Welcome to Hearing Diagnostics Limited’s (“Hearing Diagnostics”) privacy notice.
Here at Hearing Diagnostics we respect your privacy and are committed to protecting personal data. Looking after the personal information that is collected, transferred to or used by us is our top priority. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights.
Important information and who we are
Purpose of this privacy policy
This privacy notice aims to give you information on how Hearing Diagnostics collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, subscribe for a product or service, raise a support query or take part in a competition.
We keep our privacy policy under regular review and reserve the right to update this privacy policy from time to time. If we make any material changes, we will notify you by email (sent to the email address if provided) or by presenting you with a new version of this privacy policy. If permitted by applicable law, your continued use of our services after the effective date of an updated version of the privacy policy will indicate your acceptance of the privacy policy as modified.
Our details
We are a limited company registered in Scotland under company number SC575929 and have our registered office at Suite 2, Ground Floor Orchard Brae House, 30 Queensferry Road, Edinburgh, United Kingdom, EH4 2HS. We are the controller and responsible for your personal data (collectively referred to in this policy as “Hearing Diagnostics”, “we”, “us” or “our”). If you have any questions about this privacy policy or our data practices, you can contact us on the information below:
Email address: hello@hdiags.co.uk
Changes to this privacy notice and your duty to inform us of changes
This version was last updated on 21 May 2023 and historic versions can be obtained by contacting us. We keep our privacy notices under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect personal data about you in a variety of ways. Sometimes we collect the personal data directly from you and at times we may receive personal data about you from other sources and third parties. We also collect personal data automatically when you interact with our app and software.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes name, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Health Data includes any personal data you choose to provide about your health, physical and mental well-being.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our app and software.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about the frequency of use of our services, areas and features that you access, visit or use and engagement with particular features.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Data from external sources. We may receive personal data about you from various third parties, like information to enhance or supplement existing user information or for statistical purposes and analytics.
Children’s Data
The website and our products are not intended for children and we do not knowingly collect personal information about children under 13 years old. If you are aware of anyone under the age of 13 using our website, product or otherwise providing us with personal data, please contact us and we will take required steps to delete such information.
How is your personal data collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our publications;
- request marketing to be sent to you;
- request sales support;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
How we use your personal data
We will not collect and use your personal data without letting you know.
Principles of processing
We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you. We also will not collect any personal data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your approval before we begin that processing.
We will not sell or rent your personal data and will get your consent before giving your personal data to any third party for direct marketing communications.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data when you visit our website, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Managing support queries raised by you on-line | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support and reporting) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We may provide you with details of any offers or discounts that we have negotiated with third parties but this will be optional for you to use, and we will not share any personal data with third parties for this purpose.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External Third Parties – we will share your personal data with service providers we have appointed to act as our processors, such service providers being based in the UK to provide financial transaction and payment services and app and software support services.
- Where required by law or under any legal order.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Aggregated Data. We may aggregate, anonymize or de-identify your personal data so that it cannot reasonably be used to identify you. Such data is no longer personal data but we will still take care of it. This is done for our legitimate interest as well as the wider societal interest.
International transfers
We do not transfer your personal data outside the UK or the EEA. If there was any international transfers, we would ensure that a similar degree of protection is afforded to it by having appropriate safeguards in place prior to any international transfer taking place.
Data security
We have put in place reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will limit access to your personal data to those parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Where we have anonymised your personal data (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.
Your legal rights
We are committed to providing you with privacy rights in relation to your personal data. Details of the rights you have are set out below. If you wish to exercise any of the rights set out above, please contact us.
Individual Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Your right to be informed: You have the right to understand how we collect and use your data. This privacy policy is our main way of giving you this information but you can also contact us for further information if required.
- Your right of access: You have the right to ask us for copies of your personal information.
- Your right of rectification: You have the right to ask us to rectify information you think is inaccurate.
- Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing: You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.
You can read more about all of these rights at https://ico.org.uk/global/privacy-notice/your-data-protection-rights/.
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.