This Privacy Policy applies to any data you provide us.  This Privacy Policy outlines how by Amplifon S.p.A. and our “affiliates” (i.e. the companies belonging to the Amplifon Group) (collectively “we”, “us” or “our”), may collect and use information from you for the Purpose noted below. This Privacy Policy is intended to comply with the applicable laws and regulations on the protection of personal data including, without limitation, the New Zealand Privacy Act 1993, the EU Regulation no. 2016/679 (collectively “Applicable Laws”). We are committed to protecting the privacy of your data and we invite you to read the following policy.

Any personal data you voluntarily provide us will be processed by us on paper or via computer or electronic support. With regard to the data we receive, we will ensure:

• accurate recording, so that the data corresponds to what you have communicated;
• appropriate updating, based on any request for change you make;
• storage in an identifiable form (i.e. that makes it possible to identify you) only for as long as necessary for the purposes for which they were collected.

We collect certain personally identifiable information that is specific to you and may include your contact information such as, full names, addresses, phone numbers, and email addresses.  We may also collect your responses to certain questions which help us to identify the services and promotional initiatives which may be of interest to you consistent with the Purpose (collectively your answers and personally identifiable information is your “Personal Information” or “personal data”).  We will not provide any of your personal data to any unaffiliated third parties without your express consent.

We may also collect and process information about the physical location of your mobile device using GPS or other location technologies, such as sensor data from your mobile device providing information about nearby Wi-Fi access points and cellular network towers (“Location Information”). You have the ability to control access to Location Information through the control settings on your device.

We may also collect information regarding your use of our website through software application tools and data files, such as cookies, web log files, IP addresses, device state information, unique device identifiers, device hardware and OS information, and information relating to how the website is functioning (“Usage Information”).  You have the ability to control access such Usage Information through the control settings on your device.

Please note that your election to remove our access to Personal Information, Location Information or Usage Information may impact our ability or that of our affiliate to provide you with the services and promotional initiatives noted above as the Purpose. If you have any questions about our use of Personal Information, Location Information or Usage Information, please feel free to contact us.

The data we ask you to provide (i.e. your Personal Information) is collected in order to allow you to get in touch with our affiliate operating in your area of residence to book a hearing test, as well as to allow us to keep you updated on specific promotional initiatives reserved for you (the “Purpose”). In particular, we collect data through our website and transfer it to the affiliate operating in the territory where you live in order to allow our affiliate to pursue the Purpose. We use your Personal Information to:

·      Ensure the correct affiliate may then contact you by traditional means - by mail or telephone - or automated - such as mms, sms, email, WhatsApp or automated calls (profiled marketing, see also the next point).

·      Respond to any requests you make to us regarding your rights under the Applicable Laws.

·      Perform data analytics.

·      Communicate with you, including as noted above by our affiliate or in response to any request you make or question you may ask through our contact information.

·      Provide you with information on hearing testing or promotional initiatives.

We use Location Information to ensure the appropriate affiliate contacts you.

We use Usage Information to assess our products, services and customer support, and enhance, improve and develop new products and services.

We reserve the right to remove this data from our archive if it is inaccurate, incomplete or outdated.

You may voluntarily elect to provide us with the data requested by us; your provision of this data is optional. However, if you elect to not provide us with your data, we will be unable to invite you to participate in our affiliate’s hearing test or propose promotional initiatives that may be of interest to you (i.e. the Purpose).

In any case, even if you give your consent, you have the right to revoke it at any time, without prejudice to the lawfulness of processing before revocation.

The legal basis for processing is therefore your informed consent (i.e. as the “data subject”).  Except for our affiliates, we will not share Personal Information or Location Information with an unaffiliated third party without your prior authorization, unless doing so is necessary (1) to enforce this Privacy Policy, to comply with Applicable Laws or to protect the rights, property or safety of us or others, (2) to comply with a valid order or process from a public authority, (3) to protect against misuse or unauthorized use of our website, (4) to detect or prevent criminal activity or fraud, or (5) in the event that we or substantially all of our assets are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, in which case such information may be one of the transferred assets.

