“We protect your privacy – the short version”
At Oticon A/S we respect and protect your privacy. We are
dedicated to be as transparent as possible regarding the
use of your personal data in the App.
The Oticon RemoteCare Application (App) is an application
designed for remote communication between you and
your hearing care professional. The application allows you
to have follow-up appointments with your hearing care
professional from the comfort of your own home.
Remember, you can always easily stop all collection of information by the App by uninstalling or stopping use of the App.
To provide you with this service we collect and process your personal data. We do this in compliance with relevant Data Protection Regulation, including the General Data Protection Regulation (GDPR).
You are entrusted with several rights, including the right to information and right of access.
Please read the full Privacy Notice below for detailed information.
This Privacy Notice only applies to information gathered on or via the Oticon RemoteCare App (the App).
By using the App and affiliated services (“the Service”), you accept this Privacy Notice and Oticon A/S’ processing of your personal data as described herein.
1. DATA CONTROLLER
Data Controller is:
Company registration no. (CVR no.): 42334219
(hereafter ”Oticon”, ”we”, ”us” or ”our”)
Oticon is part of the Demant Group.
2.1 Purpose and functionalities
This App has been created for remote communication between you and your hearing care professional and allows you to make follow-up appointments from the comfort of your home. The App enables data communication between your hearing aids and your hearing professional via an internet connection. The App runs on your Mobile device and it will allow you to see, hear and text your hearing care professional during your remote appointment.
Features and functionalities in the App may be added,
changed and discontinued at the full discretion of Oticon.
2.2 Right of use
Oticon grants you a non-exclusive, non-transferable, revocable license to use the Services for your personal, non-commercial use and only on devices as permitted by the applicable platform terms and in accordance with this Privacy Notice. All other rights in the Services are reserved by Oticon.
2.3 Children’s privacy
We restrict the use of our services to individuals age 18 and above. We do not knowingly collect, maintain, or use personal information from children under the age of 18.
2.4 For free and “As Is”
The App is made available for your use for free. The
information contained in and functionalities available via
the App is provided “as is” and Oticon offers no warranties
of merchantability or fitness for a particular purpose.
2.5 TwinlinkTechnology and relevant devices
The App is designed to be used with Oticon wireless hearing aids using TwinlinkTechnology. The App sends and receives signals from the hearing aids via selected mobile devices for which the App has been developed.
Notifications of application updates on your device should not be disabled, and it is recommended that the user installs all updates to ensure that the App will function correctly and will be kept up to date.
The App must only be used with Oticon devices for which it is intended. The App specifications will state device and/ or operating system requirements. We cannot guarantee that your specific device is able to download and run the App irrespective of fulfilling the general requirements stated. Such malfunctions may be caused by circumstances outside our control.
2.6 Limitation of Liability
We strive to keep the Service accessible 24/7. Yet the Service can be inaccessible in situations, which can be due to safety or maintenance reasons, unstable network connection, failure in communication links or hardware. We execute back-ups on a regular basis, but cannot guarantee that there will be no data loss.
To the fullest extent permitted by law, Oticon shall not be liable for damages resulting from use of the App, including direct, indirect, incidental, consequential, punitive, specific or other damages, lost opportunities, lost profit or any other loss or damages of any kind.
2.7 Intellectual Property
The Oticon name and logo, and other Oticon trademarks, service marks, graphics and logos used in connection with the App are trademarks of Oticon and may not be copied, imitated or used, in whole or in part, without the prior written permission of Oticon or the applicable trademark holder. The App and the content featured in the App may be protected by copyright, trademark, patent and other intellectual property and proprietary rights which are reserved to Oticon.
2.8 Breach of terms
In the event of your breach of these terms we will be
entitled to terminate the use license immediately.
DATA PRIVACY RELATED MATTERS
3. OUR RESPONSIBILITY AS DATA CONTROLLER
3.1 We take the protection of your personal
We have adopted this Privacy Notice to inform you how we
process your personal data. Oticon is the data controller
and we ensure that your personal data is processed in
accordance with applicable legislation.
3.2 We ensure fair and transparent data processing
When we ask to make your personal data available to us,
we will inform you of the personal data we are processing
and the purpose hereof. You will receive this information
when your personal data is being collected.
4. PROCESSING OF PERSONAL DATA
4.1 Collection of non-personal aggregated data
When you use the app, we may automatically collect general information. The information collected cannot be used to identify you as an individual, as we aggregate data across all the App users. The information is only used in aggregate form to tell us how the application features are used in general. This could be information about when the feature is typically activated and/or how extensively a feature is used.
4.2 Collection of personal data
To use the App, you need to create an Oticon account. This account can be created in the App. Account registration requires you to submit your e-mail address and a password of your own choice.
When your register with your Oticon account and
start using the App, we collect the following types of
We only process personal data about you, which is relevant
and sufficient for the purposes defined above. This means
that we do not use your personal data more extensively
than necessary for the specific purpose.
4.3 Legal basis for processing your personal data
When you activate the App, we ask for your explicit consent to collect and use your personal data. As the use of hearing aids may reflect health information, we will always require your explicit consent before processing sensitive personally identifiable information concerning to you.
