Terms of use and privacy policy

Last updated: December 2018

Terms of use introduction

Starkey.com and StarkeyPro.com (each referred to herein as the "Website") are owned and operated by Starkey Laboratories, Inc. d/b/a Starkey Hearing Technologies ("Starkey"). The following terms and conditions (these "Terms of Use"), govern your access to and use of this Website, including any content, functionality and services offered on or through the Website. Your use of this Website is conditioned upon your acceptance of these Terms of Use. If you do not agree to these terms and conditions, you are not authorized to access or use this Website. We may revise and update these Terms of Use from time to time in our sole discretion. All changes are effective immediately when we post them. Your continued use of the Website following the posting of revised Terms of Use means that you accept and agree to the changes. You are expected to check this page from time to time so you are aware of any changes, as they are binding on you.

Starkey grants you permission to access and use this Website for your personal, non-commercial purposes only. You must not reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store or transmit any of the material on our Website, except as follows:

  • Your computer may temporarily store copies of such materials in RAM incidental to your accessing and viewing those materials.
  • You may store files that are automatically cached by your Web browser for display enhancement purposes.
  • You may print or download one copy of a reasonable number of pages of the Website for your own personal, non-commercial use and not for further reproduction, publication or distribution.
  • If we provide desktop, mobile or other applications for download, you may download a single copy to your computer or mobile device solely for your own personal, non-commercial use, provided you agree to be bound by our end user license agreement for such applications.
  • If we provide social media features with certain content, you may take such actions as are enabled by such features.

You agree that you will not:

  • Use the Website in any way that violates any applicable federal, state, local or international law.
  • Use the Website to engage in any other conduct that restricts or inhibits anyone's use or enjoyment of the Website, or which, as determined by us, may harm Starkey or users of the Website or expose them to liability.
  • Use the Website in any manner that could disable, overburden, damage, or impair the site or interfere with any other party's use of the Website.
  • Use any robot, spider or other automatic device, process or means to access the Website for any purpose, including monitoring or copying any of the material on the Website.
  • Use any manual process to monitor or copy any of the material on the Website or for any other unauthorized purpose without our prior written consent.
  • Use any device, software or routine that interferes with the proper working of the Website.
  • Introduce any viruses, trojan horses, worms, logic bombs or other material which is malicious or technologically harmful.
  • Attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of the Website, the server on which the Website is stored, or any server, computer or database connected to the Website.
  • Attack the Website via a denial-of-service attack or a distributed denial-of-service attack.
  • Otherwise attempt to interfere with the proper working of the Website.

This Website and all of its contents, features and functionality (including but not limited to the information, software, text, displays, images, video and audio, and the design, selection and arrangement thereof) are the property of Starkey and its licensors and other suppliers of such material and are protected by U.S. and international copyright, trademark and other intellectual property rights laws.

The Starkey name and all related names, logos, product and service names, designs and slogans are trademarks of Starkey or its affiliates or licensors. You must not use such marks without the prior written permission of Starkey. All other names, logos, product and service names, designs and slogans on this Website are the trademarks of their respective owners.

The information presented on this Website is not intended to be medical advice and should not be relied upon as such. If you suspect a hearing problem, Starkey Hearing Technologies strongly urges you to consult with a qualified physician or hearing professional.

You understand that we cannot and do not guarantee or warrant that files available for downloading from the Internet or the Website will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our site for any reconstruction of any lost data. WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

YOUR USE OF THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER STARKEY NOR ANY PERSON ASSOCIATED WITH STARKEY MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY OR AVAILABILITY OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, NEITHER STARKEY NOR ANYONE ASSOCIATED WITH STARKEY REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

STARKEY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT AND FITNESS FOR PARTICULAR PURPOSE.

THE FOREGOING DOES NOT AFFECT ANY WARRANTIES WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

IN NO EVENT WILL STARKEY, ITS AFFILIATES OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, ANY WEBSITES LINKED TO IT, ANY CONTENT ON THE WEBSITE OR SUCH OTHER WEBSITES OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR SUCH OTHER WEBSITES, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT OR OTHERWISE, EVEN IF FORESEEABLE.

