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COCHLEAR GLOBAL PRIVACY NOTICE

Cochlear published this revised version of our Privacy Policy in May 2021 and it will become effective in June 2021. If you wish to view the current Privacy Policy click here.

When you interact with Cochlear, we may collect and use your personal information as set out in this Privacy Notice (“Notice”). Please read this Notice carefully as it explains how your personal information is collected, used and disclosed by Cochlear Limited and its subsidiaries around the world (the “Cochlear Group”). It also tells you how you can access and update your personal information and make certain choices about how your personal information is used.

This Notice covers both our online and offline data collection activities, including personal information that we collect through websites, apps, paper forms, customer services and events.

Please note that we might aggregate personal information from different sources (website, offline events) and across different devices. As part of this, we may combine personal information that was originally collected by different Cochlear entities or Cochlear partners.

Please note: this Privacy Notice 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;
  • biological and demographical information such as your age, date of birth, gender, health or medical treatment when registering a device, or using or requesting information about our products and services;
  • financial information such as your credit card number when purchasing products or services from us;
  • Customer service and purchase history and any information that you voluntarily share with us about your experience of using our product and services (e.g., market research and consumer feedback);
  • Location data such as data derived from your IP address, country and precise geolocation of your mobile device (where we have provided appropriate notice and choice);
  • Audio, electronic, or visual information if you participate in our events or provide us with a talent or media release; or
  • Other personal information you may provide to us when you contact us, via telephone, online or through any “contact us” features.

If you are a healthcare professional, we may also collect information about your medical specialty, your clinical interests, and your involvement with Cochlear products.

You are not required to provide personal information to us, but in some circumstances, we might not be able to provide all of our services to you without your personal information.

Personal information collected through your use of our products and services.

Cochlear receives information when you use Cochlear apps and services. This information includes how you use an app and/or your hearing device, and information about your sound processor (e.g., device number, your account number, model, hardware version). 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, services and activities, 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 healthcare provider may register with us your hearing implant serial number, sound processor serial number and settings, 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 personalised 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 for the purposes described below and those described in the Privacy Supplements.

Purpose of using personal information Why we do this Our legitimate interests (the benefits and/or outcomes)
Warranty and records. We use your personal information to keep and maintain records relating to our medical devices and to track warranty periods, maintain a distribution record and device history record of Cochlear products and maintain a record of medical queries and/or complaints relating to our products.
  • With your consent (where required)
  • Fulfilling contractual obligations (e.g., Cochlear’s Global Limited Warranty)
  • Regulatory obligations
  • Faster handling of service and repair cases
  • Research and product development
Registration of devices. We use your personal information to register your devices to enable us to keep proper records and to provide full support for service and repairs.
  • With your consent (where required)
  • Our legitimate interests
  • Faster handling of service and repair cases
  • Research and product development
Marketing. We use your personal information to enable our marketing and promotional efforts, such as inviting you to participate in surveys and provide feedback to us, or by contacting you with offers and other information related to our products and services, which we believe will be of interest to you.
  • With your consent (where required)
  • Our legitimate interests
  • Fulfilling contractual obligations
  • Identifying which of our products and services may interest you and letting you know about them
  • Defining types of customers for new products and services
  • Optimising our product and service offerings
Personalisation. We use your personal information to provide you with a personalised experience when you use our websites and apps. We may create a profile from the interactions we have with you to help us understand what information you might be interested in receiving.
  • Our legitimate interests
  • Identifying which of our products and services may interest you and letting you know about them
  • Defining types of customers for new products and services
Customer Service. We use your personal information for customer service purposes, including responding to queries and requests for information about our products and services. We may also provide you with service-related notifications such as warranty expirations.
  • Fulfilling contractual obligations
  • Legal obligations
  • Our legitimate interests
  • To respond to your enquiries
  • Improving and developing new products and services
  • Improving our efficiency
Product and service development and improvements. We may use your personal information to test, support and develop upgrades and improvements to our products and services (e.g., to enable the proper configuration, activation, maintenance and management of devices) as well as to develop new products and services, to analyse product performance, service and reliability data and to improve the content, functionality and usability of our websites and apps.
  • With your consent (where required)
  • Our legitimate interests
  • Improving and developing new products and services
Other general purposes (e.g., internal or market research, analytics, security). In accordance with applicable laws, we may use your personal information for other general business purposes, such as maintaining your account, conducting internal or market research and measuring the effectiveness of advertising campaigns. We reserve the right, if you have Cochlear accounts, to reconcile those accounts into one single account. We may also use your personal information for management and operation of our communications, IT and security systems and to monitor for security or anti-fraud purposes.
  • Legal obligations
  • With your consent (where required)
  • Our legitimate interests
  • Improving and developing new products and services
  • Improving our efficiency
  • Protecting our systems, networks and staff

 

Use of de-identified data. There may be circumstances where we are permitted by law to aggregate or de-identify your personal information, to ensure that the information is no longer connected to you, and after aggregation or de-identification, the data is no longer classified as personal information. Such uses of information are not subject to this Notice.

