PRIVACY POLICY – SENTEAN GROUP BV
Welcome to the Sentean Group’s mobile application (“The Fusion App” or “Service”). The Fusion App is operated by the Sentean Group BV (“the Sentean Group,” “company,” “we,” “our,” or “us”).
This privacy statement explains how we collect, use, share and protect information through the Fusion App, and describes the choices a user and a customer (defined below) have about the collection and use of personal information from or through the Fusion App. It applies only to information collected, used or stored about Fusion app users through the Fusion app; it does not apply to other information collected or obtained through other means or to information collected by third parties.
1. BACKGROUND
This privacy statement establishes the terms and conditions applicable to “customers” and “users.” “Customers” are companies and other entities that have separately contracted with the Sentean Group to provide a range of software applications and other services (“service agreement”). In the course of such customers’ daily business and in connection with the performance of the service agreements, such customers may require their employees (and contractors or other third parties, if applicable) (“employee”) or patients (“patients”) to use the Fusion App on smartphones or tablets (“device(s)”). Any such employee or patient may own the device or have received it from the client for use under their employment or treatment terms respectively with the client. The terms of use of these devices in connection with a client’s service or business operations – for example, when and how a client may control the use of a device – are determined solely by the client, and the client is solely responsible for communicating these terms to the employee or patient. The Sentean Group has no information and disclaims any liability for how an employee or patient uses a device for any purpose.
To use the Fusion App on an unattended device, an employee or patient must use a user ID and initial password provided by the client. The Fusion App cannot be used and cannot collect data or information unless the employee or patient uses this username and password.
The customer’s Fusion administrator may also enforce a password policy for devices running the Fusion App. To support this functionality, the Fusion App may require you to accept that password policy in order to use the Fusion App.An individual who either uses the Fusion App on a client-controlled device or who has downloaded the Fusion App on a personal device and accessed the Fusion App as explained above is considered a “user.”
Unless otherwise provided in a separate agreement, all use of the Fusion App shall be deemed to be done by users on behalf of and for the benefit of the the Sentean Group customer who has granted access to the user, such as providing that user with the agreed upon user ID and initial password. The de Sentean Group customer is the sole entity authorized to make decisions regarding personal information collected by the Fusion app, including, but not limited to, decisions regarding the deletion of information. Therefore, users should have no expectation of privacy when using the Fusion app on any device.
This Privacy Statement describes how the Sentean Group handles users’ personal information collected or processed by any device on which the Fusion App is installed.
To the extent that the Fusion App is used to collect or transmit information about other individuals, for example, clients or patients of a client, the policy regarding the handling of this other information is provided in a separate document for which the hospital has responsibility
2. CONSENT; AMENDMENTS
A user’s use of the Fusion App constitutes the user’s agreement to the terms of this Privacy Statement. Customers and users should ensure that they read this privacy statement carefully.
We may change this privacy statement from time to time. We will notify users and customers of material changes to this privacy statement by posting the amended terms in accordance with applicable law. A user who does not agree with the proposed changes should notify the customer and cease using the Fusion App before the new privacy statement takes effect. If a user continues to use the Fusion App after the new terms take effect, the user will be bound by the amended privacy statement.
A user who disagrees with our privacy statement may choose to uninstall the Fusion app, using the method provided by the device manufacturer. See also section 9, “Deleting or deleting information.”
3. INFORMATION WE COLLECT
We collect the following information from users when they interact with the Fusion app:
Registration information: information provided by the user when first accessing the Fusion app; for example, the user’s email address.
Electronic communications: electronic communications the user shares with us, such as support requests.
Device information: the type of device on which the Fusion app was downloaded, operating system name and version, application version and IP address.
Log file information: log files that record each time a device accesses our servers, and information about the device.
Usage Data: Data about how the user uses the Fusion App, such as time, username and mode of use and interaction with the Fusion App; date stamp, type of access.
Photos: If access is granted to the device, the Fusion app has access to all photos taken while using the Fusion app, and users can select and upload the selected photos to the Fusion app for shipment to the client.
Messages: text messages sent or received with the Fusion App.
4. USE OF INFORMATION
In addition to some of the specific uses of information described in this privacy statement, we may use the information we have collected to:
Facilitate the use of the Service; Archive the content of each user’s account; Improve, test and monitor the effectiveness of the Fusion App; Compile statistics on the use of the Fusion App to identify usage trends; Develop features on the Fusion App that may be of interest to users; Perform data analysis, auditing, fraud monitoring and prevention; and Any other functions that we believe in good faith are necessary to protect the security or proper functioning of the Fusion App.5. SHARING OF INFORMATION
We will not disclose a user’s information to third parties without notifying the user and the customer, except as stated in this Privacy Statement.
