COCHLEAR GLOBAL PRIVACY POLICY
In pursuing our mission to help people hear and be heard, Cochlear may collect, use and share personal information. This may be through use of our websites, apps, products or services, or via communications with us. We want you to understand what personal information we collect, how we use it, with whom we share it, how we endeavour to protect it, how you can access and/or correct it, and, finally, how to contact us if you have any questions or concerns.
This Privacy Policy applies to the websites, apps, products and services provided by Cochlear Limited and its subsidiaries around the world (the “Cochlear Group”), a list of which can be found here, as well as communications with Cochlear.
Please note: this Privacy Policy does not govern Cochlear’s collection, use, or disclosure of Protected Health Information as defined by the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). You may view our HIPAA Notice of Privacy Practices.
WHAT PERSONAL INFORMATION DOES COCHLEAR COLLECT?
Personal information provided by you
When you interact with Cochlear, you may provide us with your personal information. For example, you may provide:
- your name and contact details when registering for a Cochlear account on our websites or via one of our apps, or when visiting a Cochlear facility or event;
- information about your personal hearing journey in our Cochlear Community forums or other services;
- information about your age, health or medical treatment when registering a device, or using or requesting information about our products and services; or
- your credit card number when purchasing products or services from us.
If you are a healthcare professional, we may also collect information about your medical specialty, your clinical interests, and your involvement with Cochlear products.
Personal information collected through your use of the products and services.
Enabling certain features within Cochlear apps and services may allow you to share additional information about your use of the app and/or your hearing device. Additionally, when you visit our websites or use our apps, your computer or mobile device may send certain analytic data to us such as your IP address, your browser version, the version of the app you are using and any errors encountered. For additional details read the section below on how Cochlear uses cookies, and for details about specific products and services, see the Privacy Supplements section.
Personal information from third parties.
From time-to-time, we may acquire information about you from other organisations or individuals. For example, upon receiving a hearing implant, your clinic may register with us your hearing implant serial number, sound processor serial number and configuration, and contact details to make sure you have our full support. We may also acquire data from third- party providers to supplement our market analysis and marketing efforts. This additional data helps us to provide you with a more personalized experience.
HOW DOES COCHLEAR USE PERSONAL INFORMATION?
In order to transform the way people understand and treat hearing loss, and innovate and bring to market a range of implantable hearing solutions, we use personal information to provide, maintain and improve our products and services. For example, we use personal information:
- to test, support and develop upgrades and improvements to our products and services (e.g., to enable fitting, activation, maintenance and management of devices) as well as to develop new products and services
- to analyse product performance, service and reliability data
- to improve the content, functionality and usability of our websites and apps
- to maintain a distribution record and device history record of Cochlear products
- to comply with regulatory requirements, such as maintaining a record of medical queries and/or complaints relating to our products
- for security, credit or anti-fraud purposes
- in the course of assessing employment applications and throughout our recruitment process
We also use personal information to support our marketing and promotional efforts, including:
- to invite you to participate in surveys and provide feedback to us
- to contact you with offers and other information we believe will be of interest to you
- to provide you with a personalised experience when you use our websites and apps
- to create a profile from the interactions we have with you to help us understand what information you might be interested in receiving
You can always unsubscribe from promotional communications either via the unsubscribe links within the communications or by contacting us via one of the methods described at the end of this Privacy Policy.
WHEN DO WE SHARE PERSONAL INFORMATION AND WITH WHOM?
Within the Cochlear Group.
We may share personal information within the Cochlear Group globally. Each member of the Cochlear Group will use and share your personal information only as set forth in this Privacy Policy.
With Our Service Providers.
We share personal information with organisations that provide or perform services to or on behalf of Cochlear; for example, companies that provide website support services, or that help us market our products and services. In some cases you may provide your personal information directly to these third party service providers (e.g. when you make a purchase in our online store and enter your credit card information for payment, that data is sent directly to a third party payment processor), and the data may or may not be shared by that third party with Cochlear. Our service providers are required by contract to protect the confidentiality of the personal information we share with them and to use it only to provide services to us.
With Health Care Partners, Providers and Care Givers.
We may share your personal information with your health care providers (e.g. your surgeon, audiologist, etc.) to assess your suitability for our products, to help with your use of our products, or for other reasons related to treatment, health care operations, or payment. For example:
- when you place an order online for an applicable product or service, we may share your personal information with organisations paying for health services on your behalf (for example, Medicare or Medicaid in the U.S., and reimbursement authorities and insurance companies in Europe); and
- when using Cochlear’s cloud technologies to allow sound processor MAP files to be securely backed-up by Cochlear and shared among your designated healthcare providers.
Additionally, in accordance with applicable laws, we may disclose personal information to parents, guardians or care givers (as applicable).
Business Transactions.
