Mobile Application Privacy Policy

Effective Date: 2nd May 2017

This mobile application (“Sivantos App”) is provided by Sivantos GmbH (“Sivantos”). Your designated hearing care professional (“HCP”) will be responsible for guiding you through the registration and operation process, and will be your primary point of contact should you have any queries during your use of the Sivantos App. The use of information collected through our the Sivantos App shall be limited to the purpose of providing the service for which the HCP has engaged Sivantos.

By using this App, you freely and willingly consent to the transfer of your personal data from your HCP to Sivantos and its subsidiaries and affiliates. Your data may be stored in Germany and other countries and subject to the laws of those jurisdictions.

We may change this Mobile Application Privacy Policy.  If we do so, such changes will appear on this page of the mobile application. If we make any material changes we will notify your HCP via email or by means of a notice on the website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

 

Quick Links

Use these quick links to find out more information:

 

Our Commitment to Data Privacy Protection

Protecting the security and privacy of your personal data is important to Sivantos and your HCP; therefore, we conduct our respective businesses in compliance with applicable laws on data privacy protection and data security. We hope the policy outlined below will help you understand what data Sivantos and your HCP may collect, how Sivantos and your HCP use and safeguard that data, what choices you have regarding use, access and correction of data and with whom Sivantos and your HCP may share it.

 

Personal data

Through this Sivantos App, neither Sivantos nor your HCP will collect any personal data about you (e.g. your name, birth date, gender, address, telephone number, or e-mail address), unless you voluntarily choose to provide it (for example during the registration process), provide your consent, or unless otherwise permitted by applicable laws and regulations for the protection of your personal data.

Your designated HCP will collect personal data during the registration process, and that data will be encrypted and transmitted to the Sivantos App for your use based on a unique six-digit code.  Please note that you must provide a separate authorization to the HCP to enable the HCP to register you with the Sivantos App.

When you register with an HCP, the HCP may ask you to provide data such as your name, email address, phone number, gender, hearing device data, and the level of expertise you have with a hearing device.  You do not have to provide us with personal data if you do not want to; however, unless you provide us with certain personal data, your ability to use functions of the Sivantos App may be limited. 

When you download and use our Services via mobile app, we automatically collect information on the type of device you use, operating system version, and the device identifier (or "UDID").

We may also collect additional data as required to provide and manage the services and functions of the Sivantos App.

 

Purpose of Use

When you provide your HCP with personal data, such as your name, birth date, gender, address, telephone number, e-mail address, or your user feedback on the hearing aid, your HCP may use it to provide:

When you provide us with personal data, Sivantos and its affiliates may use it in form of aggregated data (e.g., satisfaction, setting changes, frequency of usage, etc.) in order to evaluate our products and services to develop superior quality hearing products for our HCPs and customers. Sivantos will not use your personal data for direct marketing or market research.  Sivantos and its affiliates may use third party providers to assist in the administration and functionality of the Sivantos App such as to process payments or analyse usage data.  These third parties may only use the data they receive in accordance with this Policy, or as otherwise as directed by Sivantos or required by law.   Where your personal data is transferred by Sivantos to another jurisdiction, Sivantos will ensure a level of protection commensurate to that to which you are entitled in your home jurisdiction.

 

Purpose Limitation

Sivantos and your HCP will collect, use or disclose personal data supplied by you through the Sivantos App only for the purposes disclosed to you, unless the disclosure:

In certain situations, Sivantos may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Personal data may be sold, shared or assigned to third parties as a result of, or in connection with a sale, merger, change in control, consolidation, transfer of assets, reorganization, bankruptcy, or liquidation. You will be notified via your HCP and/or a prominent notice on our website, of any change in ownership, uses of your personal data, and choices you may have regarding your personal data.

 

Communications or Utilization Data

Through your use of telecommunications services to access the Sivantos App, your communications data (e.g. Internet protocol address) or utilization data (e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed) are technically generated and could conceivably relate to personal data. To the extent that there is a compelling necessity, the collection, processing and use of your communications or utilization data will occur and will be performed in accordance with the applicable data privacy protection legal framework.

