PROTECTION OF YOUR PERSONAL DATA
Sonova AG and Aureliym GmbH as independent or joint
controller
Sonova & Aureliym processes the following categories of
personal
data:
Personal information
Diagnostic data
Contact details
Therapy data
Hearing Assessment
Hearing instrument sales data
Sonova & Aureliym have the following legal basis to
process your personal data:
Consent
Performance of the contract
Legal obligation
Legitimate interest
Sonova & Aureliym processes your personal data for the following
purposes:
Send you marketing communications
Appointment arrangement
Medical/Audiological service
Contacting you
Safety purposes/ Post-market
surveillance, administrative regulations
Analytics and statistics evaluation
Your data can be shared with entities in:
The EEA
Switzerland
The UK
Sonova & Aureliym have taken the following measures
to secure the processing of personal data:
Intracompany agreements and data protection clauses
Policies and procedures
Safety and security measures
Employee training
Your rights:
Access
Rectify
Deletion
Objection
Portability
Contact:
File complaints with the national
Data Protection Authority:
Personal data we collect from you and why:
Sonova and Aureliym will only process your personal data for the following purposes.
Based on your consent:
• Send you emails communications: send you information and offers about hear care and tinnitus
products and services.
Personal data: first name, last name, e-mail address.
• Analytics: measure the impact of marketing campaigns via the mobile tracking and
attribution tool Appsflyer.
Personal data: device identifiers such as advertising ID’s, network data such as IP address
Based on the performance of the
contract and the service provided by SilentCloud. The following processing described are
part of the service
we provide you when using the SilentCloud app and therefore categories of personal data mentioned
are
shared between Aurelyim and Sonova:
• Create your account: managing your account information to provide you with the service.
Personal data: first name, last name, date of birth, gender, e-mail address, phone number, zip code,
city.
• Appointment arrangement: creating patient record to ensure continuity of service;
creating new record/lead in the local CRM database; booking an appointment.;
Personal data: personal information (first name, last name, date of birth, gender); contact
data (e-mail address, address, city, country, phone number); hearing assessment; selected Hearing
Care Professional (HCP); how you heard about the Silent Cloud app.
• Provide medical service:
activating the therapy, providing medical service and personalizing the therapy for your as a
patient (i.e. masking levels, tone frequency); guiding you through the use of the SilentCloud app;
answering patients’ questions/queries; monitoring service levels.;
Personal data: personal information, contact data, selected HCP, diagnostic data such as
medical
history questionnaire, medication use, tinnitus related questionnaires, tinnitus assessment, hearing
assessment, selected ENT, ENT prescription information, confirmation of app subscription payment/
payment confirmation;therapy data such as usage and status data (e.g., timestamps, provision for
occasional or on demand repeats), tinnitus assessment outcome (i.e., questionnaire scores, including
tinnitus severity, mental health issues, quality of life, medical patient history; and
psychophysical measurements), hearing assessment, details of therapy data (i.e., type of therapy
selected, progress of therapy, compliance of therapy, overall therapy outcome), and in some cases,
HCP and ENT data in order to verify function of the dashboard.
• Contact you: • contacting
you through email/phone (or any other agreed forms of communications) for additional medical follow
up providing you with any communication related to the service delivered by the SilentCloud app;
Personal data: e-mail address, phone number
Based on our legal
obligation:
• Safety purposes, post-market evaluation, or requirements under administrative regulations;
Personal data: diagnostic data (pseudonymized) such as medical history questionnaire,
medication
use, tinnitus related questionnaires and assessment, ENT prescription information; therapy data
(pseudonymized) such as all usage and status including timestamps and provision for occasional or on
demand repeats, therapy outcome and steps, tones for tonal therapy and volume of masking noise for
masker therapy.
Based on our legitimate
interest:
• Analytics and statistical evaluation: improving process and/or products; gaining insights about
the efficiency of communication channels; monitoring and optimizing your experience across both
Tinnitus Therapy and Hearing Instruments (HI) journeys; ensuring the continuity of the therapy and
your journey (continue where they left off and avoid repeating tasks; Add additional
assessments based on your feedback); Personal data: pseudonymized usage data;
pseudonymized
diagnostic data; pseudonymized therapy data; and pseudonymized data collected in other standard
hearing care processes, i.e. pseudonymized HI sales data (country, region, campaign code, average
customer spending, average age, average binaural factor).
• For the processing based on our
legitimate interest, you have the right to object (opt-out) at any time by contacting us at
privacy@AURELIYM.com
How long we keep your personal data: Those personal data will
be
retained for a minimal period proportional to the time required to fulfil the purposes described. In
the event applicable law or other regulations require a longer retention period, we will apply the
longer retention period in order to fulfill our legal obligations.
How we treat your personal data.
Sonova & Aureliym may share your personal data
with affiliated Sonova entities in Europe, UK, but also in Switzerland (where our headquarters
are). All our employees are required to follow these rules and are regularly trained. We have
secured our systems with modern protection and restricted the access
In cases where we need to, we share your personal data with trusted third parties as well.
