Introduction
Oticon (“we,” “us,” or “our”) respects your privacy and is dedicated to being transparent about how we use your Personal Information. Personal Information includes all information that qualifies as personal information or Personal Information under applicable data protection laws, such as information that identifies you or that could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include information that is exempt from applicable data protection laws, such as anonymized information.
This privacy policy (the “Privacy Policy” or “Policy”) describes the Personal Information we collect and how we process that Personal Information when you engage with us directly as a customer, whether online or in person. This includes interactions through our products and services, participation in Oticon-sponsored events, and visits to websites or mobile applications managed by Oticon (collectively, the “Services”). The Services and this Policy are directed to a US audience only. Residents of California should click here for California specific disclosures.
Please note that this Policy does not apply to our processing of employment or job applicant information. For information about our privacy practices relating to job applicants who are California residents, please contact us at usprivacy@demant.com. It also does not apply to our processing of Personal Information on behalf of third-party controllers, where Oticon functions as a service provider or processor of Personal Information. Where Oticon functions as a service provider, we process Personal Information in accordance with the terms of the specific agreement we may enter into with the relevant controller. You should contact these organizations directly for information about how they process your Personal Information as a data controller/business and to exercise your rights in relation to that data.
Your Consent to this Policy
By disclosing your Personal Information to us or otherwise using our Services, you consent to our collection and processing of your Personal Information in a manner that is consistent with applicable law and this Privacy Policy. Your continued use of our Services indicates your consent to the Privacy Policy then posted.
We may change this Privacy Policy from time to time, so please check back when you use our Services to make sure that you have seen the most recent version. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
How We Collect Personal Information
We may collect Personal Information that you provide to us directly, automatically through the analytics tools implemented on our Services, or from third party sources. This section provides more information on the types of Personal information we collect and how we collect it.
Information that you provide to us directly
We collect and process the information whenever you provide it to us directly. This includes any information that you provide to us when you sign up for or over the course of receiving our Services, such as your contact information and the specific products or services that you may be interested in. It also includes any information that you provide in your communications with us. Finally, this may include any information that you provide to us offline, such as at our sponsored events.
Some parts of our Services may allow visitors to post content on public online forums that we operate (for example, posting a question, comment or review). When you post content on these online forums, other visitors will be able to see certain information about you, such as your username or handle and any public content you may post. You should be aware that any Personal Information you post can be read, collected, distributed or used by other visitors and could be used by third parties to send you unsolicited messages. We are not responsible for the Personal Information you choose to post on public online forums.
Information that we may collect about you through various automated tracking technologies
We use a variety of first and third party tracking technologies to ensure the functionality of our Services, better understand our visitors, and conduct marketing and advertising activities. These technologies include session cookies, persistent cookies, pixels, beacons, and system logs. These technologies collect Personal Information, such as IP address, device identifiers, unique account identifiers, and other technical information that can be associated with unique users. These technologies may also make Personal Information available to third parties, such as our advertising partners.
The following table explains the different categories of trackers we may use and provides examples of who may serve each category, along with links to their relevant privacy notices. Please note that this list is provided for purposes of example only and may not precisely reflect trackers used in each location or on each Service.
Essential
These trackers are required for the operation of the Services and enable you to move around the Services and use its features. Disabling these trackers can negatively impact the performance of Services.
Oticon
Functionality
These trackers are used to recognize you when you return to the Services. This enables us to personalize content for you and remember your preferences. These trackers also enable your interactions with the Services such as emailing us and customer support chat.
Oticon
X
Analytics, performance, and research
These trackers allow us to analyze activities on the Services. They can be used to improve the functioning of the Services. For example, these trackers recognize and count the number of visitors and see how they move around the Services. Analytics trackers also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on the Services for those who engage with our advertising. These tools are provided by third parties, who may also have access to the information they collect, such as device information and browsing information.
Oticon
Google
X
YouTube
Social Networking
These trackers are used to enable you to share pages and content that you find interesting on our Services through third-party social networking and other websites. These trackers may also be used for advertising purposes. The providers of these trackers may also have access to the information they collect, such as device information and browsing information.
Google
X
Advertising
These trackers are used to deliver relevant ads, track ad campaign performance, or track email marketing. These tools are provided by third parties, who may also have access to the information they collect, such as device information and browsing information.
