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Privacy Notice

Last updated: June 7, 2019


This Privacy Notice describes the following:

  • The personal data that Sonova collects from and about you through the myPhonak application (“the Mobile Application” or "Mobile App") or myPhonak Web Portal together with all related technology to access or otherwise use the Mobile Application (“Mobile Service”) as described below.
  • How do 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 to complain, etc.).

This privacy notice is in line with the EU General Data Protection Regulation (GDPR), the Swiss Federal Data Protection Act (FDPA), the United States Health Insurance Portability and Accountability Act (as amended from time to time) (“HIPAA”) and other applicable data protection laws that may apply to you. In the United States, any reference to HIPAA under this Privacy Policy to personal data shall apply to your personal data that fits the definition of Protected Health Information under HIPAA. Protected Health Information is any piece of information in an individual’s medical record that was created, used, or disclosed during the course of diagnosis or treatment that can be used to personally identify you.

If you are unwilling to accept the terms and conditions of this Privacy Policy, we ask you to not use this Mobile Application and/or the Mobile Service. By using the Mobile Application or the Mobile Service, you agree to the terms of this Privacy Policy. When you submit information via the Mobile Service, you provide consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.

We reserve the right to occasionally update this Privacy Policy. At such time, we will also revise the “last updated” date shown in this Privacy Policy. We reserve the right to apply the terms of any updated Privacy Policy to the all personal data that we maintain. We shall inform you about changes to a revised Privacy Policy by posting on the website and in the app. We recommend that you periodically review this Privacy Policy.

1. Controller, Data Privacy Team and contact details

The Controller for the processing (or responsible of treatment) of personal data as described in this Privacy Notice is Sonova AG, Laubisrütistrasse 28, 8712 Stäfa, Switzerland ( 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 our Data Privacy Team at or +41 58 928 01 01.

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 the Apple App Store and Google Play Store for app compatibility.

This app enables the following:

  • Remote Control of your hearing aid, i.e. based on the setting of your hearing aid and hearing aid type, you can remote control existing functionalities of your hearing aid.
  • Hearing aid status Information, i.e. hearing aid model, wearing time, battery state of charge, hearing aid accessories.
  • Remote Support by your hearing care professional (only available in certain countries and through selected hearing care professionals).
  • Hearing Diary, i.e. to give a feedback and communicate with your hearing care professional (only available in certain countries and through selected hearing care professionals).

b. myPhonak Web Portal

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

Registration on the myPhonak Web Portal enables the usage of Remote Support and Hearing Diary to get support and adjustment of your hearing aids by your hearing care professional via the Internet.

For your convenience, we also offer you further options on the myPhonak Web Portal like registration of your hearing aids or sign-up for product information news.

3. What personal data do we gather and why?

We use your personal data to provide the Mobile Service and product support for you and if you have opted in for this option, then to personalize your experience. If you allow, we may also use your data in a de-identified form to improve our services.

a. myPhonak Mobile app

During the set-up of the Mobile App, we gather identification data to identify you and allow the Mobile App to connect. We also record whether our Privacy Notice has been accepted by you and whether you accepted or declined to help us improve our services.

To be able to use Remote Control of your hearing aid and accessories, we need to collect identificationidentification data of your hearing aid (such as model, type, serial number) and hearing aid programs and settings.

To enable you to use the advanced Remote Control in the Mobile App, we need to collect the technical custom settings you have made in the Mobile App to personalize your hearing aid programs.

If you have chosen to personalize the Mobile App, we need to collect hearing aid status information like the model, program usage or configurations.

If you register on the myPhonak Web Portal (see below b.), we may need to use your login status, e-mail address and also name in the Mobile App to provide the Mobile Services.

To be able to offer you Remote Support, we need to exchange some data you provide with the use of the Mobile App with your hearing care professional, who needs access to your hearing aids for the remote fitting. Such data is technical data like the hearing aid connection status with the phone or the audio and video data to support the session.

To be able to offer you the Hearing Diary, we need to exchange the communication data you submit (like feedback or rating as well as your program usage) with your hearing care professional.

To develop future features and products for you and do research and evaluations, we only use de-identified data. You can opt out from such data collection during the Mobile App onboarding process or also later in the settings of this Mobile App.

