Privacy Policy

1. Contact person/responsible party

The responsible party when it comes to processing personal information as outlined in the General Data Protection Regulation (“GDPR”) is

SyncLync, Inc.

1600 Landmark Dr.
Cottage Grove, WI 53527, USA

Email: [email protected]
Internet: www.synclync.com

For questions regarding the privacy policy and these data protection provisions, please contact the SyncLync data protection officer by mail at the previously mentioned postal address or by emailing [email protected].

2. Data processing when using the “SyncLync” app

All the data collected in the app is stored locally on your end device unless otherwise mentioned below.

The following data is processed when using the app:

2.1 Default settings for the app:

• Language settings (activated language)

2.2 Adjusting and controlling your hearing aids:

• Hearing aid information (serial number, model UDI No.), side assignment (left, right hearing aid),
• Connection status (hearing aid – end device),
• hearing program settings,
• location information when location services have been activated by the user,
• location-dependent activation of a hearing program.As far as the user has granted permission for using the geolocation service and the service is activated on the end device, the user will be offered the possibility to activate a hearing program automatically by linking it to the current location. The hearing program will be activated as soon as the user enters the proximity of the defined location spot.

This feature needs to have access to the Geolocation Service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The service always checks the location data of the user in the background, independently whether the app is in use or has been closed. The app does not process the location data in case of being closed.

2.3 Integrating smartphone functions into the app

• Hearing aid localization

Provided the user has allowed access to the app’s localization function, at regular intervals the app saves the most recent location of the end device and a time stamp to the end device when there is a connection to the hearing aid. This helps ascertain where and when the hearing aid was last connected to the end device should you lose the hearing aid.
Legal bases are:

• The performance of a contract or the performance of measures prior to entering a contract (Art. 6 para. 1 pg. 1 lit. b GDPR), and
• consent of the user according to Art. 6 para. 1 pg. 1 lit. a GDPR in conjunction with Art. 9 para. 2 lit. a GDPR, insofar as health data is processed.

2.4 Plugins and tools

• Google MapsThis app accesses the Google Maps map service, provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to visually display the most recent location of your end device (paired with your hearing aid) to help locate your hearing aid. When using Google Maps, Google processes data while using the map functions. You can find more information about how user data is handled in Google’s privacy statement: https://policies.google.com/privacy Data is processed based on the consent that you give (Art 6 para 1 lit. a GDPR)
• Microsoft App Center AnalyticsThe app also sends anonymous error reports to Microsoft’s “Visual Studio App Center” service. In the process, information about the country code, language, manufacturer and device operating system on which our apps are installed as well as information regarding the version of our app that is installed is transferred. In addition, we also receive detailed crash information if one of our apps is not functioning properly. The legal basis for data processing is art. 6 para. 1 pg. 1 lit. f of the GDPR. Our legitimate interest arises from the above-mentioned purposes for data collection. We do not use the data collected to draw conclusions about you as an individual.

3. Duration of data retention

The data collected in the app is saved locally to your end device unless otherwise described in these instructions. Removing the app from your end device deletes all the data collected in the app.

4. Obligatory and voluntary disclosures

The data listed above must be processed to use the features of the app. You are not obliged to provide this data however certain features of the app cannot be offered if data is not provided.

5. Transmission of personal data and recipients of personal data

Data is not disclosed to any third parties that are not SyncLync service providers included in contract processing. Personal data included in contract processing is disclosed to Internet providers. In accordance with data protection regulations, these processors are obligated to process personal data exclusively according to our instructions. In addition, our processors are subject to contractual and legal privacy and confidentiality requirements.

6. Rights of the user

Users have the right to access, correct, or withdraw their consent for the processing of their personal data at any time without stating a reason and effective for the future. Please note that the withdrawal of consent does not affect the legality of any data processing that occurred up to the time of the withdrawal of consent.
The following rights of the individuals affected are available to you to present the respective statutory requirements:

• Right of access by the data subject (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)

To exercise these rights, or opt out of marketing communications, please contact the data protection officer at [email protected]
Lastly, you are entitled to file a complaint with a regulatory authority if you are of the view that the processing of your personal data is in violation of data protection provisions, or you have not been adequately granted the rights of individuals affected.

Thank you for trusting SyncLync with your personal information. We are committed to maintaining your privacy and delivering a secure experience.

Dated: Feb. 10, 2025