Privacy Policy
Privacy Policy regarding Jacoti products and services

In this Privacy Policy, we provide you with information about the processing of your personal data by Jacoti when it provides services 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

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

  • to offer and enable the functionalities of our Site, among others by use of cookies;
  • to track how users interact with our Site and how often they visit our Site, making use of cookies. 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;
  • to allow you to make use of any other functionalities offered on our Site.
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 used by Jacoti and will receive information back from those 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 Applications to be activated and function.

We require processing a confirmed email address so as to allow our servers to recognize the installed Application owner uniquely in order to allow our Applications to run properly and to be able to communicate with you for the purpose of complaints and medical devices post marketing surveillance of our Applications.

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 your email address,
  • 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;
  • your interaction with our Applications (buttons you press, adjustments, etc.),
  • linking it to the IP address or another system identification address.

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.

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.

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.

Hearing experts

Your personal data collected by Jacoti can be accessed by, and used to assist you by, the hearing expert that you have visited and that you have given the right to do so after the expert sent you an invitation allowing you to link the expert to your web profile account. When you have linked your account to the expert concerned, and thereby have consented to the processing of your data by the expert, that expert has access to the web profile for your account.

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 have a right to request from Jacoti access to and rectification or erasure of your personal data or restriction of processing that concerns you or to object to processing as well as the right to data portability. You also have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal (it being understood that in case you withdraw consent, we will no longer be able to provide the Service). You also have the right to lodge a complaint with a competent supervisory authority.

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 or

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 October 16, 2017.