Privacy
notice
We are
pleased that you are interested in the EXOPULSE HCP App. The present
document informs you about the processing of personal data connected to the EXOPULSE
HCP App. It also provides information on your rights and provides you with
means to contact us. We process personal data in line with the General Data
Protection Regulation (GDPR).
Controller
Exoneural Network AB
Barks väg 7
17073 Solna
SWEDEN
exopulse.com
Data protection officer
The Data Protection Officer of EXONEURAL Network AB
is:
DP Dock DPO Services GmbH
Wolfgang von Sandersleben
Grüffkamp
10
24159 Kiel
GERMANY
enn@dp-officer.com
Exoneural Network AB is part of Ottobock
SE & Co. KGaA. Ottobock
has also appointed a Data Privacy Lawyer: Matthias Horn[PK1]
Purposes of the processing and legal basis for the
processing
We limit
the processing of personal data acquired through the app to purposes directly
related to providing and improving the features of the app. We do not sell
personal data.
Personal data
The
following personal data is processed by ENN:
1. Usage
data:
§ Web Access
log: IP-Address, device ID and data sent by your browser
§ Linked
devices
§ Camera use
§ Error
logging
§ Created
training plans, login times, access to reports
Purposes:
§ The app
needs to be able to store and read data on your phone. Otherwise
the app cannot even be installed.
§ The app
needs to be able to connect to the internet in order to
communicate with our servers.
§ The app
needs to use the camera to scan a QR code when connecting to a Patient.
Only necessary data for the functioning of the app and
its features is being processed.
We will store the
personal data provided by you only for the necessary amount of time unless
statutory retention periods apply. Web access logs are being deleted after 30 days, error logging is deleted after 90 days.
2. Personal
data of you as a health care professional:
§ Full name,
E-Mail, password; purpose: create an account
§ Organization,
address, country; purpose: patient can select their personal health care
professional
§ Mobile
number, landline number; purpose: contact for troubleshooting issues
§ Avatar,
photo (optional): providing a photo for your patients is optional
3. Inquiries by phone, e-mail or via the app
In case you contact us (for
example if you have any questions re the app), we will process the data which
you provided during the contact. We will store the personal data provided by
you only for the necessary amount of time unless statutory retention periods
apply.
Please take
into account that particular, unencrypted personal data - for example,
if you contact us by e-mail - can be read by third parties. Therefore, for any
queries containing information requiring special confidentiality, we recommend
using postal services.
Recipients of the personal data
Exoneural Network works with several
third parties in order to assure the functions of the
App. Exoneural only works with third parties that demonstrate
data protection compliance. Where necessary, Exoneural
Network has concluded processing contracts.
Transfer of personal data to a third country
As
mentioned, Exoneural Network works with several third
parties in order to assure the functions of the App.
Some of these third parties are based outside the European Union / the European
Economic Area. Exoneural Network pays particular
attention to GDPR compliance, and, in this context, in
particular to Article 28 and Chapter V GDPR.
Retention
In
principle, we only store your personal data as long as necessary for the
functioning of the app and business processes related to it. Your
personal data will be stored until the purpose for which it was collected has
been achieved and, in
particular, no legal retention
periods prevent its deletion.
We only pass on your personal
data to third parties if:
§ you have
given your express consent to this in accordance with Art. 6 para. 1 sentence 1
lit. a GDPR,
§ this is
legally permissible and necessary for the fulfillment of a contractual
relationship with you in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR
§ there is a
legal obligation to disclose personal data pursuant to Art. 6 para. 1 sentence
1 lit. c GDPR, or
§ the
disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is necessary to
safeguard legitimate company interests, as well as to assert, exercise or
defend legal claims and there is no reason to assume that you have an
overriding interest worthy of protection in not disclosing your personal data.
Your Rights
To enforce
your rights, please use the details provided under Controller.
Right to access
You have
the right to obtain confirmation from us about whether or not
your personal data is being processed, and, if this is the case, access to your
personal data.
Right to rectification and erasure
You have
the right to obtain the rectification of inaccurate personal data. As far as
statutory requirements are fulfilled, you have the right to obtain the
completion or deletion of your data.
This does
not apply to data which is necessary for billing or accounting purposes or which is subject to a statutory retention
period. If access to such data is not required, however, its processing is
restricted (see the following).
Restriction of processing
As far as
statutory requirements are fulfilled you have the right to demand for
restriction of the processing of your data.
Data portability
As far as
statutory requirements are fulfilled you may request to receive data that you
have provided to us in a structured, commonly used and machine-readable format
or – if technically feasible – that we transfer this data to a third party.
Right of objection
You have
the right to object to the processing of your personal data at any time,
insofar as this is based on “legitimate interest”. This is not the case here.
Withdrawal of consent
In case you
consented to the processing– of your data, you have the right to revoke this
consent at any time with effect for the future, according
to Art. 7 (3) GDPR. The lawfulness of data processing prior to your
withdrawal remains unchanged. In case you revoke your
consent, your personal data will be deleted unless statutory retention periods
apply. The use of the app will no longer be possible. To withdraw your consent,
please use the details provided under Controller.
Right to lodge complaint with supervisory authority
According to Art. 77 GDPR, you have the right to lodge a
complaint with a supervisory authority. You can appeal to the supervisory authority
which is responsible for your place of residence or your state of residency or
to the supervisory authority responsible for us. This is the following
authority:
Integritetsskyddsmyndigheten
Drottninggatan 29
5th Floor
Box 8114
104 20 Stockholm
Tel. +46 8
657 6100
Fax +46 8
652 8652
Email: imy@imy.se
Website: http://www.imy.se/
Automated decision-making, including profiling
Automated
decision-making, including profiling, does not take place.
[PK1]It is not strictly necessary to mention a lawyer in the privacy notice. Therefore, it would be ok to delete this sentence.