This is the Privacy and Cookies Policy for the Sound Steps AVT Limited’s website www.avtdirect.com. The site is operated by or on behalf of Sound Steps AVT Limited. This Privacy Notice outlines Sound Steps AVT Limited’s approach to data protection to fulfil its obligations under the Data Protection Act 2018 (“GDPR”). Throughout this document, “we”, “us”, “our” and “ours” refer to Sound Steps AVT Limited. We are committed to protecting and respecting your privacy.
Who is covered under this notice?
Any natural person in relation to whose personal data (to the extent processed by or for Sound Steps AVT Limited), the GDPR applies, shall be to the extent of such personal data and such processing be the “Covered Person(s)” or “You”.
The information we collect about you
We will collect and process the following personal data from you:
1.1 Information you give us
This is information about you and / or your child / child in your care or any other child that you give us directly when you interact with us.
- Signing Up for Content Delivered via Email: When you sign up for our services or other content delivered by email, we will ask for your email address. We will also ask for your name and address as well as capturing your IP address.
- Subscribing to our videos and services: When subscribing to any of our services, we need to know the sort of information typically used for credit card / debit card transactions, such as your name, address, telephone number, and credit card number and expiration date. We encrypt all this information using Secure Socket Layers (SSL) technology.
- Other Product Specific Services: We will also ask for additional information that include, telephone numbers, gender, occupation, pertinent records related to pregnancy, your child’s date of birth, gender, birth history, videos of your child and / or a child in your care, and pertinent audiological records for your child and / or child in your care. Recordings of all video calls and telephone calls between you and the therapists for the Premium Add-on service are made and archived. If you do not want to provide the information requested, you will not be able to take advantage of such services.
1.2 Information we collect about you from using our site:
- While on our site, we automatically log certain information about how you are using our site. This information may include the URL that you just came from, your IP address (or a partially anonymised IP address) and the pages you visit while on our site.
- We may place a pixel on pages on our site, or those of our advertisers and partners. This enables us to record in our server logs that a specific user ID has visited a particular page. This data allows us to analyse and determine our audience’s behavioural characteristics, which helps us to optimise our site, advertisement placement, and marketing focus.
1.3 Information we receive from other sources:
We may allow our partners to collect certain information when you visit our site. They may utilise cookies, pixels, beacons, or other technologies to collect and use information about you during your visit to this and other websites in order to provide advertisements they feel you would like.
1.4 Google Analytics
We have integrated the component Google Analytics (with anonymisation function) on this website.
Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website a data subject has come to a website from (so-called referrers), which subpages of the website were accessed or how often and for which period of time a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
As IP anonymization is activated on our website, your IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by a Google server in the USA. On behalf of the operator of the website, Google will use this information to evaluate your use of the website, compile reports on website activity and to provide further services related to website and internet use to us. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.
In addition, this website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data.
You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible.
In addition, you may prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en
In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.
Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/ The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/.
Our website also uses Google Analytics performance reports relating to demographics and interests and reports on Google Display Network impressions. You can disable Google Analytics for display advertising and customize the ads on the Google Display Network by visiting the ad settings at this link: https://adssettings.google.com.
2. How we process your Personal Data
3. The legal bases we rely on
The law on data protection sets out a number of different reasons for which we may collect and process your personal data in certain circumstances, including:
We can collect and process your data with your consent.
- For example, if you have given your consent to providing us with audiology reports and receiving marketing material from us at the point we collected your information.
3.2 Contractual obligations
We need your personal data to comply with our contractual obligations.
- For example, where you have provided us with your email address to receive our services, we will use this information in order to effectively deliver and communicate our services.
- For example, where you have provided us with audiology reports or videos of a child in your care, we will use this information in order to effectively deliver and communicate our services
3.3 Legal compliance
If the law requires us to, we may need to collect and process and report your data.
- For example, we can pass on details of people involved in fraud or other criminal activity to applicable law enforcement.
- For example, we can pass on details to applicable law enforcement of persons involved with inappropriate or illegal video content shared with us.
3.4 Legitimate interest
We may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our services and which does not materially impact your rights, freedom or interests.
- For example, it is in our legitimate interests to ensure that content from our site is presented in the most effective manner for you and your computer and we provide you with the information, products and services that you request from us.
4. How we use your information
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our site safe and secure.
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To keep you informed about products and services similar to the ones you subscribe to.
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
- To allow you to participate in interactive features of our service, when you choose to do so.
- Internal research: Cookies (which are discussed further below) and the other information we automatically track, are used to help us better understand how our audience uses our site as well as for internal research on users’ demographics and interests.
5. Our promotional updates and communications
Where permitted by one of the legal bases above, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products/services and those of our business partners.
You can object to further marketing at any time by: (i) checking and updating your contact details within your account page (ii) selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you; or (iii) sending us an email to email@example.com
6. Where your information is stored
The data that we collect from you is transferred to, and may be stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent Data Protection Law.
We may transfer your personal information outside the EEA:
- In order to store it.
