Privacy Policy

Sounds Delightful Hearing

EFFECTIVE 1 AUG 2020

INTRODUCTION

At Sounds Delightful Hearing, we value your business and respect your privacy. We are committed to protecting your privacy rights in accordance with the privacy and data protection laws that may apply to you, including t the General Data Protection Regulation (GDPR). For purposes of the applicable Data Protection Laws, Sounds Delightful Hearing is the “data

controller”. This means that Sounds Delightful Hearing determines the purposes for which, and the manner in which, your Data is processed.

This privacy policy describes your privacy rights related to information that you share with Sounds Delightful Hearing,
and how you contact us to exercise those rights. In addition, this privacy policy describes how Sounds Delightful Hearing collects, uses and shares information that can identify you. Services means our websites and audiologist provision.
Sounds Delightful Hearing will collect, process and share your Personal Information in accordance with this

WHO WE ARE

In this privacy policy, “Sounds Delightful Hearing”, “we”, “us” and “our” refers to the Sounds Delightful Hearing entity that you are interacting with, or that is providing you with our Services related to which you are sharing your Personal. Information.

You can contact Sounds Delightful Hearing’s Data Protection Officer at:

Sounds Delightful Hearing

Arena Business Centre, 100 Berkshire Place, Winnersh, Wokingham, RG41 5RD

Call: 0118 405 0112

Email: info@soundsdelightfulhearing.com

WHAT PERSONAL INFORMATION Sounds Delightful Hearing COLLECTS AND WHEN

Sounds Delightful Hearing collects the following information, including Personal Information, when you interact with us and use our Services:

Purchase and Warranty Information: means information, including Personal Information, that you may provide to us when you purchase Sounds Delightful Hearing Services, including related to your rights under a product warranty. Purchase and Warranty Information may include your financial information; contact information, such as your name, delivery and billing address, phone number and email address; product identification information, like hearing aid serial numbers; and health information like your audiogram or an impression (mould) of your ear.

Website Information: means information that you enter directly or otherwise provide or disclose, including Personal Information, when you use or access any of our websites. Website Information includes information about the technology that you used to access our website, including the IP address, Internet service provider, browsers, apps and devices. Website Information also includes details of your activities while on our websites, like how long you visited a webpage, the content that you clicked on or accessed and information about other sites that you visited before or after our website. Website Information includes anything that you submitted via the website like a webform to “contact us”, the content of any “chat” communications you have with us through our websites or while applying for a job through an employment-related function of our websites.

Hearing Device and App Usage Information: means information, including Personal Information, that you provide or that is generated during your use of the hearing aid devices that we sell. Hearing Device and App Usage Information includes:

Information that you enter for hearing device and app functionality, including your name, address, date of birth, gender, height, weight and audiogram, as well as information relating to the programming of your hearing aid, any
third-party contacts you have identified and any other data that you submit in connection with your use of the hearing device and app.
Information about app usage and app features, like when you activate and use a particular feature and the extent or duration of use. This helps Sounds Delightful Hearing Sounds Delightful Privacy Policy v1.1 01.08.2020 Date reviewed: 8.01.2024 Date of next review: 08.01.2026 to provide optimal functionality and overall user experience. Sounds Delightful Hearing also logs certain technical information, including information related to Internet protocol and device event information such as crashes, system activity, hardware settings and the date and time of your request.
Use time and classification of the environment in which the hearing aids are being used. This is necessary for Sounds Delightful Hearing to provide certain features and functionality of our Products and Services. You can disable the collection of this data, but doing so may limit the functionality of our Products and Services. Health and Patient Information: means information collected from you when you request an appointment, including your name and contact information, like telephone number or email address, as well as information about your hearing care needs, including health information, and your preferences for how we contact you.

Communications Information: means information that you provide while communicating with Sounds Delightful Hearing, in any way, for any reason, which may include Personal Information. Communications Information includes the information that you provide over the phone, which may include your name, phone number, address, email address, device serial number as well as the content of any phone calls you have with us.

Your Information Shared by a Third Party Who You Authorised: means your Personal Information that is provided to us by a third party, because you authorised the third party to share it. For example, you may authorise your insurance company or a hear care manufacturer to share your Personal Information with Sounds Delightful Hearing, which may include your contact information, financial information and health information. Anonymous Information: means information that does not allow you to be identified or otherwise make you identifiable. In some cases, Sounds Delightful Hearing may aggregate and de-identify data to remove all information that could be used to specifically identify you, thereby rendering it anonymous. Anonymous Information is not considered Personal Information in this privacy policy, or by applicable law.

