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Privacy Notice

Last updated: July 31, 2018

This Privacy Notice describes the following:

• The personal data that Sonova collects from and about you through the myPhonak Service (“the
Service” or “Service”) as described below.
• How we use and protect your personal data.
• The choices you have about how we use your personal data.
• How you can exercise your rights (e.g. right to access, right to rectification, right complain etc.).

This privacy notice is in line with the EU General Data Protection Regulation (GDPR), the Swiss Federal
Data Protection Act (FDPA) and other applicable data protection laws that may apply to you.

1. Controller, Representative, Data Protection Officer and contact details

The controller for the processing of personal data as described in this Privacy Notice, is Sonova AG,
Laubisrütistrasse 28, 8712 Stäfa, Switzerland (www.sonova.com). In the event of questions about: (i)
access to your personal data or the exercise of your rights in general; (ii) our collection, use,
management or disclosure of personal data; or (iii) this Privacy Notice, please contact us at
privacy@sonova.com or contact our Data Protection Officer at privacy@sonova.com.

2. Description of myPhonak Service


The myPhonak Service consists of:

a. myPhonak Mobile app

The myPhonak mobile app is an app for consumers with a smartphone and is available for iOS and
Android. Please check Apple App Store and Google Play Store for app compatibility. myPhonak Mobile
App Service is only available in certain countries and through selected audiologists.

This app enables the following:
• Get support from your audiologist
• Get your hearing aids adjusted by your audiologist via the Internet

b. myPhonak Web Portal

The myPhonak web portal is a browser-based website and application running on most common used
web browsers and compatible with most common devices such as desktop PCs, tablet and mobile
phones.

The web portal enables the following:
• Create an account with Sonova;
• Register your Hearing Aids;
• Find instructions and user manuals;
• Troubleshoot your devices;
• Sign up for product information news;
• Get support and adjustment of your hearing aids by your audiologist via the Internet.*
*Only available in certain countries and through selected audiologists

3. What personal data do we gather and why?

a. myPhonak Mobile app

We use your Email Address, First and Last Name based on our contract through your registration to
provide the service to you, manage your account and enable your audiologist to provide support and
assistance to you.

We may process additional personal data for the use of further, optional services. As far as you
provide us such personal data and consented to its use, these may comprise:
- your Hearing Aid Serial Number and your Usage of Hearing Aids to help us provide product
support, improve the service and personalize your experience;
- the address of your Audiologist to help us to provide product support and personalize your
experience;
- your address to help us provide product support and improve the service;
- your gender and date of birth to help us customize further product information.

Cookies and Usage Tracking collected from Third-Party Services in app

Google Firebase (App usage data such as IP address, Session time, Screens visited): Phonak uses
Google Analytics for Firebase, a service offered by Google Inc. “Google” which helps us generating
aggregated statistics about the usage of the app. For this purpose, your Mobile ad ID (a persistent
identifier that is different for each app) or Android ID and other information (such as number of
sessions, session durations, operation systems, updates, purchases or region) will be transmitted to
Google Firebase. Google Firebase will use cookies, stored on your mobile app to analyze your usage of
the app. Google will retain ID-associated data for a period of 60 days, afterwards personal data will be
aggregated- For further information about how Google processes your data when you use our app,
please read www.google.com/policies/privacy/partners. You can opt out of the Google Analytics for
Firebase during the onboarding process and in the settings of this app.

b. myPhonak Web Portal


We use your Email Address, First and Last Name based on our contract through your registration to
provide the service to you, manage your account and enable your audiologist to provide support and
assistance to you.

We may process additional personal data for the use of further, optional services. As far as you provide
us such personal data and consented to its use, these may comprise:
- your Hearing Aid Serial Number and your Usage of Hearing Aids to help us provide product
support, improve the service and personalize your experience;
- the address of your Audiologist to help us to provide product support and personalize your
experience;
- your address to help us provide product support and improve the service;
- your gender and date of birth to help us customize further product information.