 

 

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 out in this Privacy Notice.

With Our Service Providers.

We share personal information with organisations that provide or perform services to, for or on behalf of Cochlear; for example, our distributors, 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 Third-Party Companies.

Except in situations where you have given your consent, we do not license or sell your personal information to third-party companies for their own marketing purposes. The identity of any such third-party company will be disclosed to you at the time your consent is sought.

With Health Care Partners, Providers and Carers.

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 for an applicable product or service (or if you are in the process of placing an order), 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 other markets); and
  • when using Cochlear’s cloud technologies to allow sound processor configuration 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 carers (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, reorganisation or liquidation. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Notice 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 contain data, such as unique identifiers, that your internet browser stores to help websites keep track of information between visits. When you visit any of our websites, they may store or retrieve information on your browser, mostly in the form of cookies. 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;
  • personalise elements of our websites based on your browser, device, country and language;
  • gather information about the website you came from and other sites you have visited to help categorise 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.

Third Party Cookies

Some of the cookies used by our websites are set by us, and some are set by third parties on our behalf for the purpose described in this Notice. 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 collect data such as IP addresses 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 visit http://myaccount.google.com to control your advertising experience across Google Services.

If you do not want to allow cookies, 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 http://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).

Please visit your mobile device manufacturer’s website or operating system for instructions relating to any other additional privacy controls, for example geolocation and device identifiers.

 

Cookie Controls

By default, Cochlear’s websites directed to residents in Europe and Turkey, (Cochlear Europe Websites) set only essential cookies which are necessary for the proper functioning of the websites. If you visit Cochlear Europe Websites, you will be presented with a cookie notice through which you can agree to or decline our setting of non-essential cookies, such as those used for analytics and personalisation. You can also designate the specific categories of cookies you will permit Cochlear to set. Your choices will persist only on Cochlear Europe Websites and not on websites directed to individuals residing outside Europe and Turkey. Due to the manner in which cookies operate, your choices will also only persist on a per domain basis, meaning that you will be separately prompted when you navigate between Cochlear Europe Websites which reside on different domains (e.g. cochlear.com versus iwanttohear.com).

 

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?

Processing and storage. Cochlear is a global company, headquartered in Sydney, Australia, and with key facilities and personnel in the European Union, the United Kingdom, 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.

Transfer of your personal information. We may process your personal information outside of the country in which you are based for the purposes set out in this notice. When we transfer your personal information to other countries, we take reasonable steps to ensure that applicable laws are being followed. To the extent that personal information is collected from residents of the European Economic Area and the United Kingdom 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. We (i) have put in place European Commission-approved standard contractual clauses to protect your personal information (and you have a right to ask us for a copy of these clauses by contacting us as set out below) and/or (ii) will rely on your consent (where required by law).

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

Measures taken by Cochlear. Cochlear has implemented appropriate physical, 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.

Measures we expect you to take. It is important that you also play a role in keeping your personal information safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls we provide you in our website/app.

 

 

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, carers, 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 or carer’s consent. See the Cochlear Accounts privacy supplement for more information on creating and managing a Child Account.

 

 

YOUR RIGHTS

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. We understand that your personal information and your privacy preferences may change over time.

Where provided by law, you can access, correct, amend or delete your personal information within Cochlear’s control or restrict or object to the processing of your personal information. Where you have consented to the processing of your personal information, you have the right to withdraw your consent at any time. 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. Please note that any identification information provided to us will only be processed in accordance with, and to the extent permitted by applicable laws.

You can always unsubscribe from promotional or marketing communications either via the unsubscribe links within the communications or by contacting us via one of the methods described at the end of this Notice.

We hope that we can satisfy queries you may have about the way we process your personal information. However, if you have unresolved concerns you also have the right to complain to competent data protection authorities.

 

 

PRIVACY SUPPLEMENTS

In the supplements below, we describe how specific products, services and activities collect and use personal information in ways that are not described in our main Privacy Notice (above), or that require further clarification.

