Easy Line Remote

1. Privacy Notice

In order, among other purposes, to identify you, to enable the functionalities of Easy Line Remote and to improve our service, we will collect some information about you such as  your hearing serial number, information regarding hearing aid settings and hearing aid usage.
Please read carefully the privacy notice. The installation of Easy Line Remote is an acknowledgement that you have read, understood, and agreed to the privacy notice that will apply to any personal data that we collect when you will use Easy Line Remote and/or that we collected through your use of previous version of Easy Line Remote.
 

2. Detailed Privacy Notice 

Privacy Notice

Last updated: 2019 February 7

Sonova AG respect your privacy and are committed to protecting it through our compliance with this notice. This notice describes the types of information we may collect from you or that you may provide when you are using the Easy Line Remote  (the "Application" or “Easy Line Remote”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. You agree that this notice applies to any personal data we will collect through your use of Easy Line Remote and to any personal data we collected through your use of previous versions of Easy Line Remote.

Please read this notice carefully to understand our practices regarding your information and how we will treat it.

If you do not agree with our policies and practices, your choice is not to install the Easy Line Remote application. By installing Easy Line Remote application you agree with this privacy notice.

Controller

The controller of the collected personal information is:
Sonova AG
Laubisrütistrasse 28
8712 Stäfa
Switzerland

The company registration number is:
CHE-101.989.88

Contact details:
If you have any questions about this privacy notice or our privacy practices, please contact our DPO at the following email address: privacy@sonova.com

 

Description of Easy Line Remote

The Easy Line Remote Service consists of:

Easy Line Remote app

Easy Line Remote is a mobile 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. The Easy Line Remote app is available in certain countries and for certain smartphones.

The service enables the following:

  • Basic adjustments of the hearing aid settings (volume adjustment, program selection, ambient balance while streaming, tinnitus masker intensity) based on the settings of your hearing aid
  • Customization of program names in the app
  • Status information of your hearing aid (average wearing time, battery state of charge for rechargeable hearing aids)
  • Auto-On when out of charger configuration for rechargeable hearing aids
  • Status information for hearing aid accessories
  • Satisfaction survey (optional, if you want to share your opinion with us)

Information We Collect and How We Collect It

For identification purposes, during the app start:

  • hearing aid serial number
  • hearing aid settings to offer the starting point for your personal adjustments (program, volume, tinnitus, ambient balance, fitting information for accessories)

Collected from connected hearing aids:**

  • Hearing aid usage data (wearing time, battery state of charge for rechargeable hearing aids)
  • Hearing aid settings (program, volume, tinnitus, ambient balance, fitting information for accessories)

** Connected hearing aids are only hearing aids which can be connected to the Easy Line Remote app

Collected during use of  the app:***

  • Custom program names which can be set by you in the app
  • Privacy Notice (whether Privacy Notice  has been accepted)
  • Connected haring aid information (last connection to hearing aid, Bluetooth name, hearing aid product ID, hearing aid brand information)

***The data is stored locally in the app.

Collected when you agree to participate to our Satisfaction survey:

  • eMail (collection is optional : you can send us your opinion anonymously if you like)

Collected from Third-Party Services in the app:

  • Google Firebase. We will receive non-personal data from Google Firebase such as App usage data, Session time or pages visited. Easy Line Remote uses Google Analytics for Firebase and Firebase Crashlytics, services offered by Google Inc. (“Google”). Google Analytics for Firebase 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. Firebase Crashlytics is a crash reporter that helps us track and fix stability issues that erode your app quality. For this purpose, your Installation Universal Unique Identifier and crash traces will be collected and retained by Google for 90 days. For further information about how Google processes your data when you use our app, please read www.google.com/policies/privacy/partners. You can opt out of the Google Analytics for Firebase and Firebase Crashlytics feature during the onboarding process and in the settings of this app.

We also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data can be derived from your personal data but are not considered personal data in law as they do not directly or indirectly reveal anyone’s identity.

How we use this information (Purpose(s) of Processing)

We use information that we collect about you or that you provide to us :

  • For identification purposes at the start of the App
  • To measure and improve the services and user experience we provide you
  • To assess how you are using the App
  • To contact you (if you use our satisfaction survey and leave us your email address)
  • To support you if you contact us in case of technical problems
  • For scientific and research purposes

We also may process your personal data when it is necessary for other legitimate business purposes associated with the above purposes or when we consider it necessary for complying with laws and regulations.

We may use the information collected through the App or provided by you when using one of our support services also via email to easyline-app@sonova.com .

What is the legal basis for processing the Information?

We will only use the personal data collected when the law allows us to. Most commonly, we will use the personal data collected in the following circumstances:

a. Legitimate Interest: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Examples of these legitimate interests include:

  • Operation and improvement of our business, products, and services
  • Protection from fraud or security threats
  • Compliance with legal obligations

b. Consent: we also process personal data based on the consent you expressly grant to us at the time we collect such data. When we process them based on your consent, it will be expressly indicated to you at the point and time of collection.

c. Other Processing Grounds

From time to time we may also need to process personal data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Automated decision-making and Profiling

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

Who do we share your Information with?

