Privacy Notice

Version: 1.0
Effective date: 3 September 2026
Last reviewed: 3 September 2026

1. Who we are

HearMed Acoustic Healthcare, also trading as HearMed, HearMed Healthcare ("HearMed", "we", "us" or "our"), provides audiology, hearing healthcare and related services in Ireland.

For the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Data Protection Act 2018, HearMed is the data controller of personal data that we collect and use in connection with the provision of our services.

Company registration number: 742968

Principal contact address:
HearMed Acoustic Healthcare
Patrick Street
Tullamore
Co. Offaly
R35 F2X0
Ireland

Email: getintouch@hearmed.ie
Telephone: 0818 058 058
Websites: hearmed.ie and hearmed.app

Questions or requests concerning your personal data should be sent to our Data Protection Lead using the contact details above.

2. Scope of this Privacy Notice

This Privacy Notice explains how we collect, use, store, share and protect personal data relating to patients, prospective patients, website visitors, people who contact us, people who make bookings or enquiries, and other individuals whose information we process in connection with our healthcare services.

Separate privacy information may be provided to employees, contractors and job applicants.

3. Personal data we collect

The information we process depends upon your relationship with HearMed.

We may process identification and contact information including your name, title, date of birth, address, Eircode, telephone numbers, mobile number, email address, patient number and preferred contact details.

We may process healthcare and clinical information including audiological history, hearing difficulties, symptoms, medical and family history relevant to your hearing care, medications where relevant, referrals, clinical notes, audiograms, hearing test results, speech testing, tympanometry or other audiological measurements, diagnoses or clinical impressions, treatment and rehabilitation plans, hearing aid recommendations, fitting information, hearing aid serial numbers, earmould information, repairs, warranties, follow-up care and correspondence with other healthcare professionals.

Health information is "special category personal data" under GDPR and receives additional legal protection.

Where relevant to a service or claim, we may process PPS numbers, PRSI or other public-scheme information, insurance information and other identifiers needed to administer a grant, entitlement or payment scheme.

We process appointment information including the location, date and time of appointments, appointment type, clinician, attendance, cancellations, rescheduling, reminders, recalls and follow-up requirements.

We may process financial and transaction information including invoices, credit notes, refunds, balances, payment records, deposits, insurance or scheme contributions and accounting records. HearMed does not need to retain full card details where payment is processed by an independent card-payment provider.

We process communications with you, including emails, SMS messages, WhatsApp messages where an approved HearMed channel is used, correspondence, enquiries, telephone call metadata and records of contact preferences. HearMed's telephone platform is not intended to be used as the clinical patient record.

Where expressly enabled and separately agreed with you, a consultation may be recorded or transcribed for the purpose of producing or assisting with clinical documentation. This is optional processing and is subject to the separate consent requirements described below.

When you use our websites, we may collect information such as your IP address or a protected/hash-derived version of it, browser and device information, pages visited, clinic selected, form submissions, session information, advertising source, campaign information and advertising click identifiers.

On our advertising website, this may include identifiers such as GCLID, GBRAID, WBRAID and UTM campaign parameters where permitted by your cookie and tracking choices.

We may also receive personal data from your GP, another healthcare professional, a family member or carer acting on your behalf, an insurer, the Department of Social Protection or another public body, a hearing-device manufacturer or repair provider, or another person or organisation where there is a lawful reason for that information to be provided to us.

4. Why we use your information and our lawful bases

HearMed only processes personal data where there is a lawful basis to do so.

When you contact us, request a callback, make a booking or ask about our services, we normally process the information necessary to respond to your request and take steps at your request before entering into a contract with you. We may also rely upon our legitimate interests in operating an efficient healthcare practice, provided those interests do not override your rights and interests.

When we provide clinical care, we process ordinary personal data where necessary to perform our contract with you and, where appropriate, to comply with legal and professional obligations.