THE FOREGOING DOES NOT AFFECT ANY LIABILITY WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

You agree to defend, indemnify and hold harmless Starkey, its affiliates, licensors and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses or fees (including reasonable attorneys' fees) arising out of or relating to your violation of these Terms of Use or your use of the Website, including, but not limited to, any use of the Website's content, services and products other than as expressly authorized in these Terms of Use or your use of any information obtained from the Website.

All matters relating to the Website and these Terms of Use and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the State of Minnesota without giving effect to any choice or conflict of law provision or rule (whether of the State of Minnesota or any other jurisdiction). Any legal suit, action or proceeding arising out of, or related to, these Terms of Use or the Website shall be instituted exclusively in courts situated in the State of Minnesota, and you consent to the jurisdiction of such courts.

MODERN SLAVERY STATEMENT FOR STARKEY LABORATORIES, LTD. (UK)
FINANCIAL YEAR ENDING DECEMBER 31, 2019

INTRODUCTION
Starkey Laboratories, Ltd. (UK)(“Starkey”) is committed to improving its practices to ensure slavery and human trafficking are not taking place in any part of the business or its supply chain and this statement sets out the steps it has taken during the financial year. Starkey expects the same commitment from its suppliers, contractors and business partners.

ORGANISATIONAL STRUCTURE
Starkey Laboratories, Inc. d/b/a Starkey Hearing Technologies is a privately held, global hearing technology company headquartered in Eden Prairie, Minnesota. Founded by Bill Austin in 1967, Starkey is known for its innovative design, development and distribution of comprehensive digital hearing systems. Led today by President Brandon Sawalich, Starkey is the only American-owned and operated provider of hearing technologies. The company has more than 6,000 employees, operates 25+ facilities and does business in more than 100 markets worldwide.

OUR SUPPLY CHAINS
Starkey purchase goods and services from a range of providers, the four largest budget spends are hearing aid components and accessories, IT and marketing services.

OUR APPROACH TO SLAVERY AND HUMAN TRAFFICKING
Starkey is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of our business. Starkey acts ethically and with integrity in all its business relationships. Starkey promotes and implements effective systems to ensure slavery and human trafficking is not taking place anywhere in the business or its supply chains.

Details of our Global Compliance Program can be found by emailing compliance@starkey.com.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of Starkey’s initiative to identify and mitigate risk, we:

  • Will not support or deal with any business knowingly involved in slavery or human trafficking;
  • Expect all points in the supply chain to adopt suitable anti-slavery and human trafficking policies and processes;
  • Have in place systems to protect whistle blowers and encourage reporting of concerns;
  • Monitor potential risk areas in our supply chains; and
  • Require all employee to acknowledge and affirm Starkey’s Global Compliance Program.

SUPPLIER ADHERENCE TO GROUP VALUES
Starkey has zero tolerance to slavery and human trafficking and we expect all suppliers to have in place their own modern slavery statement if they are required to do so. Starkey has a dedicated Compliance Officer who can be contacted at compliance@starkey.com.

TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, Starkey:

  • publishes our Modern Slavery statement on Starkey’s internet and shares with suppliers upon request to promote which includes our commitment to the legislation; and
  • has training, ethics, disciplinary and whistleblowing policies and procedures in place for staff which Starkey believe are sufficient to allow and encourage staff to raise any concerns and for Starkey to take appropriate corrective action if necessary.

FURTHER STEPS
In future, we will use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Due diligence. The number and type of issues identified in due diligence of suppliers and sub-contractors.
  • Whistleblowing. The number of reported breaches in the past year.
  • Training. The number or percentage of staff trained.
  • Remedial action. The instances of remedial action being needed.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes Starkey’s slavery and human trafficking statement for the financial year ending December 31, 2019.

Roger Lewin
Managing Director, Starkey UK
Date: 19th August 2019

No waiver by Starkey of any term or condition set forth in these Terms of Use shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition, and any failure of Starkey to assert a right or provision under these Terms of Use shall not constitute a waiver of such right or provision.

If any provision of these Terms of Use is held by a court or other tribunal of competent jurisdiction to be invalid, illegal or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Terms of Use will continue in full force and effect.