All data is stored locally in the Mobile App.

Cookies and Usage Tracking collected from Third-Party Services in the Mobile app
Google Firebase (App usage data such as IP address, Session time, Screens visited): Sonova 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 You can opt out of the Google Analytics for Firebase during the onboarding process and in the settings of this app.

Passive Information Collection: As you use the Mobile Application and the Mobile Service, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies. The Mobile Application and the Mobile Service are designed to collect information about the technical performance and adjustments to the hearing device(s) linked to or otherwise adjusted by the Mobile Service as well as usage data with respect to your usage of the Mobile Application and Mobile Service. The Mobile Service also collects information about your device itself. For example, when using the Mobile Application, we and/or our service providers may track mobile-specific technical information such as type of device you are using, the device ID, IP address, operating system, mobile internet browser, internet service provider, referring/exit pages, click patterns, other applications on your device operating contemporaneously or adjacent to operation of the Mobile Application, and the way in which the Mobile Application is used. In addition, when you view the Mobile Application or the online components of the Mobile Service, we may store some information on your device(s). This information will be in the form of a cookie, flash cookie or similar file and will help us in many ways. We reserve the right to use and to permit our service providers to use, such cookies, flash cookies and web beacons, as well as other comparable or future technologies, to collect technical information regarding usage of the Mobile Application and Mobile Service. We passively collect information to understand what areas of the Mobile Application and Mobile Service are most popular, which areas may require improvement and what technologies are being used by our visitors. This information helps us to update and improve the Mobile Application and Mobile Service and/or our products and services. We also use this information for security purposes, to detect and to block security breaches and to provide you with a safe online environment.

b. myPhonak Web Portal

If you choose to register on the myPhonak Web Portal, we need to collect some personal data to provide the Mobile Service to you, manage your account and enable your hearing care professional to provide support and assistance to you. This is identification data, i.e. your name and e-mail address. In case you choose to use additional optional services like product support or personalization of your experience, you may also provide us with additional personal data such as your date of birth, your address or your hearing aid serial number.

Cookies and Usage Tracking
We use cookies, i.e. 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 the Cookie Policy on our website. For general information about managing cookies, please go to the All About Cookies website ( For more information about Google Analytics or to opt out of Google Analytics, please go to Please check our detailed Cookie Policy on the website to find more information about how we use cookies:

4. Automated decision-making and Profiling

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

5. Who do we share your personal data with?

We only share, or otherwise disclose, your personal data to your hearing care professional (only in case of remote support and assistance by your hearing care professional) 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 and/or the clauses required by HIPAA.

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 hearing care professional)
  • Survey Monkey (satisfaction survey)
  • Salesforce (account information)
  • Adobe Campaign Manager (Marketing Campaigns)
  • Google Analytics, respectively Firebase Analytics (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)


A. Hearing care professional: As described above, the Mobile Application and Mobile Service are designed to facilitate your interaction with the hearing care professional. The hearing care professional will have access to some or all of the information you submit, including but not limited to your hearing device information. You should assume that the hearing care professional will be able to see and use all of the information collected through the Mobile Application and Mobile Service. The Company is not responsible for how the hearing care professional uses or discloses this information. Any copy of your information accessed by the hearing care professional is subject to any applicable privacy practices of the hearing care professional.

B. Our Use: Your information may be used by the Mobile Service to provide push notifications and messages to you. Except as otherwise stated, we may use information collected internally to operate the services described on the Mobile Service, to improve the Mobile Service, to customize the Mobile Service to your preferences, to communicate information to you (including information about our products and services), for research purposes and for any other purpose specified in this Privacy Policy. In addition, we may make full use of all information acquired through the Mobile Application and/or Mobile Service that is not in personally identifiable form.

C. Other Disclosures: In addition to the disclosure of your information to the hearing care professional, we may disclose any of the information you provide:

  • (i) To contractors or service providers we use to support our business (such as hosting providers, technical support, web analytics and financial institutions), in which case we will require such third parties to agree to use it for the same purposes;
  • (ii) In the event of a sale, merger, liquidation, dissolution, reorganization, assignment or other transfer of the Company or the business of to which the information relates, in which case we will require any such buyer to agree to treat it in accordance with this Privacy Policy and use it for the same purposes;
  • (iii) To respond to law enforcement requests and subpoenas, where we believe in good faith that such response is required by applicable laws, court orders, or government regulations; and
  • (iv) In situations involving threats to the physical safety of any person.