 

Creating a Cochlear Account enables you to login to and use a variety of Cochlear services and apps, such as the Baha® Smart App, the Nucleus® Smart App, the Osia®Smart App, the myCochlear™ web portal, and our online store. Services which make use of Cochlear Accounts vary by market.

When you create a Cochlear Account, we ask for your name, email address and date of birth. We use this information to associate your Cochlear Account with your Cochlear device registrations to help us provide the most relevant services to you. Additionally, your email address may be used for communications related to your Cochlear account and date of birth helps us ensure that child accounts are only created with the consent of a parent or carer.

Child Accounts and Parental Consent

Cochlear services and apps may be used by children via a Child Account. Child Accounts can be created by parents or guardians through the services and apps which permit their use, such as the Nucleus Smart App. See the Nucleus Smart App FAQ for instructions on creating a Child Account.

Child Accounts may access the same Cochlear services and apps available to adults. This may result in personal information being sent to Cochlear. For example, a child using the Nucleus Smart App may enable features such as data sync which is described more fully in the Nucleus Smart App privacy supplement.

Cochlear Account-enabled services available in some markets enable the sharing of health information with designated healthcare professionals. Once enabled, parents may request such services be disabled at any time by contacting the healthcare professional or Cochlear.

Parents or carers may review, edit, request the deletion, or prevent further collection or use of their children’s personal information by contacting us as described in this Notice.

Creating a Cochlear Academy Account enables you to login to and use a variety of Cochlear online learning, classroom-based learning, webinars, reading, videos and links to websites.

Personal information collected through Cochlear Academy

When you use Cochlear Academy, we collect and use the following categories of personal information. We may obtain this personal information directly from you or, where applicable, from your organisation (e.g., clinic or hospital administration).

Category of personal information Purpose of collection and use
Your name and contact details such as your email address, your organisation, manager, address, phone number, start and end date. We use this personal information to identify you within our internal systems, communicate with you, and to keep track of our interactions.
Learning history; including what you have enrolled in, your status, completion of training including dates, and details such as answers and scores obtained. We require this personal information to provide access to training via Cochlear Academy. This personal information is used to provide you with access to the training content, reporting on the status and completion of training, recommend training, reporting and analytics. The information allows us to recommend courses to you based on your account details.

Cochlear Family is a free-to-join membership program offered by Cochlear to recipients in select markets. It supports recipients, their families and carers as they learn to use and live with their device.

When you join Cochlear Family you will receive communications from Cochlear which may include information about new services and products, promotions, special offers, invitations to events and optional surveys. These communications may be delivered through different channels, depending on the contact information you have provided, including - email, mail, phone and text.

You can leave Cochlear Family at any time by contacting us via one of the methods described at the end of this Privacy Notice. If you choose to leave Cochlear Family you will no longer be entitled to access the benefits of the program. Should you wish to re-join the program you can do so at any time by contacting your local customer support team.

Personal information collected from Cochlear Family members

Based upon your consent, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Your name and contact details such as your email address and phone number. We use this information to identify you within our internal systems, communicate with you, and to keep track of our interactions.
Biographical and health information, such as your age or date of birth, your level and duration of hearing loss, and your use of hearing devices. We use this information to better understand your personal hearing journey and/or your experience with hearing devices to evaluate how Cochlear can best support and communicate with you. We also use this information for demographic and statistical purposes to better understand our customers and potential customers.

 

Sharing of personal information

  • If applicable,
    1. your designated parent or carer will also be able to access the personal information we collect from you and/or
    2. information may be disclosed to your designated healthcare provider and/or service partner.
  • We will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

We will retain your Cochlear Family information for as long as you remain in the program.

Our Cochlear Volunteer Program is a team of volunteers made up of thousands of people and their loved ones around the world who hear with a Cochlear solution. They all share one thing in common – a passion for helping others on their hearing journey.

Our Cochlear Volunteers share their stories, offer support and provide information to anyone considering or getting a Cochlear hearing solution, including their parents, carers, family members or friends.

Personal information collected through expressions of interest

When you submit an expression of interest to become a Cochlear Volunteer, we will ask you for certain personal information to evaluate your application.

Based upon your consent, we may collect and use the following categories of personal information to determine the extent to which suitable opportunities are available for you to participate as a Cochlear Volunteer:

  • Your name and contact details such as your email address and phone number;
  • Biographical and health information, such as your age or date of birth, your level and duration of hearing loss, and your use of hearing devices;
  • Your personal history as or connection to a Cochlear implant recipient, as well as your interests, skills and availability; and
  • In some countries, a criminal background check, police clearance, or other background check for an additional security and qualification measure.