STARKEY PRIVACY POLICY

EFFECTIVE JANUARY 1, 2020

Last Updated: April 2022 – The changes include providing updates to contact information for Starkey, updated descriptions of certain health and wellness features available on certain Starkey products or services, and providing additional details about information collected from participants in Starkey’s clinical studies.

INTRODUCTION
At Starkey, we value your business and respect your privacy. We are committed to protecting your privacy rights in accordance with the privacy and data protection laws that may apply to you, including the CCPA, and the General Data Protection Regulation (GDPR).

This privacy policy describes your privacy rights related to information you share with Starkey, and how you contact us to exercise those rights. In addition, this privacy policy describes how Starkey collects, uses, and shares information that can identify you (Personal Information) related to the use of Starkey’s Products and Services. Products and Services means our websites, e-store, mobile apps, software applications, hearing devices, and hearing care providers. Starkey will collect, process, and share your Personal Information in accordance with this privacy policy.

In this privacy policy, “Starkey”, “we”, “us” and “our” refers to the Starkey entity that you are interacting with, or that is providing you with our Products and Services related to which you are sharing your Personal Information.

With respect to your rights under applicable privacy laws, the data controller of your Personal Information is Starkey Laboratories, Inc.

You can contact Starkey’s Data Protection Officer at:

Starkey Laboratories, Inc.
Attn: Data Protection Officer
6700 Washington Avenue S., Eden Prairie, MN 55344, USA
+1-800-627-5762
Data_Privacy@starkey.com

Starkey collects the following information, including Personal Information, when you interact with us and use our Products and Services:

Purchase and Warranty Information: means information, including Personal Information, that you may provide to us when you purchase Starkey Products and Services, including related to your rights under a product warranty. Purchase and Warranty Information may include your financial information; contact information, such as your name, delivery and billing address, phone number and email address; product identification information, like hearing aid serial numbers; and health information like your audiogram or an impression (mould) of your ear.

Website Information: means information that you enter directly or otherwise provide or disclose, including Personal Information, when you use or access any of our websites. Website Information includes information about the technology that you used to access our website, including the IP address, Internet service provider, browsers, apps and devices. Website Information also includes details of your activities while on our websites, like how long you visited a webpage, the content that you clicked on or accessed and information about other sites that you visited before or after our website. Website Information includes anything that you submitted via the website like a webform to “contact us”, the content of any “chat” communications you have with us through our websites or while applying for a job through an employment-related function of our websites.

Hearing Device and App Usage Information: means information, including Personal Information, that you provide or that is generated during your use of our hearing aid devices, our apps or both. Hearing Device and App Usage Information includes:

  • Information that you enter for hearing device and app functionality, including your name, address, date of birth, gender, height, weight and audiogram, as well as information relating to the programming of your hearing aid, any third-party contacts you have identified and any other data that you submit in connection with your use of the hearing device and app.
  • Information about app usage and app features, like when you activate and use a particular feature and the extent or duration of use. This helps Starkey to provide optimal functionality and overall user experience. Starkey also logs certain technical information, including information related to Internet protocol and device event information such as crashes, system activity, hardware settings and the date and time of your request.
  • Use time and classification of the environment in which the hearing aids are being used. This is necessary for Starkey to provide certain features and functionality of our Products and Services. You can disable the collection of this data, but doing so may limit the functionality of our Products and Services.
  • Information related to physical activity like the number of steps a user takes or if a user falls down. Collection and tracking of such activity information may require you to first enable and properly set up certain features in our Products and Services.
  • If you have your geolocation function (also known as “location services” or “GPS tracking” or other terms) activated and working on your mobile device, Starkey may collect location information, if you are using one of our apps. You can stop the collection of this information by disabling your geolocation function on your mobile device.

Health and Patient Information: means information collected from you when you request an appointment, including your name and contact information, like telephone number or email address, as well as information about your hearing care needs, including health information, and your preferences for how we contact you. In addition to this information, if you participate in a clinical study with Starkey, we may need to collect additional information, including your social security number.

