PROTECTION OF YOUR PERSONAL DATA
Last updated: March 24, 2025
This Privacy Notice describes how your personal data, including sensitive data, are collected and
processed. The processing of your personal data comply, according to your country, with local law
requirements, including the Swiss Federal Data Protection Act (“FDPA”), the Regulation (EU) 2016/679 of
the European Parliament and of the Council of 27 April 2016 (“GDPR”), U.S. state data privacy laws such
as the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), or the
Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) for personal data qualified as
Protected Health Information.
This Privacy Notice may be updated from time to time. In this case, we will inform you that this Privacy
Notice has been modified and the “last updated” date on top of this document will be modified. We
recommend that you periodically review the latest version of this Privacy Notice.
Who we are
Aureliym GmbH and Sonova AG act as independent or joint controllers. A given professional or ENT
specialist’ user may also act as Joint or Independent Controller for the processing described in the
applicable privacy notice for recipients.
Personal data we collect from you and why.
Sonova & Aureliym will only process your personal data for the following purposes:
-
Based on your consent:
- Send you marketing 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.
- Process your health data to deliver the requested medical service or support,
including follow-up
communication when requested and sharing your information with the ENT specialist
and/or HCP to
monitor your progress: creating your patient record to ensure continuity of
service;
creating new record / lead in the local CRM database to book the appointment requested;
activating
the therapy, providing medical service and personalizing the therapy for you as a
patient (i.e.,
masking levels, tone frequency).
Furthermore, please note that if the ENT or HCP acts as an independent data controller
and provides
you with the prescription or a code, the ENT or HCP is responsible for obtaining valid
consent to
share your personal data, including sensitive data, with Sonova AG and Aureliym GmbH in
order to
enable us to release and track your therapy in the SilentCloud mobile app.
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, other
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), 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.
-
Based on the performance of
the
contract and the service provided by the SilentCloud app: 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.
- Support you with the usage of the mobile app: guiding you through the use of the
SilentCloud app;
answering patients’ questions/queries; monitoring service levels; 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 of 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 case 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; 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 parties involved 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 Aureliym’s or Sonova’s Data Protection Officer for any of the purposes mentioned above
at privacy@aureliym.com or
privacy@sonova.com.
If you want to file a complaint about Sonova handling your personal
data, we appreciate you telling us directly, but you can also contact your local Data Protection
Authority on www.edpb.europa.eu
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
