1. Introduction

Osdko respects your privacy and is committed to protecting your personal data. This privacy policy gives you information about how Osdko collects and processes your personal data if you purchase our products or services, use our website, tools, applications, email or communicate in other ways with us for example in relation to support requests, queries, marketing activities, surveys, participate in events or interact with Osdko in relation to social media platforms etc.

Please note that other privacy policies may apply to certain specific solutions or services provided by us. We kindly refer you to read the privacy policy for the information related to the specific solutions or services you are using. This privacy policy may supplement such other policies and is not intended to replace them.

2. Who We Are

The legal entity that controls and is responsible for the processing of your data is Osdko Company (the “Company”).

How to contact our Data Protection Officer about our use of personal data

For general questions concerning personal data you may contact our Data Protection Officer on: team@Osdko.com

When referring to “Osdko”, “we” or “us” it includes the Company and/or any other relevant affiliated company whose involvement is necessary to achieve the purposes as described in this privacy policy. 

The Osdko companies may act as independent controllers or processors in relation to each other. The Osdko companies may also act as joint controllers when processing your data. In such case we jointly determine the purposes and means of processing personal data. We have determined how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations.

3. How do We Collect your Personal Data?

We collect your data in different scenarios and from different sources, such as directly from you, through third parties and/or through automated means, such as:

we collect and use personal data such as data that you provide to us yourself, e.g. when you type in information when using our websites, our apps, contact us on telephone, email, text or through other channels to purchase products or services, request support, provide ratings, apply for job positions, subscribe to newsletters or white papers, post in community forums, participate in competitions, tests, meetings, events, promotions or surveys;

We may collect contact data or other business-related data about you if you are an employee with, or otherwise engaged by our partners;

We may use personal data about you as an end user of our products and services received from our partners, such as hearing care professionals, distributors, resellers and/or similar partners to the extent provided by third parties;

We may use information from rating companies or other agencies providing information about you; and

We may use personal data about you from publicly available sources;

We may use automatically collected information about you collected when you use our websites or apps, open our emails/messages or from the use of third parties’ websites or apps; (cf. also more about Automatically Collected Information below).

We may receive personal data about you from various third parties (including social media platforms, search engines and other similar third-party websites), when you communicate with us or otherwise use our services on social media platforms and similar websites; (cf. also the section on social media platforms below).

4. What Data do we Use and Why?

We have set out below a description of how we may use your personal data. This is a generic description, and the specific use may differ in some cases and may be more detailed in a specific privacy policy for an app, a service or test etc.

We use personal data to achieve purposes such as outlined below:

to maintain a professional relationship with our business partners, we collect your and/or your company’s contact info, title, records of sales, plans, professional activities, product inquiries, minutes of meetings, services provided to you or your company etc;

to allow for purchasing, self-service and training by our customers we give you access to profile areas such as web shops or partner portals. In this connection we collect your contact info where needed, depending on the service, your access credentials and the activity you create within the portals, such as purchases, downloads, training completed etc;

to provide and supply services and products requested and/or purchased by you and to communicate with you about such services and/or products, i.e. requests, inquiries, complaints in relation to these, we may use your contact information such as name, address, email, phone number, your purchase history, payment information and your specific requests. If you are a current or potential customer of our hearing aids or other medical related products, we may also collect and use sensitive information about your health where necessary and when provided by you to us and/or your hearing care professional. If you are acting on behalf of another person, we note your contact information and our communication;

to manage our hiring process when you apply for a job in our company, we collect information such as your name, email address, postal address, phone number, nationality, language skills, education, job history, and other information you choose to include in your job application or CV. We encourage you to not provide us with sensitive information about yourself.

to recommend products and services we think you will be interested in, we may contact you on phone, text, social media, email or in browsers, subject to the consent you have given us (where required). When doing so we use your information such as name, address, email, phone number, purchase history and the information we have registered about your preferences, including but not limited to Automatically Collected Information collected via your use of Osdko websites (separate consent), emails, Osdko apps and other websites (see more about Automatically Collected Information below);

to tailor products and services to you, and subject to your consent, we collect information such as age, gender, location, usage data, hearing loss, purchases, returns, requests, complaints, ratings, feedback on surveys, hearing aid usage logs, fitting information, device usage etc. to understand your individual characteristics and to provide you with recommendations for usage, products, services, guidance etc;

to better understand how people interact with our websites, to analyze trends, to ensure security on our websites, to create statistical information, to develop optimized and personalized product and feature profiles we, subject to your consent, where required, collect certain automated information (“Automatically Collected Information”):

