Privacy Notice

PhonakPro Check Privacy Notice—HCP User

Last updated: September 1, 2025

This Privacy Notice describes how your personal data, including sensitive data, are collected and processed, related to the use of the PhonakPro Check application (the “Software”). This notice describes the types of information we may collect from you or that you may provide when you are using the "Software" and our practices for collecting, using, maintaining, protecting, and disclosing that information as described in this notice. The processing of your personal data comply, according to your country, with local law requirements, including the Swiss Federal Data Protection Act (“FDPA”), the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), U.S. state data privacy laws such as the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), or the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) for personal data qualified as Protected Health Information.

This Privacy Notice may be updated from time to time. In this case, we will inform you that this Privacy Notice has been modified and the “last updated” date on top of this document will be modified. We recommend that you periodically review the latest version of this Privacy Notice.

1. Who we are

This Software is operated by Sonova AG, on behalf of its subsidiaries and affiliates (collectively, “Sonova”). Sonova is a public limited company registered in the Commercial Registry of Zurich, under number 101 989 881, whose registered office is at Laubisrütistrasse 28, 8712 Stäfa, Switzerland.

Sonova acts as a Joint or Independent Controller for this processing, as described in the following section. A given Hearing Care Professional (“HCP”) user may also act as Joint or Independent Controller for the processing described in the applicable paragraphs below.

2. Personal data we collect from you and why

As Controller, Sonova processes your personal data for the following purposes:

- To uniquely identify professionals who download and utilize the Software, including creating linkages between the Software and other Sonova services and properties.

o This activity is based on consent to ensure the security and integrity of user accounts and the protection of personal data

- To allow professionals to purchase equipment (including accessories and other technology) create online requests for replacement/programming of processors, and review past order history, via integration with the Sonova eCommerce platform.

o This activity is based on performance of a contract, and Sonova’s contractual obligation to fulfill the business relationship with HCPs, as well as consent if Sonova asks for more data than is strictly necessary (for example, if you wish to ship a product to a specific address). Additionally, Sonova has a legitimate interest in providing HCPs and other affiliated professionals with their order histories.

- To facilitate and fulfil regulatory requirements when it comes to the deployment and use of Sonova’s hearing devices, including hearing aids and accessories.

o This activity is based on legal obligation where consumer laws or consumer safety regulations require it

- To allow Sonova to ingest pseudo-anonymized usage data collected for statistical tracking purposes, as well as to combine with previously obtained data, for further product improvement, research and claims.

o This activity is based on consent

Insofar as Sonova and you (as HCP) act as Independent or Joint Controllers, you may use the Software to process additional personal data for the following purposes:

- To understand the intent of the diagnostic action, and determine the type of acoustic coupling attached to the user’s hearing devices.

- To connect Sonova manufactured hearing devices to the Software, display hearing device information (e.g., warranty, product info, and receiver status) and to perform a diagnostic acoustic check, with suggested results supporting follow-up actions.

- To generate and print a hearing aid report (PDF) to share with the user of a hearing device as an account of the results and findings.

- To initiate a repair order, enabling you as HCP to draft repair order when recommended by the app via an API connection to the Sonova eCommerce platform. Please note, the order must be completed on the eCommerce platform.

All of the above activities in which the HCP acts as Controller are governed by consent. We rely on our HCP partners to appropriately collect this consent from the applicable data subjects prior to processing their data with the Software. A copy of this consent is attached to this Privacy Notice, and incorporated by reference.

Please note that we may also process personal data of minors. In this regard, the appropriate parent/guardian may be asked to provide a specific consent.

3. How we share your personal data

Your personal data will be processed according to the instructions we provide to our employees who have received the necessary training in data protection and are subject to an obligation of confidentiality.

Your personal data may also be disclosed to:

- Other companies in our group of companies, such as our subsidiaries, all of which are required to protect personal data in accordance with applicable privacy and data protection laws;

- Our business partners, contractors and third-party service providers. These third parties only process personal data that are strictly necessary for the services they provide to us, according to our instructions and in compliance with our privacy and security requirements.

- Other organizations and public bodies, supervisory and control authorities, including law enforcement agencies, as may be required by law.

By using the Software, only personal data that are strictly necessary for the following purposes are shared (the location(s) of your shared personal data may vary depending your country):

- Microsoft Corporation / Microsoft Ireland Operations Limited (Netherlands): provides cloud infrastructure hosting our services

- Elasticsearch B.V. (Netherlands): data logging, records IP addresses as part of logging operations for backend services

- Google LLC / Google Ireland Limited - Google Analytics: analytics

- Google LLC / Google Ireland Limited - Google Firebase: crash analytics, remote configuration.