Personal information collected from Volunteers

Based upon your consent, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Your name and contact details such as your email address and phone number. We use this information to identify you within our internal systems, communicate with you, and to keep track of our interactions.
Biographical and health information, such as your age or date of birth, your level and duration of hearing loss, and your use of hearing devices. We use this information to better understand your personal hearing journey and/or your experience with hearing devices to evaluate how Cochlear can best support you. We also use this information for demographic and statistical purposes to better understand our customers and potential customers.
Your personal history as a Cochlear implant recipient or carer, as well as your interests, skills and availability. We use this information, along with other biographical information, to identify opportunities for you to participate in the Cochlear Volunteer Program, such as by connecting you with individuals interested in learning more about your personal experience with hearing loss or as a loved one to a cochlear implant recipient.
Written materials, quotes, photographs, videos and/or audio recordings of you. We may use this information in our promotional materials.
Training records. We may provide you with access to specialised training and we keep a record of training activities to better understand your specific knowledge and expertise.

 

Sharing of personal information

In evaluating your expression of interest, Cochlear will not share your personal information with third parties without your consent or a lawful obligation to do so.

If you become a Cochlear Volunteer, Cochlear may share your details with individuals who are interested in learning more about your hearing journey or with organisations involved in events where you may speak in your capacity as a Cochlear Volunteer. If applicable, your designated parent or carer will also be able to access the personal information we collect from you. We will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

If you join the Cochlear Volunteer Program, we will retain your volunteer information for as long as you remain in the program. If you do not join the Cochlear Volunteer Program, the personal information included in your expression of interest will be destroyed shortly after such a determination.

Cochlear regularly conducts or supports a variety of events, large and small, at venues all over the world (Events). Audiences for Events include individuals seeking to learn more about Cochlear products and services, recipients of Cochlear medical devices, Cochlear Volunteers, and healthcare professionals.

Personal information collected for Events

When you register for and/or attend an Event, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Your name and contact details such as your email address and phone number. We use this information to identify you within our internal systems, communicate with you, notify you of Event details, and to keep track of our interactions.
Biographical and health information, such as your age or date of birth, your level and duration of hearing loss, and your use of hearing devices. For Events intended for candidates and/or recipients for Cochlear's hearing solutions and/or services, we use this information to ensure that we are providing relevant content and speakers for the Event. We also use this information for demographic and statistical purposes to better understand our customers and potential customers.
Your personal history as a recipient of Cochlear's products and/or services or carer, as well as your interests, skills and availability. We use this information, along with other biographical information, to identify opportunities for you to participate in the Cochlear Volunteer Program, such as by connecting you with individuals interested in learning more about your personal experience with hearing loss or as a loved one to a recipient of Cochlear's products and/or services.
Photographs, videos and/or audio recordings (together 'recorded media') of you. At some Events, we take recorded media to use in our communications and materials within Cochlear, as well as on our external websites, social media accounts, and print publications. We will always ask you before using recorded media which features you prominently in focus in an identifiable manner (e.g. a close-up photograph or video), but may use recorded media without your consent if you are merely in the background, out-of-focus, or otherwise not readily prominent or identifiable.
Travel details In limited circumstances, Cochlear may assist with booking travel and/or accommodation for Events. In these instances, we will use travel details, including any national identity documents or payment details, only as necessary to complete the booking.

 

Sharing of personal information

If you agree to a separate talent/media release, we may share recorded media featuring your image and/or voice via social media, website, print or as otherwise specified in such a media release. We will share your personal information with our service providers, as relevant to their involvement with and/or the services they provide for our Events. We will share your personal information and travel details as necessary to book any agreed travel and/or accommodation (e.g. sharing your name and date of birth with an airline to book flights). We will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

We will retain records of Event registration and attendance only for as long as is necessary for the proper management and administration of the Event and to analyse event demographics and trends over time.

Cochlear Conversations is an invitation-only program offered by Cochlear to recipients and their parents and carers in select markets. The aim of Cochlear Conversations is to conduct market research and collect feedback from Cochlear customers to help inform and improve Cochlear products and services.

When you join Cochlear Conversations you will receive invitations to provide feedback and to participate in surveys and/or other market research activities. These communications may be delivered through different channels, depending on the contact information you have provided to us, including - email, mail, phone and text.

You can leave Cochlear Conversations at any time by contacting us via one of the methods described at the end of this Notice.

