1. INTRODUCTION
1.1 This Privacy Notice explains how WSA collects and processes your personal data when you use the Mobile Fitting App/Connexx Fit2Go App (“hereinafter the App”).
1.2 Within the scope of your usage of the App your personal data will be processed in accordance with this Privacy Notice and applicable law to which the Data Controllers designated below are subject, including the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter “GDPR”).
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’).
2. RESPONSIBLES AND DATA PROTECTION OFFICER
2.1 Jointly responsible for the processing of your personal data in the context of the App are:
WS Audiology Denmark A/S,
Reg. no. 40296638
Nymøllevej 6,
3540 Lynge Denmark
Phone +45 44 35 56 00
E-mail: privacy@wsa.com
Sivantos GmbH,
Reg. no. DE30144051,
Henri-Dunant-Straße 100,
91058 Erlangen, Germany
Phone number: +49 91313080
E-mail: privacy@wsa.com
Sivantos Pte. Ltd.,
Reg. no. 198600657G,
18 Tai Seng Street, #08-08,
Singapore 539775
Phone number: +65 6370 9666
E-mail: privacy@wsa.com
You can also directly contact Sivantos GmbH’s and WS Audiology Denmark A/S’ data protection officer (“DPO”), who is the responsible person to answer questions about personal data protection for Sivantos GmbH and WS Audiology Denmark A/S. Please use the following email address: dpo@wsa.com.
2.2 The Controllers (hereinafter also: “WSA”, “we”, “us”, “our”) jointly determine the means and purposes of the processing of your personal data. Consequently, we act as joint controllers and have entered into an agreement that governs our respective responsibilities under Art. 26 of GDPR.
In summary, we have agreed that WS Audiology Denmark A/S is primary responsible for ensuring a lawful basis for our processing and that you are informed of our processing and your rights. Further, WS Audiology Denmark A/S is responsible for responding to any request you may have.
WS Audiology Denmark A/S and Sivantos GmbH are jointly responsible for securing the personal data collected and deleting your personal data.
Notwithstanding the foregoing, you may assert your rights with and against any of the data controllers.
3. THE DATA WE COLLECT, THE PURPOSE AND THE LEGAL BASIS FOR PROCESSING
3.1 You receive a randomly generated access code to enter the App. This code is not stored by us and therefore we are not able to identify you.
3.2 When you use the App, we will collect technical data about the model of your phone or tablet, the operating system and version used and the country where the App is used. Further, we will collect the App name and version, when and for how long a specific feature in the App is used as well as the date the App was installed.
We will compile the data mentioned above and associate it with a random ID that is generated when you install the App.
3.2.1 The processing of these data is necessary to pursue our legitimate interest in maintaining, troubleshooting and performing improvements to the App and in general to improve the products and services offered by WSA (Article 6(1) (f)) of the GDPR).
4. HOW IS YOUR PERSONAL DATA COLLECTED
4.1 All the data we collect and process will be obtained from your App.
5. DISCLOSURE OF YOUR PERSONAL DATA
5.1 Your personal data may be disclosed to third parties who process personal data on our behalf and therefore acts as our data processor(s). We use third parties as hosting providers. We have entered into data processing agreements that comply with article 28 of the GDPR with all our data processors to ensure that such data processors implement appropriate organisational and technical security measures in such a way that the processing complies with the requirements of the GDPR and ensures the protection of your rights.
6. TRANSFER OF YOUR PERSONAL DATA TO THIRD COUNTRIES
6.1 Your data may be transferred to our data processors established outside the EEA. Consequently, the usage of the App may involve a transfer of your personal data to countries outside the EEA. We always ensure that the recipient of your personal data either has an appropriate level of data protection and that the requirements of art. 44 of GDPR are met or that the so-called EU standard contractual clauses of the European Commission have been entered into with the recipient, cf. art. 46 of GDPR.
6.2 If you require further information on the above data transfers, you can request it from us. Please send your request to us as laid out above.
7. YOUR RIGHTS
7.1 You can contact us at any time. You also have one or more of the following rights:
- You have the right to receive information about how we process your personal data as well as to receive a copy of the data we keep about you (art. 15 of GDPR).
- You have the right to ask us to correct any incomplete or inaccurate information that we store about you (art. 16 of GDPR).
- You have the right to ask us to delete your data where there is no good reason for us to keep it anymore. To the extent that we need to keep your data, for example in order for us to comply with our legal obligations or for legal requirements to be established, enforced or defended, we are not required to delete your personal data (art. 17 of GDPR).
- You have the right to object at any time, on reasons relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of art. 6 (1) (f) GDPR (data processing on the basis of a balance of interests).If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate reasons for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising, or defending legal claims (art. 21 of GDPR).
8. You may have the right to ask us to restrict our processing of your personal data. This enables you to ask us to suspend our processing, for example if you want us to establish its accuracy or the reason for processing it (art. 18 of GDPR).
9. You may have the right to receive the personal data that you have provided to us in a structured, common and machine-readable format (“data portability”) and the right to have this data transmitted to another person responsible if the requirement in art 20 (1) of GDPR are present.
If you believe that the processing of your personal data violates data protection law, you also have the right under art. 77 of GDPR to complain to a data protection supervisory authority of your choice. This also includes the data protection supervisory authority responsible for us:
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Denmark
Tlf. 33 19 32 00
dt@datatilsynet.dk
and
Bayerisches Landesamt für Datenschutzaufsicht
Promenade 18
91522 Ansbach
Germany
Phone: +49 (0) 981 180093-0
Telefax: +49 (0) 981 180093-800
E-Mail: poststelle@lda.bayern.de
10. DATA RETENTION
10.1 The data that we process for maintenance and troubleshooting purposes will be deleted within 30 days. The data that we collect, compile and associate with a random ID for performing improvements to the App and in general to improve the products and services offered by WSA are deleted after 3 years.
11. CHANGES TO THIS PRIVACY NOTICES
11.1 We may change this Privacy Notice from time to time. If we make any changes to this Notice, you will be notified.
This Privacy Notice was last updated 05/20/2023.