Health and other special-category data used for the provision or management of healthcare is processed under Article 9(2)(h) GDPR together with the applicable provisions of Irish law, including section 52 of the Data Protection Act 2018, where those requirements apply.

Where processing is required to comply with a legal obligation, including accounting, taxation, regulatory, professional, safety or record-retention requirements, we rely upon Article 6(1)(c) GDPR.

In an emergency, information may be processed where necessary to protect the vital interests of a person and where the applicable requirements of GDPR are satisfied.

Marketing by email, SMS or similar electronic means is conducted in accordance with GDPR and the Irish ePrivacy Regulations. Where consent is required, marketing is not sent unless the appropriate consent has been obtained. Where the limited existing-customer exception permitted by law applies, we will still provide an easy method of opting out.

You have an absolute right to object to direct marketing at any time.

Non-essential cookies, advertising technology, analytics and conversion tracking are based on your consent. Rejecting these technologies does not prevent you from accessing HearMed's healthcare services.

5. AI-assisted clinical documentation and consultation recording

HearMed may make approved AI-assisted clinical documentation tools available to clinicians through our clinical platform.

Where a consultation is recorded or raw consultation audio is sent to a transcription service, this will only occur where the feature has been approved for use and the required explicit consent has been obtained from the patient.

Consent to recording, transcription or optional AI processing is separate from consent to receive healthcare. Refusing or withdrawing this consent will not prevent you from receiving clinical care.

AI output is an aid to the clinician. It does not replace the clinician's professional judgement. A clinician remains responsible for reviewing and approving information that becomes part of the clinical record.

Where consultation audio is used to create a transcript or clinical document, the audio will be retained only for the period needed for that purpose and will be deleted in accordance with HearMed's approved retention schedule once the derived clinical documentation has been reviewed and finalised, unless there is a separate lawful reason for retaining it.

HearMed does not permit patient clinical information to be used to train general-purpose AI models unless a separate lawful basis, transparency process and specific approval have first been established.

6. Our clinical management platform: Clinear

HearMed uses Clinear, a clinic-management and electronic health-record platform supplied by Clinear Limited.

HearMed remains the data controller of its patient information. Clinear Limited acts as HearMed's data processor when it hosts or otherwise processes HearMed patient, clinical, appointment, communication, financial or staff information on our behalf.

Our agreement with Clinear requires it to process HearMed data only on documented instructions, maintain appropriate security, assist HearMed with data-protection obligations and control the subprocessors that it engages.

Depending upon the features used by HearMed, Clinear's approved processing infrastructure may include providers for EU database hosting, encrypted object storage, email delivery, SMS, transcription, approved EU-region AI processing, monitoring, hosting and related infrastructure.

HearMed maintains, or can make available on request, information about the categories of processors used for patient data.

7. Other organisations with whom information may be shared

We may share personal data with organisations that provide services to HearMed, but only where required for a legitimate purpose and subject to appropriate contractual and security safeguards where they act as processors.

These may include our clinical software provider, cloud and website hosting providers, secure email and productivity providers, telephone and messaging providers, approved SMS providers, website support providers, accountants or payroll providers where applicable, secure data-storage providers and other information-technology support providers.

Where a third party processes personal data solely on HearMed's instructions, we require an appropriate data-processing agreement in accordance with Article 28 GDPR.

We may also share information with organisations that act as separate data controllers rather than processors. These may include GPs and other healthcare professionals, hospitals, public bodies, the Department of Social Protection, insurers, hearing-aid manufacturers or repair laboratories where information is genuinely necessary, payment providers, professional advisers, regulators, law-enforcement bodies or courts where disclosure is lawful and necessary.

We disclose only the information reasonably necessary for the relevant purpose.

8. Hearing-aid manufacturers and suppliers

Where a hearing aid, earmould, repair or related product is ordered on your behalf, information may need to be provided to the relevant manufacturer, supplier or laboratory.

The exact information depends on the product or service and may include your name or patient reference, ear side, prescription or fitting information, impression or mould information, device details and other data necessary to manufacture, configure, repair or supply the item.