Personal information collected from Cochlear Conversations members

Based upon your consent, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Your name and contact details such as your email address and phone number. We use this information to identify you within our internal systems, communicate with you, and to keep track of our interactions.
Biographical and health information, such as your age or date of birth, your level and duration of hearing loss, and your use of hearing devices. We use this information to better understand your personal hearing journey and/or your experience with hearing devices to evaluate how Cochlear can best support and communicate with you, and which market research activities will be most relevant to you. We also use this information for demographic and statistical purposes to better understand our customers and potential customers.
Market research responses When you provide feedback, complete surveys or otherwise participate in market research activities as part of Cochlear Conversations, we will use the information you provide to help improve our products and services. Your responses will be collected and reported on at an aggregate level, but we will always notify you beforehand if survey responses will be associated with you.

 

Sharing of personal information

If applicable, your designated parents or carer will also be able to access the personal information we collect from you. We will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

We will retain your Cochlear Conversations information for as long as you remain in the program. We will de-identify any retained data within 12 months of you leaving the program.

Personal information collected

When you apply to work at or for Cochlear, you are asked to provide a variety of information, such as contact details, a detailed employment and educational history (e.g. CV/resume and/or academic transcripts), proof of work eligibility (e.g. passport and/or visa), and a description of your skills (e.g. foreign languages).

Personal information about you may also be collected from others as a result of:

  • Interview feedback
  • Reference checks
  • Background checks
  • Web searches such as via Google or LinkedIn
  • Psychometric assessments

The specific information requested from you and collected from others may vary by country.

Purpose of collection

Personal information collected in the job application process is used for purposes such as assessing your suitability for one or more roles, maintaining a record of representations made to Cochlear at the time of application, and helping us assess the effectiveness of our job applicant screening tools and processes. This information is also used to ensure we understand your background, strengths, and opportunities for development.

Sharing with third parties

Beyond our use of service providers acting on Cochlear’s behalf, personal information collected in the job application process will not be shared with third parties without your consent. When you provide personal or employment references as part of your job application, Cochlear may contact those individuals and disclose to them that you have applied to work at Cochlear.

Retention period

In the event that your application to work at or for Cochlear is successful, we will retain your job applicant data for the duration of your employment/engagement at Cochlear. If you leave Cochlear’s employment/engagement, your job applicant data will be deleted in accordance with Cochlear’s internal data retention and deletion standards.

Cochlear deletes job applicant data within 12 months of an unsuccessful application, unless you have asked Cochlear to keep the application data on file to consider you for future roles, in which case the data will be deleted within 5 years of the last time you were considered for a role.

With the Nucleus® Smart App, you can optimise your hearing experience directly from a compatible Apple® or AndroidTM device. The app lets you pair a compatible sound processor via Bluetooth® with your compatible smartphone, allowing you to quickly change programs, adjust volume, control streaming accessories, access operating tips and locate a lost or misplaced sound processor.

Data sync

When you enable data sync, hearing data from your sound processor and the Nucleus® Smart App will be regularly synchronised with Cochlear services to make it accessible from all of your connected devices. The data sent includes data from the Nucleus Smart App's Hearing Tracker feature, such as how much time you spend in speech and how often your sound coil is disconnected. The synchronised data does not include or reveal details of your medical condition. By synchronising this data with Cochlear, users of multiple mobile devices will see the same data in Hearing Tracker across each mobile device.

The data sync feature is enabled on a per-recipient basis. When a parent or carer enables the data sync feature for a Cochlear implant recipient, the feature will also be enabled for their spouse and/or other carers that are using the Nucleus Smart App with the implant recipient's device. For example, if the parent or carer of a Cochlear implant recipient enables the data sync feature for their child’s sound processor(s), this will also enable the feature for the implant recipient’s other parent/carer who is using the Nucleus Smart App to control their child's sound processor from their own mobile device. Similarly, when one parent or carer disables the data sync feature, it is disabled for all other carers of the implant recipient.

Cochlear uses the personal information received via the data sync feature to provide the synchronisation service and to enable other Cochlear services available in select markets. Additionally, Cochlear uses the personal information only in a de-identified form, without the names of the recipients or of the carers, to identify trends, to advance and share scientific research findings, to understand how its products and services are used, and to continually improve its products and services. We will retain the data sync data for as long as you maintain your Cochlear account or until you request otherwise.

The data sync feature is not necessary for your use of your sound processor. It is an optional feature that you can enable or disable from the Settings screen within the Nucleus Smart App at any time.