Microsoft Ireland Operations Limited (Ireland), Microsoft Azure (data are stored in EU or US
depending on user’s location), which is the infrastructure hosting our services; Lavabeam Ltd
(UK) which is our reporting dashboard supplier and will have access to pseudonymize data for
development purposes; AppsFlyer Ltd (US) (data are stored in EU) which is our marketing
analytics tool.
Sonova & Aureliym ensure your personal data is protected at the same level as it would be in
your home country. We have agreements with all involved parties to make sure no one uses your
data in an illegal way.
You have rights.
Within the framework of the collection and processing of
your personal data, and as per applicable law, you may have the right to request access,
rectification, erasure of your personal data, or restriction of processing. In addition, you may
object to the processing, request data portability and withdraw your consent at any time.
According to your country, you may have other rights such as providing instructions for how your
personal data should be processed posthumously. Under HIPAA you may also have the right to
request an accounting of disclosures of your personal data, and the right to receive a paper
copy of this notice upon written request.
Please note that the exercise of such rights is
subject to the limitations provided by applicable law.
How to contact us.You can
always contact the Data Protection Officer of Sonova
or Aureliym for any of the purposes mentioned above at privacy@aureliym.com or
privacy@sonova.com.
If you want to file a complaint about Sonova or Aureliym handling
your personal data, we appreciate you telling us directly, but you can also contact your local
Data Protection Authority on
Terms of Service
These Terms of Service ("Terms", "Terms and
Conditions") govern your relationship with:
- the website www.silentcloud.com operated by Sonova AG of Laubisrütistrasse
28, 8712 Stäfa, Switzerland, registration number CHE-101.989.88
- the SilentCloud app manufactured by Aureliym GmbH of Hauptstrasse
96, 53474 Bad Neuenahr-Ahrweiler, Germany, registration number HRB 26319, Koblenz.
Together these two elements constitute the "service".
Contact: privacy@sonova.com, privacy@aureliym.com, website:
www.sonova.com/www.aureliym.com ("us",
"we", or "our").
Please read these Terms and Conditions carefully before using the Service. Your
access to and use of the Service is conditioned on your acceptance of and compliance with these Terms. These
Terms apply to all visitors, users and others who access
or use the Service. By accessing or using the Service you agree to be bound by these Terms. If you disagree
with any part of the terms, then you may not access the Service.
Intellectual property
The Service and its original content, features and functionality are
and will remain the exclusive property of us and its licensors. The Service is protected by copyright,
trademark, and other laws of both the Germany and foreign countries.
Our trademarks and trade dress may not be used in connection with any product or service without the prior
written consent of us.
Links to other web sites
Our Service may contain links to third-party web sites or services that
are not owned or controlled by us. We have no control over, and assumes no responsibility for, the content,
privacy policies, or practices of any third-party web sites or
services. You further acknowledge and agree that we shall not be responsible or liable, directly or
indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or
reliance on any such content, goods or
services available on or through any such web sites or services. We strongly advise you to read the terms
and conditions and privacy policies of any third-party web sites or services that you visit.
Limitation of liability
In no event shall we, nor its directors, employees, partners,
agents, suppliers, or affiliates, be liable for any indirect, incidental, special, consequential or punitive
damages, including without limitation, loss of profits, data, use, goodwill,
or other intangible losses, resulting from (i) your access to or use of or inability to access or use the
Service; (ii) any conduct or content of any third party on the Service; (iii) any content obtained from the
Service; and (iv) unauthorized
access, use or alteration of your transmissions or content, whether based on warranty, contract, tort
(including negligence) or any other legal theory, whether or not we have been informed of the possibility of
such damage, and even if a remedy
set forth herein is found to have failed of its essential purpose.
Disclaimer
Your use of the Service is at your sole risk. The Service is provided on an "AS
IS" and "AS AVAILABLE" basis. The Service is provided without warranties of any kind, whether express or
implied, including, but not limited to, implied warranties
of merchantability, fitness for a particular purpose, non-infringement or course of performance. Our
subsidiaries, affiliates, and its licensors do not warrant that a) the Service will function uninterrupted,
secure or available at any particular
time or location; b) any errors or defects will be corrected; c) the Service is free of viruses or other
harmful components; or d) the results of using the Service will meet your requirements.
Governing law
These Terms shall be governed and construed in accordance with the laws of
Germany, without regard to its conflict of law provisions. Our failure to enforce any right or provision of
these Terms will not be considered a waiver of those rights.
If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions
of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our
Service and supersede and
replace any prior agreements we might have between us regarding the Service.
Changes
We reserve the right, at our sole discretion, to modify or replace these Terms at
any time.
What constitutes a material change will be determined at our sole discretion. By
continuing to access or use our Service after those revisions become effective, you agree to be bound by the
revised terms. If you do not agree to the new terms,
please stop using the Service.
Contact us
If you have any questions about these Terms, please contact us
at privacy@sonova.com or privacy@aureliym.com
