CROS Hearing Aids Privacy Policy

Effective as of: 03/06/2021

Introduction

This Privacy Policy discloses the privacy practices for the CROS Hearing Aids website (collectively, “CROS Hearing Aids” or the “Website” located at www.croshearingaids.co.uk and croshearingaids.co.uk). CROS Hearing Aids (referred to as “us”, “we” and “our”) is committed to protecting your privacy online. Please read the following to learn what information we collect from you (the “User” or the “End User”) and how we use that information. If you have any questions about our privacy policy, please email us.

CROS Hearing Aids is a business trading name of Pocket Hearing Ltd. Due to the different natures of CROS and BICROS hearing aids vs ‘regular’ hearing aids, a separate website and business model was created to improve efficiency and effectiveness for the customer and the business operators.

Please read this Privacy Policy carefully. By accessing or using our website, you acknowledge that you have read, understand and agree to be bound to all the terms of this privacy policy and our website’s terms of use. If you do not agree to these terms, exit this page and do not access or use the website.

The Types of Information That We Collect

Two types of information are collected from visitors of our website: personally identifiable and non-personally identifiable information.

If you purchase our products or services, we request certain personally identifiable information from you on our order form. This includes contact information such as your name, email address, and shipping address, as well as financial information such as a credit card number and its expiration date. We use the personally identifiable information that we collect for billing purposes and to fulfil your orders. If we have trouble processing an order, we also will use this information to contact you. Note that we do not store any financial data, including debit/credit card details although part information is stored with the third party payment company, currently Stripe.

If you contact us by email through our website, we may keep a record of your contact information and correspondence. In any event, we reserve the right to use your email address and any other personally identifiable information that you provide to us to respond to you and to send you marketing materials for our own products and services. We will not share your information with outside parties who wish to market other products and services to you.

If at any time you would like to change your personally identifiable information, or if you no longer wish to receive materials from us or would like your personal information removed from our database, please contact us at contact@croshearingaids.co.uk. Alternatively, if you receive materials from us by email you can make use of the “unsubscribe” provision in our communications so that we know that you no longer wish to receive any materials from us.

Our website may incorporate “pixel tags”, “cookies” or similar tracking technologies that allow us to track the actions of visitors of our website. Pixel tags and cookies are used to collect non-personally identifiable information, such as the name of your internet service provider, the IP address of the computer you are using, the type of browser software and operating system that you use, the date and time you access our website, the website address, if any, from which you linked directly to our website, the website address, if any, to which you travel from our website, your home page customization preferences and other similar traffic-related information. We may aggregate your information with similar data collected from other visitors to help us improve our website and the products, services, applications, content and features that we provide through our website. We do not use non-personally identifiable information in any way to create or maintain a personal profile of you or collect personally identifiable information from you.

What we do with the information we collect about you

Generally, we will not disclose the personally identifiable information that we collect through your use of our website to unaffiliated third parties. We reserve the right, however, to provide such information to our employees, contractors, agents, and designees to the extent necessary to enable them to perform certain services for us, including order fulfilment and website-related services such as web hosting, to improve website-related services and features, to perform maintenance services, and to distribute advertisements and other marketing materials on our behalf. We also reserve the right to disclose any personally identifiable information that we collect to any third party if we believe that we are required to do so for any or all of the following reasons:

  1. to comply with the law;

  2. to comply with legal processes or governmental requests;

  3. to prevent, investigate, detect, or prosecute criminal offences or attacks on the technical integrity of our website or our network; and/or

  4. to protect the rights, property, safety and security of Pocket Hearing and its employees, our website visitors, and/or the public.

Our website is only offered to those of age 18 and over. We do not knowingly solicit or collect information from anyone below 18 years of age. Whenever children use their computers, parents should supervise their activities.

Protection of Information

Our physical, electronic, and procedural safeguards meet or exceed current EU/UK and USA federal standards regarding the protection of customer information. We also require contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us. Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. Consequently, while we use commercially reasonable efforts to protect your personally identifiable information, we cannot guarantee the security of our or third party servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the website. Any information that you provide to us is done so entirely at your own risk.

Changes to this Privacy Statement

From time to time we review this Privacy Policy to ensure that it complies with applicable law. Consequently, we reserve the right to update and revise this Privacy Policy at any time. You will know if this Privacy Policy has been revised since your last visit to the website by referring to the “Effective as of” date at the top of this page. Your use of our website constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us from time to time, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

Privacy Policy in the event of a Business Transfer

As with any other business, we could merge with, or be acquired by another company. If this occurs, the successor company would acquire the information we maintain, including Personally Identifiable Information. However, Personally Identifiable Information would remain subject to this Privacy Policy.

