Privacy Policy 

Date: 25/05/2018

We at Blackberry Hearing (collectively, “we” and “us”) know you care about how your personal data is used and shared, and we take your privacy seriously.

Please read the following to learn more about how we collect, store, use and disclose your personal data*.

*Personal data is data relating to a living individual who can be identified, or is identifiable, using this data or if this data is used in conjunction with other data that is in Blackberry Hearing’s  possession, or could come into its possession.

Who is the Data Controller

Every company should appoint a Data Controller. A Data Controller is the person in the company responsible for safeguarding your personal information and whose responsibility it is to decide to inform you and/or the DPC in the event of an external data breach, such as a computer theft. In Blackberry Hearing the Data Controller is Dave Gleeson and he may be contacted on the main telephone number.

Personal data you provide to us

Blackberry Hearing will only keep and use the personal data which has been specifically provided by you. We do not use any third party to gather personal data unless it has been specifically provided by you for the purpose of us, Blackberry Hearing, providing you with a consultation or potentially providing you with a hearing solution. Your personal data will not be shared with any other company and will not be transmitted outside the EU. You may choose to contact us or inform us by phone, email, in person, in the clinic, on Facebook or other social media platforms or by interacting with us on our website. In all cases, we will request and use only that personal data that enables us to provide you with a consultation or a hearing solution.

For example, we will use the following personal data for the following reasons:

•   Name and number: Contact as agreed by you and after purchase to enable us to provide a follow-up service.
•   Address: To provide you with any additional accessories, replacements, batteries, and so on and consultations or follow up visits at home if agreed.
•   PPS Number and Date of Birth: We have a portal to the Department of Social Protection which enables us to check your grant eligibility. In the event, you are eligible this enables us to discount you the amount of the grant at the time of purchase. It also allows us to inform you of the net price so that you can make a fully informed decision.
•   Credit Card details: To enable a purchase in the clinic or over the phone of hearing aids, replacement parts or accessories. The data will only be kept as long as it is necessary to process the agreed payment.
•   Health and general personal information: This may be collected on the phone or in the clinic with the purpose of ensuring you get the optimum solution to suit your lifestyle and to ensure your wellbeing, as much as is possible.

When you engage with Blackberry Hearing we will receive and store personal data that you provide directly to us. In some cases, you may be ‘opting in’ for an ‘offer’ or ‘promotion’ on our website or a social media platform. You will be made explicitly aware that your data is being collected for our use and the processing of your interest in our products and service.

The types of personal data we may collect directly from you include names, email addresses, postal addresses, phone numbers, social insurance numbers as well as any other contact or other information you choose to provide us in connection with our business and to allow us to fully inform you of our products, services and prices.

Should you contact us and not proceed with a consultation in the short term but express an interest in us making contact with you at a later time we will keep the necessary personal data on file to enable us to that.

If you purchase from us we will keep your personal data on file to ensure we can provide you with the follow-up service that is required for hearing aid users.

Disclosure of Your Personal Data to Third Parties

We do not rent or sell your personal data to anyone.

Protection of Blackberry Hearing and Others: We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of Blackberry Hearing, our employees, our customers, or others.

Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

How We Secure Your Personal Data

We use appropriate technical, organizational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction.

For example, on our website:

•   We use regular Malware Scanning on our site to confirm it is safe to use
•   We use a range of security tools to monitor activity on the site and identify unusual activity.
•   Your personal information is only accessible to a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
•   In addition, all information you supply through the website is encrypted via Secure Socket Layer (SSL) technology between your browser and the site.

In terms of local devices, Blackberry Hearing has implemented a range of security measures to protect the information we hold in our records. For example:

•   All devices use encryption so data is secure.
•   All data is saved to the cloud where it may be wiped or deleted in the event of a theft of a computer or smartphone.
•   All our computers are fitted with anti-virus and anti-spam software
•   All paper files with personal data will be securely locked away

Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. In the unlikely event that such a breach occurs, we will contact you and/or the DPC if we feel that your personal data is compromised.

How Long We Retain Your Personal Data

Personal data is retained for only as long as Blackberry Hearing has a legitimate basis to retain the data.This personal data is used to support our clients with follow up visits, batteries, filters and other accessories. In some cases, it is retained in order to contact clients, and potential clients when requested, with a follow-up telephone call and information. If you are a client we will keep the data for at least the duration of the hearing aids’ warranty, which is 4 years to enable us to provide a full back up service.

Privacy with regard to Facebook Messenger

Blackberry Hearing on Facebook

Data privacy notice for Messenger

This data privacy notice (April 2019) applies to the information processed by Blackberry Hearing. This notice is intended to inform you about the processing of personal data in the Facebook Messenger (Messenger).

Processing of data by Blackberry Hearing                                                                                                                               

If you are registered with Facebook or Instagram, you can have ads placed in your timeline or directly in the Messenger App. If you click on the ad and activate the “call-to-action button” a chat window will open, and a message is sent to us via the message function. Such messages are invisible to other Facebook users.

