Privacy Policy

1. Who is responsible for your information

Budget Hearing Aids LLC is the controller of personal information collected through this website and the Sonaire Hearing consultation enquiry process. Our address is Hm Revenue And Customs Ruby House 8 Ruby Place Aberdeen, AB10 1ZP. Our email is [email protected] and our telephone number is +44 312 584 801. VAT number: GB 384116400.

This privacy notice is written for people in the United Kingdom and is intended to explain our processing in a clear way under the UK GDPR, the Data Protection Act 2018 and, where storage or access technologies are involved, the Privacy and Electronic Communications Regulations 2003 as amended. Where law or regulatory guidance changes, we may update this notice to reflect the current position.

2. Information we collect

When you complete the consultation questionnaire, we collect the information you choose to provide. This can include your name, email address, telephone number, postcode, age range, whether you currently use hearing aids, the listening situation you find most difficult and your preferred way to take the next step. We also record your consent to the processing described at the point where you submit the form.

Some answers may reveal information about your hearing or use of hearing aids. Information concerning health can be special category personal data under UK data protection law. We therefore ask for explicit consent before you submit hearing-related information through the consultation form. You do not have to provide the information, but without it we may not be able to tailor the consultation request to the circumstances you described.

When you browse the website, limited technical information may also be processed to deliver pages, protect the website and maintain basic security. Depending on your cookie choices, optional analytics or marketing technologies may be used. More detail about storage and access technologies is provided in our Cookie Policy.

3. Why we use your information and our lawful bases

We use enquiry and contact information to respond to your request, understand what you want to discuss, organise an appropriate consultation and communicate with you about the next step. For this voluntary enquiry process, our principal Article 6 lawful basis is consent. Where your answers contain health-related information, we rely on your explicit consent for special category processing under Article 9(2)(a) of the UK GDPR.

We may also process limited information where necessary for our legitimate interests in operating a secure, reliable website, preventing misuse, maintaining records of enquiries and defending or establishing legal claims. When we rely on legitimate interests, we consider whether those interests are necessary and whether they are overridden by your rights and reasonable expectations. We do not use legitimate interests as a substitute for the explicit consent required to use hearing-related special category data for the consultation you requested.

Where the law requires us to keep or disclose information, we may process it to comply with a legal obligation. If a dispute arises, information may also be used where necessary for the establishment, exercise or defence of legal claims. We do not use the consultation questionnaire to make solely automated decisions that produce legal or similarly significant effects for you.

4. How we use consultation information

Your questionnaire answers are intended to provide context for a human consultation. For instance, a response indicating difficulty in busy rooms may help the consultant ask more relevant questions about speech in background noise, while an answer indicating that you already use hearing aids may shift the discussion towards current fit, comfort or whether a fresh assessment is appropriate.

The questionnaire is not a hearing test, diagnosis or clinical assessment. We do not treat a quiz response as proof of hearing loss or suitability for a device. Where a professional assessment is appropriate, hearing-aid suitability should be determined through an appropriate hearing test and discussion with a qualified hearing professional.

5. Sharing personal information

We may share information with service providers that support the operation of the website, communications, secure hosting, enquiry handling or appointment administration, but only where they have a legitimate need to process the information for the services they provide to us. Where a processor acts on our behalf, we expect appropriate contractual, confidentiality and security protections.

If your enquiry needs to be passed to an appropriate hearing-care provider in order to progress the consultation or assessment you requested, we will use the information for that purpose in line with the consent and information presented to you. We do not sell your hearing-related information. We may disclose information if required by law, court order or a competent public authority, or where necessary to protect legal rights.

We do not name third-party hearing providers in this notice unless an arrangement is relevant to the service being delivered. If a separate provider becomes independently responsible for your information, that provider should give you its own privacy information explaining its processing.

6. International transfers

Some technology or support suppliers may process information outside the United Kingdom. If personal information is transferred internationally, we take steps intended to ensure that the transfer is made under a lawful mechanism and with safeguards appropriate to the destination and the nature of the information, such as an adequacy regulation or approved contractual safeguards where required.

The fact that a website resource can be accessed globally does not by itself change our responsibilities as controller. We aim to minimise the personal information involved in technical services and to use suppliers whose handling is compatible with applicable UK data protection requirements.

7. How long we keep information

Consultation enquiry information is kept only for as long as reasonably necessary to respond, manage follow-up and maintain an appropriate record of the enquiry. As a general working period, enquiry records may be retained for up to 24 months after the most recent substantive interaction unless a shorter period is appropriate, you withdraw consent and no other lawful basis requires retention, or a longer period is necessary for a legal claim or statutory obligation.

Consent records and limited administrative records may be retained for a period that allows us to show how and when the relevant privacy choice was made. Security records may be kept for a shorter operational period unless an incident requires further investigation. Cookie and similar technology retention is explained by category in the Cookie Policy.

Retention periods are reviewed in context. We do not keep hearing-related consultation information indefinitely simply because it was once submitted.

8. Your rights

Depending on the circumstances, UK data protection law gives you rights to ask for access to personal information, correction of inaccurate information, erasure, restriction of processing and data portability. You may also have the right to object to processing based on legitimate interests. These rights are not absolute in every situation, and a legal exemption may apply to a particular request.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not make earlier processing unlawful. If you withdraw explicit consent for hearing-related information, we will stop using that information on the consent basis for future consultation activity unless another lawful ground genuinely applies, for instance where limited information must be retained for a legal claim.

To exercise a privacy right, contact Budget Hearing Aids LLC using [email protected], +44 312 584 801 or the postal address set out above. We may need to take reasonable steps to verify that a request relates to you before disclosing or changing personal information.

9. Complaints

If you are concerned about how we use personal information, please contact us first so that we can review the issue. You also have the right to complain to the UK Information Commissioner’s Office if you believe your data protection rights have been infringed. Information about making a complaint and the ICO’s contact routes is available from the ICO.

Raising a privacy concern will not affect your ability to ask general questions about hearing support. We aim to separate privacy complaint handling from any commercial discussion about hearing-care services.

10. Cookies and storage or access technologies

The website uses necessary technologies to support core operation and remember privacy choices. Optional analytics and marketing categories are controlled through the cookie settings interface. Where consent is required under PECR, optional technologies are not intended to be activated on the basis of silence or inactivity.

You can reject optional categories or adjust them through the settings presented on the website. Our Cookie Policy explains purposes, categories, indicative retention periods and how choices can be managed.

11. Security

We use organisational and technical measures intended to protect personal information against accidental loss, unauthorised access, alteration or disclosure. Access should be limited to people and providers who need the information for an authorised purpose. No internet service can promise absolute security, but privacy and security considerations are part of how the enquiry process is designed.

If a personal data breach occurs, we assess it under applicable law and take the steps required by the circumstances, including notification to the regulator or affected individuals where the legal threshold for notification is met.

12. Children

This website is directed at adults seeking hearing-care information and is particularly designed around the needs of older adults in Britain. The consultation questionnaire is not intended to collect information from children. If you are seeking help for a child, use an appropriate paediatric hearing or healthcare service rather than submitting a child’s health information through this form.

13. Changes to this policy

We may revise this Privacy Policy to reflect legal changes, regulatory guidance, changes in technology or changes in the way consultation enquiries are handled. The date at the top of the page shows when this version was last updated. Material changes may also be highlighted through the website where appropriate.

If a change would require a new consent for a new purpose, we will not treat an earlier consent as automatically covering that new purpose where the law requires a fresh choice.