This privacy notice was updated on 4 October 2021.

1. Introduction

This privacy notice applies to information gathered by MedRx, Inc. (“MedRx”), including, but not limited to our products and services MedRx Software and HearingBI.com. We respect and protect the privacy of our Customers and Participants, and we are dedicated to being as transparent as possible regarding the use of your personal data. This privacy notice explains how we collect and use your personal data. In this privacy notice, “we”, “us” and “our” means MedRx and Demant Enterprise A/S. We may change this privacy notice from time to time, so please check back when you use our services to make sure that you have seen the most recent version.

2. Who we are

This privacy notice applies to information gathered by MedRx via our website and various MedRx products, including: MedRx Software and HearingBI.com (“MedRx Products and Services”). The website is owned and operated by Demant Enterprise A/S, and Demant Enterprise A/S is the data controller of the personal data collected through the website and MedRx Products and Services. MedRx is a business managed by Demant Enterprise A/S. If you have any questions about this privacy notice, or you would like to exercise your rights, including making a complaint or request to access or correct your personal information, you can contact us by using the contact points below.

Demant Enterprise A/S
Kongebakken 9
DK-2765 Smørum
Denmark
Tel: +45 3917 7100
E-mail: privacy@demant.com

3. Personal data we collect and use

When MedRx Products and Services are used by our Customers, as defined below, we classify the personal data we collect, use, and disclose into two main categories: The first is data about our Customers and the second is about our Customers’ Participants. “Customers” are organizations and individuals that are involved in carrying out hearing screening or hearing testing of Participants. The term “Participant” refers to those individuals whose audiograms, hearing screening results, and/or other data is collected and processed using the MedRx Products and Services.

The way MedRx handles personal data varies depending on whether it relates to a Customer user (e.g. a Customer employee or other representative) or a Participant, as detailed below.

MedRx acts as service providers to our Customers, and where MedRx Products and Services are made available to a Participant by a Customer, Customers have the ability to export data from MedRx Products and Services. Customers are solely responsible for the use of such data and for safeguarding it. Participant personal data may also be directly held by the Customer. In addition to this privacy notice, the collection, use, and disclosure of Participant personal data will be subject to the privacy practices of the relevant Customers, so Participants should refer to them for additional data.

Customer Data

From our Customers, we collect data that is necessary to establish and maintain MedRx Products and Services to them, as well as to understand and improve the usage and performance of MedRx Products and Services, which may include the following personal data:

• Name;
• Contact information (address and e-mail address);
• Billing address;
• Billing details;
• Login information for provisioned users and databases (usernames, server locations and encrypted passwords);
• How the Customer and its users use and intend to use the MedRx Products and Services; and
• Information provided by the Customer and its provisioned users related to any support given by MedRx related to the MedRx Products and Services.

Participant Data

The use of MedRx Products and Services involves the collection and processing of Participant personal data by MedRx which may include the following personal data:

• Full name;
• Gender;
• Date of birth;
• ID number;
• Information about the Participant’s hearing;
• Test results;
• Questionnaire results;
• Location and date of the test;
• Location type (pharmacy, physician office, etc.);
• Home phone number;
• Cell phone number;
• Work phone number;
• Email address; and
• Notes.

Participants must provide their name, email, phone number and zip code to use MedRx Products and Services. The audiometry results and location information are generated and saved at the time of testing. Customers may collect additional Participant personal data using questionnaires within MedRx Products which may also be collected and processed by MedRx.

Other

We also collect personal data:

• when you make inquiries, ask to be contacted, request marketing material or sign up to receive our newsletter;
• when you visit our website and cookies are placed on your computer;
• when you email, call us or write to us or provide us with information in any other way, including by interacting with us via social media such as Facebook and Instagram.

4. Why do we collect and use your personal data and what is our legal basis for doing so?

We collect and use your personal data for the following purposes:

• to process and respond to requests, inquiries and complaints received from you, in accordance with our legitimate interest to provide our customers with a responsive service;
• to provide services and products requested and/or purchased by you and to communicate with you about such services and/or products; we do this as necessary in order to provide such products and services and in accordance with our legitimate interest to operate a business, which offers products and services related to hearing health care;
• to update our records and for audit purposes, in accordance with our legitimate interest to do so and/or when required by legislation;
• to prevent or detect fraud and to establish, exercise or in defense of legal claims, in accordance with our legitimate interest to do so;
• where legally required or where it is in our legitimate interests to do so, to comply with requests from law enforcement and regulatory authorities;
• to analyze trends and profiles, for our legitimate interest to aim to enhance, modify, personalize and improve our services and communications for the benefit of our customers;
• to carry out customer satisfaction research, for our legitimate interest to aim to enhance, modify, personalize and improve our services and communications for the benefit of our customers; and
• to recommend products and services we think you will be interested in. We do this in accordance with our legitimate interest to carry out direct marketing to our customers and, where we use your health data, email or other digital channels, only with your explicit consent.