Privacy notice

Website opening updates

For privacy requests, contact privacy@hearwellhealth.ie, or write to HearWell Health Limited, C/O Tgs Gbw, Westmoreland House, Westmoreland Park, Ranelagh, Dublin 6. Company number 818111.

We require your email and town or county to send relevant clinic-opening and first-appointment updates. We rely on your affirmative consent, and record the wording and time of that consent. Without those required details and agreement, we cannot add you to opening updates. This does not subscribe you to ongoing offers, SMS or postal marketing.

You may separately choose to provide an age group for clinic planning. Providing it indicates agreement to that optional use; leave it blank if you prefer. We do not request a birth year, clinical history or patient health consent on this form. Age groups are not used for automated clinical decisions.

Opening-update sign-ups are kept no longer than twelve months after our actual first clinic opening, with earlier removal if you withdraw or the purpose ends. If opening is delayed or cancelled, retention will be reviewed. This is separate from clinical-record retention below.

Withdrawal and your rights

To stop opening updates, email privacy@hearwellhealth.ie from your subscribed address with “Unsubscribe”. This is a request handled by our team, not an instant automated removal. You can also request access, correction, deletion, restriction or portability where applicable. Withdrawing optional consent does not affect your care. You can complain to the Irish Data Protection Commission.

Website service providers

Lovable Cloud provides website hosting and private sign-up storage. Access is restricted; the sign-up list is not publicly readable. A mailing service has not yet been selected. The website provider arrangements, storage region and any international transfers must be confirmed before launch; the patient-care EEA statement below should not be assumed to establish the website’s arrangements.

Read our cookie information for browsing technologies. Do not send health information through the opening-updates form.

Patient privacy notice — solicitor-supplied Part A

The following notice concerns clinical care. References to Part B concern the separate patient consent form, not the website opening-updates checkbox.

This privacy notice gives you information about how HearWell Health Limited collects and uses your personal data. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

A1. Who is responsible for your data

HearWell Health Limited having its registered office at C/O Tgs Gbw, Westmoreland House, Westmoreland Park, Ranelagh, Dublin 6, is the data controller and responsible for your personal data. You can contact us at this address by post or by email at privacy@hearwellhealth.ie.

A2. The data we collect about you

Depending on your care, we may collect, use, store and transfer different kinds of personal about you as follows:

Identity data – includes your name, date of birth and gender.

Contact data – includes your address, telephone number and email address.

Financial data – includes your payment information, PRSI / Treatment Benefit details and any information required by the Department of Social Protection to process your Treatment Benefit claim.

Health data (special category data) – includes details of your hearing assessments and audiometry, hEARsphere ten-domain assessment and Index score, relevant medical history, screening results (for example tinnitus, balance or cognition), device fitting and adjustment records and notes made by your audiologist.

Marketing and communications data – includes your preferences in receiving marketing from us and your communication preferences.

A3. Why your health information is “special category” data

Information about your health is classified as special category personal data under Article 9 of the General Data Protection Regulation (GDPR). This type of data is afforded enhanced legal protection and we treat it with the utmost care and keep it secure and confidential at all times.

We rely on your explicit consent to the processing of this data, which is obtained in accordance with Part B.

A4. Why we process your personal data and the legal basis for processing your personal data

We will only process your personal data for the purpose for which we collected it which includes the following:

To provide your clinical hearing care.

To manage your relationship with us.

To administer your Programme and collect payment.

To process your Treatment Benefit claim.

To verify your identity and prevent fraud.

To meet legal, regulatory and professional obligations.

For optional purposes (including marketing, anonymised research, and sharing with your GP).

Legal basis

We are required to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you. We may use your personal data where it is necessary to perform our Agreement with you.

Legitimate interests. We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

Legal obligation. We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent. We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example under Part B.

A5. Who we share your data with

Our clinical and administrative staff will have access to your data which is relevant to their function.

Data is shared with the following third parties:

HearLink - our clinical practice-management and records system.

Stripe - our payment and subscription-billing provider.

Xero - our accounting system.

Device manufacturers (for example Widex / Signia, via WSA) - only as needed to repair, programme or replace your devices.

The Department of Social Protection - to process your Treatment Benefit claim.

We do not share your data with bodies outside of the European Economic Area (EEA).

A6. Data storage and security

Your personal data is stored within the EEA. If it becomes necessary to transfer your data outside the EEA, we will only do so where appropriate safeguards are in place as required by data protection legislation.

We will ensure that your personal data is processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisational measures.

A7. Data retention

We only keep your personal data for as long as we need it. In accordance with HSE guidance, adult clinical records are generally retained for 8 years from the date of your last clinical contact. We may retain records for a longer period where required.

We may anonymise your personal data (so that it can no longer be associated with you) for research purposes, in which case we may use this information without further notice to you.

A8. Automated decision-making and profiling

We do not use any personal data for the purpose of automated decision-making or profiling.

A9. Your rights relating to personal data

You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:

Right to access the data. You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.

Right to rectification. You have the right to request that any inaccurate data that is held about you is corrected.

Right to erasure. You have the right to request us to delete personal data that we hold about you.

Right to restriction of processing or to object to processing. You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.

Right to data portability. You have the right to request us to provide you or a third party with a copy of your personal data in a structured, commonly used machine readable format.

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

A10. Complaints

If you think your data rights have been breached, you can raise a complaint with the Data Protection Commission. You can lodge a complaint on www.dataprotection.ie or by email info@dataprotection.ie.