Communications Information: means information that you provide while communicating with Starkey, in any way, for any reason, which may include Personal Information. Communications Information includes the information that you provide over the phone, which may include your name, phone number, address, email address, device serial number as well as the content of any phone calls you have with us.

Your Information Shared by a Third Party Who You Authorised: means your Personal Information that is provided to us by a third party, because you authorised the third party to share it. For example, you may authorise your hearing care provider to share your Personal Information with Starkey, which may include your contact information, financial information and health information. We also collect Personal Information about you through websites that we manage for third parties, like a third-party hearing care provider.

Anonymous Information: means information that does not allow you to be identified or otherwise make you identifiable. For example, we collect generic information about the type of mobile device and mobile operating system that you use to access and interact with our Products and Services, as well as generic information about your hearing aid devices, like the make and model, and the firmware used by the hearing aid devices. In some cases, Starkey may aggregate and de-identify data to remove all information that could be used to specifically identify you, thereby rendering it anonymous. Anonymous Information is not considered Personal Information in this privacy policy, or by applicable law.

We collect your Personal Information because it is necessary to provide the services, features or functionality of our Products and Services that you have elected to use. Starkey also collects your Personal Information for legitimate business purposes, to protect Starkey and its customers, and for legal reasons. We only collect and process your Personal Information based on our legitimate interests when we have determined that our legitimate interests are not outweighed by your privacy and data protection rights.

Depending on your interaction with Starkey, and your use of our Products and Services, Starkey may collect your Personal Information for the following reasons:

  • providing you with access to and use of our Products and Services, either independently or with the assistance of your healthcare provider;
  • operating, maintaining and improving our Products and Services;
  • entering, performing and terminating a contract with you;
  • scheduling and communicating with you about your appointment;
  • assembling and processing your job application;
  • sending you important administrative notifications or confirmations, as well as technical notices about things like updates and security alerts;
  • responding to your comments and questions and providing you with customer support;
  • preventing abuse of our Products and Services, and investigating or prosecuting any potential threat or misuse;
  • to protect, investigate and deter against fraudulent, unauthorised or illegal activity;
  • protecting the rights and property of Starkey and its customers, including in the event of legal claims
  • tracking and analysing our advertising and promotional efforts;
  • sending you marketing or promotional communications that may be based on your behaviour and Personal Information, and that may include social notifications, surveys or other newsletters depending on your settings; and
  • fulfilling any purpose for which you have given us your consent.

Some features of our websites allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via email. The email response or confirmation may include your Personal Information, including your name and contact information. We cannot guarantee that our emails to you will be secure from unauthorised interception.

When required by law, we will obtain your consent before sending you certain marketing communications. You can withdraw consent at any time by contacting our Data Protection Officer. See the Who We Are section of this privacy policy for details. You may also opt-out of receiving future marketing information, like marketing emails, at any time, by using the instructions provided in marketing communications.

In the case of information relating to your hearing and your location, we will first obtain your consent before using such information. You may withdraw your consent at any time by either disabling location tracking through your device’s settings, or where possible, using the functions in our Products and Services to switch off geolocation information tracking, or by terminating Starkey’s access to your account (for example, by deleting a mobile app).

You Give Starkey Information Directly
We collect the information that you give us when purchasing and using our Products and Services. For example, when you download a Starkey mobile app, in order to create a user account, pair the app with your hearing aids, and activate and utilise features of the app, it may be necessary for you to provide information to Starkey. The information you may give us may include Personal Information, like your name, address, date of birth, gender, height, weight and audiogram as well as information relating to the programming of your hearing aid, third-party contacts and any other data that you submit in connection with your use of our Products and Services.

You Give Starkey Information Indirectly (Collected Using Technology like Cookies)
We use tracking technology like cookies to collect information about how you use our Products and Services, and to provide you with essential services, functionality and personalisation of our Products and Services. The purpose of this section is to provide you with the necessary information regarding our use of cookies, and the storage of such cookies on your device when you access our websites, to enable you to choose whether to allow cookies to be placed on your device.

If you are located in the European Economic Area, please review our Cookie Policy for further information on how we use cookies and other related types of tracking technology.

