EFFECTIVE September 1, 2020
WHAT PERSONAL INFORMATION HEARFON ONLINE COLLECTS AND WHEN?
HearFon Online collects the following information, including Personal Information, when you interact with us and use our Products and Services:
Purchase and Warranty Information: means information, including Personal Information, you may provide to us when you purchase HearFon Products and Services, including related to your rights under a product warranty. Purchase and Warranty Information may include your financial information; contact information, such as your name, shipping and billing address, phone number, and email address; product identification information, like hearing aid serial numbers; and health information like your audiogram or an impression (mold) of your ear.
Website Information: means information that you enter directly or otherwise provide or disclose, including Personal Information, when you use or access any of our websites. Website Information includes information about the technology you used to access our website, including the IP address, internet service provider, browsers, apps, and devices. Website Information also includes details of your activities while on our websites, like how long you visited a webpage, the content you clicked on or accessed, and information about other sites you visited before or after our website. Website Information includes anything you submitted via the website like a webform to “contact us”, the content of any “chat” communications you have with us through our websites, or while applying for a job through an employment-related function of our websites.
Hearing Device and App Usage Information: means information, including Personal Information, you provide or that is generated during your use of our hearing aid devices, our apps, or both. Hearing Device and App Usage Information includes:
Health and Patient Information: means information collected from you when you request an appointment, including your name and contact information, like telephone number or email address, as well as information about your hearing care needs, including health information, and your preferences for how we contact you.
Communications Information: means information you provide while communicating with HearFon, in any way, for any reason, that may include Personal Information. Communications Information includes the information you provide over the phone, which may include your name, phone number, address, email address, device serial number, as well as the content of any phone calls you have with us.
Your Information Shared by a Third-Party You Authorized: means your Personal Information that is provided to us by a third-party, because you authorized the third-party to share it. For example, you may authorize your Finance provider to share your Personal Information with HearFon, which may include your contact information, financial information, and health information.
WHY HEARFON COLLECTS YOUR PERSONAL INFORMATION?
We collect your Personal Information because it is necessary to provide the services, features, or functionality of our Products and Services that you have elected to use. HEARFON also collects your Personal Information for legitimate business purposes, to protect HearFon and its customers, and for legal reasons. We only collect and process your Personal Information based on our legitimate interests when we have determined our legitimate interests are not outweighed by your privacy and data protection rights.
Depending on your interaction with HearFon, and your use of our Products and Services, HearFon may collect your Personal Information for the following reasons:
Some features of our websites allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via email. The email response or confirmation may include your personal information, including your name and contact information. We cannot guarantee that our emails to you will be secure from unauthorized interception.
When required by law, we will obtain your consent before sending you certain marketing communications. You can withdraw consent at any time by unsubscribing to such communications.You may also opt-out of receiving future marketing information, like marketing emails, at any time, by using the instructions provided in marketing communications.
In the case of information relating to your hearing and your location, we will first obtain your consent before using such information. You may withdraw your consent at any time by either disabling location tracking through your device’s settings, or where possible, using the functions in our Supplied Products and Services to switch off geolocation information tracking, or by terminating HearFon’s access to your account (for example, by deleting a mobile app).
HOW HEARFON COLLECTS INFORMATION?
You Give HearFon Information Directly
We collect the information you give us when purchasing and using our Products and Services. For example, when you download Hearfon Connect app, in order to create a user account, it is necessary for you to provide information to HearFon. The information you give us includes Personal Information, like your name, address, date of birth, gender, height, and audiogram as well as information relating to the programming of your hearing aid, third-party contacts, and any other data that you submit in connection with your use of our Products and Services.
You Give HearFon Information Indirectly (Collected Using Technology like Cookies)
Cookies are small text files that can be stored on your computer by a website that you visit. Cookies are widely used to make websites work, or work more efficiently, as well as to provide web services and functionalities for users.
Cookies may be either “persistent” or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser until its set expiry date (unless deleted by the user before the expiry date). A session cookie, or temporary cookie, will expire at the end of the user session, when the web browser is closed.
Web beacons are small files (also called “pixels”, “image tags”, or “script tags) that may be loaded on our websites, applications, and tools, that may work in concert with cookies to identify our users and provide anonymized data about their activity.
Privacy laws in some jurisdictions require that we obtain your consent before cookies may be stored or accessed on your equipment, except that we do not need consent for cookies that are strictly necessary to provide our Products and Services.
You Authorize a Third-Party to Give HearFon Your Information
You may authorize a third-party, like a Financial Instituition, to give HearFon information about you.
HOW HEARFON SHARES PERSONAL INFORMATION?
