CogniFit - Privacy Notice

This Privacy Notice describes how your personal data are collected and processed when using the ActivEar Application Freemium Version, (“Mobile App”) according to local applicable law.

1. Who we are

This Mobile App is developed by Sonova Audiological Care, part of Sonova Group which headquarter is Sonova AG, Laubisrütistrasse 28, 8712 Stäfa, Switzerland (“Sonova”), acting as Controller.

The Mobile App is developed in collaboration with ConigFit Inc., a company located at 600 California Street, San Francisco, CA 94108, United States of America (“CogniFit”), acting as Processor.

2. What personal data are collected and why

By using the Mobile App, the following personal data are processed:

• Based on your consent:
  
  • To create unique access credentials: your email, name, date of birth, gender (optional), training data (e.g scores per game, cognitive age, cognitive score, etc…);
  • The use of the Hearing Screener feature: outcome of the hearing screener (good, fair or poor). By using this feature, please note that Sonova does not have access to those data, and that those are not shared by Cognifit with any third parties.
    
• Based on the performance of the contract/service:
  
  • To match you with your corresponding cognitive norms by age: age range;
  • To match you with your corresponding cognitive norms by gender (optional): your gender, age range.
  • To monitor your training progress: training data (e.g scores per game, cognitive age, cognitive score, etc…);
  • To contact you if you requested to be called by our Geers Call Center in order to book an appointment with an Hearing Care Professional (“HCP’) to perform a hearing assessment: your name, surname, email, phone number, date of birth, language, city, country. Please note you can also decide to not register and therefore not provide those personal data and call our Call Center directly.

If you visit our HCP to perform a hearing assessment, and depending on the results, you may decide to try another version of the ActivEar App (1 month Trial version or 365 days Premium version). In this case, the following personal data are processed via a Cognifit Dashboard, based on your consent:

• To allow the HCP to create you an account: Email, name, age, gender, training data (e.g. scores per game, cognitive age, cognitive score etc.);
• To allow the HCP to activate your subscription: type of subscription (1 month Trial version or 365 days Premium version).

Also, please know that by using the Mobile App usage data are collected for analytics purposes, but in an anonymous form, which means it is not possible to identify you after their collection.

3. Disclosure of your personal data

By using the Mobile App:

• Your personal data, as well as the information collected in the dashboard used by the HCP, are stored in CogniFit’s infrastructure based in AWS systems (Amazon AWS), located in Northern Virginia, USA.
• Your personal data mentioned above will be shared with our Geers Call Center, only if you requested this service.
• Your personal data mentioned above will be shared with Sonova German CRM only if you become a Sonova customer.

4. Personal data transfer

Please note that some of the above-mentioned third parties can be located outside your country. Therefore, your personal data may be transferred to countries that do not provide the same level of protection of personal data as your own country. In such cases, we undertake to:

• Implement adequate procedures to comply with applicable law;
• Adopt appropriate organizational, technical and legal safeguards in order to ensure an adequate level of protection of the personal data transferred;
• Implement, if necessary, and according to applicable law, standard contractual clauses as adopted by the European Commission;
• Depending on the country of the importing third party, take additional measures such as a transfer impact assessment.

5. How long your personal data are kept

Your personal data will be retain as long as your account will be active. As soon as you will delete your account all your personal data will be deleted from CogniFit’s database. In any case, we will retain your personal data for a minimal period proportional to the time required to fulfill the purposes outlined in the precedent section. In the event applicable law or other regulations require a longer retention period, we will apply the longer retention period in order to fulfill our legal obligations.

6. Your rights

As per local applicable law, you may have the right to request access, rectification, erasure of your personal data, restriction of processing, object to the processing, request data portability and withdraw your consent. If you consider that the processing of your personal data infringes applicable law then you may also lodge a complaint with the local supervisory authority. Please note that the exercise of such rights is subject to the limitations provided by local applicable law.

7. Contact us

For any request to access your personal data and request a copy of your personal data handled, or for any request concerning the deletion of your account, please contact CogniFit at privacy@cognifit.com. In order to exercise your other legal rights, or for any other request concerning this Privacy Notice or the processing of your personal data, please contact Sonova at privacy@sonova.com with the headline “ActivEar App”.

Last updated: May, 29 2024