Cookies are small text files that can be stored on your computer by a website that you visit. Cookies are widely used to make websites work, or work more efficiently, as well as to provide web services and functionalities for users.

Cookies may be either “persistent” or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser until its set expiry date (unless deleted by the user before the expiry date). A session cookie, or temporary cookie, will expire at the end of the user session, when the web browser is closed.

Web beacons are small files (also called “pixels”, “image tags” or “script tags”) that may be loaded on our websites, applications and tools, which may work in concert with cookies to identify our users and provide anonymised data about their activity.

Privacy laws in some jurisdictions require that we obtain your consent before cookies may be stored or accessed on your equipment, except that we do not need consent for cookies that are strictly necessary to provide our Products and Services.

  • Essential Cookies are necessary to provide you with core website functionality, personalisation and browsing history. For example, a preference cookie is required to maintain a record of your consent or non-consent preferences so that we may respect them for future visits. These can only be disabled by changing your browser preferences. Starkey does not share this information with third parties.
  • Functionality Cookies help us to customise our website content based on your preferences, to provide you with a more personal experience on our websites. The information that these cookies collect may be anonymised and does not include browsing activity on third-party websites.
  • Analytics Cookies are used to collect information about traffic to our websites and user activity on our websites. The information is aggregated and anonymous and does not identify any individual visitor. It includes the number of visitors to our websites, the pages visited and other similar information. We use this information to help operate, maintain and improve our websites.
  • Social Media Cookies. We allow users to share links to our websites on social media sites like Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work.
  • Disabling Cookies. Most web browsers allow the control of cookies through the browser settings. By adjusting your web browser, you may avoid receiving cookies. However, this might result in the website not functioning optimally. The method used to block cookies will depend on the web browser used. Consult the “Help” or corresponding menu in your web browser for instructions.

To find out more about cookies, including how to see which cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics visit tools.google.com/dlpage/gaoptout. We do not currently respond to Do Not Track signals sent by the browser.

You Authorise a Third Party to Give Starkey Your Information
You may authorise a third party, like your hearing care provider, to give Starkey information about you. For example, you may authorise your hearing care provider to provide your Personal Information to Starkey, which may include your contact information, financial information and health information. We also collect Personal Information about you through websites that we manage for third parties, like hearing care providers.

Third Parties Designated by You. We may share your Personal Information with third parties where you have provided your consent for us to do so. One example would be: if you identify third-party contacts in the fall alert feature of our Products and Services, and those contacts have agreed to receive notifications, they could receive certain Personal Information about you.

External Processing. We may share your Personal Information with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure, email delivery and other similar services. We require that our third-party service providers use your Personal Information only to provide the services that we’ve requested based on our instructions and in compliance with our privacy policies and any other required confidentiality and security measures.

For Legal Reasons. We may share your Personal Information as we believe necessary or appropriate (a) to comply with applicable laws; (b) on reasonable request by a law enforcement or regulatory authority, body or agency; (c) in the conduct or defence of legal claims; (d) when obtaining professional advice (including legal advice) in relation to audits and our business and consider this in our legitimate interests in managing our business; (e) to enforce our agreements; and (f) to protect our rights, privacy, safety or property, or that of you or others. We will not delete Personal Information if it is relevant to an investigation or a dispute; relevant information will be stored until such issues are fully resolved.

New Owner of Our Business. We may share your Personal Information with a third party (new owner) in the case of a merger, acquisition, dissolution or sale of one or more of our business entities. In that case, we would also be sharing your Personal Information with that third-party’s advisors related to the transaction.

Affiliates. We may share your Personal Information with other companies owned by Starkey (Affiliates). Our Affiliates are bound to protect Personal Information in accordance with applicable privacy and data protection laws.

Starkey works to secure the information that we collect, including by employing administrative and technical security measures to protect information from unauthorised access, loss, misuse, corruption, alteration and destruction. Starkey uses commercially accepted means to secure your Personal Information, including encryption, but we cannot guarantee its absolute security.

