Listen Responsibly Privacy Policy

In full compliance with the rules on the protection of personal data (Regulation (EU) No 2016/679), Amplifon S.p.A. invites you to read the following privacy policy to understand how your personal data, which may be acquired:

Directly: when registering the user and filling in additional fields containing personal information.
Indirectly: based on the information you actively provide using the APP will be processed through the "Listen Responsibly" APP.

Methods of data processing

"Amplifon receives and processes your data with respect and attention."

The personal data provided by you through the APP will be processed by Amplifon S.p.A. on information or computer medium.

With regard to the data received, Amplifon will carry out:

the proper registration, in the way they correspond to data you provided;
the update upon each of your communications of change;
storage in a form that allows your identification for no longer than it is necessary for the purposes for which they were collected.

Purpose of the processing

"We request your data to provide you with the most comprehensive experience in environmental noise detection."

The data provided will be processed for the following purposes:

MANDATORY PURPOSES (legal basis: your consent)

To allow the use of the services made available through the APP, such as:
a. measuring the intensity of sounds in different environments;
b. display on the interactive map of your own measurements of noise levels associated with the places where they were made, as well as those made by other users (which you will display anonymously) until that moment.
To fulfil obligations under governing laws or regulations or to comply with to instructions given by the competent supervisory and control authorities/organisations.

OPTIONAL PURPOSES: (legal basis: your consent)

carry out promotional activities by Amplifon S.p.A., which may include business communication or the sending of advertising material, or direct sales activities, market research as well as monitoring the degree of satisfaction of the data subject with regard to the products marketed by Amplifon with automated contact methods via APP (e.g., banners, push notifications)
carry out business profiling activities by Amplifon S.p.A. aimed at analysing your behaviour and your habits in using the APP (see the following paragraph). 6(b)).

Amplifon reserves the right to remove from its archives any data received, if, upon inspection, they are inaccurate, incomplete or outdated.

In addition, while preserving your anonymity and for the same purposes, Amplifon may use all the data provided for statistical purposes.

The provision of personal data requested by Amplifon is optional.

However, failure to provide data for:

mandatory purposes: would not allow you to use the services offered by the APP.
optional purposes: would not allow you to receive useful and advantageous promotions on our products or to customise your experience according to your specific needs.

Type of data processed

"We request your explicit consent, which you may revoke freely at any time."

Amplifon requests the following data from you in order to use the APP and benefit from its services:

Common data (identifiers): these are the data that allow you to be directly identified (name, surname, date of birth, tax code, e-mail, etc.)
Geolocation data: these are the data that could detect the location or movements of the data subject.

In order to process your data, we request your explicit consent, including for the above mandatory purposes, which may be freely revoked at any time but without prejudice to the lawfulness of the processing before revocation. The consent may be easily revoked in the "Privacy" section of the APP.

Scope of data flow

"Your data will be processed by as few people as possible, specifically authorised by Amplifon"

For the pursuit of the purposes described in paragraph 2 above, the personal data provided may flow in the following areas:

Areas attributable to Amplifon - Your data may be used by employees or independent contractors of Amplifon:

a) who has been assigned a specific role as Data Manager or person in charge of the data processing or Data Processor;

b) to whom appropriate instructions have been given;

c) also bound by an obligation of confidentiality.

Your personal data will be made accessible only to those who, within the company, need them to carry out their work. These persons are suitably instructed in order to avoid loss, destruction, unauthorised access or unauthorised processing of data. Furthermore, the data may be used by third party companies that carry out instrumental activities on behalf of Amplifon such as:

External consultants for legal assistance and advice for the management of possible litigation;
Service companies (also IT companies): entities that provide services for the management of IT systems, entities that carry out data entry activities, suppliers of cloud systems, etc.;
Public entities or supervisory and control authorities and bodies that receive communications from Amplifon and, more generally, public or private entities in the capacity of public officers or persons in charge of a public service;
Companies belonging to the same group to which the Data Controller belongs, for administrative-accounting or archiving purposes.

The above-mentioned persons act as external data processors and under the direction and monitoring of Amplifon.

Pursuant to Article 44 of the GDPR, Amplifon may transfer your personal data to group companies located in countries outside the European Union or the European Economic Area. In this circumstance, Amplifon shall adopt contractual guarantees (such as the signing of standard contractual clauses approved by the EU Commission) signed with the foreign company receiving the data; these clauses ensure a level of data protection corresponding to that established by European legislation.