Your consent will be our basis for processing personal data regarding you. Your consent is voluntary and you can withdraw your consent at any time by contacting us. Use the above stated contact information if you wish to withdraw your consent or want further information.
You can also easily stop all collection of information in the App by uninstalling the App. You may use the standard uninstall processes available as part of your mobile device or via the mobile application marketplace or network.
Please note, that we are not automatically informed when you uninstall the App. Accordingly, we continue to process personal data concerning you until inactivity will result in deletion of inactive accounts, or if you contact us and object to the processing.
If we process your information based on another legal basis, we will notify you of such legal basis when obligated to do so.
4.4 Disclosure of your personal data
We will not rent, sell or otherwise share or disclose your
personal data, except as described herein or otherwise
stated at the time the data is collected.
We may share your personal data with other companies within the Demant Group in order to deliver and improve our products and services and for research purposes. Please refer to the organizational chart in our latest annual report to see which companies are part of the Demant Group. You can find our latest annual report at www.demant.com.
We may also disclose your personal data, if the disclosure is warranted by law, court order or judicial act.
We may share non-identifiable information in aggregated form publicly and with companies, organizations or individuals outside of Oticon or with our partners, i.e. publishers, advertisers or connected sites. For example, we may share non-identifiable information publicly to display trends about the general use of our applications.
Transfer to recipients outside the EU
If we transfer your personal data to a company in the Demant Group situated in a jurisdiction outside the EU, the EEA, or the European Commission-approved countries providing ‘adequate’ data protection, we will always ensure that adequate safeguards are taken to ensure data protection, e.g. by way of EU Commissions Standard Contractual Clauses.
We may also share your personal data with service providers who perform services and functions related to the App on our behalf. Such service providers will not gain any right to process your data for any other purposes but to help us deliver the services to you.
We only use service providers that give sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the relevant Data Protection laws including ensuring the protection of the rights of the data subject.
We use Microsoft’s Azure cloud services and the personal data we collect are transferred to and stored in Microsoft’s data centers located in the EU & US. Microsoft is certified under the Privacy Shield Framework, which provides an adequate level of data protection to enable data transfers from EU countries to US. You can read more about the services and regulatory compliance here: https://www.microsoft.com/en-us/trustcenter/compliance.
4.5 We control and update your personal data
We ensure that the personal data, we process about you is not incorrect or misleading. We also make sure to update your personal data continuously.
As our Service depends on your correct and updated personal data, we kindly ask you to inform us if there are any relevant changes regarding your personal data. You may use our contact information above to notify us of any changes.
4.6 We protect your personal data
We protect your personal data against unintended loss or alteration of your data and against unauthorized disclosure of or access to your personal data.
If we experience a data breach, we will notify you as soon as possible, if the breach is likely to result in a high risk to your rights e.g. theft of ID, economic loss, discrimination of you, loss of reputation or other significant inconvenience.
5. YOUR RIGHTS AS DATA SUBJECT
5.1 You have the right to access your personal data
You have the right, at any time, to receive information about the personal data we are processing about you, where we have collected your data, and what we are using your data for. You also have the right to know how long we will keep your personal data, and who we share your data with.
You can request a copy of the personal data we process concerning you. Your access can be restricted to ensure other people’s privacy protection, trade secrets and intellectual property rights. You also have the right to data portability.
If you want to exercise your rights, you can contact us at
the contact points listed above.
5.2 You have the right to have inaccurate personal data
corrected or deleted.
If you think the personal data we are processing about you is inaccurate, you have the right to request correction. You must contact us and inform us about the inaccuracies and how to rectify the information.
In some instances, we are obliged to delete your personal data. This might be the case if you withdraw your consent. If you are of the opinion that your personal data is no longer necessary in accordance to the purpose for which we collected them, you are entitled to request deletion of your data. You can also contact us if you believe your personal data is being processed contrary to applicable law or other legal obligations.
We will investigate if the conditions are fulfilled, when you make a request of having your personal data rectified or erased. If so, we will carry out the amendments or deletion as soon as possible.
5.3 You have the right to object to our processing of
your personal data
You have the right to object to our processing of your personal data. You can use the contact information above to submit an objection. If your objection is justified we will ensure the termination of the processing of your personal data. If you wish to make a complaint about our processing of your personal data, you have the right to contact the Danish Data Protection Authority (“Datatilsynet”):
+45 3319 3200,
5.4 You have the right to delete your Oticon account
You have the right, at any time, to delete your Oticon account. If you want to exercise your right, you can contact us at the contact points listed in section 1.0 above.
Oticon reserves the right to amend this Privacy Notice at any time with an appropriate notice to you. The Terms in force at any time are available through the Service. If you continue to use the service, you are deemed to have accepted such changes.
7. DANISH LAW
Our Service is based in Denmark. The information we collect is governed by applicable Danish law. We operate the Services in Denmark, and depending on your country of residence, the submission of Personal Information via the Services may involve transfer of personal information to Denmark, or where our servers are located.