Data Privacy Policy
Information on data processing according to Art. 13 and 14 General Data Protection Regulation (GDPR)
We care about the protection of your personal data and your privacy. For this reason, we will inform you in the following about our handling of your personal data, in particular for what we process your personal data, to whom we transmit them and the data protection claims and rights to which you are entitled. When we subsequently talk about data, we mean your personal information. This is all the information that identifies you as a person, directly or indirectly.
Please read the following information carefully.
About this Policy
This policy explains when and why we collect personal information, how we use it and how we keep it secure and your rights in relation to it. We may collect, use and store your personal data, as described in this Data Privacy Policy and as described when we collect data from you. We reserve the right to amend this Data Privacy Policy from time to time without prior notice. You are advised to check our website (www.stiwell.medel.com) regularly for any amendments (but amendments will not be made retrospectively). We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. For the purposes of the GDPR, we will be the "controller" of all personal data we hold about you.
Who is responsible for data processing?
MED-EL Elektromedizinische Geräte Gesellschaft m.b.H. | Business Unit Neurorehabilitation STIWELL®
Fürstenweg 77a
6020 Innsbruck
Österreich
Tel.: +43 5 77 88
Tel.: +43 5 77 88 56 52
[email protected]
The responsible data protection officer can be contacted directly:
oder
MED-EL Elektromedizinische Geräte GmbH
z.Hd. Datenschutzbeauftragter
Fürstenweg 77a
6020 Innsbruck
Austria
Which data are being processed and from which sources does this data come from?
We process personal data that we receive from you in the course of the business relationship. In addition, we process personal data that we receive from third parties and/or public accessible sources (eg business register, register of associations, country register, press, media) in a permissible manner (eg for the fulfillment of orders / contracts, fulfillment of legal obligations or consent granted by you).
Your personal data includes in particular:
- Name
- Contact information including e-mail address and phone numbers
- Demographic information such as postal code, geographic location, preferences and interests
- Data for direct invoicing to health insurance companies (STIWELL® rental)
- Data for the individual configuration of your STIWELL® device
- Further information that is needed to provide our services
- Other information relevant to market research studies
- IP-Adress
- Usernames and Passwords for protected areas of the website
- For job applications, in addition to name and contact details, the personal data you provide, training, further knowledge and qualifications, earlier employers and sent documents such as CV, certificates, etc.
For what purposes and on what legal basis is your data being processed?
We process your personal data in accordance with the data protection regulations (DSGVO and the Data Protection Act (DSG) in the current version).
MED-EL Academy
You can use our online learning management system containing information, webinars, programs, and courses on MED-EL products and services. To register, you have to provide the following data to us: name, e-mail, address, city, country, profession, and organisation. The Academy also collects online learner behaviour and progress metrics to provide insight into learning experience and proficiency.
Purpose:
Registration and use of our Academy online learning management system
Legal basis:
Performance of a contract – Art. 6 (1) lit. b) GDPR
Contact Forms
You are able to contact MED-EL (e.g. requests about products, support, etc.) by filling out our contact forms. The contact is normally made by email, if a phone number is given by phone.
When submitting the contact form your data of the contact fields (name, occupation (e.g. surgeon, home care, audiologist), interests (professional interests), telephone, address (street, house number, city, zip code, region, country), e-mail, interest to be included in mailing list) are processed.
Purpose:
Answering/assisting you with your request
Legal basis:
Performance of a contract or to perform pre-contractual steps – Art. 6 (1) b) GDPR
In some of our contact forms we use “Google reCAPTCHA”, Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, Information on data privacy. With this we check if the data entry is done by a human or by an automated program. Analysis starts automatically as soon as you visit our website. reCAPTCHA uses different information for this analysis (e.g. IP address, time of the visit, mouseclicks).
Legal basis:
Legitimate interest – Art. 6 (1) f) GDPR - Protection against abusive automated spying and spam.
Newsletter, E-Mail marketing and Survey
We offer various free subscription services via our website and social media that provide information about MED-EL products, services and our work. From time to time we send out optional surveys that ask for your anonymous feedback. In order to provide relevant and accurate marketing we process your name, profession and professional interests, phone number, address, email address and user behavior (opening emails, clicking on links). You can unsubscribe anytime, a link is included in each newsletter. MED-EL cares about the privacy of our users and partners with the following providers in order to deliver marketing and communications to you securely, and in a legal manner:
MailChimp: https://mailchimp.com/legal/privacy/
Survey Monkey: https://www.surveymonkey.com/mp/privacy/
Purpose:
Information about MED-EL specific topics, products and services
Legal basis::
Consent – Art. 6 (1) lit. a) GDPR and Legitimate interests – Art. 6 (1) lit. f) GDPR advertising and optimizing of online offers.
Online Meetings, Webinars and Videoconferences
MED-EL offers online events, webinars and meetings, as well as support for audiologists, speech pathologists and surgeons via videoconference. For registration purposes and to communicate with you, we will process the following data: first name, last name, email address, profession, institution, city/country, name of MED-EL representative.