Please see https://www.google.com/about/datacenters/locations/ for more information about Google’s localization.

Before we disclose any personal data to other third parties than those listed above, we will explicitly ask you for your consent. However, if we are obliged to disclose personal data without your consent, we will only disclose personal data that are strictly necessary for that purpose to fulfil our legal obligations.

4. International personal data transfers

Please note that some of the above-mentioned third parties can be located outside your country. Therefore, your personal data may be transferred to countries that do not provide the same level of protection of personal data as your own country. In such cases, we undertake to:

- implement adequate procedures to comply with applicable law;

- adopt appropriate organizational, technical and legal safeguards in order to ensure an adequate level of protection of the personal data transferred;

- implement, if necessary, and according to applicable law, standard contractual clauses as adopted by the European Commission;

- depending on the country of the importing third party, take additional measures such as a transfer impact assessment.

5. How long we keep your personal data

Sonova will retain your personal data for a minimal period proportional to the time required to fulfil the purposes outlined in Section 2. For example, relevant personal data will no longer be retained if you delete your account or if our contractual obligations are fulfilled. In the event applicable law or other regulations require a longer retention period, we will apply the longer retention period in order to fulfill our legal obligations.

6. Your legal rights

Within the framework of the collection and processing of your personal data, and as per applicable law, you may have the right to request access, rectification, erasure of your personal data, or restriction of processing. In addition, you may object to the processing, request data portability and withdraw your consent at any time. According to your country, you may have other rights such as providing instructions for how your personal data should be processed posthumously.

You may exercise your rights by using the contact details in the “How to contact us” Section below. Please note that the exercise of such rights is subject to the limitations provided by applicable law.

If you consider that the processing of your personal data infringes applicable law then you may also lodge a complaint with the local supervisory authority or the competent regulator.

7. How to contact us

In the event of questions about this Privacy Notice, or the processing of your Personal Data, please contact our Data Privacy Team at privacy@sonova.com.

CONSENT LANGUAGE

☐ I consent to the collection and processing of my personal data for the purpose of utilizing the PhonakPro Check software.

☐ I consent to the collection and processing of my personal data for secure processing by Sonova AG, to improve the functions and features of the PhonakPro Check experience.

☐ I consent to to the combination of my personal data collected by PhonakPro Check with previously obtained data, for further product improvement, research and claims.

☐ I understand that this app is intended to collect and process the personal information of my clients, and agree to collect their freely given and specific consent in line with the Client Privacy Notice, and applicable law.

PhonakPro Check Privacy Notice—Client User

Last updated: September 1, 2025

1. Who we are

2. Personal data we collect from you and why

Insofar as Sonova and your HCP act as Independent or Joint Controllers, the Software may be used to process additional personal data for the following purposes:

To connect Sonova manufactured hearing devices to the Software, display hearing device information (e.g., warranty, product info, and receiver status), determine the type of acousting coupling attached to the user’s hearing devices,and to perform a diagnostic acoustic check, with suggested results supporting follow-up actions. This also includes the possibility to generate and print a hearing aid report (PDF) to share with the user of a hearing device as an account of the results and findings.
To initiate a repair order, enabling you as HCP to draft repair order when recommended by the app via an API connection to the Sonova eCommerce platform. Please note, the order must be completed on the eCommerce platform. Furthermore, please note that if you choose to have your product shipped to a specific address, your personal data may also be processed to execute your request as part of the repairment process.
To allow Sonova to ingest pseudo-anonymized usage data collected for statistical tracking purposes.
Collect and combine personal data and information on usage and identification of the hearing devices, as well as previously obtained data under the purpose of our legal obligation as a manufacturer, for further product improvement, research and claims.

All of the above activities in which the HCP and Sonova act as Controller are governed by consent. We rely on our HCP partners to appropriately collect this consent from the applicable data subjects prior to processing their data with the Software. A copy of this consent is attached to this Privacy Notice, and incorporated by reference.

Please note that we may also process personal data of minors. In this regard, the appropriate parent/guardian may be asked to provide a specific consent.

As Controller, Sonova may processes your personal data for the following purposes:

- To facilitate and fulfil regulatory requirements when it comes to the deployment and use of Sonova’s hearing devices, including hearing aids and accessories.

o This activity is based on legal obligation where consumer laws or consumer safety regulations require it