Data Sharing

The Data Sharing feature of the Nucleus Smart App is available in select markets and enables you to share hearing data with a participating clinic. When you share hearing data with a clinic, the clinic will be able to view data from the hearing implant, sound processor and the Nucleus Smart App, as well as any data specifically related to services that rely upon the Data Sharing feature, such as Remote Check. The data shared with the clinic can help your health care professional better understand how the device is being used and its performance.

To enable Data Sharing, you must first enable Data sync (described above) to regularly synchronise your data to Cochlear. Data Sharing is only available to participating clinics in select markets. If your clinic enrols you in a service that relies upon Data Sharing, such as Remote Check, you will be prompted within the Nucleus Smart App to enable the request to share your data with the clinic. From within the Settings menu in the Nucleus Smart App, you can view which clinics you are sharing data with and which ones have requested you to enable Data Sharing. You can disable Data Sharing at any time.

Essential Data

When you log in to the Nucleus Smart App with your Cochlear Account, information related to the implant and sound processor is sent to Cochlear. This information allows us to validate that the app is being used with approved hardware.

Notifications

The Nucleus Smart App asks you to enable notifications to allow the app to notify you with important alerts regarding the sound processor/s. This feature also enables background features such as the Hearing Tracker.

You can enable or disable this feature in your smartphone's app notification settings.

Find My Processor / Location Services

The Nucleus Smart App uses the device’s GPS and Wi-Fi or cellular network to help you find a lost or misplaced sound processor. It does this by storing the last place a sound processor was used, and the last location where the app was used with the sound processor. Your location data is not sent to Cochlear.

You can enable or disable this feature within your smartphone's settings for location services.

Analytic Data

The Nucleus Smart App collects and sends de-identified data to Cochlear about how the app is used and any errors it encounters. This data helps Cochlear continually improve the Nucleus Smart App and other Cochlear products and services. Examples of analytic data include the type of mobile device and operating system used, how often features within the app are used, and internet protocol addresses to assess the general geographic region in which the app is used. Cochlear implements technological and administrative measures to prevent this data from being associated with your identity.

With the Osia® Smart App, you can optimise your hearing experience directly from a compatible Apple® or Android™ device. The app lets you pair an Osia Sound Processor via Bluetooth® with your compatible smartphone, allowing you to change programs, adjust volume, control streaming accessories, access operating tips and locate a lost or misplaced sound processor.

Personal information collected through the Osia Smart App

Based upon the services you request and/or upon your consent, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Information from your Cochlear Account A Cochlear Account is required to login to and use the Osia Smart App. Depending upon your Cochlear Account settings, we may use your Cochlear Account to communicate with you. See the privacy supplement for the Cochlear Account to learn more.
Analytic Data The Osia Smart App collects and sends de-identified data to Cochlear about how the app is used and any errors it encounters. This data helps Cochlear continually improve the Osia Smart App and other Cochlear products and services. Examples of analytic data include the type of mobile device and operating system used, how often features within the app are used, and internet protocol addresses to assess the general geographic region in which the app is used. Cochlear implements technological and administrative measures to prevent this data from being associated with your identity.
You can enable or disable this feature within the Osia Smart App settings screen.

 

Sharing of personal information

If applicable, your designated parent or carer will also be able to access the personal information we collect from you. We will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

The information related to your Cochlear Account is stored by Cochlear unless and until you direct us to delete it.

Notifications

The Osia Smart App asks you to enable notifications to allow the app to notify you with important alerts regarding the sound processor(s). This feature also enables background features such as the Hearing Tracker.

You can enable or disable this feature in your smartphone’s app notification settings.

Find My Processor / Location Services

The Osia Smart App uses your device’s GPS and Wi-Fi or cellular network to help you find a lost or misplaced sound processor. It does this by storing the last place the sound processor was used, and the last location where the app was used with the sound processor(s). Your location data is not sent to Cochlear.

You can enable or disable this feature within your smartphone’s settings for location services.

With the Baha® Smart App, you can optimise your hearing experience directly from a compatible Apple or Android™ device. The app lets you pair a Baha 6 sound processor via Bluetooth® with your compatible smartphone, allowing you to change programs, adjust volume, control streaming accessories, access operating tips and locate a lost or misplaced sound processor.

Personal information collected through the Baha Smart App

Based upon the services you request and/or upon your consent, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Information from your Cochlear Account A Cochlear Account is required to login to and use the Baha Smart App. Depending upon your Cochlear Account settings, we may use your Cochlear Account to communicate with you. See the privacy supplement for the Cochlear Account to learn more.
Analytic Data The Baha Smart App collects and sends de-identified data to Cochlear about how the app is used and any errors it encounters. This data helps Cochlear continually improve the Baha Smart App and other Cochlear products and services. Examples of analytic data include the type of mobile device and operating system used, how often features within the app are used, and internet protocol addresses to assess the general geographic region in which the app is used. Cochlear implements technological and administrative measures to prevent this data from being associated with your identity.
You can enable or disable this feature within the Baha Smart App settings screen.