WHY Sounds Delightful Hearing COLLECTS YOUR PERSONAL INFORMATION

We collect your Personal Information because it is necessary to provide the services, features or functionality of our Services that you have elected to use. Sounds Delightful Hearing also collects your Personal Information for legitimate business purposes, to protect Sounds Delightful Hearing and its customers, and for legal reasons. We only collect and process your Personal Information based on our legitimate interests when we have determined that our legitimate

interests are not outweighed by your privacy and data protection rights.

Depending on your interaction with Sounds Delightful Hearing, and your use of our Products and Services, Sounds Delightful Hearing may collect your Personal Information for the following reasons:

providing you with access to and use of our Services, either independently or with the assistance of a third party you have authorised;
operating, maintaining and improving our Services;
entering, performing and terminating a contract with you;
scheduling and communicating with you about your appointment;
assembling and processing your job application;
sending you important administrative notifications or confirmations, as well as technical notices about things like recalls, updates and security alerts;
responding to your comments and questions and providing you with customer support;
preventing abuse of our Services, and investigating or prosecuting any potential threat or misuse;
to protect, investigate and deter against fraudulent, unauthorised or illegal activity;
protecting the rights and property of Sounds Delightful Hearing and its customers, including in the event of legal claims;
tracking and analysing our advertising and promotional efforts;
sending you marketing or promotional communications that may be based on your behaviour and Personal Information, and that may include social notifications, surveys or other newsletters depending on your settings; and
fulfilling any purpose for which you have given us your consent.

Some features of our websites allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via email phone call or text message. The written response or confirmation may include your Personal Information, including your name and contact information. We cannot guarantee that our emails to you will be secure from unauthorised interception.

When required by law, we will obtain your consent before sending you certain marketing communications. You can withdraw consent at any time by contacting our Data Protection Officer. See the Who We Are section of this privacy policy for details. You may also opt-out of receiving future marketing information, like marketing emails, at any time, by using the

instructions provided in marketing communications.

HOW Sounds Delightful Hearing COLLECTS INFORMATION

You Give Sounds Delightful Hearing Information Directly We collect the information that you give us when using our Services. For example, when you complete a wax removal questionnaire. The information you may give us may include Personal Information, as well as information relating to your hearing and any other data that you submit in connection with your use of our Services.

You Give Sounds Delightful Hearing Information Indirectly (Collected Using Technology like Cookies) We use tracking technology like cookies to collect information about how you use Services, and to provide you with essential services, functionality and personalisation of our Services. The purpose of this section is to provide you with the necessary information regarding our use of cookies, and the storage of such cookies on your device when you access our websites,
to enable you to choose whether to allow cookies to be placed on your device.

Cookies are small text files that can be stored on your computer by a website that you visit. Cookies are widely used to make websites work, or work more efficiently, as well as to provide web services and functionalities for users.

Cookies may be either “persistent” or “session” cookies. A persistent cookie consists of a text file sent by a web server to
a web browser, which will be stored by the browser until its set expiry date (unless deleted by the user before the expiry date). A session cookie, or temporary cookie, will expire at the end of the user session, when the web browser is closed.

Web beacons are small files (also called “pixels”, “image tags” or “script tags”) that may be loaded on our websites, applications and tools, which may work in concert with cookies to identify our users and provide anonymised data about their activity.

Privacy laws in some jurisdictions require that we obtain your consent before cookies may be stored or accessed on your equipment, except that we do not need consent for cookies that are strictly necessary to provide our Services.

Essential Cookies are necessary to provide you with core website functionality, personalisation and browsing history. For example, a preference cookie is required to maintain a record of your consent or non-consent preferences so that we may respect them for future visits. These can only be disabled by changing your browser preferences. Sounds Delightful Hearing does not share this information with third parties.
Functionality Cookies help us to customise our website content based on your preferences, to provide you with a more personal experience on our websites. The information that these cookies collect may be anonymised and does not include browsing activity on third-party websites.
Analytics Cookies are used to collect information about traffic to our websites and user activity on our websites. The information is aggregated and anonymous and does not identify any individual visitor. It includes the number of visitors to our websites, the pages visited and other similar information. We use this information to help operate, maintain
and improve our websites.
Social Media Cookies. We allow users to share links to our websites on social media sites like Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work.
Disabling Cookies. Most web browsers allow the control of cookies through the browser settings. By adjusting your web browser, you may avoid receiving cookies. However, this might result in the website not functioning optimally. The method used to block cookies will depend on the web browser used. Consult the “Help” or corresponding menu in your web browser for instructions.