Oticon
Google
X
YouTube
Microsoft
You may delete or disable certain of these technologies at any time via your browser settings. To opt out of analysis by Google Analytics on our website and other websites, please visit https://tools.google.com/dlpage/gaoptout. Please be aware that if you disable or remove tracking technologies, some parts of the Services may not function correctly.
Mobile Apps: We may collect location data through our mobile app(s). You can stop all collection of information via an app by uninstalling the app. You can also reset your device at any time through your device settings, which allow you to limit the information that we can access through and about your device.
Information We May Collect from Third Parties.
We may collect certain information about you from third parties who collect that information from or about you. These third parties include lead generators, partners and affiliates, and advertisers. For example, we may collect information about you from our advertising and analytics partners, which we use for the purposes of improving our Services and advertising.
The Information We Collect, Why We Collect It, and How We Disclose It
The following chart identifies the purposes for which we collect Personal Information, the categories of Personal Information we collect, and how and to whom we may disclose that information.
Account Creation and Management
Account Information
Analytics Information
Contact Information
Social Media Information
Yes / No
Analytics Information
Analytics Providers
Third Party Advertisers
Provision of Goods or Services
Analytics Information
Commercial History
Contact Information
Scheduling Information
Health Related Information
Yes / No
Analytics Information
Commercial History
Contact Information
Analytics Providers
Third Party Advertisers
Marketing and Advertising
Analytics Information
Commercial History
Contact Information
Social Media Information
Yes / No
Analytics Information
Commercial History
Contact Information
Analytics Providers
Third Party Advertisers
Lead Generators
Analytics and Research
Analytics Information
Commercial History
Contact Information
Social Media Information
Yes / No
Analytics Information
Commercial History
Contact Information
Social Media Information
Analytics Providers
Third Party Advertisers
Customer Service
Analytics Information
Contact Information
Chat Information
No / No
N/A
N/A
Website Security and Maintenance
Analytics Information
Commercial History
No / No
N/A
N/A
Other Ways We May Collect, Use, or Disclose Your Information
We may also reserve the right to collect, use, or disclose each of the categories of Personal Information described above for the following purposes:
- For legal purposes. We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either Personal Information or reports about lawful of unlawful user activity regarding our Services. We also reserve the right to share your Personal Information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your Personal Information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personal Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information. If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
- Business transactions or mergers. We reserve the right to disclose your Personal Information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive Personal Information in connection with the diligence. If we close a transaction, the third party may transfer Personal Information, which we would use as described in this Policy.
- Bankruptcy or insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may disclose your Personal Information to third parties as part of the sale or reorganization process.
- Information from our partners. We may collect information from our partners such as market research firms and our affiliates, subsidiaries, joint ventures, or other companies under common control. We may combine that information with other information we collect about you, but we will always use the information as described in this Policy.
- With your consent. In the course of using our Services, you may consent to the disclosure of your Personal Information to various third parties. Where we rely on your consent to disclose your Personal Information, we will disclose the categories of data and third-party recipients at the time of obtaining your consent.
- With third-party service providers. From time to time, we may enter into arrangements with companies whose expertise is essential to the functionality of our Services. We may disclose to these service providers Personal Information necessary for them to provide services on our behalf. We implement measures reasonably designed to limit the types and amount of data disclosed and restrict such service provider’s ability to use Personal Information outside of their relationship with us by contract.
- Emergency disclosures. We may disclose or otherwise process your Personal Information to act in emergency circumstances or to protect the personal safety of our users and customers.
GPC Signals and other Universal Opt-Out Mechanisms
We recognize and respond to the Global Privacy Control (GPC) to satisfy universal opt-out requests. If we receive a signal from your browser, we will treat it as a request to opt out of the sale or sharing of your Personal Information for targeted advertising in accordance with applicable state data protection laws.
Children’s Privacy
Our website and online services are intended for a general audience and not directed at children under thirteen (13) years of age. We do not knowingly gather Personal Information (as defined by the U.S. Children’s Online Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If a person under thirteen (13) submits information through any part of our Service, and we learn the person submitting the information is a child, we will attempt to delete this information as soon as possible unless we have received consent from the child’s parent or guardian. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us as set out in the “Contact Us” Section below. We will remove the data to the extent required by applicable laws.
Retention - How long we keep your data and how we secure it
We retain your Personal Information only as long as necessary to fulfill legitimate business or legal obligations, including compliance with applicable laws.