Disclosure of data

"Your data will never be disclosed."

Your personal data will never be published, displayed or made available to undetermined persons.

Profiling

"Your data will not be subject to fully automated decisions"

Amplifon does not subject your data to fully automated decisions that produce legal effects that concern you or that have a similarly significant impact on you, but collects and analyses, through the intervention of personnel in charge and instructed to process the data provided by you also through the normal use of the APP in order to carry out activities of analysis of your behaviour, preferences and habits, so as to allow the Data Controller to carry out promotional activities more in line with your individual needs. (optional purpose). For example, if the surveys carried out show that persons are spending time in environments with above-average noise levels and potentially harmful to hearing, hearing protection devices may be proposed.

Data retention

"Your data will be stored for the time necessary for the personalised use of the APP, together with related activities to promote our products"

The personal data that you provide us will be kept for a period not exceeding the achievement of the purposes:

of a mandatory nature: for the duration of your use of the APP; to provide you with a personalised user experience and to allow you to view the interactive geographical map with the noise measurements you have made. In any event, your personal data may not be stored for more than five years after your last interaction with the APP.
of an optional nature: personal data processed for business communication purposes and possible profiling will be processed for no more than 15 years from the granting of consent and/or the last purchase/test, given the particular type of products and services offered by Amplifon and the ongoing assistance relationship that is established with the Customer, who may his/her consent at any time without prejudice to the lawfulness of the processing before revocation.

Rights of the data subject

"You have the right to request Amplifon access, portability and erasure of your data, as well as the limitation and opposition to processing"

In relation to the processing of your personal data, you have the right to request Amplifon:

Access: you may request confirmation whether or not data concerning you are being processed, as well as further clarification of the information contained in this privacy policy.
Rectification: you may request that the data you have provided us with be rectified or completed if they are inaccurate.
Erasure: you may request that your data be erased if they are no longer necessary for our purposes, if you revoke your consent or if you object to their processing, if they are processed unlawfully, or if there is a legal obligation to erase them.
Restriction: you may request that your data be processed only for the purposes of storage, excluding other processing, for the period necessary to rectify your data or in the event of unlawful processing for which you object to the erasure or if you have to exercise your rights in court and the data stored by us may be useful to you or, finally, if you have objected to the processing and a verification whether our legitimate grounds override yours is pending.
Objection: you may object to the processing of your data at any time, unless there are legitimate grounds for us to carry out the processing that override yours, for example for the exercise of a right or our defence of legal claims.
Portability: you may request to receive the data you provide us, or have them transmitted to another data controller indicated by you, in a structured, commonly used and machine-readable format.

Furthermore, we hereby inform you that if the Data Controller fails to respond or partly responds to the above mentioned requests, you shall have the right to lodge a complaint or bring an action with a supervisory Authority.

At any time, you may exercise your privacy rights with respect to Amplifon without any formality, including through an authorised third party with a specific proxy, communicating by means of:

registered mail: Amplifon S.p.A. - Via Ripamonti n. 133 - 20141 Milan attn. Data Manager Corporate HR
e-mail: privacy@amplifon.com

Data Controller, Data Processors and DPO

"The Data Controller of your data is Amplifon S.p.A. The list of Data Managers is available on request. The DPO is the Legal Affairs Officer"

The Data Controller is the Corporate organisational structure of Amplifon S.p.A. - with registered office at Via Ripamonti No. 133, 20141 Milan, Italy, in the person of the pro tempore Chief Executive Officer (hereinafter referred to as "Amplifon Corporate" or the "Data Controller").
The updated list of Data Managers may be requested at the following email address privacy@amplifon.com.
The Data Protection Officer of Amplifon S.p.A. is the pro-tempore Legal Affairs Officer and may be contacted at the following email address privacy@amplifon.com

CONSENTS

Having read the privacy policy:

Age declaration:

☐ I hereby declare that I am over 16 years of age

Data usage in the app

☐ I hereby grant my consent to the processing of my data in order to use the services offered by the APP as per paragraph 2, letter a) of the privacy policy

Receive promotional materials

☐ I hereby grant my consent to the processing of my data in order to receive promotional information from Amplifon as per paragraph 2, letter c) of the privacy policy directly via APP (e.g., banners, push notifications)

Commercial profiling purposes

☐ I hereby grant my consent to the processing of my data for business profiling purposes by Amplifon S.p.A. as per paragraph 2, letter d) of the privacy policy aimed at analysing my behaviour and habits in using the APP.