Privacy Policy and Online Shop Policies

Privacy Policy

Sonova Audiological Care New Zealand Ltd, trading as Triton Hearing (“Triton”) recognises the importance of client privacy and supports best practice procedures in the way your personal information is handled by us. By providing your personal information you agree and consent to the collection, use, disclosure, storage and holding of your personal information in accordance with this privacy policy. In this policy, Triton is also referred to with the words “we”, “us” and “our”.

At Triton we are committed to our client’s privacy and security. All our client information is held and disposed of securely.  We will never pass on your personal details to a third party except the necessary information required by providers of products or services you have purchased. This commitment is backed up by the New Zealand Privacy Act 2020 and the requirements of The Health Information Privacy Code, which provides strict parameters in how your personal information can be used.  You have the right to access and update your personal information. To do so please contact us by phone 0800 45 45 43 or email info@tritonhearing.co.nz. 

Email & Phone

If you have provided Triton Hearing with your email address or phone number, you consent to us contacting you with relevant offers or information.  You are able to opt out of receiving marketing emails by selecting unsubscribe on the email you have received or with a Triton Hearing representative over the phone.  This will opt you out of emails and calls with offers, but not any clinic correspondence such as appointment confirmations or any other communications allowed under law.

Websites

Sonova Audiological Care New Zealand Ltd (trading as Triton Hearing) operates a number of websites and Apps including: www.tritonhearing.co.nz; www.tritonlyric.co.nz, www.tritonstories.co.nz, www.greatbighearingcheck.co.nz, www.tritonhearingbatteries.com, www.shop.tritonheraing.co.nz, www.testmyhearing.co.nz and the Triton Hearing Kiosk self screen test and other promotional websites from time to time. We respect the privacy of our website users and are committed to protecting your security and privacy.

Terms of use

This privacy policy must be read in conjunction with our terms and conditions.

Collection of your information

We collect information about you through our websites, apps, and in person in an effort to improve your experience, as well as to communicate with you about our products, services, and promotions.

We may collect personal information from you (including, without limitation, your name, email address, phone number, and postal address) when you access our websites,  register with our websites, complete a hearing test online or via our hearing screening app, place an online order, save your information with us online, contact us with a question or concern, or participate in a promotion.

We receive and collect the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our site and your time zone; and any search engine or inbound hyperlink used to reach this website. This information is used only for statistical purposes and in regards to how we may enhance the customer experience.  We collect this information automatically using various technologies, including:

• “Cookies”, which are data firls that are place on your device or computer and often include an anonymous unique identifier.  See below for more about cookies.
• “Log files”, which track actions occurring on our websites and which collect data including your IP address, browser type, internet service provider, referring / exit pages, and date / time stamps.
• “Web beacons”, “tags”, and “pixels”, which are electronic files used to record information about how you browse our websites.

 

Storage and security

Security of personal information is important to us, and we take all reasonable precautions to protect your personal information.
 

Use of personal information

Your personal information may be used for purposes relating to the services and products that we supply, including:

• By our clinicians for the diagnosis and ongoing treatment of your hearing loss
• By our clinic administrators to ensure that you are receiving appropriate hearing healthcare appointments
• By our client contact team to book appointments and to ensure that your telephone enquiry can be dealt with appropriately and in a timely manner
• By our management team in the event of a complaint or for statistical analysis purposes
• To process and fulfil your order, including sending emails to confirm your order status and shipment, along with customary business communications
• To verify your identity and to assist you if you have forgotten your username or password
• To communicate with you and to send you information by phone, email, postal mail or other means about our products, services and promotions, where you agree to receive such information
• To help us learn more about your shopping preferences and personalise the website in accordance with your preferences
• To analyse trends and statistics
• To improve or update the website and our products / services
• To protect the security or integrity of our website and our business
• To respond to your enquiries and communicate with you if necessary

You always have the choice not to receive marketing and promotional information. It is our policy to remove any member from our database or mailing list upon the members’ request. Please contact us if you wish to opt out of receiving communications from Sonova Audiological Care New Zealand Ltd.
 

Disclosure of personal information

Your personal information may be disclosed to third parties for purposes relating to the services and products that we supply, including:

• Third party service providers; specifically when your personal information is required to access funding or for the approval of your insurance claim or for ongoing hearing aid payments.  Such organisations include: ACC, Ministry of Health, War Pensions and insurance companies
• To hearing aid manufacturers (your name only) in the event your hearing aid(s) require repair
• With third parties who provide services on our behalf including logistics / delivery services and credit card payments, who are required to take appropriate security measures to protect your data in line with our policies. We permit them to process your data only for specified purposes and in accordance with our instructions. We do not allow them to use your data for their own purposes. 'Pay As You Hear' credit card transactions are processed through 3rd party payment software called Recurly.  Recurly is PCI-DSS Level 1 compliant as a merchant service provider which meets and exceeds all industry-standard payment security practices
• Your personal may be included in systems provided by our parent company.  This means it may be accessible to related companies in Switzerland and other countries in the European Union.  These companies are subject to privacy laws that are comparable to the Privacy Act 2020.   