  • Sonova Group: We share only pseudonymized personal data with other Sonova Group companies in order to ensure a consistently high service standard across our group, and to provide services and products to you
  • Third-Party service providers to perform business operations on our behalf. We provide our Third-Party service providers only with the information they need to perform the business operations we request, and we require that they protect this information and they are obligated not to disclose or use it for any other purpose. Among other service providers, we use  Google Firebase, Salesforce.and Survey Monkey (satisfaction survey company),
  • Research Institute such as Universities: We only share with them pseudonymized personal data or aggregated data for scientific and research purposes
  • Other third party providers
  • Public or regulatory authorities: If required from time to time, we disclose personal data to public authorities, regulators or governmental bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so

We may also disclose your personal information

  • As required by law, for example, to comply with a subpoena or similar legal process. 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 information to 3rd parties as part of a legal process
  • As required in response to lawful requests by public authorities, including requests from national security or law enforcement authorities

Please note, that these third parties as mentioned above, may be located outside your country of domicile, including the United States of America, 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.

Where is your data stored?

Your personal data is directly stored in the app. We do not use additional services to store your data.
If you decide to leave your eMail address in the Satisfaction survey (optional) the eMail address is stored in our web account at Survey Monkey. Please check https://www.surveymonkey.com/curiosity/gdpr-how-surveymonkey-protects-you-and-your-respondents/ for further information.

Security of your information

To help protect the privacy of your data and personally information 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 information to provide the Service to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Retention period

We will retain your Personal Information for the duration of your relationship with Sonova as necessary to fulfil the purposes detailed in this Privacy Notice. Following the fulfilment of the purposes your personal information will be deleted when you choose to delete the app, unless a longer or shorter retention period is required or permitted by law or Regulation. Please check section about “Your rights as Data Subject” below for further information.

If you are located in the EU, you have, subject to certain conditions, the following rights:

  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restriction of processing
  • The right to data portability
  • The right to withdraw consent
  • The right to Lodge a complaint with a Supervisory Authority

More detailed information about your rights and how to exercise them can be found in later sections.

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.

Children's privacy

Our Service does not address anyone under the age of 13 ("Children"). We do not knowingly collect Personal Information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we will take steps to remove that information from our servers.

Changes to this Privacy Notice

We may update our Privacy Notice from time to time. You are advised to review the updated Privacy Notice. Changes to this Privacy Notice are effective when they are posted on this page.

 

More detailed information about your rights and how to exercise them

You have full access to all information stored on the app and the right to withdraw your consent to process your personal data and delete your personal data at any time by uninstalling the app from your smartphone.

If you are located in the EU, you have the following rights, subject to certain conditions:

Right to Access

You have the right to access your personal data and supplementary information.

How to exercise
We only store your eMail address outside of the app (if you fill it in the Satisfaction survey).
Please send an eMail to privacy@sonova.com providing details of your request.

Right to Rectification

You have the right to have personal data rectified if it is inaccurate or incomplete.

How to exercise
Your personal information which is collected from the hearing aid is based on your hearing aid information. Please contact your hearing care professional to proceed to any rectification.
Collected information in the app can only be corrected by you (custom program names)
Regarding your eMail address (Satisfaction survey) and for all other information, please send an eMail to privacy@sonova.com providing details of your request.

Right to Erasure

The right to erasure is also known as ‘the right to be forgotten’. This enables you to request the deletion or removal of personal data where there is no compelling reason for its continued processing, for example, where:

  • your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
  • you withdraw your consent and there is no other legal justification to process your personal data
  • the personal data has to be erased in order to comply with a legal obligation

How to exercise
You can withdraw your consent by deleting the app from your smartphone.
Regarding your eMail address (Satisfaction survey) and for all other information, please send an eMail to privacy@sonova.com providing details of your request.

Right to Restriction of Processing

You have the right to request to ‘block’ or suppress processing of your personal data, for example, where:

  • you contest the accuracy of the personal data
  • processing is unlawful, and you oppose erasure and request restriction instead
  • Sonova no longer needs your personal data but you require the data to establish, exercise or defend a legal claim

How to exercise
You can withdraw your consent by deleting the app from your smartphone.
Regarding your eMail address (Satisfaction survey) and for all other information, please send an eMail to privacy@sonova.com providing details of your request.

Right to Data Portability

The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services.
It allows you to move, copy or transfer your personal data easily from Sonova to another Service in a safe and secure way, without hindrance to usability.

How to exercise
Please send an eMail to privacy@sonova.com providing details of your request.

Right to Withdraw Consent

You have the right to withdraw your consent at any time and in an easy way.

How to exercise
You can withdraw your consent by deleting the app from your smartphone.
Regarding your eMail address (Satisfaction survey) and for all other information, please send an eMail to privacy@sonova.com providing details of your request.

Right to Lodge Complaint with SA

You have the right to lodge a complaint with a Supervisory Authority.

How to exercise
Contact details for all EU National Data Protection Authorities can be found here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
This includes contact details for European Free Trade Area (EFTA) Countries including Switzerland.