Privacy Policy
Privacy Policy regarding Jacoti products and services

Pursuant to the EU Data Protection Directive (95/46) and its implementation in your country, we would like to provide you with information about the processing of your personal data for the use of the services provided to you as a result of your use of the Jacoti applications and website (hereinafter: “the Service”).

By your use of Jacoti’s Service, including the use of our website and (mobile phone) applications (our “Site” and “Applications”), you consent to the processing of your personal data, if any, for the purposes set out in this Privacy Policy.

Use of Website

Jacoti’s Site provides information about the Service and allows you to contact Jacoti. When you access the Site Jacoti collects and processes your personal data for the following purposes:

  • to offer and enable the functionalities of our Site, among others by use of cookies.
  • The cookies that we use allow us to track how users interact with our website and how often they visit, but they do not send your personal data such as email address to us. For more information regarding cookies, see our cookie policy.
  • to interact with you when you fill in contact details in the email form on our Site
  • to allow you to log into your web profile
How does the Service work?

In order for the Service to be performed you have to install the Application on your mobile device and permit the device to connect to the internet. The Application will send information from the Application to the servers of Jacoti and receives information back from the servers to optimize the audio experience provided by the Application. If you are a user, you may authorize hearing experts to link to your web profile in order to optimize configuration of your Application.

What data is collected and processed?

We collect personal data during the installation procedure of the Applications and your setting up/configuration of your web profile with Jacoti. We subsequently process (technical) information about your sense of hearing that is required to optimize personal hearing loss compensation, in order to provide you with the Service in general and to acquire knowledge to further improve and develop our service. Using the Application implies information sharing with Jacoti for the purpose of your web profile and identification as registered user. Furthermore, there are minimum requirements of data sharing required for the application to be activated and function.

We require processing a unique application identifier (UAI) that is unique for each installation of any Application so as to allow our servers to recognize the installed application in order to allow our application to run properly and to be able to communicate with you for the purpose of complaints and medical devices post marketing surveillance of our product. The UAI is not linked to any information external to the application.

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, linking it to the IP address, other system identification address or the UAI.
  • your interaction with our application (buttons you press, adjustments, etc.), also, however, on an anonymous basis, linking it to the IP address, other system identification address or the UAI.

If you have enabled the InterApp audio processing option, the Application will process audio related data that other apps on your mobile device, such as apps that record and/or play audio and/or video, allow the Application to process. In that case the Application will access the other app’s audio data stream using the InterApp audio function, for the purpose of improving your audio experience. For example, the Application’s access to the audio data stream of another app could allow it to optimize the audio generated by the other app for environmental conditions, such as background noise.

Applications can only process the audio data stream of another app if that app allows for Inter-App audio access. The Applications do not aggregate user related data or monitor user behavior via the InterApp functionality.

By installing and using the Application(s) you consent to Jacoti anonymising your personal data to the effect that it is no longer personally identifiable and to use that anonymised data for other purposes, including commercial purposes.

Hearing experts

The only third party that can access your personal data collected by Jacoti is the hearing expert that you have visited and that has provided you with a pre-generated code that allows you to link the expert to your web profile account. When you have linked your account to the expert concerned, that expert has access to the web profile for your account.

Where is your data processed?

Your data is processed and stored in a number of different locations in the European Union. The data is not exported outside the European Union.

What will happen if you refuse to consent to your data being processed?

The provision and processing of provision of your personal health data is necessary to successfully conclude the registration process and for the performance of the Service. Your refusal to consent to processing of the data means that the Service cannot be provided to you.

To whom will your personal data be disclosed?
Jacoti group companies and branch offices

Jacoti may share your data with affiliated companies in the Jacoti group of companies and its branch offices in the European Economic Area.

Third party service providers

Jacoti will only disclose personal data about its users, if any, to third party service providers:

  • for processing purposes associated with the supply of its goods and services, such as in the case of hearing experts that a user allows to link to the user’s web profile,
  • 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.

Supervisory authorities

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.

Business sale

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.

How long will we keep your data?

We keep your personal data for as long as we provide the Services to you. If you cease use of the Services, the audio related data that has been communicated to Jacoti remains part in anonymised form of the overall dataset that is used to improve the listening experience of other users going forward. Other users will not have access to data relating to individuals that have ceased use of Jacoti products and services.

Security

Jacoti has implemented appropriate technical and organizational measures to safeguard the personal data, which it processes, if any, against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and other unlawful forms of processing. Jacoti uses administrative, technical, and physical measures to safeguard data against loss, theft and unauthorized uses, access or modifications. Certain areas of our Site or Service may be password protected. If you are a user of our Site or Service 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.

Your rights?

You may exercise your legal rights with respect to the processing of your personal data for the purpose of the Service by contacting:

Jacoti bvba, with its registered office at Vlamingstraat 4, 8560 Wevelgem, Belgium, registered in the Belgian Crossroads Bank of Undertakings under number 0440.463.241

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 the Service, 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 July 3, 2014.