Data controller
References in this Privacy Policy to “Beltone”, “we”, “us” or “our” shall mean GN Hearing A/S (a company registered in Denmark and the owner of the Resound, Beltone and Interton brands). Being a Data Controller (as defined herein) means Beltone is committed to protecting your privacy rights in accordance with the privacy and data protection laws that may apply to you, including the California Consumer Privacy Act (“CCPA”), and the General Data Protection Regulation (“GDPR”)..
We are part of a corporate group of companies (“GN Group”), which includes entities in several countries as shown on our websites www.resound.com, www.beltone.com, www.interton.com.
The entity responsible for the processing of your personal information (formally called the “Data Controller”) is:
GN Hearing A/S
Lautrupbjerg 7
DK-2750 Ballerup
Denmark
Reg. no. 55082715
Telephone number +45 45 75 11 11
Data protection officer
If you have questions or concerns in relation to data protection, you are always welcome to contact via this form or by phone +45 45 75 00 00
Personal data we collect about you
When using the term “personal data” in this policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we possess. Your personal data may include for example your name, your contact details, information relating to purchases or information on how you use our websites and apps or how you interact with us.
We collect personal data from you, for example when you use our websites or apps, use our services or contact us.
The data we collect
We may collect and process the following categories of information about you:
A) Contact details
When you take an online hearing test or wish to find a hearing care professional close to you we may ask for your name, telephone number and email address to be able to contact you. If you create an account on our website / when you purchase our products we will also ask for your address, to be able to send the products to you.
B) Hearing tests
In order to perform hearing tests, contacting you by means of any communication methods (including phone, email, direct mail etc.), to discuss test results, hearing care, surveys and scheduling a hearing test, we will ask for your consent to collect and process contact details about you and the result from your hearing test. It will also include a right to share the data with your local hearing care professional.
C) In order to manufacture, deliver and repair hearing aids we may register information such as serial number, fittings, audiograms and contact information about you if provided by you or hearing care professionals.
D) User IDs and Passwords
Provides you with access to your profile areas on our web shops or other digital applications (on websites).
E) The communications you exchange with us, e.g. emails, letters, calls, messages or our online chat service Used to raise and respond to issues and inquiries of all types. Also used to distribute information about Beltone’s products and services.
F) Information about payments When purchasing products at Beltone’s websites, we cooperate with third party payment providers. We will not have access to your payment details. We refer you to the payment providers privacy policies
G) Beltone Internet Protocol Reporting
Beltone uses your IP (Internet Protocol) address to monitor web site traffic and to help diagnose problems with our server. We do not use IP addresses to personally identify users
H) Use of data cookies
We kindly refer you to our Cookie policy. You can find the Cookie policy on our websites.
I) Apps
When you download the app and use the app, Beltone may collect information about device specific information such as your mobile device unique device id, the type of mobile device you use, the ip address of your mobile device, bluetooth name, bluetooth mac address and your mobile operating system.
Apps for use with wireless hearing aids:
In general, Beltone collects aggregated, non-personally identifiable data across all the active app users by analyzing how the application features are used in general. This could be information about how extensively a feature is used and when the feature is typically activated. Also, we can tell if the volume bar is used by a majority of all users but we are not tracking your individual use of the volume bar.
Some of our apps will allow you to receive firmware updates, remote fine tuning services and receiving customer services, to get the most out of your hearing instrument. If this is the case, we will be asking for your acceptance when installing the app. Use of the app is optional and gives you the added benefit and flexibility of being able to receive firmware updates etc, but as a result of this, some of your personal information will need to be processed in the manner described below. By using the app, you will be allowing us to access and process the information below about you and your use of the app: The hearing instrument’s serial number, hardware identification number and software version, hearing instrument settings, the length of time you use your hearing instrument, device type information and technical log information and the location (when you have accepted the GPS-enabled services).
To receive remote fine tuning services you have to contact your hearing care professional, and sign a consent. We kindly refer you to the privacy notice that you received when you consented to the remote fine tuning services.
If you withdraw your consent you will not be able to receive firmware updates for your hearing instrument via the app. If you withdraw your consent to receive remote fine tuning services you will not be able to use this service. If you are using the location service, you are free to switch off the location and GPS function on your mobile device at any time and prevent the collection and processing of this information.
Apps for use without a need of hearing aids:
Some of our apps allow you to subscribe to functionality, for example, to create your own plan for managing tinnitus. No personal data beyond what is mentioned above in this section I (device specific information) will be processed in this regard.
Payment for subscription management apps is handled either through Apple Appstore and your iTunes account or through your Google Play Store account, Beltone will not have access to your payment information. We refer you to the payment service providers personal data policies.
J) Additional personal data we collect about you as hearing care professional or business partner.