Online events may be recorded and are made available via the MED-EL Academy.
Depending on the type of online event, we use the following providers:
“WebEx” is a service of Cisco Systems Inc., 170 West Tasman Dr., San Jose, CA 95134, USA. Privacy information: http://www.cisco.com/c/en/us/about/legal/privacy.html.
Adobe Connect is a service of Adobe Systems Software, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland. Privacy information: https://www.adobe.com/privacy.html.
Microsoft Teams is a service of Microsoft Corporation, One Microsoft Way Redmond, Washington 98052. Privacy information: https://privacy.microsoft.com/en-us/privacystatement.
Purpose:
Registration and access to events, webinars and video conferences.
Legal Basis:
Performance of a contract – Art. 6 (1) b GDPR and Legitimate interests – Art. 6 (1) f GDPR – Provide online events and training material.
Online Job Application
You can submit an unsolicited application as well as an application for a specific listed position through our website.
For more information acc. to Article 13 of the General Data Protection Regulation (GDPR) in connection with the collection and processing of your personal data in the context of the online application please have a look at our MED-EL Data Privacy Information for applicants.
Purpose: Job application
Legal basis: Consent – Art. 6 (1) lit. b) GDPR
Social Media
You can find the Business Unit Neurorehabilitation STIWELL® online via social media. We use these platforms to communicate with you and publish information about our products and work. Your feedback is used to improve our products and services. We receive anonymous statistics from these providers about: comments, sharing, likes, subscriptions and similar interactions, you can find their privacy information below.
We are jointly responsible with the providers. For inquiries about your personal data, you can contact both, the operator and us.
Purpose:
Online communication, publish information about products and services. Evaluate Feedback for product and service improvement.
Legal Basis:
Legitimate interests – Art. 6 (1) f) GDPR – public relations and communication, improvement of products and services.
YouTube
YouTube is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Data protection information: https://policies.google.com/privacy.
LinkedIn
LinkedIn is a service of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. Data protection information: https://www.linkedin.com/legal/privacy-policy.
Facebook and Instagram
are services of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. More information on the processing activities can be found in the privacy policy of Facebook
https://www.facebook.com/privacy/explanation or Instagram https://help.instagram.com/519522125107875. Further information
on the use of personal data can also be found here: https://www.facebook.com/legal/terms/page_controller_addendum
STIWELL® rental and sale
If you provide us with personal data for the use of services or for the purpose of contractual performance, you expressly consent to the transmission, processing and storage of this data. We process the data only in the scope required for the provision of a service or the performance of a contract, e.g. we will use your contact data only for communication with you.
Purpose:
Provision of a service or execution of a contract.
Legal basis:
Performance of a contract – Art. 6 (1) lit. b) GDPR
Who receives your data?
Within MED-EL Elektromedizinische Geräte Gesellschaft m.b.H | Business Unit Neurorehabilitation STIWELL®, only those departments or employees receive your data, as far as they need it for processing for the corresponding purposes.
Transmission of data to third parties:
We use various service providers and third parties ("data processors") to continuously improve our website and mobile applications and to provide you with user-friendly services.
MED-EL only uses data processors who have signed the corresponding data protection agreements and offer sufficient guarantees under applicable law. As far as possible, we select cooperation partners who are based or have their servers within the European Union (EU).
In order to be able to offer you certain services, we commission third-party providers with headquarters or servers outside the EU. Unless otherwise stated below, we use the EU standard contractual clauses as suitable guarantees: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj to ensure a GDPR-compliant level of protection of your data.
In addition, we pay attention to additional security measures and data protection regulations or certifications of our partners.
Update
The updating of your personal data takes place primarily on the basis of your direct feedback or change notices to us. However, updating is also possible due to information from third parties or the use of publicly available information.
How long will your data be stored?
We process your personal data, as far as necessary, for the duration of our business relationship (initiation, processing and termination of a contract) as well as in accordance with the statutory storage and documentation obligations arising from the Austrian Commercial Code (UGB) and the Federal Tax Code (BAO) or to assert, exercise or defend legal claims. In addition, the storage period is also judged by the statutory limitation periods, which may be, for example, under the General Civil Code (ABGB) usually 30 years, in some cases, but only 3 years. Basically, your data will therefore be deleted after complete execution of the contract, revocation of your consent or your objection, if the storage for the fulfillment of a legal obligation or for the establishment, exercise or defence of legal claims is not required. Further processing will only take place if you have expressly consented to the further use of your data or if we have reserved any further data processing that is permitted by law. There is the possibility that anonymisation of the data is carried out instead of a deletion. In this case, any personal reference is irretrievably removed, which is why the data protection cancellation obligations no longer apply. In this case, no personal reference can be restored.
