PRIVACY NOTICE - VIBE SINGAPORE

Last updated: 20 May 2024

1. ABOUT THIS PRIVACY NOTICE

This Privacy Notice (“Notice”) explains how Sivantos Pte. Ltd. (“we”, “our”, “us”) collects, uses, discloses and retains (collectively, how we “process”) your personal data. You consent to our processing of your personal data described in this Notice if you interact with us. If you have concerns or queries in relation to this Notice or our data protection practices, please contact us at dataprotection.apac@wsa.com.

2. WHAT PERSONAL DATA DO WE COLLECT?

“Personal data” refers to any data, whether true or not, about you which can be used to identify you either directly from that data, or from that data and other information which we have or to which we are likely to have access. We only collect personal data that is strictly necessary in relation to the purposes for which they are processed and always in accordance with what is permitted under the law. Depending on the nature of your interaction with us, we may process the following types of personal data which you provide to us:

1. Name
2. Email Address
3. Whatsapp / Mobile number
4. Date of birth or Age range
5. Country
6. Hearing aid model and serial number
7. Transactional information (e.g. account information, enquiries, payment details, shipping information, where applicable).
8. Information about your hearing loss
9. Other data provided by you.

We may also process certain data automatically from you or your device when you interact with us, including through the implementation of cookies and similar technologies. This type of data includes Internet Protocol (IP) addresses, geographic location, language and other regional settings, timestamps, browsing activity and similar information, and device information such as manufacturer and model. Only to the extent necessary and only with your consent, we may provide your contact details to a clinician should you require recommendations for one.

3. HOW DO WE USE YOUR PERSONAL DATA?

We may process your personal data to:
1. manage, operate, provide, administer your use of and access to any of our websites;
2. fulfil your sales order, generate invoices, communicate with you, and to respond to, process and handle your queries, complaints, feedback and requests;
3. maintain records relating to your sales order;
4. develop our applications, products and services, including by carrying out planning, research, analysis and testing;
5. generate insights for innovation and studies;
6. monitor and manage our infrastructure and business operations, and comply with internal policies and procedures;
7. manage and monitor the security and integrity of our technology and systems;
8. send you updates on our products and services, including to contact you in relation to any after-sales services or to inform you of any promotions;
9. defend ourselves in connection with any claims, actions or proceedings and/or protecting and enforcing our legal rights and obligations, including under our terms of use;
10. deal with and/or facilitate a business asset transaction or a potential business asset transaction relating to our business or company;
11. meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us;
12. assess your suitability for our products and services;
13. contact you about upcoming product trial or demonstrations or audiology appointments;
14. fulfil purposes which are reasonably related to any of the above purposes;
15. fulfil any other purpose which we may notify you at the time of obtaining your consent; and
16. fulfil any other purpose which is permitted by applicable data law.

We may use your personal data for marketing purposes, where we have your consent. This may include sending you information on promotions and offers.

4. WHO WILL WE SHARE YOUR PERSONAL DATA WITH?

We may share or disclose your personal data for the above purposes, with the following persons:

1. your clinician and other healthcare professionals as notified and consented to by you
2. agents, contractors, and third-party service providers who provide operational services to us, including but not limited to telecommunications, information technology, payment, billing, processing, technical services, market research, marketing, advertising attribution or any other services;
3. our affiliates;
4. our professional advisers such as auditors and lawyers;
5. and any other party to whom you consent for us to disclose your personal data to.

We may also share non-personally identifiable, aggregated, and/or public information with third-parties in addition to those listed above.

5. WHO IS RESPONSIBLE FOR THIRD PARTY SERVICES AND WEBSITES?

You may see advertisements and links to applications, websites or services operated by third parties in the course of interacting with us. We do not monitor and are not responsible for the privacy practices of third-party applications, websites or services that are linked from our platform or which you use. Please refer to the privacy notice published by the relevant third party before using them.

6. IS YOUR DATA TRANSFERRED OVERSEAS?

Your personal data may also be lawfully processed outside of your country by personnel who work for us in other countries (including Singapore, Denmark and Germany), or by our third-party service providers, suppliers, contractors or affiliates. In such a case, we will ensure that such personal data remains subject to a level of protection comparable to what is required under the laws of your country (and, in any event, in line with our commitments in this Notice).

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

The security of your personal data is of utmost importance to us. We will use all reasonable efforts to protect and secure your personal data against access, collection, use, disclosure or modification by unauthorised persons and against unlawful processing, misuse, interference, accidental loss, destruction and damage or similar risks.

Unfortunately, any transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the integrity and accuracy of any personal data which you transmit over the Internet, or that such personal data would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond our control.

8. WHAT ARE YOUR RESPONSIBILITIES?

We rely on personal data provided by you and we can only assist you effectively if you provide true, accurate and relevant information about yourself. You should only provide personal data that is strictly necessary for the purposes of processing above. If you are providing us with any personal data that is not yours, you should only provide us with such data if you have the consent or the necessary authority to do so.

Please always keep your account details confidential and do not share your account details, including your password, with anyone and you must always maintain and be fully responsible for the security of the device that you use.

9. HOW LONG WILL WE RETAIN YOUR PERSONAL DATA FOR?

We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and where there is no longer any legal or business purpose to do so.

10. HOW YOU CAN ACCESS, CORRECT YOUR DATA OR WITHDRAW YOUR CONSENT FOR US TO PROCESS YOUR DATA

You may request access to your personal data that we have. Depending on the nature and complexity of your request, we may charge a fee to process your request. We will inform you of any such fees before such a fee is charged. If any personal data which we have about you is inaccurate, you may request that we correct the data.

You may also withdraw your consent for us to process your personal data at any point in time to the extent permitted under applicable law. However, where your withdrawal of consent relates to information which we require for the provision of services to you, we might be unable to continue the further provision of such services. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

You may contact dataprotection.apac@wsa.com to exercise any of your rights in relation to your personal data.

11. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time without prior notice by posting a new version on this platform. You should check this page regularly to ensure that you are familiar with any changes. Your continued use of this platform and continued dealings with us for the provision of our products and services, after any changes to this Privacy Notice has been made, constitutes your acceptance to such changes.

12. HOW CAN YOU CONTACT US?

Please contact us at dataprotection.apac@wsa.com.

To report on any violation of this Privacy Notice or to make a complaint about an alleged breach of any applicable privacy and data protection laws, including but not limited to the Personal Data Protection Act 2012, please also contact us at the above e-mail address. We will investigate any complaint about the way we manage personal data and take reasonable steps, where necessary, to remedy any issues resulting from any failure to comply with applicable privacy and data protection laws.