Privacy Notice for Oticon Medical’s processing of personal data on social media platforms
At Oticon Medical, we respect and protect the privacy of our users, and we are dedicated to being as transparent as possible regarding the use of your personal data.
This privacy notice ("Privacy Notice") explains how Oticon Medical processes your personal data in connection with your interaction with Oticon Medical as a data controller by use of different social media platforms, such as Facebook, Instagram, Twitter, YouTube and LinkedIn.
In this Privacy Notice, "we", "us" and "our" mean Oticon Medical.
We may change this Privacy Notice from time to time, so please check back when you use our services to make sure that you have seen the most recent version.
2. WHO WE ARE
If you have any questions about this Privacy Notice, or you would like to exercise your rights, you can contact us by using the contact points below.
Oticon Medical A/S
3. PERSONAL DATA WE COLLECT AND USE
We may process the following types of personal data:
- Information about you, such as your name, email, age, gender, country, job title, current and former employer, education background, profile picture, interests, your friend list/connections/followers etc., and other publicly available information, provided that you have published all this information on your social media profile or posted it on one of Oticon Medical’s social media pages.
- Other information you provide to us by posting on Oticon Medical’s social media page, including your comments and/or likes to our posts and pictures or direct messages you send to us via Oticon Medical’s social media platforms.
In some cases, for instance, in relation to our Facebook page, Oticon Medical acts as joint controller together with Facebook in relation to the processing of your personal data. Thus, we recommend that you read Facebook's privacy notice to understand how Facebook processes your personal data.
We generally refer to the different social media platforms' privacy notices for more information about their processing of your personal data. Below you will find a listing of the social media platforms that Oticon Medical uses and a reference to their privacy notices.
4. WHY DO WE COLLECT AND USE YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS FOR DOING SO
We use your personal data for the following purposes:
- To understand the audience to our social media channels by getting to know the demographic, preferences and interests which enables us to provide relevant information.
- To analyse trends and profiles to enhance, modify, personalise and improve our services and communications for the benefit of our audience.
- To process and respond to requests and enquiries received from you.
- To carry out market surveys to enhance, modify, personalise and improve our services and communications for the benefit of our users through Oticon Medical’s social media pages on Facebook, Instagram, Twitter, YouTube and LinkedIn.
- To recommend products and services we think you will be interested in. We do to carry out direct marketing to our customers and/or potential customers. However, if we use electronic methods, such as email or direct messaging through our social media pages, for instance, via Facebook and/or Instagram, to send direct marketing to you, we will only do so if it is permitted under the applicable rules on direct marketing.
The legal basis for collecting and processing your personal data via Oticon Medical’s different social media pages is our legitimate interest as described above in accordance with EU General Data Protection Regulation (“GDPR”) art. 6(1)(f). Our legitimate interests are under these circumstances regarded to override your interests.
5. HOW WE SHARE YOUR PERSONAL DATA
We will not pass, sell or otherwise share or disclose your personal data, except as described herein or otherwise stated at the time the personal data is collected.
As mentioned under section 3, we may act as joint data controller in relation to the processing of your personal data via our social media pages together with the specific provider of the social media, for instance, Facebook Inc. or Facebook Ireland Ltd. This means that we are jointly responsibly for processing of your personal data. We have inserted a reference to Facebook’s privacy notice in section 3.
We may share your personal data with affiliated companies within the Demant Group in order to deliver, enhance and develop our products and services. Please refer to the organisational chart in our latest annual report to see which companies form part of the Demant Group. You can find our latest annual report at www.demant.com.
We may share your personal data with our service providers for a variety of tasks, such as:
- assisting us with administering or troubleshooting our website;
- assisting us with the supply or design of our products or with our business administration;
- assisting us with our marketing campaigns, for instance, via Facebook Custom Audiences and Facebook Lookalikes;
- providing us with electronic or physical storage services or systems.
We will only share your information under these circumstances, if it is necessary in order for our service providers to perform the specific service for us. These service providers are not authorised to keep or use your personal data for any other purposes, and they will always be under an obligation to keep your personal data safe and confidential.
6. TRANSFER OF DATA TO THIRD COUNTRIES
In order to deliver our products and services to you, we may share your personal data with affiliated companies in the Demant Group located outside the EU/EEA and non-affiliated companies, such as service providers or business partners located outside the EU/EEA provided this is considered necessary in relation to a particular data processing activity or performance of the service.
If your personal data are transferred outside the EU/EEA, we will implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the relevant data protection laws including ensuring the protection of the rights of the data subject. Where necessary, we have entered into the EU Commission’s standard contractual clauses with the recipient of the personal data. The EU Commission finds these clauses to provide adequate guarantees for the protection of privacy, basic rights and liberties, as well as for exercising the associated rights.
7. HOW LONG DO WE KEEP YOUR PERSONAL DATA
We will keep your personal data for as long as necessary for legitimate legal or business reasons, including to comply with any regulatory obligations.
We will delete your personal data, when it is no longer required in relation to the purpose for our collection, processing and storage of your personal data. We will also store personal data that we are obliged to keep in accordance with the law.
If you have commented on any of our posts on social media platforms, such comments will be deleted at the time when the post in question is deleted. We may, however, choose to delete specific comments at an earlier point in time. You may also at any time choose to delete your own comment.
Information that is collected via social media platforms for a specific purpose, for instance, a targeted marketing campaign, will be deleted 1 year after the specific processing activity is carried out. Certain data may be retained up to 2 years after the specific campaign for documentation purposes.
If you would like more detailed information about our retention policy, please contact us by using the contact points in section 2 above.
8. YOUR PRIVACY RIGHTS
Pursuant to the GDPR, as a result of our processing of your personal data, you may exercise a number of rights. They are:
- The right to access to your personal data
- The right to have us rectify (correct) your personal data
- The right to have us delete your personal data
- The right to restrict our processing of your personal data
- The right to data portability
- The right to object to our processing
These rights may, however, be subject to conditions and/or exemptions, e.g. to ensure other people’s privacy, trade secrets, intellectual property rights or to comply with a legal obligation.
If you would like to exercise one or more of your rights, please contact us by using the contact points in section 2 above.
9. RIGHT TO LODGE A COMPLAINT
If you have a concern in relation to how we use your data, please let us know, and we will reply to your queries and, if necessary, take steps to ensure our practices are consistent with our obligations. If you are still not satisfied with the way we use your data, you have the right to lodge a complaint with Datatilsynet (+45 3319 3200, email@example.com), or the relevant national data protection authority.
10. CHILDREN’S PRIVACY
We provide solutions for children but our social media pages on Facebook, Instagram, Twitter, YouTube and LinkedIn are not intended or designed to collect personal data about children under the age limit in any given country. We do not intentionally collect personal data from any person we know to be under the age limit in any given country.
11. THIRD PARTY LINKS
Oticon Medical’s social media pages on Facebook, Instagram, Twitter, YouTube and/or LinkedIn may contain links to websites of other companies and organizations. This Privacy Notice does not apply to such third-party sites, and we suggest that you contact those third-party sites directly for information on their data collection and distribution policies.
12. CHANGES TO THE PRIVACY NOTICE
We may update this Privacy Notice from time to time by publishing a new version on our website and different social media pages on Facebook, Instagram, Twitter, YouTube and/or LinkedIn.
This Privacy Notice was updated on 15.01.2021.