We do not subject your data to fully automated decisions, which produce legal effects that concern you or that significantly affect your person, rather we collect and analyze the data you supply in order to carry out an analysis of your behaviour, preferences and habits, so as to allow our affiliate to provide the promotional activities that are more in line with your individual needs.

For the purposes described in the paragraph above, your data may be used by our or our affiliates’ employees:

1. who have been assigned a specific role;
2. who have received appropriate instructions;
3. who are also bound by an obligation of confidentiality.

Your Personal Information will only be made accessible to people within our company or our affiliate who need such access for our business needs and the Purpose. These persons shall be appropriately instructed in order to avoid loss, destruction, and unauthorised access or processing of such data. The data may also be transmitted to external subjects, appointed as data processors, who perform specific tasks or services on our behalf (for example, companies providing IT services or data hosting services). 

Your personal data will never be published, displayed or made available to unknown third parties.

In order to allow the pursuit of the Purpose, your data will necessarily be transferred to our affiliate operating in the territory where you live.

In relation to the Purpose, you have the right to request from us:

• Access: You may request confirmation of whether or not data concerning you are being processed, as well as further clarification of the information contained in this document.
• Correction: You may ask to correct or supplement the data you have provided to us if inaccurate.
• Erasure / Deletion: You may request that your data be deleted, if it is no longer necessary for our purposes, in case of revocation of consent or your objection to such data processing, in case of unlawful processing, or a legal obligation to delete exists.
• Limitation: you may request that your data be processed only for the purpose of storage and not for other processing, for the period necessary to correct your data, in the event of unlawful processing that you want deleted, if you need to exercise your legal rights and the data we stored may be useful to you and, finally, if you object to processing and a verification is in progress to see whether our legitimate grounds take precedence over yours.
• Objection: You may object at any time to the processing of your data, unless our legitimate grounds for us to proceed with the processing take precedence over yours, for example for the exercise or our defence in court.
• Portability: You can ask to receive your data, or to have them transmitted to another holder you have indicated, in a structured, commonly used format, readable by automatic device.

Furthermore, we inform you that you have the right to lodge a complaint against us with the Supervisory Authority, which in Italy and in New Zealand is - respectively - the Guarantor for the Protection of Personal Data and Office of the Privacy Commissioner.

At any time, you may ask to exercise your previous rights by contacting us by sending an email to: privacy-NZ@earpros.com.

Each communication sent to the e-mail address stated above should contain at least the following mandatory information:

• Your name and surname;
• Your state of residence;
• The type of the request.

The personal data you provide us with will be kept for the period necessary to carry out the Purpose indicated above, and in any case no later than 7 years after your consent has been given.

Data security is implemented through appropriate physical, administrative, and technical safeguards we put in place and operational procedures we follow to protect your Personal Information in accordance with Applicable Laws. We protect your transactions involving your Personal Information over the Internet using Secure Sockets Layer (SSL) technology. We restrict access to your Personal Information in our database to our authorized employees, agents, certain of our authorized affiliates as appropriate or necessary for the Purpose.

We do not knowingly collect information from children under the age of 13, nor does our website target children under the age of 13.  By using our website and providing your information, you represent that you are not younger than 13.

The Data Controller is the organisational unit of Amplifon S.p.A. that manages personal data in reference to the Global market - with registered office at Via Ripamonti 133, 20141 Milan, in the person of the pro-tempore Group CEO.

An updated list of Data Managers can be obtained from privacy@amplifon.com.

The Data Protection Officer of Amplifon S.p.A. is the pro-tempore Italy Legal Affairs Director, who can be contacted at privacy@amplifon.com.

We may modify, alter or update our privacy policy at any time, so we encourage you to review our privacy policy frequently. We will not provide individual notice to you of changes to our privacy policy, but when we make updates to our privacy policy, we will update the date in this section.