 

Sharing of personal information

If applicable, your designated parent or carer will also be able to access the personal information we collect from or about you. We will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

The information related to your Cochlear Account is stored by Cochlear unless and until you direct us to delete it. Analytic data is stored indefinitely in a de-identified form to enable us to identify trends in the use and operation of the Baha Smart App.

Notifications

The Baha Smart App asks you to enable notifications to allow the app to notify you with important alerts regarding the sound processor(s). This feature also enables background features such as the Hearing Tracker.

You can enable or disable this feature in your smartphone’s app notification settings.

Find My Processor / Location Services

The Baha Smart App uses your device’s GPS and Wi-Fi or cellular network to help you find a lost or misplaced sound processor. It does this by storing the last place you used the sound processor(s), and the last location where the app was used with the sound processor(s). Your location data is not sent to Cochlear.

You can enable or disable this feature within your smartphone’s settings for location services.

Bring Back the Beat is a fun mobile app to help Cochlear implant recipients regain or develop a new appreciation of music by learning to distinguish instruments, tones and pitch. When you use the app we collect some personal information and use it to bring you the best experience possible.

Personal information collected

When you use Bring Back The Beat, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Your name and contact details such as your email address and phone number We use this information to create your Cochlear Account, if you don’t already have one, and to enable your access to Cochlear websites, apps and services, including Bring Back the Beat. See the Cochlear Account privacy supplement for more details.
Game data, such as your game progress and your gamer photo By using your Cochlear Account to log in to Bring Back the Beat, we can save your game progress. This means that if you change phones or login from a different device, Bring Back the Beat will be waiting right where you left off. We also use this information to enable the leaderboard, which allows you to see how you’re progressing along with the rest of the Bring Back the Beat players.
Spotify data If you connect your Spotify account to Bring Back the Beat, we collect information about the tracks and artists you listen to in Spotify to enable the Repertoire game mode to help you reach new levels of music appreciation.
Analytic data Bring Back the Beat collects and sends to Cochlear de-identified data about how the app is used and errors it encounters. This data helps Cochlear continually improve Bring Back the Beat and other Cochlear products and services. Examples of analytic data include the type of mobile device and operating system used, how often features within the app are used, and internet protocol addresses to assess the general geographic region in which the app is used. Cochlear implements technological and administrative measures to prevent this data from being associated with your identity.

 

Sharing of personal information

When you use Bring Back the Beat, we use your first name and last initial to identify you on the leaderboard to other Bring Back the Beat players. If you connect Bring Back the Beat to your Spotify account, we will also send information to Spotify about your use of Bring Back the Beat. Otherwise, we will share your personal information with other third parties only with your consent or based on a lawful obligation to do so. Note, if you choose to upload a photo to personalise your gaming experience, the photo will not be displayed on the leaderboard or shared with other players.

Retention of your personal information

We will retain your Bring Back the Beat game data for as long as you have a Cochlear Account or until you ask us to delete it. If you delete your Cochlear Account, we may retain de-identified analytic data about how you used Bring Back the Beat.

We will keep your Spotify data for as long as you keep your Spotify account connected to Bring Back the Beat. You can disconnect your Spotify account from within the Bring Back the Beat app by tapping the Spotify icon within the Repertoire game mode and following the disconnect prompts.

Cochlear’s Remote Check enables Cochlear implant recipients to use the Nucleus Smart App to conduct self-tests at home and share those results and device diagnostic information with a participating clinic. When the self-tests are conducted, the test results, including personal information will be sent to Cochlear.

Participation in Remote Check is optional, and you may withdraw from Remote Check at any time by contacting your clinician or by contacting Cochlear as specified below.

Personal information collected from Remote Check participants

Based upon your consent, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Your name and contact details such as your email address We use this information to identify you within our internal systems and to communicate with you. We may use this information to provide you messages about your participation in Remote Check, such as reminders to complete your self-tests or responses from your clinic.
Information from your Cochlear Account and the Nucleus Smart App Your Cochlear Account and the Nucleus Smart App are used to provide you the Remote Check service. See the privacy supplement for each respective service to learn more.
Your Remote Check results, including hearing test data, photographs of your implant site, questionnaire results, and diagnostic data from your implant(s) and sound processor(s) We collect this information to enable you to share it with your designated clinic(s) for them to analyse your hearing health without requiring a visit to the clinic.
Your debit/ credit card number If applicable, we collect this information to enable a built-in payment functionality, which is facilitated by a third-party payment provider. The Payment Gateway will process your payment. Cochlear does not store, if applicable your debit card/credit card information, for this purpose.