Privacy Policies of Third Party Websites

This Privacy Policy only addresses the use and disclosure of information we collect from you on www.croshearingaids.com and www.croshearingaids.co.uk Other websites that may be accessible through this Website have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you to review the website’s privacy policy. We are not responsible for the policies or practices of third parties.

Notice of Privacy Practices (especially with respect to HIPAA & GDPR)

As required by the privacy regulations created as a result of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and The General Data Protection Regulations (GDPR) 2018, this notice describes how health information may be used and disclosed and how you can get access to your individually identifiable health information.

Please review this notice carefully

A. Our commitment to your privacy:

Pocket Hearing Ltd is dedicated to maintaining the privacy of your individually identifiable health information, also called Protected Health Information (PHI) and Patient Data. In conducting our business, we may create records regarding the services we provide to you. We are required by law to maintain the confidentiality of health information that identifies you. We also are required by law to provide you with this notice of our legal duties and the privacy practices that we maintain in our practice concerning your PHI/PD. By federal, state law and EU Law, we must follow the terms of the Notice of Privacy Practices that we have in effect at the time.

We realise that these laws are complicated, but we must provide you with the following important information:

  • How we may use and disclose your PHI/PD,

  • Your privacy rights in your PHI/PD,

  • Our obligations concerning the use and disclosure of your PHI.

The terms of this notice apply to all records containing your PHI/PD that are created or retained by our company. We reserve the right to revise or amend this Notice of Privacy Practices. Any revision or amendment to this notice will be effective for all of your records that our practice has created or maintained in the past, and for any of your records that we may create or maintain in the future. Our practice will post a copy of our current Notice on our website at all times, and you may request a copy of our most current Notice at any time.

B. If you have questions about this Notice, please email contact@croshearingaids.co.uk

C. We may use and disclose your PHI/PD in the following ways:

The following categories describe the different ways in which we may use and disclose your PHI.

1. Treatment. Pocket Hearing Ltd. may use your PHI/PD to ascertain if a hearing aid is appropriate for you. For example, we will ask you to have tests (i.e., audiogram) complete questionnaires, and have discussions over the phone and via text. People who work for our business – including, but not limited to, technicians and assistants – may use or disclose your PHI/PD in order to assist others in your treatment. Additionally, we may disclose your PHI/PD to others who may assist in your care, such as your spouse, children or parents. Finally, we may also disclose your PHI/PD to other health care providers for purposes related to your care.

2. Payment. Pocket Hearing Ltd., may use and disclose your PHI/PD in order to bill and collect payment for the services and items you may receive from us. For example, we may contact your health insurer to certify that you are eligible for benefits (and for what range of benefits), and we may provide your insurer with details regarding your treatment to determine if your insurer will cover, or pay for, your treatment. We also may use and disclose your PHI/PD to obtain payment from third parties that may be responsible for such costs, such as family members. Also, we may use your PHI/PD to bill you directly for services and items. We may disclose your PHI/PD to other health care providers and entities to assist in their billing and collection efforts.

3. Health care operations. Pocket Hearing Ltd., may use and disclose your PHI/PD to operate our business. As examples of the ways in which we may use and disclose your information for our operations, our business may use your PHI/PD to evaluate the quality of care you received from us or to conduct cost-management and business planning activities for our practice. We may disclose your PHI/PD to other health care providers and entities to assist in their health care operations.

4. Treatment options. Pocket Hearing Ltd., may use and disclose your PHI/PD to inform you of potential hearing aid options or alternatives.

5. Health-related benefits and services. Pocket Hearing Ltd., may use and disclose your PHI/PD to inform you of health-related benefits or services that may be of interest to you.

6. Disclosures required by law. Pocket Hearing Ltd, will use and disclose your PHI/PD when we are required to do so by federal, state, local or EU/UK law.

D. Use and disclosure of your PHI in certain special circumstances:

The following categories describe unique scenarios in which we may use or disclose your identifiable health information:

1. Public health risks. Our business may disclose your PHI/PD to public health authorities that are authorised by law to collect information for the purpose of:

  • Reporting problems with products or devices.

  • Notifying individuals if a product or device they may be using has been recalled.

2. Health oversight activities. Pocket Hearing Ltd., may disclose your PHI/PD to a health oversight agency for activities authorised by law. Oversight activities can include, for example, investigations, inspections, audits, surveys, licensure and disciplinary actions; civil, administrative and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.

3. Lawsuits and similar proceedings. Pocket Hearing Ltd., may use and disclose your PHI/PD in response to a court or administrative order if you are involved in a lawsuit or similar proceeding. We also may disclose your PHI/PD in response to a discovery request, subpoena or other lawful process by another party involved in the dispute, but only if we have made an effort to inform you of the request or to obtain an order protecting the information the party has requested.