The security of your data is important to us. We use administrative, technical and organizational measures to protect your Personal Information against unintended loss or amendment, unauthorized disclosure and unauthorized persons accessing your Personal Information. Please note that despite these protections, complete security on the internet does not exist. Therefore, we will notify you of any security incident impacting your Personal Information where required by applicable law.
Where We Store Your Personal Information
We process Personal Information on our servers in the United States of America, and may do so in other countries. If you use our Services or otherwise provide us with information from outside of the United States, you acknowledge and agree to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States. We implement appropriate safeguards to protect such Personal Information, which may include (without limitation) European Commission approved standard contractual clauses.
US State Privacy Right Disclosures
Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia residents have certain rights with respect to their Personal Information. These rights are established through the Colorado Privacy Act (“CPA”), the Delaware Personal Information Privacy Act (“DPDPA”), the Iowa Consumer Data Protection Act (“ICDPA”), the Montana Consumer Data Privacy Act (“MCDPA”), the Nebraska Data Privacy Act (“NDPA”), the New Hampshire Privacy Act (“NHPA”), the New Jersey Data Protection Act (“NJDPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”). The chart below explains these rights and lists the states whose residents may exercise those rights. Residents of California can access California specific disclosures here.
Right to Know/Access
You have the right to confirm whether we are processing your Personal Information and the right to access that data. Residents of Delaware, Minnesota, and Oregon may request a list of the third parties, other than natural persons, to whom we have disclosed your Personal Information.
California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia
Right of Correction
You have the right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
California, Colorado, Connecticut, Delaware, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Virginia
Right of Deletion
You have the right to request deletion of your Personal Information provided by you or obtained about you.*
* In Utah and Iowa, this right is limited to only that information that you have provided directly to us.
California, Colorado, Connecticut, Delaware, Iowa*, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia
Right of Portability
Up to two times per calendar year, you have the right to obtain your Personal Information in a portable and—to the extent technically feasible—readily usable format that allows you to transmit the data to another entity without hindrance.
California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia
Right to Opt-out:
You have the right to opt-out of the processing of your Personal Information for the purposes of:
Targeted advertising;
The sale or sharing of your Personal Information; and/or
Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. *Profiling opt-out not available in Utah and Iowa.
You may opt-out at any time using the controls available in the footer of our website. We also recognize the GPC.
California, Colorado, Connecticut, Delaware, Iowa*, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah*, Virginia
Right to Non-Discrimination
We will not discriminate against you based on your choice to exercise the privacy rights available to you under applicable law.
All.
Exercising your Rights
Residents of the above listed states may submit privacy rights requests at any time by emailing us at usprivacy@demant.com. Please specify in your email the right(s) you would like to exercise and provide any additional information you think may be relevant or necessary for us to complete your request. If necessary, we may request additional information reasonably necessary to authenticate you and your request. We reserve the right to refuse or limit requests where permitted by applicable law.
In certain circumstances, you may make a request on behalf of another such as if you are an authorized agent or the parent or guardian of a child on behalf of whom you wish to exercise their rights. Generally, when an authorized agent makes a request on behalf of the consumer, the following is required: (i) signed permission by the consumer that the consumer has authorized the agent to act on behalf of the consumer; (ii) the consumer must verify the consumer’s identify directly with Oticon; and (iii) the consumer must directly confirm with Oticon that the consumer has provided the authorized agent permission to submit the request. However, in the context of a California resident, if the consumer has provided the authorized agent with power of attorney pursuant to Cal. Probate Code sections 4121 to 4130, the verification process is as follows: the authorized agent must provide written verification of such power of attorney and the agent must confirm the agent's identity in order to verify the request.
We will respond to these consumer requests, if applicable, within 45 days of receipt of the request and without undue delay. If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.
We will provide responses to your requests free of charge unless certain exclusions apply, depending on the state in which you reside.
Verifying Rights Requests
To ensure the protection of your Personal Information, we may be required to verify the identity of the individual submitting the request. As part of this verification process, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
Making a verifiable consumer request does not require you to create an account with us.
We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of consumers where we have reason to believe a request is fraudulent.
