This Privacy Notice describes how your personal data are collected and processed, related to the Inner Circle and mySuccess dashboards.
The processing of your personal data complies, according to your country, with local data protection 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"), and / or, as may be applicable, the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") for your personal data qualified as Protected Health Information.
1. Who we are
Sonova US Inc, 750 N. Commons Drive, Aurora, Illinois, USA acts as a Controller for the processing listed in the following section.
2. Personal data we collect from you and why
If you decide to enroll in Inner Circle / mySuccess, a program which permits you to earn points and access business and marketing services, please note that we will need to process your name, surname, email address, telephone number and credentials to manage your registration. This processing is based on your consent.
Furthermore, to improve the functions of the platform, we will analyze analytics data (e.g. Dashboard usage, length of viewing per page, clickthrough data to support materials). This processing is conducted through the usage of cookies and therefore it is based on the logics of our cookie privacy notice, which you can consult here.
3. How we share your personal data
Your personal data will be processed according to the instructions we provide to our employees who have received the necessary training in data protection and are subject to an obligation of confidentiality.
Your personal data may also be disclosed to:
- Other companies in our group of companies, such as our subsidiaries, all of which are required to protect personal data in accordance with applicable privacy and data protection laws;
- Our business partners, contractors, and third-party service providers. These third parties only process personal data that are strictly necessary for the services they provide to us, according to our instructions and in compliance with our privacy and security requirements.
- Other organizations and public bodies, supervisory and control authorities, including law enforcement agencies, as may be required by law.
4. International personal data transfers
Please note that some of the above-mentioned third parties can be located outside your country. Therefore, your personal data may be transferred to countries that do not provide the same level of protection of personal data as your own country. In such cases, we will implement adequate measures including appropriate organizational, technical, and legal safeguards in order to govern the relevant transfer and to ensure the necessary level of protection is established under applicable law.
5. How long we keep your personal data
We will retain your personal data for a minimal period proportional to the time required to fulfil the purposes outlined in Section 2. For example, relevant personal data will no longer be retained if you delete your account or if our contractual obligations are fulfilled. 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.
For processing based on the consent you may have given, your personal data are processed until you revoke the consent you freely decided to give us.
6. Your legal rights
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. You can exercise your right to object by contacting us at firstname.lastname@example.org.
You can de-activate your account and/or close the membership by contacting us at email@example.com for the Inner Circle program and at firstname.lastname@example.org for the mySuccess program.
Please note that the exercise of such rights is subject to the limitations provided by applicable law.
7. How to contact us
In the event of questions about this Privacy Notice, or the processing of your Personal Data, please contact our Data Privacy Team at email@example.com.
CONSENT- Web consent:
☐ I confirm I have read and understood the Privacy Notice and I agree to the processing of my personal data to manage my subscription to the Phonak Loyalty Portal.