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Privacy notice - myRogerMic app

Privacy notice

Last updated: 02.14.2024

This Privacy Notice describes how your personal data, are collected and processed as they relate to the use of the Roger On microphone and your hearing devices, and according to local applicable law. In this context, this Privacy Notice covers the processing of your personal data carried out via the “myRogerMic” Application (“Mobile App”). The processing of your personal data comply, according to your country, with local law requirements, including the Swiss Federal Data Protection Act (“FDPA”) and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”).

1. Who we are

Sonova AG, Laubisrütistrasse 28, 8712 Stäfa, Switzerland (www.sonova.com), (“Sonova AG”) acts as a Controller for the processing listed in the following section.

2. Personal data we collect from you and why

Sonova AG processes your personal data for the following purposes:

Based on your consent (those processing are not mandatory and will occur only if you agree and consent to it):

- Understand your demographics and preferences in using the Mobile App: Your location such as City/Region/Country (Sonova will not store your location information and will not be able to track you in any way), phone information (e.g., brand, model, operating system information, platform and language), basic interaction with the Mobile App (e.g., first open of the Mobile App, screen transitions and engagement with the Mobile App e.g., buttons, sliders and features), Mobile App version, IP address.
- Submit satisfaction survey to you on the Mobile App via SurveyMonkey: answers are anonymised, however IP address is collected by SurveyMonkey

3. How we share your personal data

By using the Mobile App, and only if you provide your explicit consent, personal data as listed above may be disclosed to:

- Google Ireland Limited - Google Analytics (Ireland): analytics.
- SurveyMonkey Inc. (United States, Ireland): used to collect user satisfaction surveys.

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 organisational, 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 the precedent section. 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

You have the right to withdraw your consent at any time. As per local applicable law, you may also have the right to request access, rectification, erasure of your personal data, restriction of processing, object to the processing or request data portability, as well as provide instructions for the use of your personal data posthumously. 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. Please note that the exercise of such rights is subject to the limitations provided by local applicable law.

You may exercise your rights by using the contact details in the “How to contact us” section below.

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.