Please contact our Data Protection Officer immediately if you have reason to believe that your Personal Information or any of our Products and Services are not secure or have been accessed without authorisation. If you receive a communication that purports to be from Starkey that you believe is suspicious, do not open or respond to it, and please contact our Data Protection Officer.

The US Federal Trade Commission provides more information on how you can protect yourself from identity theft on its website: https://consumer.ftc.gov/articles/how-protect-your-privacy-online.

If you are located in the European Economic Area, you have certain data protection rights under the GDPR. Depending on your interaction with Starkey and your use of our Products and Services, Starkey collects and processes your Personal Information on the following legal bases:

  1. As necessary to enter into, perform or terminate a contract with you, and to provide you with, and facilitate your use of, our Products and Services.
  2. Because you have provided consent.
  3. As necessary to operate our business and pursue our legitimate business interests, where our interests are not overridden by your privacy and data protection rights.
  4. To comply with the law.

Starkey takes reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information.

Opt-out. You can contact us any time to opt out of (a) promotional and marketing communications; (b) any new processing of your Personal Information that we may carry out beyond the original purpose; or (c) the cross-border transfer of your Personal Information. Please note that your use of some features of our Products and Services may be affected upon opt-out.

Object. You can ask us to stop using your Personal Information where we no longer need it to provide our Products and Services or for other legitimate reasons.

Access. You can ask us to confirm if we are processing your Personal Information and you can ask at any time to access the Personal Information that we have collected from you by contacting us directly.

Update. You can ask us to correct your Personal Information if it is wrong.

Move. You can request to move your Personal Information to other companies. You may ask that we provide your Personal Information in an easily readable format.

Erase and forget. In certain situations, you can ask us to stop using your Personal Information or delete your information, including where we no longer need it to provide our services to you.

If you wish to exercise any of these rights, please contact us at:

Starkey Laboratories, Inc.
Attn: Data Protection Officer
6700 Washington Avenue S.,
Eden Prairie, MN 55344, USA
+1-800-627-5762
Data_Privacy@starkey.com

In your request, please clearly state (a) what Personal Information is concerned, and (b) which of the above rights you would like to enforce. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request, usually within a month, and we will tell you if we need additional time.

Please note that, under applicable law, these rights may be qualified, for example, where your information is being used in legal proceedings. We may need to retain certain information for record-keeping purposes or to complete any transactions that you began before requesting the change or deletion, unless a longer retention period is required or permitted by law (for example, for regulatory purposes).

Starkey’s EU Representative for the purposes of Article 27 of the GDPR is Starkey Laboratories GmbH, located at Weg beim Jäger 218, 22335 Hamburg, Germany, with telephone number +49 40 4294730.

When you receive promotional emails from us, you can also unsubscribe or opt out by clicking the link provided in the emails. You cannot opt out of receiving administrative communications (e.g. communications related to your use of our Products and Services, or related to your hearing care that we are providing).

Where allowed by applicable law, Starkey’s Products and Services may be delivered using servers and other technical resources in various countries, including the United States. Therefore, your Personal Information may be transferred and processed outside of the country you are located in, including outside of the European Economic Area (EEA). If we transfer Personal Information outside the country or region you are located in, we will take steps to protect and safeguard your Personal Information, in general, by making the transfer subject to the Standard Contractual Clauses approved by the European Commission, to ensure that your data is treated securely and in accordance with this privacy policy. For further details, please contact our Data Protection Officer.

If you have a contract with Starkey, we will keep your Personal Information for the term of the contractual relationship, and for Starkey’s use as described in this privacy policy, as allowed by applicable law. Starkey will retain your information for such further period as necessary to defend ourselves from legal claims.

If you make a request for Starkey to delete your Personal Information, Starkey will keep a record of your request, to honour your request in the future. Starkey will then delete the Personal Information that you asked to be deleted, subject to any legal retention requirement, or legal exceptions to deletion requests.

The California Consumer Privacy Act (CCPA) requires us to provide California residents with certain information about how we handle their personal information.