We do not otherwise distribute to third parties your personally identifiable information. However, we will have no liability for disclosure of information obtained due to errors in transmission or the unauthorized intervention of third parties.

D. Usage Statistics, Aggregated Information and De-identified Information: We may de-identify and aggregate your personal information (including, without limitation, usage statistics and geo-location information) with information from other users of the Mobile Application and/or Mobile Service. We may use or disclose such aggregated information for purposes of operating, modifying, improving, promoting or otherwise commercializing the Mobile Application and Mobile Service or the aggregate data, but in no event shall such aggregated information include any personally identifying information.

6. Where is your data stored?

Your personal data is stored by Sonova AG on servers provided by Microsoft Azure Cloud Services in The Netherlands and on servers provided by Salesforce in Germany in compliance with European and local data privacy laws Please check and for further information. Furthermore, Adobe Campaign Manager stores in Ireland (for European users) and the USA (for North American 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.

7. 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 Mobile Service and Mobile Application to you or to those individuals and entities that we are otherwise authorized to disclose under this Privacy Policy or applicable laws. 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.

8. Retention period

We will retain your personal data for the duration of your relationship with Sonova AG 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.

9. 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. Specifically, in the United States under HIPAA you will have the following specific rights: (1) the right to request restrictions on certain uses and disclosures (and we are not required to agree to a requested restriction in the case of disclosure restricted under HIPAA), (2) the right to receive confidential communications related to your personal data as required under HIPAA, (3) the right to inspect and copy your personal data as required by HIPAA, (4) the right to amend your personal information as allowed under HIPAA, (5) the right to receive an accounting of disclosures of your personal data as required under HIPAA and, (6) the right to receive a paper copy of this notice upon written request in the event you have agreed to receive this notice electronically.

Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time by providing such revocation in writing. 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. In the United States specifically, we will not use your personal data for marketing or any other purposes not specifically allowed under HIPAA or described in this notice and we will not sell your personal data without your prior written consent.

We are required by law to maintain the privacy of your personal data, to provide individuals with notice of our legal duties and privacy practices with respect to your personal data and to notify you in the event of a breach of your personal data. We are required to abide by the terms of the Privacy Notice that are currently in effect. You can update your contact details, delete your account or withdraw your consent by accessing your account profile at The withdrawal of consent must be made in writing. For all other information or to exercise your rights, please send an e-mail to

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:, contact details for the Office of the Privacy Commissioner of Canada can be found here: In the Unites States, you may complain to Sonova AG or to the Secretary of Health and Human Services if you believe your privacy rights have been violated by submitting a written description of such violation. You will not be retaliated against for such filing. 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.

10. 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.

11. Children's privacy

Our Service is not intended for use by children under the age of 13 ("Children"). We will not knowingly collect personal data from children under 13. If you are a parent or guardian and you are aware that your child has provided us with personal data without your consent, please contact us. If we become aware that we have collected personal data from a child under age 13 without verification of parental consent, we take steps to remove that personal data from our servers. If a child has provided us with personally identifiable information, a parent or guardian of that child may contact us via email at, if they would like this information deleted from our records. We will use all reasonable efforts to delete the child’s information from our databases.

12. Intellectual Property

All trademarks, logos, designs, slogans, and trade dress appearing in the Mobile App and/or the Mobile Service, are owned by Sonova AG, its affiliated companies or their service providers or are used under license. No right or license is granted to use any trademark, service mark or logo displayed in the Mobile App or the Mobile Service or any other intellectual property rights of Sonova or any third party. You should assume that everything you see or read in the Mobile App or the Mobile Service is copyrighted unless otherwise noted and may not be used without our written permission.

13. Disclaimers; Limitation of Liability; Not Medical Advice

You acknowledge and agree that neither the Mobile Application nor the Mobile Service is intended to offer medical advice from Sonova. The Mobile Application and Mobile Service are designed to facilitate your communication with, and treatment by, a hearing care professional, but are not a substitute for the professional judgement of a suitably qualified and trained hearing care professional.