstall the App or stop using it (art. 7(3) in the GDPR).

      6.1.8 If you have unresolved concerns, you also have the right to complain to the Danish Data Protection Agency or to the data protection authorities in the country where you live or where you consider a breach of data protection law has occurred (art. 77 in the GDPR). 
      The Danish Data Protection Agency may be contacted as follows: e-mail address dt@datatilsynet.dk or telephone number +45 33 19 32 00. In Canada, you may also file a complaint with the applicable privacy commissioner in your jurisdiction if you believe there’s been a violation of privacy rights.
 

7. DATA RETENTION

    7.1 Data related to your remote care session

      7.1.1 We only process your personal data during the remote care session. Such personal data will not be stored by Widex. 
    7.2 Technical data collected by the App

      7.2.1 Technical data collected by the App will be deleted after two years. 
 
8. DATA SECURITY
    8.1 We have put in place appropriate security measures to prevent your personal data from being lost, used, accessed in an unauthorised way, altered or disclosed.

    8.2 In addition, we have limited access to your personal data to employees and contractors who have a relevant and reasonably required need to access your personal data to perform their work and have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
 
9. CONTACT INFORMATION
    9.1 Widex is data controller for the personal data, which are processed about you.

    9.2 If you have any questions regarding this Privacy Notice or request to exercise your rights please use the contact information set out below.

    Widex A/S
    Nymøllevej 6
    3540 Lynge
    Denmark

    Email: gdpr@widex.com

10. FOR CALIFORNIA RESIDENTS
    We do not share any of your information transmitted through the App or collected by Widex with affiliated or unaffiliated third parties for their own direct marketing purposes.  If you are a California resident, you may request information about our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us using the information in the “Contact Information” section above. You must put the statement “Your California Privacy Rights” in the subject field.  We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
    This App does not support Do Not Track requests.
     
11. FOR FRENCH RESIDENTS
    You are at any time entitled to issue directives relating to the fate of your Personal Data after death.

12. CHILDREN’S PRIVACY
    12.1 The App is meant for configuration of hearing aids of individuals with a hearing loss above the age of 18 (eighteen). Consequently, Widex does not knowingly collect personal data from individuals below the age of 18 (eighteen).  

13. LINKS TO WEBSITES
    13.1 The App contains links to Widex websites, which are subject to separate privacy notices.  Please see the applicable website privacy notice for more information.

14. CHANGES TO THIS PRIVACY NOTICES
    14.1 We may change this Privacy Notice from time to time. If we make any changes to this Notice, you will be notified. 

    14.2 This Privacy Notice was last updated 2019.05.02. 
 

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Widex A/S

Nymøllevej 6

3540 Lynge

Denmark

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