Variphone Privacy Statement

Why this privacy statement? 
Variphone is an organisation focused on: 
-    the development of products and services that can be used to combat noise pollution and improve communication in noisy environments, and 
-    the prevention of hearing damage caused by loud music or machine noise with two legal entities in Europe (in Belgium and the Netherlands):

  • the Netherlands: CoC 37136654 Branch no. 000019942788, Netwerk 11, 1446 XB Purmerend  
  • Belgium: Company no. 0435.153.381, Deusterstraat 72, 3990 Peer (B)

Our organisation and corporate culture can be summarised in 3 words: innovation, competence and accessibility. These are our core values that also form the basis for how we handle your personal data. This privacy statement describes:

  • How we handle your personal data and comply with our legal obligations.
  • How we advise you on your preventive hearing care.
  • How we determine your hearing quality. 
  • How we fit your hearing protection.
  • How we help you or your employer determine the noise level at your workplace. 

Our products and services are jointly also referred to as the “Healthy Hearing Programme”.  This Privacy Statement also applies if you only visit our website or our online environment.

When does this Privacy Statement apply to you?
This Privacy Statement applies to you, if:
You approach us directly for one of our products and services as a customer. 

  • We have obtained your data from your employer if we are hired to provide our products and services.
  • You make use of our services through one of our accredited Hearing Coaches. 
  • We have obtained your data when you purchase our products and services through one of our dealers. 
  • You deliver products and services to us in as a supplier. 
  • You visit our website and/or use the online environment. 
  • This Privacy Statement only applies to the Variphone platform and not to third-party websites to which the Variphone website links. If you visit a third-party website through a hyperlink, this Privacy Statement does not apply to your visit to that website. Variphone advises you to study the privacy policy of any third-party websites.

What personal data do we process?
Variphone processes personal data that we receive for the delivery of our products and services. These concern:  

  • General data, such as a name, address, telephone number, personnel number. We also collect data about your use of hearing protection and possible noise impact. 
  • We collect special personal data to provide our services. We collect data about the quality of your hearing if you use our Hearing Quality service, directly or based on the agreement we have concluded with your employer. Once you have given permission, these data will only be shared with the medical advisor/ physician of the company of your employer. The medical advisor/company physician is subject to confidentiality requirements pursuant to his professional duties as a healthcare provider (patient confidentiality). 

We limit our collection of data to those data we need to achieve our purposes.

For what purposes do we collect personal data?

Data about you as a customer 
We only use your personal data for carefully defined purposes. In some cases, we obtain your personal data directly from you to implement the agreement for the provision of services. We can also obtain your personal data through your employer based on an agreement. Your employer will have informed you about this in advance. 
If we do not obtain your personal data from you or your employer, we will not be able to provide you with our products and/or services. 

Data about you as a supplier
We collect and use information about you or persons within your organisation to be able to communicate with you, to be able to receive products and services, as well as to arrange the corresponding payment within the framework of our agreement.

Cookies: Website visitor and online user
We primarily use information about our website visitors and online users to improve our website(s). We also use website data to monitor visitor behaviour.
If you contact us through the website, we will also collect data about you. 

Legitimate interests
We may sometimes process your personal data if this is “necessary for the legitimate interests of the controller or a third party, except if the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these first interests (...).”
However, you have the right to object to our processing of your personal data on this ground. In that case, you can contact us.

Permission.
We will record any permission you have given us. If we have obtained your permission for the processing of your personal data for certain products and/or services (e.g. to register your hearing quality or to fit your hearing protection), you can revoke this permission at any time unless we believe that there is an alternative ground to justify the processing of your data for this purpose. We will inform you about this ground if this is the case.

With whom may we share your personal data?
We can share your personal data in a variety of ways based on different grounds with the following categories of persons where appropriate and in accordance with local laws and regulations;

  • All business entities that are part of Variphone. 
  • Medical advisers and company physicians of our clients, your employer.
  • Your employer, insofar no medical data are provided.
  • Third parties, such as service providers who fulfil positions based on our instructions.
  • Third parties, such as outsourced IT providers and file storage providers with whom we have concluded a processor agreement. This list is not exhaustive.

Variphone considers innovation very important based on its mission and vision. This is why we are always talking with opinion leaders, research institutes, policy makers and health insurers to improve policies on the ‘prevention’ of hearing damage. Various national and international organisations rely on Variphone for the collection of facts and figures. To this end, Variphone may decide to make the data in its personal data database available for scientific research. Variphone will only carry out such transfer with a fully anonymised dataset.

How do we protect your personal data?
We have implemented suitable technical and organisational measures to secure the personal data in our possession against abuse, loss or unauthorised access. Employees of Variphone and those of our suppliers and dealers have been instructed to handle your data with care and observe their confidentiality. 

Inform us immediately if you suspect any abuse or loss of or unauthorised access to your personal data. Details on how to contact us can be found here: privacy [at] variphone.com 

How long do we keep your personal data?
We will keep your data as long as required by law and for the purpose for which we use them. This may differ per service. We observe the following principles: 
We will keep any personal data we process if you purchase products and/or services from us directly for a period of 10 years after the provision of our services. 

We will keep personal data we process based on an agreement with your employer for a period of 10 years after the termination of the agreement between your employer and Variphone.  

We will also remove your personal data from our systems if we have not had any meaningful contact with you about our products and/or services for a period of 10 years unless we are required by law or relevant regulators to keep your data for a longer period. 

International transfer of data
We will always ensure that third parties only have access to the personal data that are necessary for their specific duties. If Variphone shares your personal data internally, we always make sure there are suitable safeguards to protect these data. 
These include standard provisions used in agreements with (internal) service providers to ensure that the transfer of data to countries outside the European Economic Area complies with European laws and regulations on the protection of data.

What are your rights?
As a customer, you have a number of rights with respect to your personal data. These have been listed below: 
•    The right to information.
•    The right to access your data.
•    The right to correct any incorrect data.
•    The right to request deletion of data, and the ‘right to be forgotten’.
•    The right to request limitation of the data processing.
•    The right to object to the data processing.
•    The right to request transfer of your data (data portability).
•    The right not to be subjected to automated decision-making.

How do you access, correct or request the deletion of your personal data?
You can contact us to discuss your request and enable us to handle it within the defined period. Contact us at privacy [at] variphone.com. We will respond within one month after we receive your request.

Our Data Protection Officer
Variphone has appointed a Data Protection Officer.  You can contact our DPO at the following e-mail address: privacy [at] variphone.com

Do you have a complaint?
You also have the right to submit a complaint to your local supervisory authority. 

In the Netherlands, this is:
De Autoriteit Persoonsgegevens. 
By phone:    (+31) 900 2001 201
Online:         www.autoriteitpersoonsgegevens.nl
By post:       PO Box 93374, 2509 AJ The Hague

In Belgium, this is:
Gegevensbeschermingsautoriteit.
By phone:  +32 (0)2 274 48 00
Online:       www.gegevensbeschermingsautoriteit.be
By post:     Drukpersstraat 35, 1000 Brussels    

Formulating, conducting (a defence in) criminal proceedings
We sometimes may need to process personal data and, where appropriate and in accordance with local laws and regulations, sensitive personal data to conduct (a defence in) criminal proceedings. This is permitted pursuant to Article 9(2)(f) GDPR if the processing is “necessary to initiate, exercise or substantiate an action or if courts act within the framework of their competence.”

About this Privacy Statement
This Privacy Statement can be amended based on changes to laws and regulations and/or the way in which Variphone processes personal data. The most recent version can always be found on the Variphone.com website.