 

Information collected by us may be shared anonymously for the following reasons:

• Third party software and IT infrastructure organisations for the development of our IT systems and processes
• Government funding bodies for the purposes of statistical analysis
• Universities and registered research organisations for the improvement of hearing healthcare treatment

 

Cookies

Our websites use "cookies," which are small data files that are stored on your computer when you visit a website. Cookies may be used in a variety of ways to enhance or personalize your online browsing and shopping experience. Cookies may be used to personalise your visits to this website, eliminate the need for you to repeatedly enter the same information, enable us to improve the content, reliability and functionality of this website, evaluate the effectiveness of the advertising on this website and track website usage patterns. Accepting a cookie will not give us access to any data on your computer other than the data stored in the cookie. Although you may configure your web browser to not accept cookies, you may experience a loss of functionality as a result.

 

Linking to third-party websites

When you click on links and banners on our site that take you to third party web sites, you will be subject to the third party's privacy policies. While we support the protection of privacy on the Internet, Triton Hearing cannot be responsible for the actions of any third-party web sites.

 

Your rights of access to and correction of information

You have the right to access the personal information that we hold about You and to request correction of that information.  To do so, please email this address info@tritonhearing.co.nz 

 

Changes to our privacy policy

We reserve the right to change this privacy policy from time to time by publishing the revised privacy policy on our websites. We encourage you to check this policy regularly for any modifications or updates. Your continued use of our Services after any changes have been posted on our Website indicates your acceptance of those changes.

If you have any questions regarding our privacy policy or any other matter, please contact us:

0800 45 45 43 or info@tritonhearing.co.nz 

Please visit our webshop privacy notice here.

Purpose
This policy sets out a framework for the use of closed-circuit camera (CCTV) surveillance systems at Triton Hearing.
 
Scope
This policy applies to every person who enters a Triton Hearing facility in which CCTV systems are in operation, including all Triton Hearing employees, customers, suppliers, contractors, and visitors.  Acceptance of the use of CCTV by Triton Hearing and of this policy is a requirement for entry into Triton Hearing’s facilities.
 
Definitions
“CCTV” means closed-circuit television which is a reference to camera surveillance systems that capture images and sound of individuals or information relating to individuals.

Responsibilities
The overall responsibility for the CCTV system will rest with Triton’s Privacy Officer/Compliance Manager, who will:

• Have overall responsibility for overseeing the implementation of this policy,
• Work with Human Resources and authorised personnel for the administration and implementation of this policy,
• Work with the Privacy Officer/Compliance Manager to ensure Triton Hearing complies with the Privacy Act,
• Work with the Network Development Lead and the Operations Manager in deciding operating hours and locations of CCTV,
• Ensure that Triton Hearing staff are trained in respect of CCTV related matters.

 
Policy Statement Objectives
Triton Hearing uses CCTV:

• To increase personal safety of staff, clients and other visitors
• To protect Triton Hearing’s equipment and assets;
• To assist in the investigation of potential staff related incidents;
• To facilitate a learning environment through remote supervision where required;
• To support the Police in a bid to deter and detect crime, assist in identifying, apprehending, and prosecuting offenders;
• To protect members of the public and private property;
• For training and quality purposes.

Recordings captured using the CCTV system will only be used for these purposes.
 
Privacy Act and Privacy Policy
The operation of CCTV means that images and/or sound recordings of identifiable individuals will be collected, held, and disclosed by Triton Hearing. Compliance with the Privacy Act principles is required by all Triton Hearing staff.
Triton Hearing’s Privacy Policy will also apply to the personal information collected through the CCTV system.  A copy of that policy is available on the Triton Hearing website: www.tritonhearing.co.nz.
 