In addition to the above we collect information from business related interactions that we plan to have or have had with you as a hearing care professional or a business partner. We collect and process only the information necessary to be able to contact and/or follow up with you to maintain the professional relationship and to deliver the agreed customer service level.
We may collect and process the following categories of information about you as a heath care professional or business partner:
a) Customer Relations and Service Management
To professionally manage our customer and partner relations, we record the date, contact data, purpose and agreed outcomes of meetings and events with customers and partners. In addition, we store information about Beltone product’s service provided to customers based on enquires from customers and partners when related to Beltone product quality and product application.
b) Training
To enable professional use of Beltone products and deliver training qualified by third party as merited continued medical education, we store customer’s contact name, date and content of training provided.
Collection of personal data
We collect your personal data from the following source(s):
a) directly from you, such as the information you enter the app or other forms or information you provide to Beltone through our websites or oral communication;
b) directly from the apps and the use of the websites;
c) from hearing care professionals.
Purposes and legal basis for processing of personal data
Beltone limits its collection, storing and processing of personal data to situations where a specific purpose exists. With reference to the EU General Data Protection Regulation (GDPR), we have listed the most relevant purposes and some of our activities associated with the purposes.
We process your personal data on the following legal bases:
a) Article 6.1.a (Consent):
E.g. when you have accepted to receive newsletters from us, using location service in an app or accept firmware updates of an app.
b) Article 6.1.b (Necessary for the performance of the contract between you and Beltone):
E.g. when it is necessary for Beltone to process your personal data to be able to sell and send products to you.
c) Article 6.1.f (Necessary for the pursuit of legitimate purposes of Beltone)
E.g. when Beltone stores some of your personal data with the purpose of administration resources on various projects.
Any collected application usage data is an important part of ensuring that we always provide, maintain, protect and improve the services, Beltone offers. Further, it enables us to identify the need to improve existing functionality and develop new apps
d) Article 9.2.a (explicit consent)
Health data when Beltone stores data regarding remote fitting, or online hearing test (including your consent to share the hearing test result with a local hearing care professional).
Recipients of personal data
Beltone will generally limit sharing your personal data and always only to the extent necessary. However, we might share your personal information with:
• Hearing Care Professionals, suppliers, business partners and vendors that we work with to assist our business (meaning service providers, technical support, payment services, webshop providers, analytics providers, supply services, and financial institutions);
• Other collaborators (such as internet providers);
• Group entities;
• Public authorities.
Certain business partners and vendors process personal information on behalf of Beltone and may only process your personal data in accordance with the instructions given by Beltone and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. These third parties may not process your personal data for their own purposes. To the extent Beltone disclose or transfer your personal data to these third parties who may use your personal data for their own purposes, such disclosure or transfer will only take place if it is in accordance with applicable law or with prior consent obtained from you.
From time to time authorized third parties may need access to some of your personal information. For example, if Beltone ships something to you, it is necessary to provide your name and address to a shipping company. We strictly limit third party access and use of your personal information.
We may share aggregated information publicly and with companies, organizations or individuals outside of Beltone or with our partners, which could be publishers, advertisers or connected sites. For example, we may share aggregated information publicly to display trends about the general use of our applications.
If Beltone is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of the mobile application information and give affected users notice before information is transferred or becomes subject to a different Privacy Policy.
International Data Transfer
To the extent possible and where allowed by applicable law, we may transfer your personal data outside of the country you are located in. Beltone’s products and services may be delivered using servers and other technical resources in various countries, including, but not limited to, the United States. In the event that we transfer personal information outside the country or region you are located in, we will take all reasonably necessary steps to protect and safeguard your personal data. Beltone. Such transfers will only take place for the specific purposes mentioned herein, and we will always ensure that appropriate safeguards are in place for such transfer as set out below, either:
a) If the country/countries has/have been deemed by the Commission of the European Union to have an adequate level of protection of personal data, or using EU US-Privacy Shield; or
b) If the country/countries has/have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data, we will provide appropriate safeguards for the transfer, either through the use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities. You may obtain more information about the contract/agreement by contacting us.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Pursuant to the California Consumer Privacy Act (CCPA), we are required to provide all California residents with certain information about how we handle their personal information.
CCPA Categories of Personal Information
Beltone may collect the following categories of personal information identified under CCPA; however, not all examples listed below are collected from every consumer:
1. Identifiers
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
3. Protected classification characteristics under California or federal law
4. Commercial information
5. Biometric information
6. Internet or other similar network activity
7. Geolocation data
8. Sensory Data
9. Professional or employment-related information
10. Inferences drawn from other personal information
Beltone may collect this information when you visit our websites or purchase and/or use our products and services. We collect your personal information because it is necessary to provide, operate, maintain and support our products and services, as well as to administer and promote our business. We are providing this notice to comply with the CCPA, as amended. Any terms defined in the CCPA have the same meaning when we use them in this notice. We encourage you to refer to the other sections of our Privacy Policy for further detail, including the sections Purposes And Legal Basis For Processing of Personal Data and Personal Data We Collect About You. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Your Choices and How to Exercise Your Rights
The CCPA provides consumers (California residents) with specific rights regarding their personal information. Subject to specific limitations under the CCPA, California residents have the right to make the following requests:
1. You have the right to request that Beltone disclose certain information to you about our collection and use of your personal information over the past 12 months and to request a copy of the specific pieces of personal information that we have collected about you in the previous 12 months.
