1. Introduction
1.1 This Privacy Notice is intended to provide you with information on how WS Audiology Denmark A/S (hereinafter “we”, “us”, “our”) collect and process your personal data when you use the firmware update app (hereinafter “Widex Update Center”).
1.2 This Privacy Notice explains how and for which purposes we process your personal data. We will only process your personal data in accordance with this Privacy Notice and applicable law to which we are subject, in particular the General Data Protection Regulation (EU 2016/679) (hereinafter the “GDPR”) and other applicable laws in the jurisdiction in which you live.
1.3 WS Audiology Denmark A/S is data controller in relation to your personal data. You can contact us by using the contact information in Section 9.
2. The data we collect, the purpose and the legal basis for processing
AGGREGATED DATA
2.1 In order to pair your accessory with your mobile device (if you have accepted this) we will use your location.
2.1.1 The processing of this information is necessary to pursue our legitimate interest in maintaining, troubleshooting and performing improvements to the software in Widex Update Center (article 6 (1)(f) in the GDPR.
3. How is your personal data collected
3.1 We will collect your personal data from Widex Update Center.
4. Disclosure of your personal data
4.1 Your personal data may be shared with third parties who process data on our behalf, e.g. IT service providers. Contractual arrangements are established to ensure that such data processors are only allowed to process data in accordance with our instructions and for our purposes, as explained in this notice, and to require such data processors to establish adequate organisational and technical security measures.
5. Transfer of your personal data to third countries (outside the EU)
5.1 We use Microsoft’s servers that are located in EU, US and Japan to store personal data. Whereas Japan is considered to provide an adequate level of data protection, appropriate safeguards to transfer personal data to the US have been made in the form of the EU Commissions Standard Contract Clauses.
6. Your rights
6.1 Under certain circumstances, where applicable in the jurisdiction in which you live, you have one or more of the following rights:
6.1.1 You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (art. 15 in the GDPR).
6.1.2 You may have the right to request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected (art. 16 in the GDPR).
6.1.3 You may have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. To the extent that continued processing of your personal data is necessary, for example in order for us to comply with our legal obligations or for legal requirements to be established, enforced or defended, we are not required to delete your personal data (art. 17 in the GDPR).
6.1.4 You have the right to object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground (art. 21 in the GDPR).
6.1.5 You may have the right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it (art. 18 in the GDPR).
6.1.6 You may have the right to request the transfer of your personal data to another party (also known as data portability) (art. 20 in the GDPR).
6.1.7 You may have the right to request information of the public and private entities with which we carried out the shared use of data;
6.1.8 We take our privacy obligations seriously. If you lodge a complaint with us about a concern that we have breached an applicable law, we will respond to you as soon as possible and in any case within 30 days.
6.1.9 If you have unresolved concerns, you also have the right to complain to the Danish Data Protection Agency or to the data protection authorities in the country where you live or where you consider a breach of data protection law has occurred (art. 77 in the GDPR).
The Danish Data Protection Agency may be contacted as follows: e-mail address dt@datatilsynet.dk or telephone number +45 33 19 32 00. In Canada and Australia, you may also file a complaint with the applicable privacy commissioner in your jurisdiction if you believe there’s been a violation of privacy rights.
7. Data retention
7.1 Data are anonymized upon collection.
8. Data security
8.1 We have put in place appropriate security measures to prevent your personal data from being lost, used, accessed in an unauthorised way, altered or disclosed.
8.2 In addition, we have limited access to your personal data to employees and contractors who have a relevant and reasonably required need to access your personal data to perform their work and have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
9. Contact information
9.1 WS Audiology Denmark A/S is data controller for the personal data, which are processed about you.
9.2 If you have any questions regarding this Privacy Notice or request to exercise your rights please use the contact information set out below.
WS Audiology Denmark A/S
Ny Møllevej 6
3540 Lynge
Denmark
Email: privacy@wsa.com
9.3 We have appointed a Data Protection Officer. If you have any questions or comments in relation to this Privacy Notice you may also write to dpo@wsa.com.
10. For California Residents
We do not share any of your information transmitted through Widex Update Center or collected by us with affiliated or unaffiliated third parties for their own direct marketing purposes. If you are a California resident, you may request information about our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us using the information in the “Contact Information” section above. You must put the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
Widex Update Center does not support Do Not Track requests.
11. FOR FRENCH RESIDENTS
11.1 You are at any time entitled to issue directives relating to the fate of your Personal Data after death.
12. Changes to this privacy notices
12.1 We may change this Privacy Notice from time to time. If we make any changes to this Notice, you will be notified.
This Privacy Notice was last updated 01/01/2022