- In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
- Where we are legally required to do so.
- In order to facilitate the operation of our service, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
7. How long we keep your information
We retain personal data for as long as necessary to fulfil any legal obligations we may have as well as for purposes of processing your information (for example, if you continue to subscribe to one of our services, we will need your information to deliver the service to you). We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
8. Cookies and other technologies
Cookies contain bits of data that websites such as ours place on your computer’s hard drive for record keeping purposes. Cookies can make the internet more useful by collecting and storing information about your preferences on a particular site and help websites operate more efficiently. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.
We use our cookies:
- With the aim of optimising our website and improving subscriber experience. Cookies help us estimate our audience size, determine usage patterns and help us better target content and advertisements based on our users’ interests.
- You have the option of not accepting the cookies we set. However, if you reject our cookies, you will not be able to take advantage of most of the features on our site, including subscription-based services.
9. The Cookies We Set
We set cookies when you visit www.avtdirect.com. To help you better understand why we’re setting them, we’ve used the categories and definitions set by the International Chamber of Commerce (“ICC”):
- Strictly Necessary: cookies that enable the services that you have specifically asked or paid for
- Performance: cookies that collect information on how visitors use our site including the pages visited and most frequented as well as the sources of our traffic. They are used to help us improve how the site works
- Functionality: cookies that help us remember the choices you have made so we can provide you with a more personalised experience; and
- Advertising: cookies used to deliver more relevant ads, and to make sure you do not see the same advertisements over and over again.
10. Cookies set by our partners and other data processors
- We have several partners who also set cookies on our pages. These partners include companies that help us better understand how to serve you, companies that serve our house ads, power the tools on our site, and provide you with a consistent online experience across browsers and devices.
11. Cookie Removal and More Information
- You can always modify your browser so as not to accept cookies or to notify you when cookies are sent to it.
- You can remove the Google Analytics and DoubleClick cookies. You should be aware that this will affect your Google cookies on all sites, and not just ours.
- Please refer to www.allaboutcookies.org
12. Information Sharing and Disclosure
- We do not rent, lend or sell individual information to any third party. Furthermore, we will not disclose any information about individual users, except as described below.
- Medical practitioners, clinical physicians, audiologists etc who may be located and practice outside the UK and the EEA
- Current or Prospective Advertisers/Partners: We may share your data with advertisers and business partners to deliver more relevant advertising and content.
- Third Party Service Providers: We may employ the services of third-party providers to aid us in certain aspects of our operations (such as the hosting of videos or the distribution of our email products or conducting a survey for us). Depending on the services performed, some of these providers may be provided with user information. These contractors would be subject to confidentiality agreements which limit their use and disclosure of all information they obtain through their relationship with us to Sound Steps AVT Limited business only, consistent with this policy.
- Legal Requests: We may disclose your personally identifiable information to protect the rights and property of Sound Steps AVT Limited as well as to comply with any applicable law or valid legal process. This includes, but is not limited to:
- Requests by Government Agencies. We will disclose any information we have in our possession to law enforcement or government officials in response to any inquiry or investigation or if in our sole discretion, we believe it is necessary or appropriate in connection with any investigation or activity that is or may be illegal or may expose us or you to legal liability.
- Disclosures we are legally required or entitled to make under any enactment, rule of law or by the order of a court.
We are committed to protecting your personal information. All information that you provide to us is stored on our secure servers. Access to paid-for areas of the site is password-protected for your privacy and security. While we do our best to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are responsible for maintaining the secrecy of your passwords and/or any account information. If you need to change your password, please follow the steps outlined.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
14. Changing Your Information or Closing Your Account
- If you want to change your email address for delivery of your paid-for subscriptions (e.g. Basic, Standard or Premium Add-on Tiers), or you would like to change your password, you should go to the account section of our website
- If you would rather not hear from us by email please click the unsubscribe link, which you will find at the bottom of our email messages. If you are paying for one of our services, please note that clicking on this link will not cancel your paid subscription.
- If you want to close your account – i.e., so that it cannot be logged into please contact us at firstname.lastname@example.org
- Your account is not auto renewed each month. You cannot cancel a subscription you have paid for.
15. Users Aged 21 or Under
Protecting the safety of children when they use the internet is important to us.
The site is intended for use only by persons who are at least 21 years of age. By using this site, you confirm to us that you meet this requirement. If you are aged 21 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to our website. Users without this consent are not allowed to provide us with personal information.
16. Changes to this Privacy and Cookie Statement
We may amend this Privacy and Cookie Statement from time to time. If we make any substantive changes to this policy, we’ll announce it on our site and notify you by email.
17. Your rights
- You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us
- to request the rectification or erasure of your personal data held by us
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example)
- to object to the further processing of your personal data, including the right to object to marketing
- to request that your provided personal data be moved to a third party.
- Your right to withdraw consent: Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at email@example.com You can also change your marketing preferences at any time.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your data, as well as deal with any complaints that you have about our processing of your personal data.