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This is a campaign of Sonova Audiological Care Polska sp. z o. o. in cooperation with Sonova Marketing GmbH

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Global Privacy Policy

A. GENERAL INFORMATION
Sonova AG is registered under Swiss law as a data controller, with its registered office at Laubisrütistrasse 28, 8712 Stäfa, Switzerland, and operates with its affiliates located around the world (collectively, the "Company" or "we" or "our").
Because the Company processes personal data in its daily operations, this Global Privacy Policy ("Policy") has been developed and implemented to describe the Company's practices regarding the use of Personal Data relating to its customers, contractors, and partners ("Data Subjects"). The Company pays particular attention to respecting privacy and personal data and is committed to complying with this Policy in accordance with applicable local laws.
By "Personal Data," we mean any information relating to an identified or identifiable natural person.
By "Processing," we mean any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
B. APPLICABLE LAW POLICY
The Company is committed to complying with applicable data protection laws ("Applicable Law"). Therefore, depending on the countries in which the Company is based, the processing of personal data will be subject to local applicable law. While certain requirements may vary from country to country, the Company places particular importance on the privacy of data subjects, and this Policy constitutes a global guideline to which the Company is committed.
In particular, the Company undertakes to comply with the following legal provisions, where applicable:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) ("GDPR"). The GDPR aims to harmonize and define the framework for the processing of personal data within the European Union in order to provide a uniform legal framework for professionals and aims to strengthen citizens' control over the use of their personal data. This Regulation applies to the processing of personal data of EU citizens or residents and to the activities of a controller or processor within the EU.
The Swiss Federal Data Protection Act of 19 June 1992 ("FADP"), as amended in 2020 to adapt to current technology and align with the GDPR and other recent European regulations.
The California Consumer Privacy Act of 2018 ("CCPA"), which aims to provide greater transparency and guarantee enhanced rights for consumers residing in California whose personal data is processed by businesses.
The Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), which sets out US regulations for the electronic processing of health data by healthcare organizations and business associates.

C. COLLECTED PERSONAL DATAThe Company may process the following personal data:

Identity data: surname, first name, nationality, and date of birth
Contact data: postal address, private telephone number, private email address, and emergency contact
Social security reference number and insurance company
Financial data: means of payment, financial institution, IBAN
User health data: weight, height, medical conditions, prescription, hearing, activity tracking (step count, exercise intensity, exercise minutes), fitness data (heart rate, energy expenditure, blood pressure)
User behavior data on the website
Data regarding the product purchased by the customer: model, serial number, usage data
Data regarding the service provided
Data regarding customer feedback about our products and services: comments and remarks

Furthermore, because our business is primarily focused on the production of innovative hearing aid solutions, we may be required to collect sensitive personal data, specifically health data. Depending on the country in which the data subject resides, this sensitive personal data may benefit from special protection, particularly with regard to implemented security and confidentiality measures. D. PURPOSES OF PROCESSING PERSONAL DATA The following legal bases constitute the foundation on which the Company relies when processing personal data. Other legal bases may be used depending on the data subject's place of residence and the relevant applicable law. Firstly, some personal data processing activities may be based on the consent of the data subject. Processing of personal data for this purpose may include:

Marketing purposes, such as sending newsletters and information about products and services offered by the Company
Improving the performance of our website
Assistance and cooperation in creating an account, contacting us via the contact form, responding to user inquiries via Sonova, and conducting an online hearing test

Furthermore, the processing of personal data carried out by the Company may also be based on the performance of a contract or pre-contractual measures with data subjects. Processing personal data for this purpose may include:

Fulfilling our contractual obligations towards data subjects
Providing after-sales services after a customer purchases a product
Social security/insurance administration
Claims management

The Company may also process personal data based on its legitimate interests, in particular to improve our products and services, customer service, and internal processes. Processing personal data for this purpose may include:

Conducting statistical/usage analyses
Performing internal administrative functions
Processing customer requests
Preventing fraudulent activities and improving security
Managing relationships with data subjects
Assessing the suitability of our products and services

The Company may also process personal data to comply with legal requirements. Processing based on legal requirements depends on applicable law.E. STORAGE OF PERSONAL DATAPersonal data will not be stored longer than necessary for the above-mentioned purposes. This means that personal data will be deleted as soon as the purpose of personal data processing has been achieved. However, the Company may retain personal data for longer periods if necessary to comply with applicable law or if necessary to protect or exercise our legal rights, to the extent permitted by applicable data protection law. After the retention period ends, we may need to archive personal data, for a limited period and with restricted access, to comply with applicable law. These retention periods may vary depending on the country in which the data subjects are located and in accordance with applicable law. F. DISCLOSURE OF PERSONAL DATAThe Company may share personal data, with your consent or other appropriate legal basis, with the following third parties:

