Effective Date May 26th 2018 – For compliance with GDPR regulations
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. When the UK leaves the European Union the UK will adopt the GDPR regulations and this policy will in effect remain (unlike the UK!)
An overview in layman’s terms
(All information in more detail in the follwong sections)
GDPR regulations serve to better protect personal data and to ensure data is now used by consent.
Collection of date comes in several forms:
- Personal data is data that can identify someone (name, address etc)
- Essential online data (i.e. non-personal data that is required in order for our websites to work)
- Non-essential online data (i.e. non-personal data such as cookie files that enhance website use).
YOU can withdraw consent for us to store and use any data at anytime.
YOU can request a copy of information held on record (for a fee of £50 we will supply it).
Personal data – Crystal Hearing uses and stores personal data to ensure you are looked after following a purchase. If you withdraw consent to store personal data we will most likely NOT be able to sustain aftercare. We have to keep some records by law (such as payment records).
Essential online data – Systems use some data in order to make our website work on your computer and for you to make payments online. You can block such data but this WILL hinder you using our website.
Non-Essential online data – Systems store data, such as cookie files, to make browsing a better experience. You can block such data being stored but this MAY hinder using our website.
If you make an enquiry or a purchase of goods or services:
If you purchase a product of service – personal data will be stored to ensure we can look after you subsequently. Payment data may be stored in respect of card payments receipts as is required by law for 6 years. We will invite you to join our newsletter.
Crystal Hearing does not market anyone direct without their consent. Once subscribed you can easily unsubscibe.
We may invite you to write a review.
How we collect information
When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.
When you contact us using our contact form, we collect the following information: your name, email address and any information you include in the message field. We also collect your company name if you provide it.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
When you place an order for goods on our website, we collect the following mandatory information: name, email address, phone number, billing address, company name (if applicable) and payment details.
If you do not provide this information, you will not be able to purchase goods from us on our website. See the section below ‘Online payments’.
What we do with the Information we Collect?
Like other Web publishers, we collect information to enhance your visit and deliver more individualised content and advertising. We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we required comply by law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Aggregated Information (information that does not personally identify you) may be used in many ways. For example, we may combine information about your usage patterns with similar information obtained from other users to help enhance our site and services (e.g., to learn which pages are visited most or what features are most attractive). Aggregated Information may occasionally be shared with our advertisers and business partners. Again, this information does not include any Personally Identifiable Information about you or allow anyone to identify you individually.
Personally Identifiable Information collected by www.crystalhearinguk.co.uk may also be used for other purposes, including but not limited to site administration, troubleshooting, processing of e-commerce transactions, review collection and other communications with you. Certain third parties who provide technical support for the operation of our site (our Web hosting service for example) may access such information. We will use your information only as permitted by law. In addition, from time to time as we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses. In such transactions, user information may be among the transferred assets. We may also disclose your information in response to a court order, at other times when we believe we are reasonably required to do so by law, in connection with the collection of amounts you may owe to us, and/or to law enforcement authorities whenever we deem it appropriate or necessary. Please note we may not provide you with notice prior to disclosure in such cases.
Sharing your information
In order to perform hearing test, deliver, service and maintain your hearing aid (the “Purpose”) We need your consent (the “Consent”) to collect and process the following data about You: Name, address, phone number, date of birth, results from hearing test. Data can be transferred to the relevant hearing aid manufacturer in order for them to deliver, service and repair your hearing aid/s. The information that they typically receive is your audiogram (hearing test profile), hearing aid fitting and usage data. If hey are provided with contact information from Crystal Hearing such as name, address, phone number or e-mail, they may use such information to communicate with You about delivery, questions, complaints, repair or service of your hearing aid/s.
We collect and process the personal data described above (“Your Data”) to achieve the purpose described above (“Purpose”) in this consent (“Consent”) on the following conditions:
- We collect and process Your Data on basis of Your consent, which constitutes a legal ground pursuant to article 9(2)(a) of GDPR.
- The recipients of Your Data are:
- The relevant hearing aid manufacturer of your chosen hearing aids
- Data Processors, such as IT-service providers and other companies providing services and they will only (i) get access on a need basis and (ii) use Your Data to achieve the Purpose.
