Sonarworks SIA is committed to protecting your privacy. This Privacy Statement (“Privacy Statement”) explains why and how we collect and use personal data and provides information about individuals’ rights.

The data controller responsible for the processing of personal data described in this Privacy Statement is Sonarworks SIA, a company registered in Latvia, with its registered address at Šmerļa iela 3, Riga, LV-1006, Latvia.

Personal data is any information relating to an identified or identifiable living person. When we use “you” or “your” in this Privacy Statement, we are referring to the relevant individual who is the subject of the personal data.

We process personal data in accordance with applicable legislation, including the General Data Protection Regulation (the "GDPR") and the applicable national data protection laws.

We process personal data for numerous purposes, and the means of collection, legal basis of processing, use, disclosure, and retention periods for each purpose may differ.

We do not carry out automated decision-making within the meaning of Article 22 GDPR.

To find out more about our specific processing activities, please choose the relevant sections of this Privacy Statement.

One or more data processing activities may apply simultaneously.

1. Customers, potential customers, and former customers and software users

Purposes of the data processing

We process your personal data to:

• Provide products and services that you have requested and perform deliveries in accordance with an end user license agreement (“EULA”) or purchase agreement;
• Identify users who have difficulties using the program;
• Offer support for our products and services;
• Carry out security activities, including detecting and preventing security threats and malicious use of our products and services;
• Carry out quality and risk management activities;
• Administer, manage, and develop our products and services and improve their quality by analyzing data;
• Inform you about our products and services that are closely related to the products and services you already use or have tried to use;
• Communicate information that is relevant for our deliveries in particular and our customer relations in general;
• Publish your review if your consent for that is received;
• Process orders, invoices, payments, and perform financial follow-ups;
• Comply with the legal obligation we are subject to.

Legal basis for the data processing

Legal basis for processing your personal data for the purposes mentioned above is:

• Performance of a contract or to take steps at your request prior to entering into a contract;
• Legitimate interests, namely, to ensure security conditions, to provide the quality of our products and services, and to promote our business;
• Necessity to comply with legal obligations that apply to us;
• Consent (in case it is necessary to receive it according to the GDPR).

Categories of personal data we process

To ensure the conclusion of a contract, performance of the contract, and to accomplish other purposes stated above, we process the following categories of personal data:

• Name, phone number, email address, postal address;
• Contact details, such as the name of the company you work for, your position, email address, and phone number;
• Payment information;
• Data you provide to Sonarworks to be able to provide services, resolve issues;
• Computer ID (CID), IP, computer name, computer type, headphone name, headphone profile, microphone profile name, input/output device name and ID, calibration profile name;
• Unique user information for user accounts, such as email address, password, and security question;
• Specific information, such as a student or teacher certificate, personal identification number, educational establishment where you work or study, to get discounts offered by Sonarworks;
• Other information you have provided to us.

The provision of data is mandatory for customers based on contractual regulations. The contractual relationship cannot be established and carried out without providing data.

Data retention

All your data relevant to contracts and bookkeeping shall be stored for a period of ten calendar years after the contract expires.

2. Website visitors

Purposes of the data processing

We process your personal data for the following purposes:

• To administer and manage our website;
• To confirm and authenticate your identity;
• To prevent unauthorized access to restricted areas of the site or restricted content;
• To conduct quality and risk management reviews;
• To develop our products, services, and websites by analyzing how people use our websites;
• To personalize your browsing experience by displaying content that is more likely to be relevant and of interest to you;
• To monitor and enforce compliance with our terms and conditions;
• To communicate with you in order to distribute requested information or materials, or ask for further information;
• Any other purposes for which you provided your personal data to us.

Legal basis for the data processing

The legal basis for processing your personal data for the purposes mentioned above are the following:

• Legitimate interests, namely, the demand-oriented design of the website, developing our products and services, and ensuring network and information security;
• Consent for the processing of personal data or for the processing of personal data for purposes for which the consent of the data subject is required by law.

Collection of personal data

We process your personal data, which you have provided when using our website, such as name, email address, and any additional information you have included in the message.

We may also collect limited personal data automatically, including via the use of cookies.

Cookies are small files that websites save to your hard disk or to your browser's memory. Our website may use them to track the number of times you have visited the website, to track the number of visitors to the website, to determine and analyze visitors' use of our websites, to store data that you provide (such as your preferences), and to store technical information related to your interactions with our website. We may also use session cookies, which are deleted when you close your browser, to store your user ID, to facilitate your movement around our websites (particularly in connection with information searches and order placement), and other information useful in administering the session.

The use of the website is not possible without the disclosure of personal data, such as the IP address. Communication via the website without providing data is not possible.

 Data retention

We will retain personal data collected via our website as long as it is necessary for communication with you, but not longer than 5 years. The retention period for data that is collected via the use of cookies is determined in our Cookies Policy.

