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Privacy Policy

  1. Website
  2.  Gmail Add on

 

WEBSITE

This privacy policy sets out how InterHearing Ltd uses and protects any information that you give us when you use this website.

We are committed to protecting and respecting your privacy.  This policy (together with our Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. For the purpose of the General Data Protection Regulation, we are a ‘processor’.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 2 September 2018.

What we collect

We may collect the following information:

  • name
  • contact information including email address
  • the nature of your enquiry

What we do with the information we gather

We may process information contained in any enquiry you submit to us regarding services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.

Marketing

We will not share your information for marketing purposes with anyone.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

About Cookies

A Cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies We Use

We use cookies to help us to analyse the use and performance of our website and services

Cookies used by our Service Providers

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

We may publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website).  You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

Managing Cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites.  If you block cookies, you will not be able to use all the features on our website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

You may request details of personal information which we hold about you for which a small fee may be payable. If you would like a copy of the information held on you please contact us via our contact form.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or contact us as soon as possible. We will promptly correct any information found to be incorrect.

 

FLEXI RESPONDER – GMAIL ADDON

Your privacy is important for INTERHEARING and an essence to our service. This Privacy Policy explains what information we collect about you and why, what we do with that information, and how we handle that information

At INTERHEARING, we care about the confidentiality and privacy of your data and are fully committed to protecting it. This is something that will never change. INTERHEARING is not in the business of selling or renting your information. INTERHEARING shall not sell your personal data to third parties and shall only share it when necessary for the rendering of the INTERHEARING service as stated below.

Table of contents

  1. Introduction
  2. Processing of personal data of Users by INTERHEARING (as Controller)
  3. Processing of personal data on behalf of Users by  INTERHEARING (as Data Processor)
  4. Security
  5. Frequently asked questions about privacy
  1. Introduction

This Privacy Policy establishes the conditions for the processing of personal data of users (the “User” or “you”) of the Flexi Responder service (the “Service”) by INTERHEARING,  (“INTERHEARING” or “we”) as well as the conditions for the processing of personal data by INTERHEARING on behalf of Users within the Service.

INTERHEARING shall process personal data in accordance with European Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and applicable data protection laws.

  1. Processing of personal data of Users by INTERHEARING (as Controller)

2.1. This Section explains the processing of personal data of Users by INTERHEARING as a controller, that is, when INTERHEARING decides about the purposes and means for the processing of the data. This only happens regarding the data of the User used by INTERHEARING to render the Service (having an account, invoicing…). This does not include the communications sent by the User through the Service and related-data, which shall only be processed in accordance with Section 3 below.

INTERHEARING shall process as controller your personal data to provide you with the Service and to manage and improve the Service, including sending of communications regarding the Service or with information about the Service or INTERHEARING.

2.2. Personal data of Users processed by INTERHEARING for the above purposes may include contact information, such as name or email address, language preferences, current location for the proper price/currency displaying, payment data, and other personal data provided by the User in the context of the provision of the Service.

2.3. The legal basis for the processing of personal data of Users is the contractual relationship between the Users and INTERHEARING for the Service and also the legitimate interest of INTERHEARING of informing registered Users about the Service and the company, unless they opt out to receive this information.

2.4. Personal data of the Users will be processed by INTERHEARING throughout the term of the contractual relationship for the Service and subsequently for the period during which applicable regulations require such personal data be he held thereafter.

2.5. INTERHEARING may share the personal data with third parties, some of which may be located outside of the European Economic Area, only for the provision of the Service and at all times subject to the guarantees and requirements provided by applicable data protection laws.

2.6. The User may at all times exercise his rights to access, rectification, erasure and restriction of processing and data portability as provided in the GPDR and applicable regulations by contacting INTERHEARING or, by sending an email. The User may also lodge a complaint through the ICO data protection authority.

If at any time the User wishes to stop receiving communications regarding INTERHEARING or with commercial information about the Service, the User may request so by sending an email to INTERHEARING.

  1. Processing of personal data on behalf of Users by INTERHEARING (as Data Processor)

3.1. This Section explains the processing of personal data by INTERHEARING on behalf of Users, as a data processor, that is, when the purposes and means for the processing of the data are decided by the User and INTERHEARING only access the data for the rendering of the Service and on behalf of the User.

The Service may imply the access and processing by INTERHEARING of personal data controlled by the User and generated within the Service in relation to each electronic mail sent by the User through the Service (“Accessed Data”). In such cases, INTERHEARING shall be deemed as the data processor and shall process such personal data only on behalf of the User and not for its own purposes.

The Accessed Data shall comprise:

  • Information required to identify the electronic mails sent through the Service:
    • information of the recipients;
    • subject of the email; and
    • date and time in which the email was sent; and

Accessed Data is the only information to which INTERHEARING shall access to provide the Service. Authorizations for Gmail and the connection to your Google account are needed technically for the rendering of the Service by INTERHEARING and to provide the Flexi Responder service, but do not imply the access by INTERHEARING to any data or information of the User other than the Accessed Data. For your better understanding, this is the detail of the use of the above permissions by INTERHEARING:

  • Basic permissions: view your email metadata such as labels and headers, but not the email body. The Service needs this permission to identify your emails.
  • Spread sheet permissions: It is needed for containing the out of office responses in a spreadsheet format.
  • View and manage your basic email settings: The Service needs to know your settings (e.gl alias, design style) to work properly.
  • Manage mailbox labels:  The Service needs this permission to add labels to your emails if the option is active.
  • Read, send, delete and manage your email: The Service needs to be able to forward your emails if this option is active in the settings. No one at INTERHEARING will read your emails, INTERHEARING will never share the content of your emails.

