1. Introduction

This Privacy Policy explains how Sivantos Pte. Ltd. (“we”, “our”, “us”) collects, uses and discloses your Personal Data on this site.

To the extent required under applicable law, including without limitation to the Personal Data Protection Act 2010, Act 709 of the Laws of Malaysia, you consent to us collecting, using, processing and disclosing your information in accordance with this Privacy Policy. If you do not consent to our collection, use, processing or disclosure of your personal data, please do not use this site.

 If you have concerns or queries in relation to our Privacy Policy or our data protection practices, please contact us using the information below.

2. What Personal Data Do We Collect?
For the purposes of this Privacy Policy, “personal data” refers to any data, whether true or not, about you which can be used to identify you either directly from that data, or from that data and other information which we have or to which we are likely to have access.

2.1 Information collected from you
Depending on the nature of your interaction with this site, we may collect and process the following types of personal data which you provide to us:

• Name
• Contact Number
• Email address
• Other data provided or uploaded by you either manually or generated by this site

2.2 Information collected automatically
We may also collect and process certain data automatically from you and/or your device when you use this site, including through the implementation of cookies and/or similar technologies. This type of data includes Internet Protocol (IP) addresses, geographic location, language and other regional settings, timestamps, browsing activity and similar information, and device information such as manufacturer and model.

2.3 Information collected from third parties
Depending on the nature of your interaction with this site, and only to the extent necessary, we may also collect certain personal data about you from third parties, where permitted by applicable law.

3. How Do We Use Your Personal Data?
The purposes for which we may collect, hold, use and disclose your personal data to:

• a hearing care clinician or hearing care professional near to your location
• agents, contractors, and third-party service providers who provide operational services to us, including but not limited to telecommunications, information technology, payment, billing, processing, technical services, market research, marketing, advertising attribution or any other services
• our affiliates
• our professional advisers such as auditors and lawyers
• any other party to whom you consent for us to disclose your personal data to

We may use your personal data for marketing purposes where we have your consent. This may include sending you information on promotions and offers, updates on our products and services.

4. Who Will We Share Your Personal Data With?
Subject to the provisions of any applicable law, we may share or disclose your personal data for the abovementioned purposes, with the following recipients:

• agents, contractors, and third-party service providers who provide operational services to us, including but not limited to telecommunications, information technology,
• payment, billing, processing, technical services, market research, marketing, advertising attribution or any other services
• our affiliates
• our professional advisers such as auditors and lawyers
• any other party to whom you consent for us to disclose your personal data to

We may also share non-personally identifiable, aggregated, and/or public information with third-parties in addition to those listed above.

5. Who is Responsible for Third Party Services and Websites?
Our site may contain advertisements and links to applications, websites or services operated by third parties. We do not monitor and are not responsible for the privacy practices of third-party apps, websites or services that are linked from our site. You are advised to refer to their privacy policy before using them.

6. Is Your Data Transferred Overseas?
Your personal data may also be stored or processed outside of your country by personnel who work for us in other countries (including Singapore, Denmark and Germany), or by our third-party service providers, suppliers, contractors or affiliates, to the extent permitted under applicable law. In such a case, we will ensure that such personal data remains subject to a level of protection comparable to what is required under the laws of your country (and, in any event, in line with our commitments in this Privacy Policy).

7. How Do We Protect Your Personal Data?
The security of your personal data is of utmost importance to us. We will use all reasonable efforts to protect and secure your personal data against access, collection, use, disclosure or modification by unauthorised persons and against unlawful processing, misuse, interference, accidental loss, destruction and damage or similar risks.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, you acknowledge that we cannot guarantee the integrity and accuracy of any personal data which you transmit over the Internet, nor guarantee that such personal data would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond our control. 

8. What are your responsibilities?
We generally rely on personal data provided by you. You are responsible for keeping your account details confidential and you must not share your account details, including your password, with anyone and you must always maintain and fully responsible for the security of the device that you use.

9. How Long Will We Retain Your Personal Data For?
To the extent permitted by applicable laws, we will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purpose.

10. How You Can Exercise Your Data Protection Rights
You may request access to your personal data in our control or possession. Depending on the nature and complexity of your request, and to the extent permitted by applicable law, we may charge a fee to process your request. We will inform you of any such fees and seek your approval before such a fee is charged. If any personal data which we have about you is inaccurate, you may request that we correct the data. 

You may also withdraw your consent for us to process your personal data at any point in time to the extent permitted under applicable law. However, where your withdrawal of consent relates to information which we require for the provision of services to you, we might be unable to continue the further provision of such services. 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.

You may contact our Customer Care using the contact information set out below to exercise any of your rights in relation to your personal data.

11. Changes To This Privacy Policy and Language
We may update this Privacy Policy from time to time without prior notice by posting a new version on this site. You should check this page regularly to ensure that you are familiar with any changes. Your continued use of this site and continued dealings with us for the provision of our products and services, after any changes to this Privacy Policy has been made, constitutes your acceptance to such changes. 

This Privacy Policy may be translated into one or more other languages. If there is any inconsistency between the English version of this Privacy Policy and other language versions, the English version shall prevail.

12. How Can You Contact Us?
To put in a request to exercise any of your data protection rights, e.g. delete your personal data, please email our Customer Care at customerservice.sg@wsa.com or call us at +65 6370 9681 / +65 6370 9575.

To report on any violation of this policy or to make a complaint about an alleged breach of any applicable privacy and data protection laws, please contact our Data Protection Personnel at dpo@wsa.com. We will investigate any complaint about the way we manage personal data and take reasonable steps, where necessary, to remedy any issues resulting from any failure to comply with applicable privacy and data protection laws.