3. Recruitment applicants

Purposes of the data processing

We process your personal data for the following purposes:

• Screen and select employees by evaluating your suitability for employment with Sonarworks, including through interviews and assessments, and conducting background checks;
• Hire and onboard employees by making an offer to successful applicants and carrying out pre-employment screening checks.

Legal basis for the data processing

The legal basis for processing your personal data for the purposes mentioned above is the following:

• In connection with recruitment activities, we process your personal data for our legitimate interests to attract and hire the best candidate to work with us;
• If you are a successful candidate and we are planning to conclude an employment contract with you, we process your data to take steps at your request prior to entering into a contract.

Categories of personal data we process

Personal data we process for recruitment activities is the following:

• Name, date of birth, nationality;
• Contact details: email address(es), telephone number(s), postal address;
• Professional experience and knowledge, such as experience, education, academic and professional qualification included in CVs and motivation letter;
• Areas of interest: hobbies, etc.
• Any information provided as references from your named referees;
• Verification of information provided during the recruitment process by contacting relevant third parties (for example, previous employers, education and qualification providers) or using publicly available sources (for example, to verify your experience, education, and qualifications);
• If you have indicated any disabilities, which necessitate any special arrangements in the context of the selection procedure;
• Interview and assessment results and feedback;
• Bank account details if your application is successful.

Provision of personal data is required for examination of your application and, if applicable, conclusion of an employment contract. Without personal data, an application cannot be considered.

Data retention

We retain your personal data processed in connection with recruitment activities as follows:

• If your application is successful, we will retain relevant personal data as part of your employee record after the end of your employment with Sonarworks for a period specified in the applicable law;
• If your application is unsuccessful, we will retain and use the information you provided as part of your application for a period of one year to deal with any matter that may arise in connection with your application, for purposes of contacting you regarding other employment opportunities.

4. Distributors and dealers

Purposes of the data processing

We may process your personal data for the following purposes:

• To ensure the company you work for can distribute our products and services;
• To provide information about us and our range of services;
• To advertise our products and services;
• To process payments.

Legal basis for the data processing

Legal basis for processing your personal data as a contact person or representative is legitimate interests, namely communication with you in relation to the conclusion of a contract or execution of a contract, and documentation of the communication processes.

Legal basis for data processing may also be legal obligations.

Categories of personal data we process

To ensure the conclusion of a contract, performance of the contract, and accomplish other purposes stated above, we process your contact details, such as name, name of the company you work for, your position, email address, and phone number.

Processing of the contact data of distributors is necessary to conclude and execute a contract or an order. If data is not provided, communication may be considerably impaired.

Data retention

We retain your personal data for a period of ten years after the contract expires.

5. Affiliates

Purposes of the data processing

We may process your personal data for the following purposes:

• To ensure you could promote our products and services;
• To provide information about us and our range of services;
• To advertise our products and services;
• To process payments.

Legal basis for the data processing

The legal basis for the processing of your personal data is mostly preparation for the conclusion of a contract or execution of a contract.

Legal basis for data processing may also be legal obligations, in particular accounting, tax, and commercial law provisions.

Categories of personal data we process

To ensure the conclusion of a contract, performance of the contract, and to accomplish other purposes stated above, we process the following personal data:

• Name, personal identification number, address, telephone number, email address, and password for user account;
• Payment information.

Processing of contact data of distributors or affiliates is necessary to execute a contract or an order. If data is not provided, communication may be considerably impaired.

Data retention

We retain your personal data for a period of ten years after the contract expires.

6. Suppliers and service providers

Purposes of the data processing

We may process your personal data for the following purposes:

• To receive products that are necessary for our business;
• To receive services from you or from your organization, including marketing services, services for maintaining and administering our organization and business, IT services, services for managing our website and systems;
• To ensure we comply with legal obligations imposed on us by law;
• To process payments.

Legal basis for the data processing

Legal basis for processing your personal data as a supplier or service provider is mostly the preparation for the conclusion of a contract or execution of a contract. If the contract will be or is concluded with a legal person, the legal basis of processing your personal data as a contact person or representative’s personal data is legitimate interest, namely communication with you in relation to the contract and documentation of communication processes.

Legal basis for data processing may also be legal obligations, in particular, accounting, tax, and commercial law provisions.

Categories of personal data we process

To ensure the conclusion of a contract, performance of a contract, and to accomplish other purposes stated above, we process the following personal data:

• Name, address, name of the company you work for, your position, telephone number, and email address;
• Personal identification number if the supplier or service provider is a natural person;
• Payment information.

The processing of contact data of the supplier or service provider is necessary to execute the contract or order. If the data is not provided, the communication may be considerably impaired.

Data retention

We retain your personal data for a period of ten years after the contract expires.

7. Endorsers

Purposes of the data processing

We process your personal data to publish your opinion and photo or video accurately and in high quality.