Cookies and Usage Tracking

We use cookies, small text files that are automatically placed on your computer’s hard drive when you
access certain websites, and similar technologies, directly or through third parties, such as web
analytics services like Google Analytics. Cookies allow us to store information, such as your domain
name, your internet service provider, your operating system, the date and time of access, the pages
you visit or the types of searches you perform. We collect such data, for example, to conduct system
administration and report aggregated information to affiliates, business partners and/or vendors who
conduct website and application analyses and website performance reviews on our behalf.

We use this information to store your preferences and settings, to help improve the contents of our
websites or applications, to enable you to register to websites and applications, and to compile
aggregated statistics to evaluate visitors’ use of our website or website activity, and for internal and
market research purposes.

You have the right to choose whether or not to accept cookies and to opt out of Google Analytics. You
can block cookies by changing your browser settings so that cookies from the website cannot be placed
on your computer or mobile device. However, please note that if you choose to refuse certain
functional cookies, you may not be able to use the full functionality of the website. For further
information about the types of cookies we use, please visit our Cookie Policy here. For general
information about managing cookies, please go to the All About Cookies website
(http://www.allaboutcookies.org/manage-cookies/). For more information about Google Analytics, or
to opt out of Google Analytics, please click here and go to https://tools.google.com/dlpage/gaoptout.

Please check our detailed Cookie Policy on the website to find more information about how we use
cookies https://www.phonak.com/us/en/cookie-statement.html

3. Automated decision-making and Profiling


The Service does not use any automated decision-making processes nor profiling that could affect
your rights.

4. Who do we share your personal data with?

We only share, or otherwise disclose, your personal data to your audiologist (only in case of remote
support and assistance by your audiologist) and our subsidiaries, affiliated companies or other trusted
business partners providing services on our behalf, such as for technical support, to evaluate the
usefulness of our websites and applications, for marketing purposes (if we have your consent), or for
other types of service delivery. We have contracts in place with these parties to ensure that personal
data are processed based on our instructions and in compliance with this Privacy Notice and any other
appropriate confidentiality and security measures.

We only share your personal data with these parties and other third parties mentioned above,
including governmental authorities, as far as this is necessary to provide any services that you have
requested or authorized, to protect your, our, or others’ rights, property or safety, to maintain the
security of our services or if we are required to do so because of applicable laws, court or other
governmental regulations, if such disclosure is otherwise necessary in support of any legal or criminal
investigation or legal proceeding or where it is necessary for the purpose of a prospective business
transaction if the information is necessary to determine whether to proceed with the transaction or
to complete the transaction, or a completed business transaction where the information is necessary
to carry on the activity that was the object of the transaction, such as the purchase, sale or other
acquisition or disposition of an organization or a part of an organization, or any of its assets or any
other arrangement between two or more organizations to conduct a business activity.
Where obliged or permitted to disclose personal data without consent, we will not disclose more
personal data than is required. To the extent we are legally permitted to do so, we will take
commercially reasonable steps to notify you in the event that we are required to provide your
personal data to third parties as part of a legal process.

Please note that the above-mentioned Sonova affiliates and subsidiaries, as well as authorities,
customers and suppliers to whom we may disclose your personal data, may be located outside of your
country of domicile, potentially including countries such as the United States, whose data protection
laws may differ from those in the country in which you are located. In such cases, we will ensure that
appropriate safeguards are in place to protect your personal data by implementing appropriate legal
mechanisms, such as EU Standard Contractual Clauses.