Your personal information may be transferred to a company that has acquired the stock or assets of a member of the Cochlear Group or one of our operating divisions; for example, as the result of a sale, merger, reorganization or liquidation. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Privacy Policy and the privacy preferences you’ve expressed to us.
Legal/Government Requests and the Protection of Cochlear and Others.
We may disclose personal information when we, in good faith, believe disclosure is appropriate to:
- comply with the law (or a court order or subpoena);
- comply with lawful requests from public and governmental authorities;
- prevent or investigate a possible crime, such as fraud or identity theft; or
- protect the rights, property or safety of the Cochlear Group, our users or others.
HOW DOES COCHLEAR USE COOKIES, SOCIAL MEDIA PLUG-INS AND SIMILAR TECHNOLOGIES?
Cookies are small files that your internet browser stores to help websites keep track of information between visits. Our websites use cookies to help us:
- understand which of our web pages you visit, how often and from what types of devices;
- gather and remember information about your browsing devices and preferences;
- personalize elements of our websites based on your browser, device, country and language; and
- gather information about the website you came from and other sites you have visited to help categorize your browsing into a market segment for market analysis; and
- provide you with more relevant content, promotional communications and advertisements.
As an example, when you visit our websites, cookies help us identify what you search for, what content you visit, and how frequently you return. Although the information we collect via cookies does not directly identify you, once you register on our websites we may associate your prior and future activity on our websites and apps with the contact details you have provided.
Some of the cookies used by our websites are set by us, and some are set by third parties on our behalf. Our use of cookies from third parties enables interest-based advertising that may cause you to be shown advertisements from Cochlear on other websites that you visit.
We use Google Analytics to obtain statistical data about use of our websites and apps, and Google Adsense and Google DoubleClick for managing and placing advertisements (together “Google Services”). Google Services allow your usage to be correlated across multiples devices, such as across your mobile phone and desktop computer. Click here to learn more about Google Analytics or prevent it from collecting information about your visit to our websites, or login to your Google Account to control your advertising experience across Google Services.
If you do not want cookies set, you can configure your internet browser to reject cookies. Doing so may prevent certain features of our websites from working as intended. To learn more about cookies and similar technologies, visit allaboutcookies.org. You can also opt-out of interest-based advertising via industry-operated websites by visiting http://www.networkadvertising.org/choices, http://www.aboutads.info/choices and http://www.youronlinechoices.com (for European residents).
Social Media Plug-ins
In addition to cookies, we have also implemented social media plug-ins from social networks like Facebook and Twitter so that you can share things from our websites with your online friends and connections. With every visit to our sites which include a plug-in, your browser will connect to the Facebook and/or Twitter servers. If you are logged-in to the Facebook and/or Twitter services while you are visiting our websites, they may associate your browsing on our website with your respective user account.
STORING PERSONAL INFORMATION
Where is personal information processed and stored?
Cochlear is a global company, headquartered in Sydney, Australia, but with key facilities and personnel in the European Union, the United States and elsewhere. Your personal information may be transferred to, processed and stored anywhere Cochlear, the Cochlear Group or their respective service providers operate. To the extent that personal information is collected from EU/EEA residents and transferred to countries which may have lower legal standards for protection of personal information, Cochlear will take steps to protect and otherwise process it in accordance with EU standards of data protection.
For how long will Cochlear retain personal information?
Cochlear will only keep personal information in an identifiable form for as long as it is necessary to fulfil the purpose for which it was originally collected or any additional uses you have agreed to, or to satisfy our regulatory and legal record keeping obligations. After that, we will either delete the information or de-identify it so that it is no longer associated with you.
SECURITY
How does Cochlear help secure personal information?
Cochlear has implemented appropriate administrative, technical and organisational measures to help protect personal information from misuse, loss, and unauthorised access or disclosure. Our security measures include appropriate access control, encryption (where appropriate) and regular security assessments.
CHILDREN'S INFORMATION
How does Cochlear address children's privacy and parents' rights?
Our websites and services are intended for general audiences, such as patients, parents, and the general public, and they are not specifically directed toward children. Certain Cochlear services and apps are accessed via a Cochlear Account and Child Accounts can be created with a parent’s consent. See the Cochlear Accounts privacy supplement for more information on creating and managing a Child Account.
ACCESSING AND CHANGING INFORMATION
How can you access, correct or delete personal information?
We respect your right to make choices about how we collect, use and share your personal information. Whenever we collect your personal information, we take steps to help ensure that it is accurate, complete, and up-to-date. But we understand that your personal information and your privacy preferences may change over time.
Contact us via one of the methods listed below in order to access, correct, amend or delete your personal information within Cochlear’s control. To help protect your privacy and security, we will take reasonable steps to verify your identity before providing you with access to your details or correcting, amending or deleting our records.
PRIVACY SUPPLEMENTS
In the supplements below, we describe how specific products and services collect and use personal information in ways that are not described in our main Privacy Policy (above), or that require further clarification.