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Privacy Notice

Last updated: 2018-04-04

This Privacy Notice describes the following:

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

Controller and contact details

The controller of the collected personal information is:
Sonova AG
Laubisrütistrasse 28
8712 Stäfa
Switzerland
The company registration number is:
CHE-101.989.88
Our contact details are as follows:
Email: privacy@sonova.com
Website: www.sonova.com
Contact details for our Data Privacy Officer (DPO) is:
Email: DPO@sonova.com

Description of myPhonak Service

The myPhonak Service consists of:

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 internet

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 internet*
*Only available in certain countries and through selected audiologists

What Information do we gather?

myPhonak Mobile app
• Email Address
Collected from connected hearing aids**
• Hearing Aid usage data (wearing time, program logs)
• Hearing Aid serial number
** Connected hearing aids are only hearing aids which can be connected to myPhonak mobile app
Collected from Third-Party Services in app
• Google Firebase (App usage data such as IP address, Session time, Screens visited)

myPhonak Web Portal
Entered by you
• First Name
• Last Name
•  Email Address
• Hearing Aid Serial Number (optional)
• Gender (optional)
• Address (optional)
• Phone number (optional)
• Usage of hearing aids (optional)
• Address of your Audiologist (optional)
Collected from application cookies in browser
Please check or detailed Cookie Policy on the website
Cookies
Please check or detailed Cookie Policy on the website

Why do we process the Information (Purpose(s) of Processing)
We use your Personal Information to:
• Provide product support
• Provide the Service to you
• Manage your account
• Improve the Service
• To personalize your experience
• Enable your audiologist to provide support and assistance to you
• To provide product marketing information to you
•  Communicate with you about your use of the Service

What is the legal basis for processing the Information?
The legal basis for processing your information is your Explicit Consent.

Automated decision-making and Profiling

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

Who do we share your Information with?

We share your information with:
• Your Audiologist (only in case of remote support and assistance by your audiologist)
We use Third-Party service providers to perform business operations on our behalf.
In so doing, we need to share your personal information with them.
We provide our Third-Party service providers only with the personal information they need to
perform the business operations we request, and we require that they protect this information and
they are obligated not to disclose or use it for any other purpose.
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)

We may also disclose your personal information

•  As required by law, for example, to comply with a subpoena or similar legal process. 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 information to 3rd parties as part of a legal process.
• As required in response to lawful requests by public authorities, including requests from national security or law
enforcement authorities.

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 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.
Adobe Campaign Manager stored in Irleand (Europe users) and USA (North America users).

Security of your information

To help protect the privacy of your data and personally information 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 information 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 information. We commit to taking appropriate disciplinary measures to enforce our
employees' privacy responsibilities.

Retention period

We will retain your Personal Information 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
Informationwhen you choose to delete your account unless a longer retention period is required or permitted by law
or Regulation. Please check section about “Your rights as Data Subject” below for further information.

Your rights as a Data Subject
You have the following rights:
• The right of access
• The right to rectification
• The right to erasure
• The right to restriction of processing
• The right to object to Processing
• The right to data portability
• The right to withdraw consent
• The right to Lodge a complaint with a Supervisory Authority
More detailed information about your rights and how to exercise them can be found in later sections

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.

Children's privacy

Our Service does not address anyone under the age of 13 ("Children"). We do not knowingly collect personal
information from children under 13. If you are a parent or guardian and you are aware that your child has provided
us with Personal Information, please contact us. If we become aware that we have collected Personal Information
from a child under age 13 without verification of parental consent, we take steps to remove that information from
our servers.

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.

More detailed information about your rights and how to exercise them

Right to Access
You have the right to access your personal data and supplementary information
How to exercise
Please send an email to privacy@sonova.com providing details of your request

Right to Rectification
You have the right to have personal data rectified if it is inaccurate or incomplete.
How to exercise
You can update your contact details by accessing your account profile at www.myphonak.com.
For all other information, please send an email to privacy@sonova.com providing details of your request.

Right to Erasure
The right to erasure is also known as ‘the right to be forgotten’. This enables you to request the deletion or removal
of personal data where there is no compelling reason for its continued processing, for example, where:
• Your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
• You withdraw your consent.
• The personal data has to be erased in order to comply with a legal obligation.
How to exercise
You can delete your account or withdraw your consent by accessing your account profile at www.myphonak.com.
For all other information, please send an email to privacy@sonova.com providing details of your request

Right to Restriction of Processing
You have the right to request to ‘block’ or suppress processing of your personal data, for example, where:
• You contest the accuracy of the personal data
• Processing is unlawful, and you oppose erasure and request restriction instead.
• Sonova no longer needs your personal data but you require the data to establish, exercise or defend a legal claim.
How to exercise
Please send an email to privacy@sonova.com providing details of your request.

Right to Object to Processing

You have the right to object to:
• Processing based on legitimate interests or the performance of a task in the public interest/exercise of official
authority (including profiling);
• Direct marketing (including profiling);
• Processing for purposes of scientific/historical research and statistics.
How to exercise
Please send an email to privacy@sonova.com providing details of your request.

Right to Data Portability

The right to data portability allows you to obtain and reuse your personal data for your own purposes across
different services. It allows you to move, copy or transfer your personal data easily from Sonova to another
Service in a safe and secure way, without hindrance to usability.
How to exercise
Please send an email to privacy@sonova.com providing details of your request.

Right to Withdraw Consent

You have the right to withdraw your consent at any time and in an easy way.
How to exercise
Please send an email to privacy@sonova.com providing details of your request.

Right to Lodge Complaint with SA

You have the right to lodge a complaint with a Supervisory Authority.
How to exercise
Contact details for all EU National Data Protection Authorities can be found here**.
This include contact details for European Free Trade Area (EFTA) Countries including Switzerland.
**http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080