Your rights
Under the GDPR you have the following rights:
- Right of access - Art. 15 GDPR:
The right to obtain confirmation as to whether or not personal data concerning yourself are being processed, and, where that is the case, access to the personal data; - Right to rectification - Art. 16 GDPR:
The right to obtain without undue delay the rectification of inaccurate personal data concerning yourself; - Right to erasure ('right to be forgotten') - Art. 17 GDPR:
The right to obtain the erasure of your personal data concerning yourself without undue delay; - Right to restriction of processing - Art. 18 GDPR:
The right to obtain restriction of processing of your personal data; - Right to data portability - Art. 20 GDPR:
The right to receive the personal data concerning yourself, which you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance; - Right to object - Art. 21 GDPR:
The right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning yourself which is based on Art. 6 (1) lit. e) or f) GDPR.
Should you wish to access your information, change your contact preferences, or raise any questions or concerns about this privacy policy or how we handle your personal information, please email [email protected] oor contact the Business Unit Neurorehabilitation STIWELL®: [email protected] Although we will strive to address any questions or concerns you may have, if you believe that the processing of your data violates
data protection law or if your data protection claims have otherwise been violated in a way, you can complain to the supervisory authority. In Austria the data protection authority is responsible.
Is there an obligation to provide data?
As part of the business relationship, you only need to provide the personal information that is required to establish and conduct the business relationship or that we are required to collect by law. You are also required to notify us of any changes in your data. Without this data, we will usually have to refuse the conclusion of the contract or the execution of the contract or an existing contract can no longer be performed and consequently terminated.
Is my data used for automated decision making including profiling?
We do not use automated decision-making according to Art. 22 GDPR.
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.
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.
About cookies on this website
In order to offer you an optimal user experience (e.g. your preferred language or page settings), we use cookies to save your login data, to ensure secure login, to collect statistical data to optimize website functions and to provide you with tailored content. Cookies are also important for the correct functioning of our website.
Click on „Accept all Cookies“, to accept all cookies and navigate directly to the website; or click on „Cookies Settings“, to get a detailed description of the types of cookies we use and to decide whether certain cookies should be saved.
We use the following providers for the improvement and optimal operation of our website:
Matomo
This website uses Matomo, an advertising analytics service provided by Matomo.org, a service of InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, NZBN 6106769..
The service does not set any cookies requiring consent and can only access to the cut-off and anonymized IP addresses of the website visitors
For more information relating to the terms of use of Matomo and its Privacy Policy see https://matomo.org/matomo-cloud-privacy-policy
You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users. Click here for opt-out.
Legal basis:
Legitimate interests - Art. 6 (1) f) GDPR - to analyze website usage and to improve our website.
Performance and Testing
This website uses the Visual Website Optimizer (VWO). With this tool we create user tests to optimize and further develop our website. VWO analyses static data about the use of our website. In addition, the tool is used as an A/B test tool. Data such as the number of visitors, click behaviour and average active residence time of the website user are assigned to the corresponding test variants.
Legal basis:
Consent – Art. 6 (1) a GDPR
Social Media Plugins
We also use so-called social media plugins (hereinafter “buttons”) to link our website to social networks:
When you visit our website, these buttons are disabled, i.e. they do not send any data to the respective social networks without your intervention. You can activate the buttons with your click. The buttons remain active until you de-activate them or delete your cookies.
After activation, a direct connection is established with the server of the social network. If you are logged in to the social network, this can assign your visit to this website to your user account.
We have no influence on the amount of data transferred to the social network.
For the purpose and scope of data collection and use of data by the social network as well as your related rights and settings options to protect your privacy, please refer to the privacy policy of the respective social networks.
Legal basis:
Consent – Art. 6 (1) a GDPR
Google Tag Manager
We use the Google Tag Manager, a tool of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, on our website.
The Google Tag Manager itself does not store cookies or process personal data. However, it enables additional tags to be triggered that can collect and process personal data to allow a needs-based design and to optimize our website.
For more information on the Tag Manager please visit: https://support.google.com/tagmanager/answer/9323295?hl=de
Google Ads / Doubleclick
We use ”Google Ads“, a service of Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland.
For more information on Google data protection please visit:https://policies.google.com/technologies/ads?hl=de.
We use Google Ads for marketing and optimization purposes, mainly to show you relevant and interesting ads and to improve reports on campaign performance. We do not collect or process any personal data. We only receive anonymized statistical evaluations from Google. Google Ads automatically establishes a direct connection with the Google server. We have no influence on the extent and further use of the data collected by Google.
Purpose:
Optimization of our marketing offer.
Rechtsgrundlage:
Consent – Art. 6 (1) a GDPR
Facebook-Pixel and Facebook Custom Audiences
We use the services “Facebook Pixel” and “Facebook Custom Audiences” of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
For more information on Facebook data protection please visit:https://www.facebook.com/about/privacy.
These services enable Facebook to show our ads on Facebook only to those Facebook users who visited our website and showed interest in certain topics or products.
Purpose:
We use Facebook Pixel and Custom Audiences for marketing and optimization purposes, mainly to place relevant and interesting ads on Facebook and thus improve our offer.
Legal basis:
Consent – Art. 6 (1) a GDPR
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