Third-Party service providers we use and the business operations they perform:
• Microsoft Azure (host web portal and provide web services for remote support by your
audiologist)
• Survey Monkey (satisfaction survey)
• Salesforce (account information)
• Adobe Campaign Manager (Marketing Campaigns)
• Google Analytics, respectively Google Analytics for Firebase (customer and consumer feedback)
• Sendgrid (has access to the emails sent to the end user as the email service provider)
• Twilio (has access to the public IP of the end user as a WebRTC provider)
• Xirsys (has access to the public IP of the end user as a WebRTC provider)

5. Where is your data stored?

Your personal data is stored by Sonova on servers provided by Microsoft Azure Cloud Services in
Ireland and Netherlands (European users) and USA and Canada (North America and Canadian users)
and on servers provided by Salesforce in Germany in compliance with European privacy law and
GDPR. Please check https://www.salesforce.com/gdpr/overview/ and
https://www.microsoft.com/en-us/TrustCenter/CloudServices/Azure/GDPR for further information.
Furthermore, Adobe Campaign Manager stores in Ireland (Europe users) and USA (North America
and Canadian users). Please note that your personal data may also be subject to access by and
disclosure to law enforcement agencies under the applicable foreign legislation.

6. Security of your personal data


To help protect your personal data through your use of the Service, we maintain physical, technical
and administrative safeguards. We update and test our security technology on an ongoing basis. We
restrict access to your personal data to those employees who need to know that personal data to
provide the Service to you. In addition, we train our employees about the importance of
confidentiality and maintaining the privacy and security of your personal data. We commit to taking
appropriate disciplinary measures to enforce our employees' privacy responsibilities.

7. Retention period

We will retain your personal data for the duration of your relationship with Sonova as necessary to
fulfil the purposes detailed in this Privacy Notice. Following the fulfilment of the purposes we will
delete your personal data when you choose to delete your account unless a longer retention period
is required or permitted by law or Regulation. Please check the section about “Your rights with
respect to the collection, use and disclosure of your personal data” below for further information

8. Your rights with respect to the collection, use and disclosure of your personal data


Within the scope of the data protection laws applicable to you and under certain conditions, you may
have the right to access your personal data, the right to request the correction or erasure of your
personal data or to request the restriction of processing of your personal data. You may have further
rights depending on your domicile. E.g., if you reside in the EU, you may further have the right to data
portability.

Where the processing of your personal data is based on your consent, you have the right to withdraw
your consent at any time. In this case, we will not continue to process your personal data. Please note,
however, that the withdrawal of consent shall not affect the lawfulness of processing based on consent
before its withdrawal.

You can update your contact details, delete your account or withdraw your consent by accessing
your account profile at www.myphonak.com. For all other information or to exercise your other
rights, please send an e-mail to privacy@sonova.com providing details of your request.

Finally, you may have the right to lodge a complaint to your supervisory authorities (Contact details
for all EU National Data Protection Authorities including such for the EFTA can be found here:
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080, contact details for the
Office of the Privacy Commissioner of Canada can be found here https://www.priv.gc.ca/en/contactthe-opc/).
Please also note that we reserve the right to enforce statutory restrictions, for example, if
we are obliged to retain or process certain data, have an overriding interest in them, or require the
data to assert certain claims.

9. Links to other sites

The Service contains links to other sites that are not operated by us. If you click on these links you
will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every
site you visit. We have no control over, and assume no responsibility for the content, privacy policies
or practices of any third-party sites or services.

We cannot and do not guarantee, represent or warrant that the content or information contained in
third-party sites and resources is accurate, legal, non-infringing or inoffensive. We do not endorse
the content or information of any third-party site or resource and, further, we do not warrant that
such sites or resources will not contain viruses or other malicious code or will not otherwise affect
your computer. By using the Service to search for or link to a third-party site, you agree and
understand that we shall not be responsible or liable, directly or indirectly, for any damages or losses
caused or alleged to be caused by or in connection with your use of, or reliance on the Service to
obtain search results or to link to a third-party site.

10. Children's privacy


Our Service does not address anyone under the age of 16 ("Children"). We do not knowingly collect
personal data from children under 16. If you are a parent or guardian and you are aware that your
child has provided us with personal data, please contact us. If we become aware that we have
collected personal data from a child under age 16 without verification of parental consent, we take
steps to remove that personal data from our servers.

11. Changes to this Privacy Notice


We may update our Privacy Notice from time to time. You are advised to review the updated Privacy
Notice. Changes to this Privacy Notice are effective when they are posted on this page.