What data does Blackberry Hearing collect?

In the chat we ask you to provide following contact data: your first name and surname, e-mail address, phone number in order to enable us to provide you a follow-up service.

We also ask you to provide your location to schedule an appointment near you or data of birth to check your grant eligibility. In the event, you are eligible this enables us to discount you the amount of the grant at the time of purchase.

If you chat with us, you might provide also other personal data voluntarily including data relating your health status like the quality of your hearing.

We process all personal data contained in a message sent by you to Blackberry Hearing exclusively in order to respond to your inquiry. You active the chat by giving consent with the call-to-action button (Art. 6 I a) GDPR). The legal basis for processing data in the chat is Art. 6 I f) or Art. 9 II e) insofar this personal data relates to health-related problems that are made public by you. Insofar as you wish to enter into a contractual relationship with Blackberry Hearing with your inquiry, the legal basis for such processing is Art. 6 I b) GDPR.

We shall not retain personal data asked by Blackberry Hearing any longer than is required for the purposes described or required under applicable legislation. The Messenger chat is deleted if your inquiry has been answered and no other grounds exist to entitle or oblige us to keep the said message which is in any case no longer than 3 months.

We are not cognizant of the manner in which messages Blackberry Hearing sent to are analyzed, interpreted or otherwise processed by Facebook. In this regard, we refer you to Facebook’s Privacy Policy.

 

Your rights with respect to your data                                                                                                                       

You are always entitled to object to the processing of your data or withdraw your consent.

More details including about your rights in relation to processing of your personal data you can find in the Blackberry Hearing Privacy Policy.

 

 

 

With who do we share the data?

We do not transfer data to any third party without your explicit permission, unless we are obliged to do so under applicable legislation or by order of the competent supervisory authority.

We employ other companies which process data solely on our behalf, for example, to help us with marketing. Such data processors are only entitled to process the data needed to perform its services and activities and in accordance with our written instructions. The processors guarantee that they have implemented appropriate technical and organizational measures in such a way that their processing meets the requirements of the GDPR and ensure the protection of the rights of all data subjects. The processing of data by such processor shall always be governed by an agreement.

Processing of data by Facebook                                                                                                                                                                

When you use Messenger, Facebook records details including your IP address and further information, which is directed to Facebook via technical means on your device. Among other purposes, this information is used to

supply Blackberry Hearing with statistical information about the reach of the ads. For this Facebook’s Business Tools like Facebook Custom Audience for cross-device marketing is used.

Facebook’s Privacy Statement gives you more information about it: https://www.facebook.com/about/privacy/update

If you wish to object to the use of the Facebook Custom Audience, you can do so at https://www.facebook.com/ads/website_custom_audiences/

 

The data relating to you that is gathered in this connection is processed by Facebook and under certain circumstances supplied to countries outside the European Union. Facebook sets out what information it obtains and how this is used in its “Data Policy”.

 

Contact                                                                                                                                                                                          

Questions, comments, requests and complaints regarding this Policy and the information we hold are welcome and should be addressed to us at info@blackberryhearing.com. All requests will be dealt with promptly and efficiently.

 

Your Rights

•   While we have personal data about you, you have certain rights. These include:

·         Right to access

•   You may request a copy of all personal data held by Blackberry Hearing about you.

·         Right to rectify

•   You have the right to ask Blackberry Hearing to correct any inaccuracies in the personal data held about you.

·         Right to erasure

•   You have the right to ask that we erase any personal data we are processing about you. Please note that we may still be allowed to retain and use your information. For example, as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and defend or establish a legal claim.

·         Right to restrict

•   In certain circumstances, you have the right to request that we restrict the processing of your personal data.

·         Right to object

•   In certain circumstances, you have the right to object to our processing of your personal data.

·         Right not to be subjected to automated decision making

•   You have the right not to be subjected to automated decision making where the decision has legal or significant effects.

·         Right to withdraw consent

•   Where we are processing your personal data on the basis of your consent, you have the right to withdraw your consent at any time. For example, if we are sending you marketing emails, you can withdraw your consent immediately by clicking the UNSUBSCRIBE link in the footer of the email.

·         How to exercise your rights

•   Please contact us at info@blackberryhearing.com and provide us with as much information as possible to enable us to complete your request.

·         Right to complain

•   If you believe Blackberry Hearing is breaching your data protection rights, you have the right to complain to the data protection regulator. Blackberry Hearing is established in Ireland and is regulated by Ireland’s Data Protection Commission

Changes to this policy

We reserve the right to change this Policy from time to time in our sole discretion. If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this Policy as modified.

Access Request Form

You have the right to access and receive a copy of the personal information we hold about you. We ask that you download, print and complete the attached form, from the link provided below, so we can determine the details of your request and respond to and implement your request as quickly as possible. Thank you.

Blackberry Hearing- Access Request Information Form

Contact Us

Questions, comments, requests and complaints regarding this Policy and the information we hold are welcome and should be addressed to us at info@blackberryhearing.com. All requests will be dealt with promptly and efficiently.