To find out more about cookies, including how to see which cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. We do not currently respond to Do Not Track signals sent by the browser.

You Authorise a Third Party to Give Sounds Delightful Hearing Your Information

You may authorise a third party, like an insurance company or medical professional, to give Sounds Delightful Hearing information about you. For example, you may authorise your insurance company to provide your Personal Information to Sounds Delightful Hearing, which may include your contact information, financial information and health information. We also collect Personal Information about you through websites that refer you to us like Wax Removal UK.

HOW Sounds Delightful Hearing SHARES PERSONAL INFORMATION

Third Parties Designated by You. We may share your Personal Information with third parties where you have provided your consent for us to do so. One example would be: if you we need to send a hearing aid back to the manufacturer for serving under a warranty, they could receive certain Personal Information about you.

External Processing. We may share your Personal Information with our third-party service providers who provide services such as payment processing, manufacturer warranty and servicing, information technology and related infrastructure, email delivery and other similar services. We require that our third-party service providers use your Personal Information only to

provide the services that we’ve requested based on our instructions and in compliance with our privacy policies and any other required confidentiality and security measures.

For Legal Reasons. We may share your Personal Information as we believe necessary or appropriate (a) to comply with applicable laws; (b) on reasonable request by a law enforcement or regulatory authority, body or agency; (c) in the conduct or defence of legal claims; (d) when obtaining professional advice (including legal advice) in relation to audits and our business and consider this in our legitimate interests in managing our business; (e) to enforce our agreements; and (f) to protect our rights, privacy, safety or property, or that of you or others. We will not delete Personal Information if it is relevant to an investigation or a dispute; relevant information will be stored until such issues are fully resolved.

New Owner of Our Business. We may share your Personal Information with a third party (new owner) in the case of a merger, acquisition, dissolution or sale of one or more of our business entities. In that case, we would also be sharing your Personal Information with that third-party’s advisors related to the transaction.

Affiliates. We may share your Personal Information with other companies owned by Sounds Delightful Hearing (Affiliates). Our Affiliates are bound to protect Personal Information in accordance with applicable privacy and data protection laws.

HOW Sounds Delightful Hearing SECURES INFORMATION THAT WE COLLECT

Sounds Delightful Hearing works to secure the information that we collect, including by employing administrative and technical security measures to protect information from unauthorised access, loss, misuse, corruption, alteration and destruction. Sounds Delightful Hearing uses commercially accepted means to secure your Personal Information, including

encryption, but we cannot guarantee its absolute security.

Please contact our Data Protection Officer immediately if you have reason to believe that your Personal Information or any of our Products and Services are not secure or have been accessed without authorisation. If you receive a communication that purports to be from Sounds Delightful Hearing that you believe is suspicious, do not open or respond to it, and please

contact our Data Protection Officer.

YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are located in the European Economic Area, you have certain data protection rights under

the GDPR. Depending on your interaction with Sounds Delightful Hearing and your use of our

Services, Sounds Delightful Hearing collects and processes your Personal Information on the

following legal bases:

As necessary to enter into, perform or terminate a contract with you, and to provide you with, and facilitate your use of, our Products and Services.
Because you have provided consent.
As necessary to operate our business and pursue our legitimate business interests, where our interests are not overridden by your privacy and data protection rights.
To comply with the law.

Sounds Delightful Hearing takes reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information.

Opt-out. You can contact us any time to opt out of (a) promotional and marketing communications; (b) any new processing of your Personal Information that we may carry out beyond the original purpose; or (c) the cross-border transfer of your Personal Information. Please note that your use of some features of our Services may be affected upon opt-out.

Object. You can ask us to stop using your Personal Information where we no longer need it to provide our Services or for other legitimate reasons.

Access. You can ask us to confirm if we are processing your Personal Information and you can ask at any time to access the Personal Information that we have collected from you by contacting us directly.

Update. You can ask us to correct your Personal Information if it is wrong.

Move. You can request to move your Personal Information to other companies. You may ask that we provide your Personal Information in an easily readable format.

Erase and forget. In certain situations, you can ask us to stop using your Personal Information or delete your information, including where we no longer need it to provide our services to you.