4. Law enforcement. We may release PHI/PD if asked to do so by a law enforcement official:

  • Regarding a crime victim in certain situations, if we are unable to obtain the person’s agreement.

  • Concerning a death we believe has resulted from criminal conduct.

  • In response to a warrant, summons, court order, subpoena or similar legal process.

  • To identify/locate a suspect, material witness, fugitive or missing person.

  • In an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identity or location of the perpetrator).

5. Military. Our business may disclose your PHI/PD if you are a member of U.S., UK or EU military forces (including veterans) and if required by the appropriate authorities.

6. Workers’ compensation. Our business may release your PHI/PD for workers’ compensation and similar programs.

E. Your rights regarding your PHI:

You have the following rights regarding the PHI that we maintain about you:

1. Confidential communications. You have the right to request that Pocket Hearing, Ltd., communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home, rather than at work. In order to request a type of confidential communication, you must make a written request to Pocket Hearing. Privacy specifying the requested method of contact, or the location where you wish to be contacted. Pocket Hearing Ltd., will accommodate reasonable requests. You do not need to give a reason for your request.

2. Requesting restrictions. You have the right to request a restriction in our use or disclosure of your PHI/PD for treatment, payment or health care operations. Additionally, you have the right to request that we restrict our disclosure of your PHI/PD to only certain individuals involved in your care or the payment for your care, such as family members and friends. We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies or when the information is necessary to treat you. In order to request a restriction in our use or disclosure of your PHI, you must make your request by email to contact@croshearingaids.co.uk. Your request must describe in a clear and concise fashion:

  • The information you wish restricted,

  • Whether you are requesting to limit our business’s use, disclosure or both,

  • To whom you want the limits to apply.

3. Inspection and copies. You have the right to inspect and obtain a copy of the PHI/PD that may be used to make decisions about you, including patient medical records and billing records. You must submit your request by email to contact@croshearingaids.co.uk in order to inspect and/or obtain a copy of your PHI/PD. Pocket Hearing Ltd., may charge a fee for the costs of copying, mailing, labour and supplies associated with your request.

4. Amendment. You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for our practice. To request an amendment, your request must be made by email to contact@croshearingaids.co.uk. You must provide us with a reason that supports your request for amendment. Pocket Hearing Ltd., will deny your request if you fail to submit your request (and the reason supporting your request) by email. Also, we may deny your request if you ask us to amend information that is in our opinion: (a) inaccurate and incomplete; (b) not part of the PHI/PD kept by or for the business; (c) not part of the PHI/PD which you would be permitted to inspect and copy; or (d) not created by our business, unless the individual or entity that created the information is not available to amend the information.

5. Accounting of disclosures. All of our customers have the right to request an “accounting of disclosures.” An “accounting of disclosures” is a list of certain non-routine disclosures our practice has made of your PHI/PD for purposes not related to treatment, payment or operations. Use of your PHI/PD as part of the routine business practices of our company is not required to be documented – for example, the billing department using your information to file your insurance claim. In order to obtain an accounting of disclosures, you must submit your request by email to contact@croshearingaids.co.uk. All requests for an “accounting of disclosures” must state a time period, which may not be longer than six (6) years from the date of disclosure and may not include dates before April 14, 2003. The first list you request within a 12-month period is free of charge, but our practice may charge you for additional lists within the same 12-month period. Our practice will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.

6. Right to a paper copy of this notice. You are entitled to receive a paper copy of our notice of privacy practices. You may ask us to give you a copy of this notice at any time. To obtain a paper copy of this notice, make your request by email to contact@croshearingaids.co.uk.

7. Right to file a complaint. If you believe your privacy rights have been violated, you may file a complaint with the Secretary of the Department of Health and Human Services in the US. In the UK, you should contact the Information Commissioner’s Office (ICO). To file a complaint with our practice, please do so by email at contact@croshearingaids.co.uk. All complaints must be submitted in writing. You will not be penalised for filing a complaint.

8. Right to provide an authorisation for other uses and disclosures. Pocket Hearing Ltd., will obtain your written authorisation for uses and disclosures that are not identified by this notice or permitted by applicable law. Any authorisation you provide to us regarding the use and disclosure of your PHI/PD may be revoked at any time in writing. After you revoke your authorisation, we will no longer use or disclose your PHI/PD for the reasons described in the authorisation.

Again, if you have any questions regarding this notice or our health information privacy policies, please do so by email at contact@croshearingaids.co.uk.