Binding Version
This Privacy Policy (the “Privacy Policy”) governs the processing of (personal) data of existing, prospective and former users of the services of Jacoti BVBA, with its registered office at Dr. Theo Tutsstraat 45, 2530 Boechout, Belgium, registered in the Belgian Crossroads Bank of Undertakings under number 0440.463.241 (“Jacoti”).
Jacoti is committed to abiding by this Privacy Policy and the requirements of applicable data protection and privacy laws in the operation of its business. Please read this Privacy Policy carefully as it explains what (personal) data Jacoti processes about you and what it does not. By your use of Jacoti’s services, including the use of our website and mobile phone applications (our “Sites” and “Applications”), you consent to the processing of your personal data, if any, for the purposes set out in this Privacy Policy.
Collection and use
When you use our Sites and Applications, we generally do not process personal data such as your name, postal and/or email address, financial information, credit card information etc. We mainly process anonymous (technical) information about your sense of hearing that is required to optimize personal hearing loss compensation, to provide you with our services in general and to acquire knowledge to further improve and develop our service. You will be asked to accept or refuse the information sharing and there will be minimum requirements of data sharing required for the application to be activated and function. We do require processing a unique application identifier (UAI) that is unique for each installation of any mobile application from Jacoti so as to allow our servers to recognize the installed application in order to allow our application to run properly. The UAI is not linked to any information external to the application. Deleting and re-installing the application will result in a new UAI. Without limiting the generality of the foregoing, more in particular, data collected from you with respect to the use of our Sites and Applications among others includes:
- -your IP address, or other system identification address and the UAI which are required to recognize and interact with the application so that the application can work.
- - your audiogram data, location, usage time, age, time of deafness on an anonymous basis without linking this data to your name or other personal details, but linking it to the IP address, other system identification address or the UAI.
- - your interaction with our application (buttons you press, adjustments, …), also, however, on an anonymous basis without linking this data to your name or other personal details, but linking it to the IP address, other system identification address or the UAI.
- - Jacoti therefore in principle only processes anonymous data and certain system and software identification data required to recognize and interact with your device, which is necessary to supply its goods and services, for Sites or Applications’ administration, to conduct its business, manage its relationships with the users of its services (without identifying these users, our application does not interact directly with the user but with the UAI), perform its services, market its products and services, perform market research, and improve its service.
Jacoti may collect and process personal data in order to comply with its legal obligations or to demonstrate compliance with applicable legal or regulatory requirements. We may collect personal data about you, which we require to respond to your inquiries. If Jacoti would process any personal data other than the one mentioned above, it will do so in a reasonable, lawful and fair manner. Jacoti in any event aims to provide full transparency in respect of its use of your (personal) data.
Where personal data will be processed for additional purposes that are incompatible with the above, affected data subjects will be informed of the reasons for the processing as well as the categories of recipients when required by law. Where required by law, the consent of data subjects to such processing will be obtained.
Disclosures
Jacoti will only disclose personal data about its users, if any, internally and to third party service providers for processing purposes associated with the supply of its goods and services, for Sites or Applications’ administration, for the conduct of its business, to manage its users’ relationships, to perform market research and improve its service. Third party service providers who process personal data on behalf of Jacoti, if any, will be required to take appropriate technical and organizational measures to protect the security of that data, and to act only in accordance with the instructions of Jacoti in respect of the processing of such data. Your personal data, if any, may also be transferred to Jacoti’s operations, offices, personnel and service providers throughout the European Economic Area for purposes mentioned in this paragraph or as required by law. The terms of this Privacy Policy will be respected throughout any transfer.
We may be required to disclose personal or technical data to other parties and/or for other purposes (i) by law or pursuant to legal process; (ii) to enforcement or public authorities in response to a request from such authorities; or (iii) if we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
We may disclose your (personal) data about you in the event that we sell or transfer all or a part of our business or assets. Should such a sale or transfer occur, we shall use reasonable means to require that the transferee processes your personal information in a manner that is consistent with this Privacy Policy.
Accuracy and Necessity
Jacoti takes reasonable steps to keep the (personal) data which it processes accurate, complete, and where necessary up to date. Information that is no longer required for any valid business purpose, and that we are not required to keep pursuant to any applicable law, will be routinely destroyed by secure means. However, anonymized personal data and technical data will be further processed to improve our applications and in general for historical, statistical or scientific purposes. Such anonymized personal data and the results of our further processing may also be sold or provided in any other way to third parties.
Security
Jacoti has implemented appropriate technical and organisational measures to safeguard the personal data, which it processes, if any, against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, and other unlawful forms of processing. Jacoti uses administrative, technical, and physical measures to safeguard data against loss, theft and unauthorised uses, access or modifications. Certain areas of our Sites or Applications may be password protected. If you are a user of our Sites or Applications and have a password, you can help to preserve your privacy by ensuring that you do not share your password with anyone else. Subcontractors such as IT-service providers processing data on our behalf are held by legally binding confidentiality and security requirements.
Rights of the Users of Our Services
Persons using our services have a right of access to their personal data contained in records that Jacoti holds about them (if any). They are given an opportunity to amend, update or supplement inaccurate personal data. They may request access to their personal data or make an enquiry, raise a question or make a complaint about Jacoti’s privacy practices by writing to info@jacoti.com
Changes to the Privacy Policy
This Privacy Policy may be modified to reflect changes in applicable laws or regulations, or changes in Jacoti’s practices or procedures. We reserve the right to add to or amend this Privacy Policy at our sole discretion, without prior notice to you. If we change this Privacy Policy, we will provide you with a copy of the new version by posting the new version on our Sites or Applications. The renewal of this Privacy Policy will not result in a decrease of the level of protection of your personal data.
Please review our Privacy Policy on a regular basis to make sure you have read the latest version and you understand what we do with your personal data. Your continued use of our services, including our Sites or Applications, following the posting of changes to these terms means that you consent to those changes.
This version of the Privacy Policy is effective as of [April 1, 2012].