System Overview

1. The system may comprise, but not limited to, a range of fixed position cameras, sound recorders, monitors, and public information signs.
2. Cameras will be in various places within clinics and may be relocated from time to time. CCTV may cover (but is not limited to):
   1. Reception areas
   2. General circulation / corridors / hallways
   3. Areas where cash, high value equipment, and high value information is stored or handled
   4. Areas where staff interact with clients and / or the public (i.e. clinic rooms)
   5. Entrances
3. Covert systems may be used only when there is suspicion of criminal or serious misconduct and only for a defined purpose and a fixed period, with the authority of the Managing Director.  
4. Signage advising of CCTV equipment will be installed at entry points to the clinic and close to the cameras where practicable. The Triton Hearing website will also notify visitors that CCTV is operating in Triton clinics.
5. Any staff incidents or misconduct detected by CCTV will be handled in accordance with Triton’s Policies and Procedures.
6. The placement of any and all CCTV equipment will not unreasonably intrude on the privacy of individuals, for example.
   1. CCTV will not be used in areas such as bathrooms or changing areas.
   2. CCTV footage will only be viewed by authorised personnel who have first obtained permission of the Privacy Officer/Compliance Manager.
   3. Footage will be viewed in accordance with the purpose of the cameras as detailed in this policy.
7. Subject to approval by the Privacy Officer/Compliance Manager, managers at Area Manager level and above, may view real time and recorded data that cover areas that they manage but may not keep recordings without going through the access storage and use process set out in this policy. Managers must apply in writing to the Privacy Officer/Compliance Manager giving reason(s) why they require real time and recorded data.
8. Any or all cameras and sound recorders may operate 24 hours per day, 7 days per week.
9. CCTV images are not routinely actively monitored in real time [but may be where considered necessary or appropriate for one of the purposes outlined in this policy].

 
CCTV footage access, storage, use, and disclosure

1. CCTV footage is collected by Sonova Audiological Care New Zealand Ltd, trading as Triton Hearing.  Any enquiries in relation to this policy, the CCTV system, or personal information collected by Triton Hearing should be sent to privacy@tritonhearing.co.nz.
2. CCTV footage is stored in a secure cloud-based server. Access to the recordings is governed by this policy.
3. Reception cameras are set to always be on and recording 24 hrs per day, 7 days per week for security reasons.
4. Clinic Room cameras default position is to be turned off and only turned on for training purposes or safety concerns. Turning a clinic room camera on must be requested by someone with authority to do so (as set out in point 4 below) and enacted by Triton’s IT contractor. Any staff member in the affected clinic room shall be notified before the camera is initiated.
5. Only the following staff shall have login access to the camera portal:
   • Triton’s Privacy Officer/Compliance Manager
   • Head of Innovation and Audiology
   • Executive Leadership Team
   • Network Development Lead
   • Clinical Trainer
6. Recorded CCTV footage will remain on the secure server for no more than 7 days before being overwritten in a continuous recording cycle. Footage older than this will be permanently deleted. Where an incident or suspected incident has been identified, and with the approval of the Privacy Officer/Compliance Manager, a portion of the footage may be retained for that incident.
7. Individuals identified on CCTV have the right to ask for access to recordings about them and request that information be corrected.  Requests for access should be made to Triton Hearing’s Privacy Officer/Compliance Manager at: privacy@tritonhearing.co.nz.  Any request by an individual for a copy of the footage identifying them personally will be referred to the Privacy Officer/Compliance Manager for consideration. Any response to a request will include considerations of the ease of access to the footage, and the need to protect other people’s privacy. If a request for a copy of the footage is unable to be granted without unreasonably breaching others’ privacy, a written description may be provided of activities in the footage pertaining to the individual requesting the information or a viewing of footage may be arranged. Any request will be responded to as soon as reasonably practicable and in any event within the period specified in the Privacy Act
8. The Privacy Officer/Compliance Manager will allow access only of relevant CCTV recordings to:
   • Authorised personnel of Triton Hearing who have requested footage in terms of this policy.·   Contractors on site specifically to work on the CCTV equipment at the request of the Privacy Officer/Compliance Manager.
   • New Zealand Police or other public sector agency such as the Privacy Commissioner.
   • Individuals who have formally requested information pertaining to themselves at the authorisation and direction of the Privacy Officer/Compliance Manager.
9. When a request for access to the CCTV has been received and if the footage can be located, Triton Hearing will take measures to ensure the relevant footage is saved.
10. Triton Hearing will take reasonable steps to ensure that public disclosure does not occur (i.e. not upload footage to internet, not publish still images in newspapers, not circulate it widely by email) unless the Police want it public.
11. Triton Hearing staff will take reasonable steps to check CCTV images are accurate, complete, relevant and not misleading before using them.
12. Cameras must not be covered or blocked in any way, and any deliberate tampering with cameras to alter their performance may result in disciplinary action.
13. All access to CCTV images will be logged where access is not by a Triton Hearing staff member.

 
Complaints

1. Any complaint about the CCTV will be received in accordance with Triton Hearing’s formal complaints process.
2. Any complaint is to be forwarded in writing to the Privacy Officer/Risk & Compliance Manager at privacy@tritonhearing.co.nz or writing to the following address:

Privacy Officer/Risk & Compliance Manager, Triton Hearing
6-8 Omega Street
Rosedale
Auckland 0632
 
Relevant Legislation
This policy has been created by Triton Hearing to protect the privacy of individuals and comply with its legal obligations under the Privacy Act 2020.
The policy aims to follow best privacy practice to ensure that any images captured, collected and stored are handled in a confidential manner that protects an individual’s privacy. This policy deals with all CCTV installed in all Triton Hearing clinics and places of work.