Other companies in our group, such as subsidiaries and affiliates
Trusted business partners who provide services on our behalf, such as for technical support, marketing purposes, or other types of services
Governmental and public authorities, insofar as necessary to provide any services requested or authorized, to protect the rights of customers, contractors, and partners, or ours or others' rights, property, or safety, to maintain the security of our services, or if we are required to do so by applicable law, court, or other government regulations, or if such disclosure is otherwise necessary to support any legal or criminal investigation or proceeding court

Subject to applicable law, we enter into agreements with certain third parties to ensure that personal data is processed based on our instructions and in accordance with this Policy and any other appropriate confidentiality and security measures.G. TRANSFER OF PERSONAL DATAThe above-mentioned third parties, such as affiliates and subsidiaries, as well as business partners and public authorities, to whom we may disclose personal data, may be located outside the country of residence of the data subject, potentially including in countries where data protection laws may differ from those in the country where the data subject is located. If personal data is processed in the European Union/European Economic Area, and in the event of disclosure to third parties in a country that, according to the European Commission, is not considered to provide an adequate level of protection, the Company will ensure:

Implement appropriate procedures to ensure compliance with applicable law, in particular where a request for authorisation from the competent supervisory authority is necessary.
Implement appropriate organizational, technical and legal safeguards to govern the transfer and to ensure necessary and adequate level of protection under applicable law.
Where necessary, implementing standard contractual clauses adopted by the European Commission.
Where necessary, taking additional measures, such as conducting an adequacy assessment of the data transfer, if, after assessing the circumstances of the transfer and the third country's legislation, this is necessary to protect the personal data transferred.

If personal data is not processed in the European Union/European Economic Area, or if personal data is disclosed to third parties located outside the jurisdiction of the data subject, the Company will ensure appropriate safeguards to protect personal data by implementing appropriate legal mechanisms. These mechanisms may vary depending on the country and the relevant applicable law. H. SECURITY OF PERSONAL DATA The Company implements various security measures, in accordance with applicable law, to protect personal data against security incidents or unauthorized disclosure, and therefore against personal data breaches. These security measures are considered appropriate industry standards and include, among other things, access control, password protection, encryption, and regular security assessments. In the event of a personal data breach, and in particular in the event of a security breach resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed, the Company will take appropriate measures, such as:

Investigating and analyzing to determine the consequences of the personal data breach, in particular whether it may pose a risk to the rights and freedoms of affected individuals.
If the analysis indicates a risk to the rights and freedoms of affected individuals, notifying the relevant authority and, in the event of a high risk, informing the affected individuals.
Implementing the necessary measures to remedy and mitigate the personal data breach as soon as possible.
Documenting the personal data breach to ensure its traceability.

The appropriate measures and procedures in the event of a personal data breach may vary depending on the country in which the breach occurs, the type of breach and the applicable law.I. PRIVACY RIGHTS RELATED TO PERSONAL DATADepending on the applicable law, data subjects have rights in relation to their personal data, such as the right to request access, rectification, erasure of their personal data, restriction of processing, object to processing, request data portability, obtain information and withdraw consent to the processing of personal data. Data subjects may also object to automated individual decision-making where such processing applies to them. Furthermore, in some jurisdictions, you may be able to provide instructions regarding the storage, communication, and deletion of your personal data after your death. The exercise of these rights is not absolute and is subject to limitations provided by applicable law. Data subjects may have the right to lodge a complaint with a local supervisory authority or competent regulatory authority if they believe that the processing of their personal data violates applicable law. To exercise these privacy rights, data subjects may contact us as described in the "How to Contact Us" section below. We may ask for proof of identity to respond to your request. If we are unable to comply with your request (refusal or restriction), we will justify our decision in writing. UPDATES TO THIS POLICYWe may update this Policy from time to time to reflect new or different privacy practices. When we do, we will post updated versions of this Policy on this page. The revised Policy will only apply to data collected after its effective date. We encourage you to periodically review this page for the latest information on our privacy practices.K. HOW TO CONTACT USIf you have any questions, comments, or concerns about this Policy, or to exercise your privacy rights under applicable law relating to your personal data, please contact our Data Protection Officer at the following address: Sonova AG, Laubisruetistrasse 28, 8712 Stäfa, Switzerland, or by email to:[email protected]

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