Privacy policy for the “audifon” app

Dear users,
Thank you for choosing the "audifon" app. This app allows you to customize the settings and conveniently control your hearing aids using your end device (e.g. smartphone). The following discloses the details of data processing.

1. Contact person/responsible party

The responsible party when it comes to processing personal information as outlined in the General Data Protection Regulation ("GDPR") is

audifon GmbH & Co. KG
Werner-von-Siemens-Str.2
D - 99625 Kölleda, Germany
Internet: www.audifon.com

Trusted Shops GmbH
Colonius Carré, Subbelrather Straße 15c
D - 50823 Köln
https://legal.trustedshops.com/

For questions regarding the privacy policy and these data protection provisions, please contact the audifon data protection officer by mail at the previously mentioned postal address or by email at dsgvo(at)trustedshops.de.

2. Data processing when using the "audifon" app

All of the data collected in the app is stored locally on your end device unless otherwise mentioned below. The following data is processed when using the app:

2.1 Default settings for the app
· Language settings (activated language)

2.2 Adjusting and controlling your hearing aids
· Hearing aid information (serial number, model UDI No.), side assignment (left, right hearing aid)
· Connection status (hearing aid – end device)
· hearing program settings
· location information when location services have been activated by the user
· location-dependent activation of a hearing program

As far as the user has granted the permission for using the geolocation service and the service is activated on the end device, the user will be offered the possibility to activate a hearing program automatically by linking it to the current location. The hearing program will be activated as soon as the user enters the proximity of the defined location spot.
This feature needs to have access to the Geolocation Service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The service is always checking the location data of the user in the background, independently whether the app is in use or have been closed. The app does not process the location data in case of being closed.

2.3 Integrating smartphone functions into the app
· Hearing aid localization
Provided the user has allowed access to the app's localization function, at regular intervals the app saves the most recent location of the end device and a time stamp to the end device when there is a connection to the hearing aid. This helps ascertain where and when the hearing aid was last connected to the end device should you lose the hearing aid.

Legal bases are
· The performance of a contract or the performance of measures prior to entering into a contract (Art. 6 para. 1 pg. 1 lit. b GDPR) and
· consent of the user according to Art. 6 para. 1 pg. 1 lit. a GDPR in conjunction with Art. 9 para. 2 lit. a GDPR, insofar as health data is processed.

2.4 Plugins and tools
· Google Maps
This app accesses the Google Maps map service, provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to visually display the most recent location of your end device (paired with your hearing aid) to help locate your hearing aid. When using Google Maps, Google processes data while using the map functions. You can find more information about how user data is handled in Google's privacy statement: https://www.google.de/intl/de/policies/privacy/. Data is processed based on the
consent that you give (Art 6 para 1 lit. a GDPR).

· Microsoft AppCenter Analytics
The app also sends anonymous error reports to Microsoft's "Visual Studio App Center" service. In the process, information about the country code, language, manufacturer and device operating system on which our apps are installed as well as information regarding the version of our app that is installed is transferred. In addition, we also receive detailed crash information in the event that one of our apps is not functioning properly. The legal basis for data processing is art. 6 para. 1 pg. 1 lit. f of the GDPR. Our legitimate interest arises from the abovementioned purposes for data collection. We do not use the data collected to draw conclusions about you as an individual.

3. Duration of data retention

The data collected in the app is saved locally to your end device unless otherwise described in these instructions. Removing the app from your end device deletes all of the data collected in the app.

4. Obligatory and voluntary disclosures

The data listed above must be processed in order to use the features of the app. You are not obligated to provide this data however certain features of the app cannot be offered if data is not provided.

5. Transmission of personal data and recipients of personal data

Data is not disclosed to any third parties that are not audifon service providers included in contract processing. Personal data included in contract processing is disclosed to Internet providers. In accordance with data protection regulations, these processors are obligated to process personal data exclusively according to our instructions. In addition, our processors are subject to contractual and legal privacy and confidentiality requirements.

6. Rights of the user

Users have the right to withdraw their consent for the processing of their personal data at any time without stating a reason and effective for the future. Please note that the withdrawal of consent does not affect the legality of any data processing that occurred up to the time of the withdrawal of consent. The following rights of the individuals affected are available to you upon presenting the respective statutory requirements:

· Right of access by the data subject (Art. 15 GDPR)
· Right to rectification (Art. 16 GDPR)
· Right to erasure (Art. 17 GDPR)
· Right to restriction of processing (Art. 18 GDPR)
· Right to data portability (Art. 20 GDPR)

To exercise the aforementioned rights, please contact the data protection officer (for contact details see clause 1). Lastly, you are entitled to file a complaint with a regulatory authority in the event that you are of the view that the processing of your personal data is in violation of data protection provisions or you have not been adequately granted the rights of individuals affected.

As at: January 2021