HearMed applies data minimisation and will avoid providing clinical information that the supplier does not need.

9. PRSI, grants, insurers and public schemes

Where you ask HearMed to process a PRSI treatment benefit, grant, insurance claim or similar entitlement, we may process and disclose the information necessary to verify eligibility and administer the claim.

The receiving government department, insurer or scheme administrator may act as an independent data controller and will have its own legal obligations and privacy information.

10. Telephone, SMS and messaging

We use telephone and electronic communications systems to administer appointments and communicate with patients.

Appointment confirmations, appointment reminders, clinical follow-up communications and service messages are not treated as marketing merely because they are sent electronically.

We aim to keep SMS and similar messages appropriately limited and do not intentionally include unnecessary clinical detail in ordinary appointment reminders.

If HearMed introduces call recording for any service, callers will be appropriately informed and any required consent or other lawful basis will be established before recording. Call recording will not be enabled for clinical conversations merely because the telephone system technically permits it.

Personal consumer messaging accounts must not be used by HearMed staff as substitutes for approved clinical systems.

11. Our websites and online enquiries

HearMed operates websites including hearmed.ie and hearmed.app.

Our advertising and enquiry website is intended to collect enough information to respond to an enquiry, arrange a callback or facilitate a booking. It is not intended for submission of detailed medical history, diagnoses or other sensitive clinical information.

Please do not enter unnecessary clinical information into a general website enquiry form.

Website lead and attribution information may be transferred securely into Clinear so that HearMed can respond to the enquiry, manage the appointment and maintain an appropriate patient record where the person becomes a patient.

12. Cookies and advertising technology

We use strictly necessary technologies required to provide website functions and remember privacy choices.

Our websites may also use optional analytics and advertising technologies. Optional tracking will only operate following the required consent.

On hearmed.app, technologies may include a consent-preference cookie and, where permitted by your choices, session and attribution identifiers used to understand the source of enquiries and advertising performance.

Advertising attribution identifiers may include Google advertising click IDs and campaign parameters. These are used only in accordance with applicable law, our consent controls and the relevant advertising platform's policies.

Analytics, advertising and conversion-tracking technologies are not treated as strictly necessary merely because they are useful to HearMed.

You can reject optional cookies and later change or withdraw your choice. It should be as easy to withdraw consent as it was to provide it.

13. Google advertising and conversion measurement

HearMed uses Google Ads to advertise its services and may measure whether advertisements result in enquiries or bookings.

HearMed does not send medical records, diagnoses, audiograms, clinical notes or other health information to Google Ads.

Patient-level or customer-data conversion uploads will not be enabled where doing so would breach applicable data-protection law, Google's restrictions concerning sensitive categories, or the person's valid consent choices.

Any future material change to the way first-party customer information is used for advertising measurement will be subject to a compliance review and this Privacy Notice will be updated where required.

14. Social media and third-party websites

HearMed maintains business profiles on social-media platforms.

If you interact with HearMed through Facebook, Instagram, LinkedIn, WhatsApp or another platform, the platform provider will process information under its own terms and privacy notice and may act as an independent or joint controller for some processing.

We recommend that sensitive clinical information is not sent through public social-media messaging.

15. International transfers

HearMed seeks to use EEA-based processing for clinical and health information wherever reasonably available.

Some service providers or their subprocessors may be established outside the European Economic Area or may provide support from outside the EEA.

Where a transfer of personal data outside the EEA requires a Chapter V GDPR transfer mechanism, HearMed or its processor will use an appropriate safeguard such as an adequacy decision, the European Commission's Standard Contractual Clauses, together with any necessary transfer assessment and supplementary safeguards.

16. How long we keep information

We do not keep personal data indefinitely merely because we are able to do so.

Clinical records are retained for the period required or justified by applicable legal, professional, clinical, insurance and limitation requirements. The appropriate period may depend on the patient's age, the nature of treatment and any continuing legal or clinical need.