2. You have the right to request that Beltone delete any of your personal information we collected from you and retained, subject to certain exceptions
3. While we do not sell personal information about California residents, California residents also have the right to opt-out of the sale of their personal information by Beltone.
The categories of third parties with whom we share personal information depend on, among other things, our relationship or interaction with a specific California resident. Beltone may disclose your information to certain third parties that provide valuable services to us. Examples include companies or organizations to whom we provide products or services; outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; other parties, partners, and financial institutions.
Please contact our Data Protection Officer (DPO) here; or by phone +45 45 75 00 00 for the following:
1. To exercise the access, data portability, deletion, and do-not-sell rights described above
2. To request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes, as permitted under California Civil Code § 1798.83, please contact us and indicate whether you are a California resident.
3. Inquire about how we respond to web browser “Do Not Track” signals (Note: Our websites may not be able to support “Do Not Track” codes. Beltone may not currently respond to or take any action regarding “Do Not Track” requests.)
Exceptions
The CCPA does not apply to medical information collected by a covered entity governed by the Health Insurance Portability and Accountability Act (HIPAA) or California Confidentiality of Medical Information Act (CMIA); entities subject to HIPAA or CMIA; or information collected as part of a clinical trial;
Non-Discrimination
California consumers have the right to exercise their access, deletion and other rights without discrimination, and to receive transparent disclosures about any incentives a business offers them with regard to the collection, use and disclosure of their personal information.
In the event that you exercise your rights under CCPA, Beltone will not penalize you, or discriminate against you in any manner, including, but not limited to: (i) denying you goods or services; (ii) charging you different prices or rates for goods or services, including by use of discounts, benefits, or penalties; or
(iii) providing or threatending to provide you a different level or quality of goods or services.
Retention policy
Your personal information will be stored for as long as it is necessary in order to fulfil the purposes described above and comply with minimum retention periods under applicable law.
Withdrawal of consent
We hereby inform you, that when the processing of your personal data is based on your consent, you may withdraw your consent at any time.
However, please note that this does not affect Beltone's processing of your personal data prior to withdrawal of your consent.
You may withdraw your consent here. In some apps, you can also notify us within the app.
Opting out, uninstall apps and unsubscribe
By using Beltone's website(s) and/or apps, you consent to receiving promotional emails and/or text messages from Beltone. In spite of the fact that your mobile phone number(s) may otherwise be on the federal, or a state's Do Not Call List, you agree that, to the maximum extent permitted by law, your consent overrides any prior Do Not Call request. You may opt out of receiving promotional emails or text messages from Beltone by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
We provide users the opportunity to opt out of receiving any further communications from Beltone when they receive distributions via e-mail. At the end of each email message, instructions on how to unsubscribe and be removed from the mailing list database are included. Beltone also gives users the option of contacting Beltone at any time to remove their information from our database or to stop receiving future electronic distributions.
You can stop all collection of information by the app easily by uninstalling the app. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. If you uninstall the app all future collection of information by Beltone will stop through the app.
Your rights
As the data subject we would like to inform that Beltone has taken all necessary and adequate steps in order to protect your personal data and ensure your rights. Please note, that there may be more conditions or limitations to these rights than stated below.
Right of access
You have the right to request access to any personal data which we have processed about you and additional information in relation to the processing.
Right to rectification
You have the right to get inaccurate personal data that we have stored about you rectified. That includes completion of incomplete personal data.
Right to erasure (right to be forgotten)
Under certain circumstances, you have the right to erasure, which means that upon your request, we will erase stored personal data about you.
Right to object
Under certain circumstances, you have the right to object at any time to our processing of personal data about you. In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
Right to restriction
Under certain circumstances you have the right to restrict our processing of personal data about you.
Right to data portability
Under certain circumstances, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format, and the right to have your personal data transferred to another data controller.
Exercising your rights
You may take steps to exercise your rights here
Security measures
Beltone protects the personal information you make available to us.
It is Beltone's wish to make you feel confident and informed when using our websites and apps.
Beltone is very committed to protecting Beltone, our business partners and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information in our possession. In particular:
• We encrypt data communication using strong encryption (128 or 256-bit SSL).
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to your personal information to Beltone employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Filing of complaint
If you wish to file a complaint regarding Beltone’s processing of your personal data, please contact our DPO (contact details above, section 2).