- Governmental bodies, if required by law or applicable legislation
- As part of the processing Your Data may be transferred outside of EU. In such case this will happen on the basis of standard data protection clauses adopted by the EU Commission, cf. article 46 (2) (c) of GDPR. You may obtain more information about this by contacting Us. (see contact information below).
- Your Data will be stored for as long as it is necessary to provide services in relation to your hearing aid, unless applicable law requires Us to delete it before or store it for a longer period of time.
Please be informed that you may withdraw Your Consent at any time, in which event We and the hearing aid supplier will cease processing Your Data and delete it (unless we are obligated to keep it). Withdrawal of Your Consent can be done by contacting Us and / or your hearing aid manufacturer direct.
How we Protect Your Information
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our gateway providers database only to be accessible by those authorised with special access rights to such systems, and are required to keep the information confidential.
Only one employee has access to client information passed to Crystal Hearing.
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings and other ways in which you can reject cookies, please visit www.allaboutcookies.org or see our cookies policy.
Affiliated Sites, Linked Sites and Advertisements
Crystal Hearing expects its partners, advertisers and affiliates to respect the privacy of our users. Be aware, however, that third parties, including our partners, advertisers, affiliates and other content providers accessible through our site, may have their own privacy and data collection policies and practices. For example, during your visit to our site you may link to, or view as part of a frame on www.crystalhearinguk.co.uk pages, certain content that is actually created or hosted by a third party. Also, through www.crystalhearinguk.co.uk you may be introduced to, or be able to access, information, surveys, Web sites, features, offered by other parties. Crystal Hearing is not responsible for the actions or policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party.
Traditionally Crystal Hearing added clients (all those who have had a hearing test) to our e-newsletter. Following the introduction of GDPR legislation we will invite such clients to approve being added to our mailing list to be kept up to date on the latest developments in hearing aid technology.
We do not market clients who have had other services such as ear wax removal or hearing protection.
The crystal hearing e-newsletter is managed within Crystal Hearing; therefore no data is shared with any outside companies in this respect.
Our order forms include the line: I consent to being subscribed to the newsletter blog YES / NO
You will only be added if you select to be added.
The e-newsletter can be easily unsubscribed from by clicking the link at the bottom of a newsletter, or by emailing a request to email@example.com
Ear Wax Removal
Our terms-and-conditions for this service and our privacy statement are available to be seen at the bottom of the online questionnaire that you are required to fill in.
The terms state that we may request a review and that we may email you to notify you of our office closures to assist you booking urgent appointments. If you do not agree to the terms please do not sign or submit the form. This will however prevent us from helping you.
We do not store data following general enquiries unless you agree to us passing your details onto an affiliate agent to provide more localised assistance to you. We only store your basic information for as long as is required for us to know you were looked after well.
Crystal Hearing relies heavily on good online reviews and appreciates customer help on this.
We only actively collect reviews from hearing aid sales, hearing aid accessory sales and ear wax removal.
Hearing aid sales
On our sales order forms there is a line stating: I consent to a review request YES / NO
If you opt for YES you can withdrawn your consent at any time.
Hearing aid accessories
As per above applies for orders received in person.
For online orders we may send a request for a review by email. We do not repeat or persist with such requests.
Ear wax removal
The online consent form that client’s are required to complete details the collection of reviews in the terms and conditions.
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use two third-party payment processors, including PayPal and Stripe. Your payment will be processed by the payment provider you choose to process your payment via a payment gateway.
Third party payment processors
The third party payment processors we use all collect, use and process your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following links:
Transfer and storage of your information
Stripe is based in the United States of America. Information relating to Stripe’s processing of your payment may be transferred outside the European Economic Area to the United States of America. Stripe has self-certified itself with the EU-U.S. Privacy Shield for the purpose of such transfers.
PayPal may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area. Where they do so, they will put appropriate safeguards in place.
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Crystal Hearing Ltd, 170 Little Marlow Road, Marlow, Buckinghamshire; or sending an email to firstname.lastname@example.org
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to request that we restrict our use of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information); and
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- sending an email to email@example.com, asking that we stop sending you marketing communications.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled Do we use ‘cookies’? and our cookies policy