This Website (http://www.specialpensioners.co.uk) is owned and operated by Hidden Hearing
This Policy explains how we collect and use your information. In this Policy, “we”, “us” and “our”
means Hidden Hearing Limited.
We may change this Policy from time to time so please check back when you use our services to
make sure that you have seen the most up to date version
If you have any questions about this Policy, or would like to exercise your rights, you can email our
Data Protection Officer at firstname.lastname@example.org, telephone us at 0800 0378 989, or use our
Website contact form: http://www.specialpensioners.co.uk/contact-hidden-hearing/
- Who we are
Hidden Hearing Limited is a private limited company incorporated in England and Wales (Company
number 01990227), with a registered office at Medway Street, Maidstone, Kent, ME14 1HL.
We are registered with the Information Commissioner’s Office (ICO) as a data controller in the United
Kingdom, with registration number Z7161992. You can find out more about our registration with the
ICO by visiting the ICO’s website.
- When do we collect information about you?
Some of the information we collect about you can be used to identify you. This type of information
is defined as “Personal Data” under the UK Data Protection Act 1998 and, from 25 May 2018, the
EU General Data Protection Regulation (EU) 2016/679. In this Policy we use the words “Personal
Information” to talk about your Personal Data.
We collect your Personal Information:
- when you make enquiries or book an appointment through our Website form, purchase
products from us through our Website, register for an account on our Website, request a
Free Hearing Information Brochure or sign up to receive our newsletter
- when you visit our Website and cookies are placed on your computer;
- when you make enquiries via the press;
- when you email, call us or write to us, visit our branches or provide us with information in any
other way, including by interacting with us via social media such as Facebook, Twitter,
Pinterest, YouTube, Google+ or Disqus.
- When a relative or friend gives us information about you during discussions about such
person’s hearing, or where an individual has indicated that he or she would like you to
accompany them to a hearing assessment, hearing aid fitting or service appointment.
We also check your contact information against lists which we receive from third party service
What types of Personal Information do we collect and process?
providers, or from public sources such as the electoral roll, to make sure that we have recorded
your contact details correctly. This helps us to keep our records up to date and ensure that we
can provide you with relevant information and services.
We process the following kinds of personal information if you provide it to us:
- Information about you, including your name, title, postal address, telephone number
and email address, and, if you make a purchase with us, credit or debit card details;
- Information about your use of our call centres and your branch visits.
- Information you provide to us during communications you have with us and with our
staff, whether by email, post, telephone, in person or through our Website, for
example comments or queries about the products and services we provide.
- If you register for a hearing test with us, take our online hearing test; give us
information about your hearing in store or, call one of our call centres, or purchase
one of our hearing aids you may give us sensitive information about your health. This
could include for example whether you currently use a hearing aid and if so what type
of hearing aid, information about your hearing condition and where appropriate your
family history. We will only ever collect and use this kind of information with
- If you decide to purchase one of our products using credit, we will pass your
information to our preferred lender, V12, who will contact you to make further
arrangements for this purpose.
Each time you visit the Website we may automatically gather the following information:
- technical information about your computer such as domain name, browser type and
version, operating system and platform, IP address, cookie information and time zone
- information about your visit including the full Uniform Resource Locators (URL)
clickstream to, through and from the Website (including date and time), what web
pages you visited on the Website and how long you spend on each page, page
interaction information (such as scrolling, clicks and mouse-overs), page response
times, download errors, traffic data, location data, weblogs, history of resources
accessed on the Website, methods used to browse away from the page and
information on what websites you visited before accessing the Website.
When a friend or relative gives us information about you this could include for example your name,
your relationship to the individual and your comments or reactions to that individual’s hearing.
When we collect information about you it is stored in our customer relationship
management system. This automatically integrates with a program which segments our
customers and potential customers into different profile categories. These profile
categories, loosely based on information such as post codes, age and requirements
- How often we contact you; and
- The content of our messages and the way that they are written.
This automatic profiling does not disadvantage you in any way: our aim is to make our
Why do we collect and use your information, and what are our lawful grounds for
communications with you as relevant and as tailored as possible, to provide you with a better
service. You have the right to opt out of marketing communications at any time. We will
always respect your wishes.
We use your Personal Information for the following purposes:
Where we store your Personal Information
- To process and respond to requests, enquiries and complaints received by you, in
accordance with our legitimate interest to provide our customers with a responsive
- To provide services and products requested and/or purchased by you or an attorney
on your behalf and to communicate with you or your attorney about such services
and/or products. We do this as necessary in order to carry out a contract with you,
for the purpose of our legitimate interest to operate a business which offers products
and services related to hearing.
- To update our records and for audit purposes, in accordance with our legitimate
interest to do so.
- To prevent or detect fraud, 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 analyse trends and profiles, for our legitimate interest to aim to enhance, modify,
personalise and improve our services and communications for the benefit of our
- To carry out customer satisfaction research, for our legitimate interest to aim to
enhance, modify, personalise and improve our services and communications for the
benefit of our customers.