Legal basis for the data processing

The legal basis for processing your personal data for the above purpose is your consent.

Categories of personal data we process

To provide fulfillment of the purpose mentioned above, we process the following personal data:

• Your contact details such as name, address, telephone number, and email address;
• Content you have agreed to publish by Sonarworks, including photos and videos.

Data retention

We retain your personal data processed in connection with publishing your opinion and photo or video on our website or as long as necessary for the purposes for which it was collected, but no more than 5 years from the time of its receipt.

8. Persons involved in research

Purposes of the data processing

The purposes of the processing of your personal data are the following:

• Researching of healthy human hearing;
• Create a hearing profile to evaluate hearing impairment;
• Carrying out quality and risk management activities;
• Improving the quality of our products and services;
• To process payments.

Legal basis for the data processing

The legal bases for processing your personal data for the purposes mentioned above are the following:

• Your explicit consent (Article 6(1)(a) and Article 9(2)(a) GDPR) for participation in hearing research and for the processing of hearing-related measurement data, which may constitute health data.
• Legitimate interests of Sonarworks (Article 6(1)(f) GDPR) to carry out quality and risk management activities and to improve the quality and performance of our products and services.
• Performance of a contract (Article 6(1)(b) GDPR) where processing is necessary to administer participation in research activities and to process payments.

When a research contract is concluded, the legal basis for the processing of the personal data is also the conclusion of a contract or preparatory contract.

Categories of personal data we process

The categories of personal data processed by us in relation to research are:

• Name, address, telephone number, and email;
• Interview data in written form;
• Age, gender;
• Measurements of the person's hearing threshold;
• Video, audio;
• Payment and billing information.

Data retention

We retain your personal data processed in connection with research activities for as long as necessary for the purposes for which it was collected, but no more than 5 years from the time of its receipt.

9. SoundID Tools application users

Purposes of the data processing

We process personal data collected through the SoundID Tools application in order to:

• Provide the functionality of the SoundID Tools application and enable the configuration and use of compatible Dolby Laboratories, Inc., audio products and services;
• Provide technical support and troubleshooting;
• Improve and develop Sonarworks products, services and technologies, including personalization of audio processing and calibration technologies;
• Carry out security activities, including detecting and preventing misuse of the application;
• Analyze the usage of the application in order to improve functionality and user experience.

Audio personalization using face photos

The SoundID Tools application may allow you to capture and provide photos of your face for the purpose of generating a personalized audio profile.

These photos are processed automatically by the software solely to extract acoustic characteristics required to generating a personalized audio profile. The processing is performed without human intervention and is limited to what is strictly necessary to generate the personalization parameters.

The personalized audio profile is provided directly to the user in encrypted form and may be used with compatible software, or services.

The photos are used only for the momentary extraction of acoustic characteristics and are automatically deleted immediately after the extraction process is completed. The photos are not stored or transmitted to Sonarworks.

The generated profile contains only derived acoustic parameters necessary for audio personalization and does not contain the original image data. The profile cannot be used to reconstruct the original photos.

This processing is designed in accordance with the principles of data minimization and privacy by design. The processing does not involve biometric identification, authentication, or identification of a natural person, and the generated profile is used solely for the technical purpose of audio personalization.

Legal basis for the data processing

The legal basis for processing personal data described above is:

• Performance of a contract or taking steps at your request prior to entering into a contract when you use the application or related services;
• Legitimate interests of Sonarworks to maintain and improve the functionality, quality and security of its products and services;
• Consent, where required by applicable law.

Categories of personal data we process

When you use the SoundID Tools application, we may process the following categories of personal data.

Information about your device. We may collect technical information about the device on which SoundID Tools is installed, including:

• Device identifier automatically assigned by the application;
• Device type, manufacturer and model;
• Operating system and operating system version;
• Language settings, country or region and time zone;
• IP address used by the device to connect to the internet.

Application usage information. We may collect information related to the use of the SoundID Tools application, including:

• Application version;
• Application identifiers;
• Time stamps related to application usage;
• Information regarding usage status and usage history;
• Error reports and diagnostic information.

Data retention

Personal data collected through the SoundID Tools application will be retained for as long as necessary to provide the functionality of the application and the related services but no more than 5 years from the time of its receipt.

Certain technical or usage data may be retained for longer periods where necessary to:

• Improve and develop our products and services;
• Ensure security and prevent misuse;
• Comply with legal obligations.
• Where possible, data will be aggregated or anonymized for product improvement purposes.

10. Recipients of the personal data

The primary recipient of your personal data is Sonarworks and its employees.

To be able to offer you the best possible services and remain competitive in our business, we share certain data with other organizations. As a result, personal data may be transferred outside the countries where we or the data subject is located. This includes countries outside the European Union (“EU”).