Please note that you are also entitled to contact the Danish Data Protection Agency in case of complaints that we are not able to resolve.
Danish Data Protection Agency (Datatilsynet)
Borgergade 28, 5
DK-1300 Copenhagen K
Telephone number: +45 33 19 32 00
Email address: dt@datatilsynet.dk
Website: www.datatilsynet.dk
Changes to the privacy policy
This Privacy Policy will be updated on a regular basis and when necessary due to changes in applicable law. The Privacy Policy will always include information on the effective date of the latest version. We will post any Privacy Policy changes on the Beltone webpage and notify you by updating this Privacy Policy as part of a general application update. If the changes of this Privacy Policy are regarded as material and significant, you will be expressly informed hereof.
Mobile applications Terms of Use
Beltone apps are intended to be used with Beltone’s wireless hearing instruments. Beltone’s apps send and receive signals from the Beltone wireless hearing instruments via selected mobile devices for which the apps have been developed. Notifications of application updates should not be disabled, and it is recommended that the user installs all updates to ensure that the application will function correctly and will be kept up to date. The application must only be used with Beltone devices for which it is intended. Beltone takes no responsibility if the application is used with other devices. Any and all liability arising directly or indirectly from the use of this application is hereby disclaimed. The information herein is provided "as is" and without any warranty expressed or implied. All direct, indirect, special, incidental, consequential or punitive damages arising from any use of this application or data contained herein is disclaimed and excluded.
Website Disclaimer
This site may include educational information related to certain ailments, physical conditions and their treatment. Any such information should not and may not be used as a substitute for a medical diagnosis or treatment. You should seek the advice of your physician or other qualified health care provider prior to starting any treatment or if you have any questions related to your health, physical fitness or medical conditions. Beltone is not engaged in the provision or practice of medical, nursing, or health care advice or services. GN HEARING DOES NOT WARRANT THE COMPLETENESS, CORRECTNESS, TIMELINESS, USEFULNESS OR ACCURACY OF ANY OF THE INFORMATION PROVIDED ON THIS SITE. It is your responsibility to verify all information before relying on it.
This website may contain links to other websites operated by third parties other than Beltone. Such links are provided for your convenience only. Beltone disclaims any control over, relationship with, or endorsement of any third party sites that this site may contain links to. You are advised to use discretion and judgment in browsing www.Hearing.com and any sites related or linked to it. The Internet contains material which may be inappropriate or sexually explicit, may be offensive to you, or may contain inaccurate information which may violate copyright, libel or defamation laws.
If you purchase merchandise or services from third parties or websites, Beltone is not a party to that transaction and has no liability or responsibility with respect to that transaction. NOTHING CONTAINED IN THIS SITE SHOULD BE CONSTRUED AS CONSTITUTING ANY PRODUCT WARRANTY OR AS EXPANDING OR OTHERWISE MODIFYING ANY PRODUCT WARRANTY. SEE YOUR HEARING AID DISPENSER FOR DETAILS REGARDING GN HEARING'S LIMITED PRODUCT WARRANTY.
Beltone cannot warrant or guarantee that any downloaded files from this site or from any site linked to it are free from error, viruses, or other destructive properties. You agree to assume all risk in downloading files or in retrieving any information from www.Hearing.com or any sites related or linked to it. You acknowledge that you have been advised that you should take all necessary steps to protect your computer and files from erasing, destruction, corruption or other malfunction.
Cookie Policy
About cookies
Cookies are information packets sent by web servers to web browsers, and stored by the web browsers. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers.
There are two main kinds of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, whereas persistent cookies remain stored on your computer until deleted, or until they reach their expiry date.
Cookies on our website
www.beltone.com uses the following cookies on this website, for the following purposes: SessionID cookie to remember contents of “compare basket” for product comparison. Disabling this cookie will cause www.resound.com to “forget” your comparison choices. For additional information on collection of personal information, see our Privacy Policy.
Third party cookies
When you use this website, you may also be sent the following third party cookies, which may be used for the following purposes: www.beltone.com uses Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The duration of ther cookie is throught the session, an interaction term between a visitor's browser and a particular site. When a user visits a page on the website, it creates a session. A user session expires after 30 minutes of inactivity by the user.The information generated relating to our website is used to create reports about the use of the website.
www.beltone.com uses sIFR fonts for headings. sIFR fonts are based on Flash and a cookie named sifrFetch is set to indicate whether the browser supports Flash and thus sIFR or not. Disabling this cookie can cause error messages to appear in older browsers. The cookie expires at the end of a session.
Refusing cookies
Blocking cookies will have a negative impact upon the usability of some websites.
Most browsers allow you to refuse to accept cookies.
For more information about how to manage cookies in common browsers visit www.beltone.com.