PRIVACY NOTICE – Vision & Audition

PRIVACY NOTICE FOR WEBSITE USERS

1. Introduction

1.1 At WSA we recognise and respect the privacy of everybody who entrusts us with personal data.

1.2 This Privacy Notice describes how WS Audiology A/S (hereinafter “WSA”, “we”, “us”, “our”) collects and processes your personal data when you visit and use this website. WSA A/S is hereinafter referred to as “WSA”, “we”, “us”, “our”.

1.3 WSA is established in the EU and must therefore comply with European legislation such as 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”).

1.4 WSA controls the ways your personal data is collected and the purposes for which your personal data is used. WSA is therefore the “data controller” under GDPR.

1.5 We will only process your personal data in accordance with this Privacy Notice and applicable law to which we are subject, including GDPR.

2. Contact information

2.1 Questions or complaints regarding our processing of your personal data can be addressed to: WS Audiology A/S Nymøllevej 6 3540 Lynge Denmark E-mail: privacy@wsa.com 2.2 You can also directly contact our DPO, who is the responsible person to answer questions about personal data protection. Please use the following email address dpo@wsa.com.

3. The data we collect, the purpose and the legal basis for processing

3.1 When you visit and use this website

3.1.1 When you visit and use this website, we collect cookies and online identifiers about you and the way you use the website e.g. your browser type, search terms used on the website, your IP-address including your network location and information about your computer.

3.1.2 The purpose of our processing is to optimise the user experience and the website’s functionality including creating statistics. This processing of personal data is necessary for us to pursue our legitimate interest in operating and improving this website (article 6(1) (f) of the GDPR).

3.1.3 The information will be in aggregated form, and we will not use it to identify you. Please see our separate Cookie Policy for further details which can be accessed via the “Consent settings” in the pop up in the bottom left corner of the website. You may read more about the use of cookies in our cookie policy. You may withdraw or change your consent by rejecting cookies in the “Consent settings” or by blocking cookies in your web browser.

3.2 When you use our contact form or shopfinder

3.2.1 If you complete a contact form, or when you use our Shopfinder to make an appointment request or an enquiry with a specific Hearing Care Professional we will process your contact information, your location, the Hearing Care Professional we send your personal data to as well as any information you include in your request. In some cases we will also process information that you have taken a WSA online hearing test. Please note that we will not process the result of the hearing test.

3.2.2. The purpose of our processing is to facilitate your request to check your hearing capabilities, be contacted or to book an appointment. This processing of personal data is necessary for our legitimate interest in engaging with our website users and assist them with finding the right assistance in their country (article 6(1) (f) of the GDPR). If you provide us with sensitive personal data such as health information, we will only process such personal data based on your prior consent (article 9(2) (a) of the GDPR).

4. How is your personal data COLLECTED?

4.1. We will collect some of the personal data about you directly from you, for example when you complete a contact form. When you interact with our website, we will collect technical data about your equipment, browser activity and behavior patterns. We collect these personal data by using cookies and other similar technologies. We will also in some cases collect information that you took a WSA online hearing test.

5. Disclosure of your personal data

5.1 When you use our shopfinder to make an appointment request or an enquiry we will share your personal data with the Hearing Care Professional you have selected to allow the Hearing Care Professional to contact you. If you have completed a WSA online hearing test, we will also share this with the Hearing Care Professional.

5.2 If you use a contact form or book an appointment without selecting a local Hearing Care Professional we will share you enquiry with a local Hearing Care Professional near you to allow that Hearing Care Professional to contact you.

5.3 Your personal data is further disclosed to third parties who process personal data on our behalf, and therefore acts as our data processors. 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 organizational 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 We use servers that are located within the EU. However, some of our data processors may transfer your personal data to a country outside the European Economic Area, including but not limited to the US. The appropriate safeguards to transfer personal data to such third countries are secured by EU Commissions Standard Contract Clauses (GDPR Art. 46).

6.2 Documentation of the Commissions Standard Contract Clauses having been entered into can be obtained on request by contacting us by using the contact information found in section 2.

6.3 Please also be advised that your personal data may also be transferred to a country outside the European Economic Area by our use of cookies on the website. You can read more on this in our cookie policy, which can be accessed via the “Consent settings” in the pop up in the bottom left corner of the website.

7. Your rights

7.1 As a data subject you have the following rights: 7.1.1 You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (art. 15 in the GDPR). 7.1.2 You have the right to request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected (art. 16 in the GDPR). 7.1.3 You may have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. To the extent that continued processing of your personal data is necessary, 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 in the GDPR). 7.1.4 You have the right to object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground (art. 21 in the GDPR). 7.1.5 You may have the right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it (art. 18 in the GDPR). 7.1.6 You have the right to receive the registered personal data in a structured, commonly used and machine-readable format and, in certain cases, to have it transferred from one data controller to another without hindrance (also known as data portability) (art. 20 in the GDPR). 7.1.7 If the processing of your personal data is based on your consent, you are entitled to revoke such consent at any time. Revocation of your consent will not affect the lawfulness of the processing carried out prior to your revocation of consent. You are entitled to withdraw your consent at any time (art. 7 (3) in the GDPR). If you wish to withdraw your consent please contact us by using the contact information in section 2. 7.1.8 Only for France: If you are subject to the French Data Protection Act, you are at any time entitled to issue directives relating to the fate of your Personal Data after death. 7.1.9 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 Phone 33 19 32 00 Email: dt@datatilsynet.dk

8. Data retention

Personal data about your use of the website, cf. section 3.1, will be deleted at the latest, in accordance with our cookie policy which can be accessed via the “Consent settings” in the pop up in the bottom left corner of the website.

Personal data collected as part of your request in a contact form, book an appointment, or via shopfinder, c.f. section 3.2, will be deleted at latest three months after you have submitted the request.

We do, however, reserve the right to retain your personal data for an extended period if deemed necessary to establish, exercise or defend a legal claim or in order to meet our legal obligations.

9. Data security

9.1 We have put in place appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorised way, altered or disclosed. In addition, only employees and contractors who have a relevant and reasonably required need to access your personal data to perform their work have access to your personal data.

10. Changes to this privacy notices

10.1 This Privacy Notice was last updated in January 2021 and will be continuously updated in accordance with current rules and practices as well as in accordance with adjustments in our business procedures. You can always access the latest version on our websites.