We use contractual arrangements and security mechanisms as appropriate to protect the data and to comply with applicable laws, including GDPR.

Where we transfer personal data outside the European Union (“EU”) to a country that has not been recognized by the European Commission as providing an adequate level of protection for personal data, such transfers are carried out subject to appropriate safeguards in accordance with Article 46 of the General Data Protection Regulation (GDPR).

These safeguards may include agreements incorporating Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms ensuring that personal data remains protected in accordance with EU data protection standards.

Personal data processed by us may be transferred to:

• Third party organizations that provide applications/functionality, data processing, or IT services to us, ensure the execution of sales transactions of our products and services, or otherwise assist us in providing goods, services, or information.

We use third parties to support us in providing our services and to help provide, run, and manage our internal IT systems. and execute sales transactions. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services, as well as organizations which provide us marketing activities or events and manage customer communications, prepare reports and statistics, printing materials and designing products, place advertisements on apps, websites and social media, online payment service providers.
In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

• Auditors and professional advisers.

We may share your data with our auditors if it is necessary for the provision of audit, with professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights, and obtain advice in connection with the running of our business.

• Government authorities.

To comply with our regulatory obligations, we may disclose data to the relevant authorities to check that we are complying with applicable law and regulation, for example, supervisory authorities, tax authorities, judicial/investigative authorities such as police, public prosecutors, courts, on their express and legal request.

In all of these cases, we ensure the third parties can only access personal data that is necessary for their specific tasks.

11. Security

Sonarworks implements appropriate technical and organizational security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

12. Individuals’ rights and how to exercise them

You, as a data subject, have certain rights over your personal data, and we, as the controller, are responsible for fulfilling these rights. Please see further information about these rights below, when they are available, and how to exercise them.

• Your right of access to personal data

You have the right to obtain a copy of your personal data as well as other supplementary information. It helps you to understand how and why we are using your data, and check that we are doing it lawfully.

• Your right to rectification/amendment of personal data

You have the right to request that your personal data be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.

• Your right to erasure/right to be forgotten

You have the right to have personal data erased, but this right is not absolute and only applies in certain circumstances.

You have the right to have your personal data erased if:

• The personal data is no longer necessary for the purpose for which we originally collected or processed it;
• We are relying on consent as a legal basis for holding the data, and you withdraw your consent;
• We are relying on legitimate interests as a legal basis for processing, and you object to the processing of your data, and there is no overriding legitimate interest to continue this processing;
• We are processing the personal data for direct marketing purposes, and you object to that processing;
• Your personal data has been processed unlawfully;
• Your personal data must be erased to comply with a legal obligation to which we are subject.
• Your right to restrict processing

You have the right to restrict the processing of your personal data, that is, to limit the way that we use your data, in the following circumstances:

• For a period enabling us to verify the accuracy of your personal data, where you have contested the accuracy of the personal data;
• The data has been unlawfully processed, and you request restriction instead of erasure;
• When your personal data are no longer necessary in relation to the purposes for which they were collected and processed, you can request restriction to establish, exercise or defend legal claims;
• For a period enabling us to verify whether the legitimate interests relied on by us override your interests, where you have objected to the processing based on legitimate interests.
• Your right to object to processing

The right to object to processing allows you to ask us to stop processing your personal data.

You have the absolute right to object to the processing of your personal data if it is for direct marketing purposes.

You have the right to object to the processing of your personal data also when there are other legitimate interests for processing, but then we have to verify whether your interests override the legitimate interests relied on by us.

• Your right to data portability

The right to data portability gives you the right to receive your personal data you have provided to us in a structured, commonly used, and machine readable format. It also gives you the right to request that we transmit this data directly to another controller.

The right to data portability only applies when:

• Legal basis for processing these personal data is consent or for the performance of a contract;
• We are carrying out the processing by automated means.
• Your right to withdraw consent

Where we process personal data based on your consent, you have a right to withdraw consent at any time.

• Your right to lodge a complaint

If you have a complaint about how we process your personal data, please contact us using the contact details provided in this Privacy Statement. We will review your complaint and provide a response within one month, in accordance with applicable data protection laws.

You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or the country in which an alleged infringement of data protection law has occurred. The data protection supervisory authority in the Republic of Latvia is the Data State Inspectorate, contact information:

• Blaumaņa iela 11/13-11,
• Riga, LV-1011, Latvia
• E-mail: info@dvi.gov.lv
• web page: www.dvi.gov.lv

13. Scope of the Privacy Statement

We may amend the Privacy Statement to remain compliant with any changes in law and/or to reflect changes in the processing of personal data by us.

14. Contact Us

For privacy related questions, please contact: 

Sonarworks SIA,

Smerla iela 3, Riga, 

LV-1006, Latvia

Attn: Legal Officer

Email: legal@sonarworks.com

https://www.sonarworks.com/company/contacts