Privacy Policy

DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis which HEARING PARTNERS (“we”, “us”, or
“our”), wholly owned by Demant Singapore Pte. Ltd., may collect, use, disclose or otherwise process
personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This
Notice applies to personal data in our possession or under our control, including personal data in the
possession of organisations which we have engaged to collect, use, disclose or process personal data for
our purposes.

 

PERSONAL DATA
1. As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about
any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of
any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from
that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal data which we may
collect from you include your name and identification information such as your NRIC number (last 3
digits and last alphabet, if necessary), contact information such as your address, email address or
telephone number, nationality, gender, date of birth, marital status, photographs and other audiovisual information, employment information and financial information such as credit card numbers,
debit card numbers or bank account information.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the
context so permits).

 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you
directly or via a third party who has been duly authorised by you to disclose your personal data to us
(your “authorised representative”) after (i) you (or your authorised representative) have been notified
of the purposes for which the data is collected, and (ii) you (or your authorised representative) have
provided written consent to the collection and usage of your personal data for those purposes, or (b)
collection and use of personal data without consent is permitted or required by the PDPA or other
laws. We shall seek your consent before collecting any additional personal data and before using
your personal data for a purpose which has not been notified to you (except where permitted or
authorised by law).

5. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or
services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback
from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) sending your marketing information about our goods or services including notifying you of our
marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and
other promotions;
(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to
assist in law enforcement and investigations conducted by any governmental and/or regulatory
authority;
(h) any other purposes for which you have provided the information;
(i) transmitting to any unaffiliated third parties including our third party service providers and gents,
and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the
aforementioned purposes; and
(j) any other incidental business purposes related to or in connection with the above.

6. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection
with our provision of the goods or services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any
of the functions listed in clause 5 above for us.

7. The purposes listed in the above clauses may continue to apply even in situations where your
relationship with us (for example, pursuant to a contract) has been terminated or altered in any way,
for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our
rights under any contract with you).

 

WITHDRAWING YOUR CONSENT
8. The consent that you provide for the collection, use and disclosure of your personal data will remain
valid until such time it is being withdrawn by you in writing. You may withdraw consent and request
us to stop using and/or disclosing your personal data for any or all of the purposes listed above by
submitting your request in writing or via email to our Data Protection Officer at the contact details
provided below.

9. Upon receipt of your written request to withdraw your consent, we may require reasonable time
(depending on the complexity of the request and its impact on our relationship with you) for your
request to be processed and for us to notify you of the consequences of us acceding to the same,
including any legal consequences which may affect your rights and liabilities to us. In general, we
shall seek to process your request within ten (10) business days of receiving it.

10. Whilst we respect your decision to withdraw your consent, please note that depending on the nature
and scope of your request, we may not be in a position to continue providing our goods or services to
you and we shall, in such circumstances, notify you before completing the processing of your
request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the
manner described in clause 8 above.

11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose
personal data where such collection, use and disclose without consent is permitted or required under
applicable laws.

 

ACCESS TO AND CORRECTION OF PERSONAL DATA
12. If you wish to make (a) an access request for access to a copy of the personal data which we hold
about you or information about the ways in which we use or disclose your personal data, or (b) a
correction request to correct or update any of your personal data which we hold about you, you may
submit your request in writing or via email to our Data Protection Officer at the contact details
provided below.

13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of
the fee before processing your request.

14. We will respond to your request as soon as reasonably possible. Should we not be able to respond to
your request within thirty (30) days after receiving your request, we will inform you in writing within
thirty (30) days of the time by which we will be able to respond to your request. If we are unable to
provide you with any personal data or to make a correction requested by you, we shall generally
inform you of the reasons why we are unable to do so (except where we are not required to do so
under the PDPA).

 

PROTECTION OF PERSONAL DATA
15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying,
modification, disposal or similar risks, we have introduced appropriate administrative, physical and
technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to
secure all storage and transmission of personal data by us, and disclosing personal data both
internally and to our authorised third party service providers and agents only on a need-to-know
basis.

16. You should be aware, however, that no method of transmission over the Internet or method of
electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the
security of your information and are constantly reviewing and enhancing our information security
measures.

 

ACCURACY OF PERSONAL DATA
17. We generally rely on personal data provided by you (or your authorised representative). In order to
ensure that your personal data is current, complete and accurate, please update us if there are changes
to your personal data by informing our Data Protection Officer in writing or via email at the contact
details provided in Section (21).

 

RETENTION OF PERSONAL DATA
18. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was
collected, or as required or permitted by applicable laws.

 

SAMPLE CLAUSES AND TEMPLATES FOR CUSTOMERS (published 17 October 2017)
19. We will cease to retain your personal data, or remove the means by which the data can be associated
with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for
which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

20. We generally do not transfer your personal data to countries outside of Singapore. However, if we do
so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your
personal data continues to receive a standard of protection that is at least comparable to that provided
under the PDPA.

 

DATA PROTECTION OFFICER
21. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal
data protection policies and procedures, or if you wish to make any request, in the following manner:

For Compliance Enquiries
Name: Enna Lam

Email: enla@demant.com

Contact: 6351 9450 Ext. 9446

 

For Withdrawal of Consent

Name: Charmaine Goh

Email: cmgo@demant.com

Contact: 6351 9450 Ext. 9487

 

For Change of Personal Information

Name: Ong Siah Beng

Email: sion@demant.com

Contact: 6351 9450 Ext. 9441

 

For All Other Enquiries

Name: Vinna Nasa

Email: vnas@demant.com

Contact: 6351 9450 Ext. 9466

 

 

EFFECT OF NOTICE AND CHANGES TO NOTICE
22. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses
that apply in relation to the collection, use and disclosure of your personal data by us.

23. We may revise this Notice from time to time without any prior notice. You may determine if any
such revision has taken place by referring to the date on which this Notice was last updated. Your
continued use of our services constitutes your acknowledgement and acceptance of such changes.