CCPA Categories of Personal Information
Starkey collects the following categories of personal information identified under CCPA:

  1. Identifiers
  2. Customer Records
  3. Biometric
  4. Internet or Network Activity
  5. Geolocation
  6. Sensory
  7. Professional or Employment
  8. Inferences

As described in further detail in this privacy policy, Starkey collects this information when you visit our websites or purchase and use our Products and Services. We collect your Personal Information because it is necessary to provide, operate, maintain and support our Products and Services, as well as to administer and promote our business. Please refer to the other sections of our privacy policy for further details, including the sections Why Starkey Collects Your Personal Information and How Starkey Collects Your Personal Information.

Exercising your Rights
California residents have the right to make the following requests, up to twice every 12 months:

  1. The right to request the specific pieces of personal information that Starkey has collected about You.
  2. The right to request that Starkey disclose what personal information we collect, use, disclose or sell.
  3. The right to request that Starkey delete personal information that Starkey has collected about You (subject to certain exceptions).
  4. The right to opt out of the sale of Your Personal Information.

You may exercise your rights to access and delete data by:

  • Emailing us at Data_Privacy@starkey.com; or
  • Calling our Data Protection Officer at +1-800-627-5762

This section does not address or apply to our handling of protected health information that is subject to HIPAA or the California Medical Information Act, including any data that we collect through your hearing devices or the Thrive app, or to any other personal information subject to an exemption under CCPA Section 1798.145(c) – (f).

Starkey does not sell your information for money. We do disclose your information to certain third parties that provide valuable services to us, such as analytics and advertising services, which we do not believe is considered a “sale” under the CCPA. Categories of third parties with whom we have shared personal information in the last 12 months include third-party integrations for advertising and website analytics.

If you’d like to be included in a Do Not Sell My Personal Information Register that we maintain, please contact our Data Protection Officer at Data_Privacy@starkey.com. After 12 months, we may request that you update your preference.

California Civil Code § 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us and indicate whether you are a California resident.

California law requires us to let you know how we respond to web browser “Do Not Track” signals. Our websites are not currently able to support “Do Not Track” codes. Starkey does not currently respond to or take any action regarding “Do Not Track” requests.

Non-Discrimination
Starkey will not penalise you, or discriminate against you, for exercising your rights under CCPA. In accordance with CCPA, should you elect to exercise your rights under CCPA, Starkey will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including by use of discounts, benefits or penalties; (iii) provide you a different level or quality of goods or services; or (iv) threaten or imply that you may receive a different level of goods or services.

“Do Not Track” is a preference you can set in your web browser to inform websites you visit that you do not wish to be tracked. The “Do Not Track” setting must be supported by the website you are visiting to be effective. Starkey is not currently able to support “Do Not Track” browser codes. Therefore, Starkey does not currently respond to or take any action regarding “Do Not Track” requests.

Starkey’s Products and Services are not directed to children under 13 years old. Consistent with United States law, specifically the Children's Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect Personal Information from anyone under the age of 13 in the United States without the consent of the individual’s parent or legal guardian. In the European Economic Area (EEA), we do not knowingly collect Personal Information from anyone under the age of 16, without the consent of the individual’s parent or legal guardian. Please contact our Data Protection Officer if you believe that we have been provided Personal Information of a child without the appropriate consent of the parent or legal guardian.

We may change our privacy practices and revise this privacy policy periodically. If we make significant changes (information that we collect, how we use it or why), we will highlight those changes at the beginning of this privacy policy. To the maximum extent permitted by law, any changes will become effective when we post the updated privacy policy on our websites, and you will be accepting the changes by your use of our Products and Services. We recommend that you review our privacy policy frequently as you use our Products and Services, to keep up to date on Starkey’s privacy practices.

Please be aware that any third-party websites, software applications or other products or services linked or accessible via Starkey’s websites, products or services are governed by the third-party’s terms of use and privacy policies. You should carefully review a third-party’s terms or use and privacy policies before using the third-party’s products or services.

Thank you for using our Products and Services, and for reviewing this privacy policy. We welcome your comments or questions. If you have any feedback, we encourage you to contact our Data Protection Officer at any of the following:

Starkey Laboratories, Inc.
Attn: Data Protection Officer
6700 Washington Avenue S.
Eden Prairie, MN 55344, USA
+1-800-627-5762
Data_Privacy@starkey.com