Financial and accounting records are retained for the periods required by Irish accounting and taxation law.

Website lead, call-attribution and related personal data held specifically on the hearmed.app advertising site is ordinarily scheduled for deletion after 90 days, unless it has already become part of the appropriate patient record in Clinear or another lawful reason requires retention.

Cookie and tracking retention periods are disclosed through the relevant cookie information. Current HearMed advertising-site preferences may be retained for up to 12 months, while advertising attribution identifiers, where consented to, are intended to use significantly shorter periods.

Where consent is withdrawn, consent-based future processing will stop. Withdrawal of consent does not automatically require deletion of information that HearMed is legally or professionally required to retain under a different lawful basis.

17. Security

HearMed takes appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, accidental loss or destruction.

These measures include role-based access, individual user accounts, authentication controls, appropriate encryption, secure hosting, access logging, staff confidentiality, data minimisation, system backups, processor due diligence and incident-management procedures.

No internet-connected system can be guaranteed to be completely free from risk, but HearMed regularly reviews its security measures and the systems used to process patient information.

18. Your data-protection rights

Subject to the conditions and exceptions in GDPR, you may have the right to request access to your personal data, obtain a copy of it, correct inaccurate information, request erasure, request restriction of processing, object to processing, receive certain data in a portable format, and withdraw consent where processing is based on consent.

You also have the right to object at any time to processing of your personal data for direct marketing.

A request to erase information does not necessarily mean that every part of a clinical record can be deleted. HearMed may be legally entitled or required to retain information, for example where it is necessary for legal obligations, healthcare purposes or the establishment, exercise or defence of legal claims.

We normally respond to a valid rights request without undue delay and within one month. Where GDPR permits an extension because a request is particularly complex or numerous, we will tell you within the initial one-month period.

We may need to verify your identity before releasing personal information.

19. Consent and withdrawal

Where we rely on consent, you may withdraw it at any time.

Withdrawal does not affect the lawfulness of processing that occurred before withdrawal and does not affect processing carried out under another lawful basis.

Clinical care, necessary record keeping and statutory obligations are not made dependent upon marketing consent.

Marketing consent, optional AI or recording consent, and cookie/advertising consent must be treated as separate choices.

20. Children and persons requiring assistance

HearMed may provide services to children and to adults who require assistance with decision-making.

We take appropriate steps to provide privacy information in an understandable form and to verify the authority of a parent, guardian, representative or other person purporting to act on somebody else's behalf where appropriate.

The patient's own rights and interests remain central to the processing.

21. Automated decision-making

HearMed does not make clinical decisions about a patient solely through automated processing that produces legal or similarly significant effects.

AI-supported tools may assist a clinician with documentation or administrative work, but a suitably authorised person remains responsible for clinical judgement and review.

22. Personal data breaches

HearMed maintains procedures to identify, contain, investigate and document suspected personal data breaches.

Where a breach is likely to result in a risk to individuals, we will notify the Data Protection Commission within the period required by GDPR. Where a breach is likely to result in a high risk to affected individuals, we will also inform those individuals without undue delay where required.

23. Complaints

We would ask you to contact HearMed first if you have a concern about the way your information has been handled so that we have the opportunity to investigate it.

You also have the right to complain to:

Data Protection Commission
6 Pembroke Row
Dublin 2
D02 X963
Ireland

Website: dataprotection.ie

24. Changes to this Privacy Notice

We review this Privacy Notice regularly and whenever there is a material change to our processing, systems, service providers, use of AI, advertising technology or legal obligations.

The current version will be published on our website.

25. Contact us

For privacy enquiries or to exercise a data-protection right:

HearMed Acoustic Healthcare
HearMed Acoustic Healthcare
Patrick Street
Tullamore
Co. Offaly
R35 F2X0

Email: getintouch@hearmed.ie
Telephone: 0818 058 058

Please mark written correspondence "Data Protection" where appropriate.