when you use our websites, we automatically gather and store certain information - in server log files and/or through the use of cookies or similar technologies (see more about the use of cookies and similar technologies below) including data available from your web browser, such as IP address, browser type, internet service provider, referring/exiting pages, operating system, date/time stamp and how you use our websites;

when you receive and open emails, SMS or similar messages in social media or other channels and click on links we automatically track whether you open the message and track your behavior using any links within the messages (see more about the use of cookies and similar technologies below);

when you use our apps, we may collect information about your computer or mobile device such as unique id, model, IP address, bluetooth mac address and your operating system. Osdko will also collect and use information about how our app features are used in general. This could be information about how extensively a feature is used and when the feature is typically activated. (see more about the use of cookies and similar technologies below);

to ensure payment for subscription of certain services through our websites, your contact and payment information may be collected. We may use external payment providers for this service and we will in such case not have access to your payment information. We refer you to the payment service providers’ privacy policies for information about your payment;

to communicate with current and potential customers, to market, improve and develop our products and services and to inform about various activities, we use social media platforms cf. also the section on social media platforms below;

to prevent or detect fraud and to establish, exercise or in defense of legal claims, we use your contact info such as name, address, email, phone number and the information we have registered about your requests, inquiries, purchases and returns;

to comply with applicable legislation such as tax, accounting or medical requirements and/or requests from law enforcement agencies, we use and share with such law enforcement agencies and regulatory authorities, information about purchases, returns or complaints and your contact info such as name, address, email, phone number to the extent required;

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for an additional purpose which is compatible with the original purpose. If we were to consider using your personal information for a new purpose, we will inform you or, as required, collect your consent.

5. What are our legal bases?

Under Hong Kong data protection law, we must clearly identify the legal basis on which we process your personal data. The following are the legal bases on which we process your data in different circumstances:

Our legal bases for processing personal data

We collect and use your personal data only where the following lawful conditions exist:

Legitimate Interests

We process your data where we have legitimate business interests (or those of a third party) and these interests do not override your privacy rights and fundamental freedoms.

Our legitimate interests include:

Managing our relationship with you and fulfilling our obligations to you or a third party;

Analyzing customer purchase, return, and usage behavior to improve our products and services;

Operating our business, ensuring the proper functioning of IT and administrative services, and providing you with efficient support;

Protecting your security when using our website, products, and services;

Preventing fraud and ensuring you receive the best possible service experience.

Contractual Necessity

If we need your data to perform a contract with you (e.g., to process an order or provide after-sales service), we will process your data on this basis.

Legal Obligation

Where we need to process your data to comply with Hong Kong legal requirements (e.g. tax filings, regulatory reporting), we will process your data on this basis.

Consent

In some cases (e.g., sending marketing emails, using cookies, or special categories of personal data), we will only process your data with your explicit consent. You have the right to withdraw your consent at any time.

Legal Claims

If we need to use your data to establish, exercise, or defend legal claims (e.g., to resolve a dispute or defend legal proceedings), we will process your data on this basis.

Specific Circumstances Requiring Your Consent

Under Hong Kong law, we process your data only with your consent in the following circumstances:

Sending you marketing communications (such as email or text messages);

Processing special categories of personal data (such as health information);

Using cookies or similar tracking technologies;

Transferring your data to countries outside the Hong Kong (ensuring compliance with international data protection standards).

We promise to use your personal data only as permitted by law and in accordance with the regulatory requirements of the Hong Kong Information Commissioner's Office (PCPD).

6. What Happens if You Fail to provide us with the Required Data?

Where we need to collect personal data by law, or under the terms of a contract we have with you or your company and you fail to provide us with the data when requested, or choose to withdraw a former given consent, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you or your organization have with us; but we will duly notify you about this if relevant.

7. Social Media and Online Search Platforms

This section describes how we process your personal data in connection with your interaction with us as a data controller by use of different social media platforms and online search platforms, such as Facebook, Instagram, X, YouTube, LinkedIn, Google and more.

We use social media platforms to get in contact with current and potential customers, to improve, develop and market our products and services and to inform about various activities, i.e. we use the social media platforms:

to understand our current and potential customers on social media platforms in relation to their demographic, preferences and interests;

to analyze trends to develop and improve our services and communications;

to process and respond to requests and inquiries received from you;

to carry out market surveys to improve and develop our services and communications for the benefit of our users through our social media pages; and

to recommend products and services we think you will be interested in, we carry out direct marketing to our customers and/or potential customers. If we use electronic methods, such as email or direct messaging through our social media pages, for instance, to send direct marketing to you, we will only do so if it is permitted under the applicable rules on direct marketing.