If you wish to exercise any of these rights, please contact us at:

Sounds Delightful Hearing

Arena Business Centre, 100 Berkshire Place, Winnersh, Wokingham, RG41 5RD

Call: 0118 405 0112

Email: info@soundsdelightfulhearing.com

In your request, please clearly state (a) what Personal Information is concerned, and (b) which of the above rights you would like to enforce. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request, usually within a month, and we will tell you if we need additional time.

Please note that, under applicable law, these rights may be qualified, for example, where your information is being used in legal proceedings. We may need to retain certain information for record-keeping purposes or to complete any transactions that you began before requesting the change or deletion, unless a longer retention period is required or permitted by law (for example, for regulatory purposes).

When you receive promotional emails from us, you can request to unsubscribe or opt out by contacting us. You cannot opt out of receiving administrative communications (e.g. communications related to your use of our Services, or related to your hearing care that we are providing).

INTERNATIONAL DATA TRANSFER

Where allowed by applicable law, Sounds Delightful Hearing’s Products and Services may be delivered using servers and other technical resources in various countries, including the United States. Therefore, your Personal Information may be transferred and processed outside of the country you are located in, including outside of the European Economic Area (EEA). If we transfer Personal Information outside the country or region you are located in, we will take steps to protect and safeguard your Personal Information, in general, by making the transfer subject to the Standard Contractual Clauses approved by the European Commission, to ensure that your data is treated securely and in accordance with this privacy policy.

HOW LONG WE KEEP YOUR INFORMATION

If you have a contract with Sounds Delightful Hearing, we will keep your Personal Information for the term of the contractual relationship, and for Sounds Delightful Hearing’s use as described in this privacy policy, as allowed by applicable law. For example any paper forms will be scanned and shredded within 1 month of receipt and all patient/client records are retained for 7 years for adults over 18 years and information is retained up to the age of 25 years (7 years after they become an adult), for children/young people under 18 years in accordance with UK regulations. Sounds Delightful Hearing will retain your information for such further period as necessary to defend ourselves from legal claims. If you make a request for Sounds Delightful Hearing to delete your Personal Information, Sounds Delightful Hearing will keep a record of your request, to honour your request in the future. Sounds Delightful Hearing will then delete the Personal Information that you asked to be deleted, subject to any legal retention requirement, or legal exceptions to deletion requests.

“DO NOT TRACK” BROWSER SETTINGS

“Do Not Track” is a preference that you can set in your web browser to inform websites you visit that you do not wish to be tracked. The “Do Not Track” setting must be supported by the website you are visiting to be effective. Sounds Delightful Hearing is not currently able to support “Do Not Track” browser codes. Therefore, Sounds Delightful Hearing does not currently respond to or take any action regarding “Do Not Track” requests.

PERSONAL INFORMATION FROM CHILDREN

Sounds Delightful Hearing’s Services are not directed to children under 13 years old. We do not knowingly collect Personal Information from anyone under the age of 16, without the consent of the individual’s parent or legal guardian. Please contact our Data Protection Officer if you believe that we have been provided Personal Information of a child without the appropriate

consent of the parent or legal guardian.

CHANGES TO THIS POLICY

We may change our privacy practices and revise this privacy policy periodically. If we make significant changes (information that we collect, how we use it or why), we will highlight those changes at the beginning of this privacy policy.
To the maximum extent permitted by law, any changes will become effective when we post the updated privacy policy on our websites, and you will be accepting the changes by your use of our Products and Services. We recommend that you review our privacy policy frequently as you use our Services, to keep up to date on Sounds Delightful Hearing’s privacy practices.

THIRD-PARTY PRODUCTS, SERVICES AND WEBSITES

Please be aware that any third-party websites, software applications or other products or services linked or accessible via Sounds Delightful Hearing’s websites, or services are governed by the third-party’s terms of use and privacy policies. You should carefully review a third-party’s terms or use and privacy policies before using the third-party’s products or services.

CONTACT INFORMATION

Thank you for using our Services, and for reviewing this privacy policy. We welcome your comments or questions. If you have any feedback, we encourage you to contact our Dat Protection Officer at any of the following:

Attn: Data Protection Officer

Sounds Delightful Hearing

Arena Business Centre, 100 Berkshire Place, Winnersh, Wokingham, RG41 5RD

Call: 0118 405 0112

Email: info@soundsdelightfulhearing.com