As detailed in the above permissions, some of them are never used by INTERHEARING, but the permission system from Google does not have enough granularity to select only the ones that INTERHEARING really needs.

INTERHEARING guarantees that:

  • Only automated software uses the above permissions
  • No one at INTERHEARING reads your emails
  • INTERHEARING will never send emails on your behalf
  • INTERHEARING will never share the content of your emails with third parties
  • INTERHEARING will never share your browsing data with third parties
  • INTERHEARING doesn’t store the body of your emails.

3.2. Accordingly, INTERHEARING shall:

(i) not process the Accessed Data for a purpose other than the provision of the Service requested by the User and shall not transfer such data, not even for their storage, to unauthorized parties;

(ii) process the Accessed Data only on documented instructions from the User; and if INTERHEARING is aware that or of the opinion that any instruction given by the User breaches the data protection regulations, INTERHEARING shall immediately inform the User;

(iii) notify the User promptly if it becomes aware of any data breach and shall provide full details of the relevant breach;

(iv) ensure that persons authorized to process the Accessed Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

(v) taking into account the nature of the processing, assist the User by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of the Users’ obligation to respond to requests for exercising the data subject’s rights laid down in Chapter III of the GDPR;

(vi) take all measures required pursuant to Article 32 of the GDPR (Security of Processing);

(vii) assist the User in complying with its obligations pursuant to Articles 32 to 36 of GDPR taking into account the nature of processing and the information available to INTERHEARING, including but not limited to, assisting the User with:

(viii) at the choice of the User, delete or return all the Accessed Data to the User after the end of the provision of Service, unless the storing of the data is required by applicable law; and

(ix) make available to the User all information necessary to demonstrate compliance with the obligations laid down in Article 28 of GDPR and allow for and contribute to audits, including inspections, conducted by the User or another auditor mandated by the User.

3.3 INTERHEARING shall not subcontract third parties for the processing operations which may imply access to the Accessed Data without the authorization of the User.

In this respect, the following sub-processors are deemed as authorized by the User:

  • Google services: Google Apps, Google Analytics, Webmaster Tools and Google Forms
  • HelpScout, for the provision of the customer service
  • LogEntries for server logs storage

3.4. INTERHEARING shall guarantee the confidentiality of the Accessed Data, even after the termination of the Service.

3.5. The User is the data controller of the processing of the Accessed Data within the meaning in GDPR. The User is the only one deciding the purposes and means for the processing of Accessed Data, so INTERHEARING does not use Accessed Data for its own purposes and only uses them for the rendering of the Service and on behalf of the User. To such extent, the User shall have to comply with applicable obligations under data protection regulations, including relying on an appropriate legal basis for the processing of personal data of the recipients of the emails sent through the Service. The User, and not INTERHEARING, shall be solely responsible for the compliance with such obligations.

3.6. The User acknowledges and agrees that the use of the Service and the processing of the Accessed Data as a result of the same is its own free and exclusive decision and has verified that the conditions of the Service and the processing of the Accessed Data are in line with its interests.

  1. Security

INTERHEARING shall process all personal data in the strictest confidentiality and implement the appropriate technical and organisational measures as required by applicable regulations.

We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.

  1. Frequently asked questions about privacy

5.1. How can I remove INTERHEARING access to my Google account and emails?

You can stop INTERHEARING access to your Google account . In such a case, you will not enjoy the Service any more.

5.2. Does INTERHEARING sell or rent my personal data or the content of my emails?

No, INTERHEARING does not sell or rent your personal data.

5.3. Do you need a data privacy agreement?

This Privacy Policy constitutes a binding data processing agreement (DPA) in case you need it.

5.4. How can I delete my personal data from the Service?

You can remove your Personal Data from the Service at any time by logging into your account, accessing the Account page, and then deleting your account.

5.5. How safe is my credit card information?

Your credit card information is safe. INTERHEARING does not have access to your credit card information at any point during the transaction, so we do not store your credit card information. We process every payment via Stripe or Paypal, certified Level 1 third party payment processing services.

5.6 Does INTERHEARING store the body of my emails?

No, INTERHEARING doesn’t store the body of your emails.

5.7 Why does INTERHEARING need permissions to access your Gmail / Google Account and how those permissions are used?

This is the detail of the use of the permissions by INTERHEARING:

  • Basic permissions: view your email metadata such as labels and headers, but not the email body. The Service needs this permission to identify your emails.
  • Spread sheet permissions: It is needed for containing the out of office responses in a spreadsheet format.
  • View and manage your basic email settings: The Service needs to know your settings (e.gl alias, design style) to work properly.
  • Manage mailbox labels:  The Service needs this permission to add labels to your emails if the option is active.
  • Read, send, delete and manage your email: The Service needs to be able to forward your emails if this option is active in the settings. No one at INTERHEARING will read your emails, INTERHEARING will never share the content of your emails.

As detailed in the above permissions, some of them are never used by INTERHEARING, but the permission system from Google does not have enough granularity to select only the ones that INTERHEARING really needs.

5.8 Privacy code of conduct

INTERHEARING guarantees that:

  • Only automated software uses the above permissions
  • No one at INTERHEARING reads your emails
  • INTERHEARING will never send emails on your behalf
  • INTERHEARING will never share the content of your emails with third parties
  • INTERHEARING will never share your browsing data with third parties

 

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