Customer
Unless otherwise agreed between customer and the Sentean Group, all data or information collected or stored by the Fusion App belongs to the customer. Thus, upon a customer’s request, we may provide the customer with access to any data or information created, received, transmitted, stored or otherwise processed by the Fusion App on a user’s device.
Responding to legal requests and preventing damages
We may disclose information about or associated with a user or user account to a third party in response to a prima facie valid request from a government agency or private litigant in the form of a subpoena, court order or search warrant, or when we believe in good faith that such disclosure is necessary in connection with a civil action, criminal investigation or other legal matter.
Change of control
We may disclose information about our customers to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all of our businesses, assets or stock, including in connection with bankruptcy or similar proceedings.
6. LINKS TO THIRD-PARTY APPLICATIONS
The Fusion app allows users to directly access applications managed by third parties. These links are provided solely for the convenience of users and should be used with caution. We are not responsible for any information that the services of these third parties may obtain, and we do not monitor their policies or practices. Users and customers should read the privacy policies of these third parties to understand how they may use information. This privacy statement does not apply to information provided to or collected by the third party service providers.
7. DATA RETENTION
We will retain data or information collected or generated by a user through the use of the Fusion app in accordance with instructions received from the customer to the extent necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Unless specifically stated otherwise by the customer, the Fusion system deletes all identifiable data within 24 hours of the user’s removal from the system.
8. DEACTIVATE ACCOUNT
Customers have the ability to deactivate, suspend or terminate a user’s Fusion account. For assistance, customers should contact us as outlined in the “Contacting Us” section, and we will provide any assistance needed.
Any user who wishes to deactivate or terminate his/her account, or delete specific data in his/her account, must first contact the customer. We follow the written instructions sent by or on behalf of the customer unless they conflict with the “Data Retention” section.
9. ERASURE OR DELETION OF INFORMATION
Any User may remove the Fusion App from the User’s device at any time by following the device manufacturer’s instructions.
In certain circumstances, when a user uses the Fusion App on the user’s device, a copy of all information collected, generated or stored by the Fusion App on that device may be stored on Sentean Group’s servers. When the Fusion App is removed from a user’s device, all information previously collected, generated or stored by the Fusion App, although no longer accessible from the device, remains stored on Sentean Group servers.
Unless the Sentean Group is required by applicable law or court order to take a specific action (e.g., retention, duplication, storage, deletion) with respect to such data or information stored on its servers, the Sentean Group will follow the customer’s written instructions with respect to the retention or deletion of such data or information, or if there are no such instructions, will retain such information in accordance with applicable data retention policies.
10. INFORMATION SECURITY
We take reasonable steps to protect all personal information we have to prevent its loss, misuse, unauthorized access, disclosure, alteration and destruction.
Users may not disclose any user ID or password required to access the Fusion app to third parties unless otherwise instructed by the customer and communicated in writing to the Sentean Group. Each user and customer is responsible for any use of Fusion under that user’s user ID and password unless they have notified the Sentean Group in writing (in addition to the customer) of the loss or compromise of such information in accordance with the “Contact Us ” section, and the Sentean Group has acknowledged receipt of the notification.
11. CHILDREN
The Fusion App is intended to be used for professional or business purposes. Our content is not aimed at minors or children under 13 years of age. We do not knowingly collect personal information from children under the age of 13.
12. HOW TO CONTACT US.
If you have any questions about this privacy statement, please contact us by email at support@senteangroup.nl.
13. SPECIFICS FOR AVG
a. General
The European Union’s General Data Protection Regulation, or AVG, improves the existing framework for companies processing the personal data of EU-based residents. It went into effect May 25, 2018, and brought with it a host of new obligations for those companies and new privacy rights for their end users.
b. The Sentean Group AVG Commitment.
The Sentean Group attaches the utmost importance to the given privacy of its customers. In compliance with the AVG regulations effective May 25, 2018, the Sentean Group hereby affirms the commitment to given privacy, security and transparency that the company provides to all its customers.
c. Principles for processing personal data
Fairness and legality – When we process personal data, the individual rights of data subjects must be protected. All personal data must be collected and processed legally and fairly.
Limited to a specific purpose. Personal data of Data Subject may only be processed for specific purposes.
Transparency. The Data Subject must be informed of how his/her data is collected, processed and used.
d. Data protection rights
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you would like to be informed about what personal data we hold about you and have it removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
The right to see, update or delete the information we hold about you The right to rectification The right to object The right to limitation The right to data portability The right to withdraw consent