Appealing a Rights Request Decision
If you are a resident of Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, and we deny or fail to take action on your request to exercise your applicable consumer privacy rights, you may appeal our decision. To do this, you may email us at usprivacy@demant.com. Please include in the subject line of the email the word “Appeal”, specify the right(s) you requested to exercise and the date you made the relevant request.
We will inform you in writing within 45 days of any action taken or not taken in response to the appeal. We will also provide a written explanation of the reasons for our decisions regarding your request(s).
Additional Disclosures for Nevada Residents
Nevada law (NRS 603A) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of Personal Information for monetary consideration by the business to a third party for the third party to license or sell Personal Information to other third parties. Oticon does not engage in sales as defined under Nevada law.
California Specific Disclosures
Residents of California have certain rights with respect to the collection, use, and disclosure of their Personal Information, as set forth in the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act (“CRPA”) and implementing regulations. This section provides the disclosures required under California law.
California: Categories of Information Collected
In the last twelve (12) months, we collected the following categories of Personal Information from California consumers for the following purposes:
Identifiers
A real name, alias, age, date of birth, postal address, telephone number, unique personal identifier (device serial numbers), online identifier, Internet Protocol address, and email address.
Process transactions and provide requested services
Provide product and service recommendations
Personalize your browsing experience on our websites and online applications
Conduct marketing and advertising activities
Characteristics of Protected Classifications
Such as age.
Process transactions and provide requested services
Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Process transactions and provide requested services
To provide warranty information
For quality assurance and product development purposes
Conduct marketing and advertising activities
Internet or other similar network activity
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Process transactions and provide requested services
Provide product and service recommendations
To understand how you use our products and services
Analyze website traffic and usage
Conduct marketing and advertising activities
Geolocation data
General physical location (not precise), such as that contained in an IP address.
Process transactions and provide requested services
To provide product and service recommendations
Inferences drawn from other Personal Information
Profile reflecting a person's preferences and characteristics
Provide product and service recommendations
To understand how consumers use our products and services
Conduct marketing and advertising activities
California: Sources of Personal Information
We collect your Personal Information directly from you, from your interactions with our Services, from publicly available sources, from our affiliates, and from third parties.
California: How We May Disclose Your Personal Information
In the preceding 12 months, we have disclosed each category of Personal Information listed above to our service providers, subject to appropriate contractual restrictions, and our affiliated organizations within the Demant family of companies for business purposes.
In the preceding 12 months, we have disclosed the following categories of Personal Information to analytics providers, marketing and advertising partners, and lead generators:
- Identifiers;
- Commercial Information;
- Internet or other similar network activity;
- Geolocation data; and
- Inferences drawn from other Personal Information.
We do not sell your Personal Information to third parties for money. But, the use of certain analytical and tracking tools may constitute the sale or sharing of information under the CCPA. In the preceding 12 months, we used tracking technologies that may constitute a sale or sharing of the following categories of information:
- Identifiers;
- Commercial Information;
- Internet or other similar network activity;
- Geolocation data; and
- Inferences drawn from other Personal Information.
You can opt-out of our use of these tracking technologies at any time through our cookie banner and the controls available in the footer of our website.
We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.
We do not sell or share Sensitive Personal Information to or with third parties as these terms are defined under California law.
California: Your Privacy Rights
Click here to see what rights are available to residents of California and how to submit rights requests. Residents of California also have the right to limit the use of their sensitive Personal Information. We do not process sensitive personal in a manner that triggers this right.
California: Shine the Light
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to usprivacy@demant.com.
De-Identified Information
Information is de-identified when all identifying information has been removed such that the information can no longer be linked to an individual. If we are in possession of de-identified information, we will not attempt to re-identify de-identified data.
Third Party Links and Embedded Content
Our Services may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. Additionally, we may provide embedded content, such as videos, on our websites or apps. Although these videos are available through our website, they are actually hosted and provided by third parties. Such third parties may place cookies or related trackers on your systems when you view such embedded content.
It is important to note that this Policy only applies to Oticon’s Services. We are not responsible and assume no responsibility for any Personal Information collected, stored, or used by any third party as a result of you visiting third-party websites or viewing embedded content. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.
Contact Us
We are committed to protecting your privacy and to being transparent about how we use your information. If you have any questions or concerns about our Privacy Policy or if you need to access this Policy in an alternative format due to having a disability, please do not hesitate to contact us at:
Website: www.oticon.com
Email: usprivacy@demant.com