- To recommend products and services we think you will be interested in. For this we
use our legitimate interest to carry out direct marketing to our customers or, where
we use your health data or electronic methods such as email, with your consent.
- To enable our service providers to carry out any of the purposes set out above on
our behalf. Service providers include, for example, call centre operators, website
developers, cloud storage providers, mailing house, media agencies. For this
processing we use our legitimate interest to run our business as efficiently as
possible. Our service providers will always be under a duty to keep your Personal
Information safe and confidential.
Our servers are managed by our parent company, William Demant, and are located within
How we share your Personal Information
We share your Personal Information with companies within our corporate group. We will
only share your Personal Information with unrelated third parties as described in this
We may share your Personal Information with our service providers for tasks such as:
- assisting us with administering or troubleshooting our Website;
- assisting us with the supply or design of our products or with our business
- assisting us with our marketing campaigns;
- operating our call centres; or
- providing us with electronic or physical storage services or systems.
We will only share your information in these circumstances if it is necessary to do so in order
for our service providers to perform the service for us. These companies are not authorised
to keep or use your Personal Information for any other purpose.
We may disclose your Personal Information to selected third parties such as law
enforcement agencies, regulatory authorities and our professional advisors if we are under
a duty to do so in order to comply with any legal obligation, or if it is in our legitimate
contracts with you or your company
If we sell all or any part of our business, the parties which buy it may have access to your
How long do we keep your Personal Information?
We hold your personal information for as long as we need to for legitimate legal or business
reasons, including to comply with any regulatory obligations. [Depending on the record types
and our relationship with you, retention periods range from 3 months to 10 years, or for the
period during which you request our services.]
If you would like more detailed information about our retention policy, please email us at
email@example.com or use one of the other methods in the “Contact us” section
We aim to keep your Personal Information secure. In order to prevent unauthorised access
or disclosure, we use appropriate physical, technical and organisational measures to keep
the Personal Information we collect secure. Our service providers are required to do the
Unfortunately, transmission of information via the internet is not completely secure.
Although we will do our best to protect your Personal Information once we receive it, we
cannot guarantee the security of your Personal Information transmitted to our Website; any
transmission is at your own risk. Once we have received your Personal Information, we will
use strict procedures and security features to try to prevent unauthorised access or loss.
Links to other websites
you with a good experience when you browse the Website, and also to help us to improve
the Website. Please see our for more information.
The Website may contain links to the websites of other companies and organisations
which may be of interest (“Third Party Sites”).
Once you have used these links to leave our Website, we do not have any control over
how other companies use your Personal Information collected through such Third Party
Sites. We cannot therefore be responsible or liable for the protection and privacy of any
Personal Information which you provide whilst visiting them.
Third Party Sites are governed by their own privacy policies. Please be careful when
Controlling your Personal Information
accessing Third Party Sites and make sure that you check the applicable privacy policies.
You have the right to ask us not to process your Personal Information for marketing
We will usually inform you (before collecting your data) if we intend to use your data for
such purposes, or if we intend to disclose your information to any third party for their own
You can tell us that you do not want to receive information about related goods and
services, either from us or from third parties by ticking the relevant boxes on the forms we
use to collect your Personal Information.
You can ask us to stop sending you marketing communications at any time by contacting
us here firstname.lastname@example.org or 0800 0378 989
We will never sell your Personal Information, and we will only share your Personal
Information as described in this Policy.
If we are processing your Personal Information on the basis of your consent, you have the
Access to your Personal Information, deletion, restriction, rectification and transfer
right to withdraw your consent at any time.
You have the right to request details (and a copy of) the Personal Information we hold
about you and to ask us to delete, restrict, correct (rectify) or transfer (port) your Personal
Information. Our response will depend on which legal grounds we are using to process the
data in question, and the circumstances of the particular processing. You can find out
more about your rights by viewing guidance from the Information Commissioner’s Office
You can exercise your rights by sending us a written request to our contact form here, by
emailing us at email@example.com or by using any of the other methods set out
in our “contact us” section below.
With each request please include identification information (such as a copy of your
Complaints to the ICO
passport or driving licence and a recent utility bill). If you have particular information in
mind, please be as specific as you can so that we can respond to you as quickly as
If you are unhappy with us, our service, or with the way that we treat your Personal
Information please contact us and we will work with you to resolve your issue.
You also have the right to contact the UK data protection authority, the Information
Commissioner’s Office (ICO). You can contact the ICO through its website:
https://ico.org.uk/global/contact-us/. You can also call the ICO helpline from the UK on 0303
123 1113, or +44 1625 545 745 if calling from outside of the UK.
and, where appropriate, notified to you by email.
If you have any questions on this Policy, or would like to exercise your rights, you can contact
our Data Protection Officer, Clare Foster in the following ways: