Privacy Policy

 

1.              Introduction

1.1            This privacy notice explains how WSA collects and processes your personal data when you use this portal for professional hearing care providers (hereinafter, the “Portal”).

1.2           WSA shall be understood as the WS Audiology entity that offers products or services to you in your country (hereinafter referred to as "WSA", "we", "us", "our").

1.3           We will only process your personal data in accordance with this Privacy Notice and applicable relevant legislation, including the General Data Protection Regulation (EU) 2016/679 (hereinafter "GDPR").

1.4           We encourage you to carefully review this Privacy Notice to understand how and why we are using personal data about you and what your rights are under the relevant privacy laws.

If you have any additional questions about our practices, we welcome you to consult the 'Contact Information' section of this Privacy Notice.

2.             Contact information

2.1           WSA is the data controller of the personal data that is processed about you when using the Portal. For questions related to our processing of personal data, please use the following email address: privacy@wsa.com.  

2.2           You can also contact the data protection officer (“DPO”) of WSA directly. The DPO is responsible for answering questions about our processing of personal data and exercising your rights under applicable law.

Please use the following email address: dpo@wsa.com.  

3.             The data we process when you use this portal

ORDER INFORMATION 

3.1           When placing an order through the portal, you may provide us with information relating to your customers, the user(s) of the product(s) ordered. Please ensure that any information you provide, including any information related to your customers, is shared only if you have the required legal basis to do so. We encourage you to use pseudonymization and limit the information about the user(s) of the product(s) you provide to us via the Portal to what is strictly necessary.

DATA ABOUT YOUR USER PROFILE

3.2           When you log in to the Portal, we process information related to your user profile such as your first and last name, email address, job title, phone number, and your selected language as well as your password. We will link your profile to the clinic you represent by asking you to specify the country where your clinic is located and the customer number of your clinic. We will also collect your billing and mailing address. If and when you use our online shop in the Portal, we will use the above information to link your order to the clinic you represent.

3.3           The data we process has been provided by you, your clinic representative, or is generated from our customer relationship manager (“CRM”) database based on information previously provided to us for the management of our relationship with your clinic.

3.4           The legal basis for our processing of personal data is to handle access to the Portal and purchases made through the Portal (GDPR article 6(1)(b)), as well as our legitimate interest in being able to identify you and the clinic you represent when you use our Portal and to document your purchase on behalf of the clinic (GDPR article 6(1)(f)).

DATA COLLECTED WHEN YOU USE THE PORTAL

3.5           When you visit our Portal, personal data about your behavior is collected by use of cookies if you consent to this. Cookies are collected to remember your preferences and for statistical and marketing purposes (if applicable).

3.6           We process some basic personal data about you, including your IP address, browser type and version, device type and information about your behavior on the Portal, including your purchases.

3.7           We store your personal data in cookies for as long as it is necessary to fulfil the purpose(s) for which the data are processed. For more information about how the individual cookies are stored, please read our cookie policy[CS1] . 

3.8          The legal basis for our processing of personal data is your consent (GDPR Article 6(1)(a)) provided in relation to your visit to our Portal, including your acceptance of cookies. In a few cases, we process data on the basis of our legitimate interest in optimizing our Portal (GDPR article 6(1)(f)).

4.             HOW WE MAY SHARE YOUR INFORMATION

4.1           With other account holders from your clinic. In order to manage and maintain our Portal and the orders made on it effectively, certain data you provide may be visible to authorized members of your clinic / business with administrator access.

4.2           With WS Audiology. WSA is a part of a global group of companies known as WS Audiology. We may share your information with our subsidiaries or affiliated companies who handle your information in order to provide you with access to our services, offer customer support, improve and optimize the Portal etc.  

4.3           With Service Providers. We use trusted third-party service providers to help us provide and improve the Portal, including hosting, technical support, analytics, and customer support services. These providers process personal data on our behalf and only in accordance with our instructions.

4.4           With Measurement Partners. We use third parties, such as Google Analytics, to measure and obtain insights into the performance of our websites.

4.5           With Payments Service Providers. When you use a third-party service provider to process your payments on the Portal, we may transfer or allow these payment service providers to collect information independently. The data collected or shared will be subject to your third-party service provider’s independent privacy policies and control. 

4.6           For Legal, Safety, and Security Purposes. We may disclose personal data where necessary to comply with applicable laws, respond to lawful requests from public authorities, enforce our legal rights, investigate suspected violations, or protect the rights, safety, and security of WSA, our users, or others.

4.7           Corporate Transactions. If WSA is involved in a merger, acquisition, reorganization, or similar corporate transaction, your personal data may be transferred as part of that transaction, subject to applicable confidentiality and data protection requirements.

5.             Transfer of your personal data to third countries

5.1           Your personal data may be transferred to recipients established outside the European Economic Area, which, from the perspective of the European Union ("EU"), do not guarantee an "adequate level of protection" for the processing of personal data in accordance with EU standards. However, before we transfer the data, we always ensure that the recipient of your personal data remains subject to a level of protection comparable to what is required under the laws of your country (and in any event, in line with our commitments in this Privacy Notice).

5.2           Specifically, we ensure that such recipient either provides an appropriate level of data protection and that the requirements of article 44 of GDPR are met, e.g. due to an adequacy decision by the EU Commission for the respective country in accordance with Art. 45 of the GDPR, or that the so-called EU standard contractual clauses prepared by the European Commission have been agreed with the recipient in accordance with article 46 of GDPR.

5.3           If you require further information on the above data transfers, including a copy of any agreed EU standard contractual clauses, you can request it from us by using the contact information in Section 2.

6.              Data retention

6.1           We will retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted under applicable law. The criteria used to determine our retention periods include the nature of the data, the purposes for which it was collected, legal obligations, potential disputes, technical constraints and business needs. Once the retention period expires, your personal data will be securely deleted or anonymized, or if deletion is not possible (for example, because the data has been stored in backup archives that are no longer or technically costly to retrieve access to), then it will be securely stored and isolated from further processing until it expires or is purged, as accepted by applicable laws.

6.2           Please contact us using the information provided in the "Contact Information" section of this Privacy Notice for more details about our data retention practices.

7.             Your rights

7.1            You have certain rights regarding our processing of your personal data, including:

-       The right to access your personal data

-       The right to correct inaccurate or incomplete personal data

-       The right to request deletion of your personal data

-       The right to restrict the processing of your personal data

-       The right to data portability

-       The right to object to our processing

-       The right to lodge a complaint with a competent data protection authority

-       Where processing is based on your consent, the right to withdraw your consent at any time

7.2           These rights may be subject to certain conditions, limitations, or exceptions under applicable law.

7.3           To exercise your rights, please contact us or our DPO using the contact details provided in Section 2.

8.             Changes to this privacy notice

8.1           If WSA makes any material changes to this privacy notice, you will be notified via the Portal.

8.2          This version of the privacy notice is dated September 2026.