Third Parties Designated by You. We may share your Personal Information with third parties where you have provided your consent for us to do so.
External Processing. We may share your Personal Information with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure, email delivery, and other similar services. We require that our third-party service providers use your Personal Information only to provide the services we’ve requested based on our instructions and in compliance with our privacy policies and any other required confidentiality and security measures.
For Legal Reasons. We may share your Personal Information as we believe necessary or appropriate (a) to comply with applicable laws; (b) on reasonable request by a law enforcement or regulatory authority, body, or agency; (c) in the conduct or defense of legal claims; (d) when obtaining professional advice (including legal advice) in relation to audits and our business and consider this in our legitimate interests in managing our business; (e) to enforce our agreements; and (f) to protect our rights, privacy, safety, or property, or that of you or others. We will not delete Personal Information if it is relevant to an investigation or a dispute; relevant information will be stored until such issues are fully resolved.
New Owner of Our Business. We may share your Personal Information with a third-party (new owner) in the case of a merger, acquisition, dissolution, or sale of one or more of our business entities. In that case, we would also be sharing your Personal Information with that third-party’s advisors related to the transaction.
Affiliates. We may share your Personal Information with other companies owned by Hearfon. Our Affiliates are bound to protect Personal Information in accordance with applicable privacy and data protection laws.
HOW HEARFON SECURES INFORMATION WE COLLECT?
HearFon works to secure the information we collect, including by employing administrative and technical security measures to protect information from unauthorized access, loss, misuse, corruption, alteration, and destruction. HearFon uses commercially accepted means to secure your Personal Information, including encryption, but we cannot guarantee its absolute security.
Please contact our Corporate Office immediately if you have reason to believe your Personal Information or any of our Products and Services are not secure or have been accessed without authorization. If you receive a communication that purports to be from HearFon that you believe is suspicious, do not open or respond to it, and please contact our Corporate Office.
YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
Depending on your interaction with HearFon and your use of our Products and Services, HearFon collects and processes your Personal Information on the following legal bases:
HearFon takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.
Opt-out. You can contact us any time to opt-out of (a) promotional and marketing communications; (b) any new processing of your Personal Information that we may carry out beyond the original purpose; or (c) the cross-border transfer of your Personal information. Please note that your use of some features of our App or Products and Services may be affected upon opt-out.
Object. You can ask us to stop using your Personal Information where we no longer need it to provide our Products and Services or for other legitimate reasons.
Access. You can ask us to confirm if we are processing your Personal Information and you can ask at any time to access the Personal Information we have collected from you by contacting us directly.
Update. You can ask us to correct your Personal Information if it is wrong.
Move. You can request to move your Personal Information to other companies. You may ask that we provide your Personal Information in an easily readable format.
Erase and forget. In certain situations, you can ask us to stop using your personal information or delete your information, including where we no longer need it to provide our services to you.
If you wish to exercise any of these rights, please contact us at:
Attn: Admin Officer
HearFon HealthTech Pvt. Ltd.
2, Janardhan Towers, Residency Road
In your request, please clearly state (a) what Personal Information is concerned, and (b) which of the above rights you would like to enforce. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request, usually within a month, and we will tell you if we need additional time.
Please note that, under applicable law, these rights may be qualified, for example, where your information is being used in legal proceedings. We may need to retain certain information for recordkeeping purposes or to complete any transactions that you began before requesting the change or deletion, unless a longer retention period is required or permitted by law (for example, for regulatory purposes).
When you receive promotional emails from us, you can also unsubscribe or opt-out by clicking the link provided in the emails. You cannot opt-out of receiving administrative communications (e.g. communications related to your use of our Products and Services, or related to your hearing care that we are providing).
INTERNATIONAL DATA TRANSFER
HOW LONG WE KEEP YOUR INFORMATION
If you make a request for HearFon to delete your Personal Information, HearFon will keep a record of your request, to honor your request in the future. HearFon will then delete the Personal Information you asked be deleted, subject to any legal retention requirement, or legal exceptions to deletion requests.
Categories of Personal Information
HeaFon collects the following categories of personal information
You may exercise your rights to access and delete data by:
HearFon does not sell your information for money. We do disclose your information to certain third parties that provide valuable services to us, such as analytics and advertising services, which we do not believe is considered a “sale” under the laws.
HearFon will not penalize you, or discriminate against you, for exercising your rights under the law in accordance with law, should you elect to exercise your rights , HearFon will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including by use of discounts, benefits, or penalties; (iii) provide you a different level or quality of goods or services; or (iv) threaten or imply that you may receive a different level of goods or services.
CHANGES TO THIS POLICY
THIRD-PARTY PRODUCTS, SERVICES, AND WEBSITES
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