We may use information about you, such as your name, email, age, gender, country, job title, current and former employer, education background, profile picture, interests, your friend list/connections/followers, and other publicly available information, provided that you have published all or parts of this information on your social media profile, posted it on one of our social media pages or sent it directly to us via our social media platforms.

In some cases, for instance, in relation to our certain social media platforms we may act as joint controller together with a social media platform in relation to the processing of your personal data.

We generally refer to the different social media platforms' privacy policies and cookie policies for more information about their processing of your personal data, including any information on when our use is considered joint use with the social media platform in question. 

8. Children

We do not intentionally collect personal data from children without the explicit consent of a parent or guardian. If we learn that we have collected personal data from children without the explicit consent of a parent or guardian, we will delete that personal data as soon as possible. 

9. Recipients

We will not share or disclose your personal data, except as described herein or otherwise stated at the time the personal data is collected. We will generally limit sharing of your personal data and always only share to the extent necessary.

However, we might share your personal information with:

Osdko companies, when necessary to carry out the purpose. 

service providers, e.g. hosting, maintenance, technical support and/or market partners. We will only share your information, if it is necessary in order for our service providers to perform the specific service for us. These service providers are not authorized to keep or use your personal data for any other purposes, and they will always be under an obligation to keep your personal data safe and confidential;

Selected third parties, such as hearing care professionals, distributors, resellers, payment providers, financial institutions and/or shipping/courier companies, but only to the extent this can be done in compliance with applicable law and only to fulfill our obligations to you or enforce or apply any terms and conditions or related contracts with you or your company; and

public authorities and our professional advisors if we are under a duty to do so in order to comply with any legal obligation, if it is in our legitimate interests to do so or if necessary for the establishment, exercise or defense of legal claims.

10. Data retention

will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, such as accounting, tax or other reporting requirements.

To determine the appropriate retention period for personal data, we consider the nature, the sensitivity of the personal data, the potential risk of harm from unauthorized 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 requirements.

Details of retention periods for different aspects of your personal data are available upon request.

11. Your rights

Data protection law gives you a range of rights in connection with our use of your personal data. In this regard you have the right to request access to the personal data concerning you that we use. You may request that we rectify or delete your personal data or restrict the use of your personal data, if you think the data is inaccurate. You may have the right for data portability. We are required to assess and act on your request.

Your rights may be subject to conditions or restrictions. Accordingly, there is no certainty that you will be entitled to for example data portability in the specific situation; it will depend on the circumstances of the use.

If our use of your personal data is based on your consent, you may withdraw your consent at any time. However, please note that this does not affect our use of your personal data prior to withdrawal of your consent.

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 or excessive. Alternatively, we may 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 a 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 expedite your request more efficiently.

We try to respond to all legitimate requests within one month and shorter where required. Occasionally, it may 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.

12. Unsubscribe to Marketing Communication

We provide you with the opportunity to unsubscribe to communication from us if you receive newsletters etc. via e-mail, text (SMS) or other direct message channels. At the end of each message, instructions on how to unsubscribe are included.

13. Third-party Links

Our websites may include links to third-party websites. 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 we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

14. In connection with a Sale, Merger or Related Event

If one of our corporate affiliates or a third party has acquired our business, specific assets or the business of one of our operating divisions (such as part of a sale, merger, reorganization, or similar event), your personal data will become owned by that company, unless otherwise provided for by local legislation. In that event, the acquiring company's use of your personal data will be subject to the governing privacy policy, and the privacy preferences you have expressed to us prior to any merger.

15. Data Security

Personal data is used stored in accordance with applicable data protection legislation. We take steps to ensure that the information we process is dealt with in accordance with this privacy notice and in accordance with applicable laws.

When required or appropriate, we shall obtain written assurances from third parties that may access your data that they will protect the data with equivalent safeguards to those adopted by us.

To protect the privacy of your information we maintain both technical and organizational safeguards, and we regularly update and test our security measures.

16. Changes to the Privacy Policy

This privacy policy will be updated on a regular basis and when necessary due to changes in applicable law. The updated privacy policy will always be posted on our websites and include information on the effective date of the latest version. We recommend that you regularly check this page to keep yourself updated on our privacy practices.