 

Based upon Cochlear’s interests in continually improving Cochlear’s products and services, we use also use the information collected via Remote Check in a de-identified form to better understand the use of our products and services, and to continue to innovate new hearing solutions.

Sharing of personal information

The key purpose of Remote Check is to enable you to perform self-tests and share your results with your clinic. We will only share your Remote Check information with the clinics you approve. You can control which clinics have access to your Remote Check information through the Data Sharing feature of the Nucleus Smart App. Read the Nucleus Smart App privacy supplement for more information on the Data Sharing feature. If applicable, your designated parent or carer will also be able to access the personal information we collect from or about you. We will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

The information collected through Remote Check is stored by Cochlear on your behalf unless and until you direct us to delete it.

Cochlear CoPilot is a self-guided mobile app to help Cochlear implant recipients to listen, communicate and live their life. When you use the app, we collect some personal information and use it to bring you the best experience possible.

Personal information collected

When you use Cochlear CoPilot, we collect and use the following categories of personal information:

Category of personal information Purpose of collection and use
Your name and contact details such as your email address and phone number We use this information to create your Cochlear Account, if you don’t already have one, and to enable your access to Cochlear websites, apps and services, including Cochlear CoPilot.
Analytic data Cochlear CoPilot collects and sends to Cochlear de-identified data about how the app is used and errors it encounters. This data helps Cochlear continually improve Cochlear CoPilot and other Cochlear products and services. Examples of analytic data include the type of mobile device and operating system used, how often features within the app are used, and internet protocol addresses to assess the general geographic region in which the app is used. Cochlear implements technological and administrative measures to prevent this data from being associated with your identity.

 

Sharing of personal information

When you use Cochlear CoPilot, we will share your personal information with other third parties only with your consent or based on a lawful obligation to do so.

Retention of your personal information

We will retain your Cochlear CoPilot activity data for as long as you have a Cochlear Account or until you ask us to delete it. If you delete your Cochlear Account, we may retain de-identified analytic data about how you used Cochlear CoPilot.

 

CONTACT US

 

How can you raise questions or concerns about this Notice or about how Cochlear handles your personal information?

Should you wish to access your information, or raise any questions or concerns about this Privacy Notice or how we handle your personal information, please contact us via

  1. email at privacy@cochlear.com or
  2. contact either the Cochlear entity in your country or the regional Cochlear office closest to you:

 

COCHLEAR ASIA PACIFIC
Attn: Privacy Officer
1 University Avenue
Macquarie University
NSW 2019
Australia
+61 2 9428 6555
COCHLEAR AMERICAS
Attn: Privacy Officer
10350 Park Meadows Drive
Lone Tree, CO 80124
USA
+1 800 523 5798
COCHLEAR EUROPE LIMITED
Attn: Privacy Officer
6 Dashwood Lang Road
Bourne Business Park
Addlestone
Surrey KT15 2HJ
United Kingdom
+44 1932 26 3400
COCHLEAR LATINOAMERICA S.A.
Attn: Privacy Officer
International Business Park
Building 3835, Office 403,
Panama Pacifico
Panama
+507 830 6220

 

WHAT HAPPENS WHEN THIS NOTICE CHANGES?

We may need to update this notice from time-to-time for a variety of reasons, including changes in laws, regulations and our business practices. When we make a change, we’ll post our updated privacy notice 30 days before it becomes effective to help ensure that you are aware of what’s new.

 

THANK YOU

We appreciate you taking the time to read this notice. We know that you are placing your trust in Cochlear when you choose to share your personal information with us and we intend to use it responsibly.

Last updated 22/03/2021
Effective 11/06/2021
D1425384 V12 2021-03

Baha, Bring Back the Beat, Cochlear, Osia, Nucleus, Hear now. And always, the elliptical logo, and marks bearing an ® or ™ symbol, are either trademarks or registered trademarks of Cochlear Bone Anchored Solutions AB or Cochlear Limited (unless otherwise noted)
The Bluetooth® word mark and logos are registered trademarks owned by the Bluetooth SIG, Inc. and any use of such marks by Cochlear Limited is under license.
Apple is a trademark of Apple Inc., registered in the U.S. and other countries.
Android is a trademark of Google LLC.