 

Usage Data Collected Automatically

When you access the Sivantos App, we may automatically (i.e., not by registration) collect usage data (e.g. type of Internet browser and operating system used, domain name of the web sites from which you came, the frequency with which you access the Sivantos App, average time spent and pages viewed). We may use this data and share it with our worldwide affiliates to monitor the attractiveness of the Sivantos App to improve its performance or content.

We also use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data. We do not link the information we store within the analytics software to any personal data you submit within the mobile application.

Sivantos and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.

 

Children

We will not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. Unless otherwise required by applicable laws, a “child” and “children” are defined as individuals 13 years of age or younger.

 

Data Storage

The Sivantos App makes use of Amazon Web Services (“AWS”). AWS will store data collected on or via the Sivantos App and store them on a server based in the Federal Republic of Germany as data processor.

 

Security

While transmissions over the Internet are never 100% secure or error-free, we take reasonable steps to protect it from unauthorized use, access, disclosure, alteration, destruction or loss. We require that your personal data is safeguarded using means appropriate to the sensitivity of the data.  We cannot guarantee that the data you supply will not be intercepted while being transmitted to us over the Internet and we are not liable for the illegal acts of third-parties such as criminal hackers.

The safety and security of your data also depends on you.  Please protect and secure your mobile device at all times.  We are not responsible for circumvention of your privacy settings or other personal data stored on your mobile device.

Because we operate globally, your personal data may be stored and processed in any country where we have facilities. By using our App, you consent to the transfer of data to countries outside your country of residence, which may have different data protection rules than in your country.  Where your personal data is transferred to another jurisdiction, we will ensure a level of protection commensurate to that to which you are entitled in your home jurisdiction.

Personal data is retained for as long as required to fulfill the purposes in this Policy, or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

 

Links to Other Web Sites

The Sivantos App may contain links to other web sites. We are not responsible for the privacy practices or the content of other web sites or mobile applications.

 

Access and Deletion Requests

Sivantos collects information under the direction of the HCPs, and has no direct relationship with the individuals whose personal data it processes. If you are a patient of one of our HCPs and would no longer like to be contacted by your HCP that use our service, please contact the HCP that you interact with directly. We may transfer personal data to companies that help us provide our service. Transfers to subsequent third parties are covered by the T&C with our Clients.

Your HCP will respond to reasonable requests to review your personal data and to correct, amend or delete any inaccuracies. If requested to remove data we will respond within a reasonable timeframe. If you have any questions or comments about this Data Privacy Policy (e.g. to review and update your personal data), please send your questions and feedback to your HCP. If you have a complaint about how your personal data is handled, you may contact your HCP, and the responsible data privacy personnel shall contact you within a reasonable timeframe.

We will retain personal data we process on behalf of our HCPs for as long as needed to provide services to the HCPs. Sivantos will retain this personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You may revoke your consent to the collection and processing of your personal data at any time with effect for the future by written notification to your HCP. Please note that deleting the App does not delete your account. You must contact your HCP to delete your registration and data. You may also send us an email at apps@sivantos.com to request access to, correct, or delete any personal data that you have provided to us.  If you choose to delete your account, you will not be able to take advantage of all the functions of the App, including certain personalized features.  We may not accommodate a request to change data if we believe the change would violate any law or legal requirement or cause the data to be incorrect.  In addition, your HCP may be required under applicable law to retain a copy of data as part of your patient file.

 

Questions and Comments

If you have any questions or comments about this Policy, please send your questions and feedback to your HCP or contact our privacy officer at apps@sivantos.com. The detail of our Data Privacy Officer is also available in the application’s Impressum page.

 

Sivantos GmbH

Henri-Dunant-Straße 100, 91058

Erlangen, Germany

dpo@sivantos.com

 

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