English - International

Data Privacy Policy

Information on data processing according to Art. 13 and 14 General Data Protection Regulation (GDPR)

We care about the protection of your personal data and your privacy. For this reason, we will inform you in the following about our handling of your personal data, in particular for what we process your personal data, to whom we transmit them and the data protection claims and rights to which you are entitled. When we subsequently talk about data, we mean your personal information. This is all the information that identifies you as a person, directly or indirectly.

Please read the following information carefully.


About this Policy

This Data Privacy Information explains when and why we collect personal data, how we use such data and how we protect such data and your associated rights. We process and transfer your personal data on a legal basis only, in particular to fulfil contractual requirements, for legitimate interests or based on your consent. We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. The purpose and the legal basis are mentioned separately for all functions of our mobile application.


Who is responsible for data processing?

The responsible controller is:

MED-EL Elektromedizinische Geräte Gesellschaft m.b.H.
Fürstenweg 77a
6020 Innsbruck
Austria
Tel.: +43 5 77 88
[email protected]

The responsible data protection officer can be contacted directly [email protected] or by adding attn. Data Protection Officer to the postal address above.


Which data are being processed and from which sources does this data come from?

We process personal data that we receive from you by registering for and using the AudioKey 2 mobile application.


Your personal data includes in particular:

  • Name
  • E-mail address
  • Date of birth
  • Demographic information such as address, postal code
  • Data about your MED-EL audio processor such as serial number, ear side

Your rights

You have the right of access, the right to rectification, erasure, restriction of processing, data portability and the right to object. Where data processing requires your consent, you can withdraw your consent to future use at any time. You also have the right to complain to the relevant data protection authority.


Data transfer

We do not forward your data to third parties for commercial use (or Marketing). We use service providers to operate our Internet pages or for, e.g. e-mail services, authentication or web analysis. These service providers may obtain knowledge of your personal data. We exercise caution when selecting our service providers, particularly with regard to data protection and data security, and take all steps required by data protection regulations.


Update

Updating of your personal data takes place primarily on the basis of your direct feedback or changes performed within the AudioKey 2 mobile app.


Retention Period

Your data will be deleted as soon as storage is no longer required (e.g. fulfilling legal retention requirements, generation, execution or defense of legal requirements). We may also anonymize your data instead of deleting them. In this case any information suitable to determine your identity will be irrecoverably deleted.


Is there an obligation to provide data?

For registration to the AudioKey 2 mobile app via myMED-EL we need your registration data. Provision of any further data and technical information is depending on your consent or on the features you want to use in the AudioKey 2 mobile app (e.g. geolocation for “Find My Processor” function).


Is my data used for automated decision making including profiling?

We do not use automated decision-making according to Art. 22 GDPR.


Security

We are committed to ensure that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect within the AudioKey 2 mobile application.


Links to other websites

The AudioKey 2 mobile application may contain links to other websites or mobile applications of interest. However, once you have used these links to leave the AudioKey 2 mobile application you should note that we might not have any control over that other website or mobile application. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website or mobile application in question.


Registration

You can register to the AudioKey 2 mobile application via myMED-EL. For registration you have to provide the following data to us: first name, e-mail address and country. If you provide it, we additional process this optional data: profile picture, address, postal code, date of birth. For authentication MED-EL uses the Auth0 software component which requires the transfer of your email address and password for a secure login process. See https://auth0.com/terms/ and https://auth0.com/privacy/ for more information. If you use the AudioKey 2 mobile app in the demo mode we do not process any personal data.

Purpose:
Registration to the AudioKey 2 mobile application

Basis:
Performance of a contract - Art. 6 (1) lit. b) GDPR


Connection of MED-EL audio processors

You can connect MED-EL audio processors to use the AudioKey 2 mobile application for remote controlling and to see information about your connected MED-EL audio processors. For connection you have to provide the following data about your MED-EL audio processors to us (e.g. audio processor type, serial number, configured ear side).

Purpose:
Connection of MED-EL audio processors for remote control via AudioKey 2 mobile application

Basis:
Performance of a contract - Art. 6 (1) lit. b) GDPR


Guardian Roles

In the AudioKey 2 mobile application you can define three different Guardian Roles:
Administrator: Get notifications about the person under care, use all app functions and manage the audio processor of the person under care. Act as a main manager for the person under care, update user profiles, add or remove other guardian users and maintain permission levels. Access to all data of the person under care.
Controller: Get notifications about the person under care and access the main app functions (e.g. Listening Settings, Hearing Statistics, Find My Processor) of the managed user.
Observer: Get notifications (e.g. new audio processor connected) about the person under care.

The Notification Function uses Firebase Cloud Messaging, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA94043, USA.
This service is used to send push messages or so-called in-app messages (messages that are displayed within the respective app). In this case, the device is assigned a pseudonymized push reference, which serves as the destination for the push messages or in-app messages. This function can be deactivated in the settings of the device at any time and also activated again. Information on Firebase data privacy can be found here: https://firebase.google.com/support/privacy/.

Purpose:
Support of a person under care as a Guardian via the AudioKey 2 mobile application.

Basis:
Performance of a contract - Art. 6 (1) lit. b) GDPR


Find My Processor

With the “Find My Processor” function, you can search for a lost processor. This function uses – based on your device – either the Google Maps or Apple Maps map service via an API. To use these location services, it is necessary to save your IP address. This information is generally transmitted to a server in the USA and stored there. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA or Apple Inc., One Apple Park Way, Cupertino, California. Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/ or Apple Maps Terms of Use: https://www.apple.com/legal/internet-services/maps/terms-en.html and Apple Privacy Policy: https://www.apple.com/legal/privacy/en-ww/. “Find My Processor” only works if you allow the app to access your location data. You can activate and de-activate this function anytime directly in the settings of the Audiokey 2 mobile application.

Purpose:
Search for a lost processor

Basis:
Performance of a contract - Art. 6 (1) lit. b) GDPR


Change Information

We will update this data protection information when changing our mobile application or for other reasons requiring such updates. The valid version is always available in the mobile application. Release date of current version: 01.06.2020