Privacy Regulations

Start date: These Privacy Regulations were updated on July 2, 2020 and take effect from that date.

1. General
2. Definitions
3. For what purposes does Sensotec collect Personal Data?
4. To whom can Sensotec disclose Personal Data?
5. What Personal Data can Sensotec collect or process?
6. Is Sensotec responsible for other websites?
7. How is your Personal Data protected by Sensotec?
8. What are your rights?
9. Can these Privacy Regulations be amended?
10. How long do we store your Personal Data?
11. Who can you contact should you have any queries or requests?

1. General

These Privacy Regulations describe the duties and responsibilities of Sensotec NV, with registered office at Vlamingveld 8, 8490 Jabbeke, Belgium and registered with the Kruispuntbank for Businesses under number 0429.286.663 (RPR Bruges) (“Sensotec”, “we” or “us”) regarding your Personal Data (which may include Student Data) collected by Sensotec through the Licence Server, the Web Sites and the Application and processed as a Processing Officer.

The protection of Personal Data is of great importance to Sensotec. Sensotec respects your privacy and ensures that your Personal Data is processed in accordance with applicable legislation, in particular with Privacy Laws.

These Privacy Regulations set out what information is collected and processed, the purposes of the processing, with whom Personal Data may be shared, and the choices you may make regarding Sensotec’s use of your Personal Data. It also describes the measures taken to ensure the security of your Personal Data and how you can contact Sensotec to exercise your rights of access, rectification, erasure, restriction of processing, transferability, withdrawal of your consent and objection.

By visiting or using the Websites, downloading, installing or using the Application, and/or entering Personal Data on the Licence Server, you confirm that you have received, read and understood these Privacy Regulations.

Please note that before using or providing Personal Data in any section of the Website, Application or Licence Server, you may be required to confirm your consent to these Privacy Regulations electronically by checking a specific box. Your affirmative action [ticking the relevant box] and your use of the Website, the Application and/or the Licence Server imply your consent to the collection, processing, use and transfer of your Personal Data as described in these Privacy Regulations.

Our registration of your consent to these Privacy Regulations, with its date and any future amendments to these Privacy Regulations, will be considered as conclusive written evidence of your consent.

2. Definitions

Application: the Sensotec application (Kurzweil 3000-software suite (incl. Kurzweil 3000 Mobile), WoDy software suite, Alinea software suite, Lezergame software suite);
Application Account: the account created by a User or Educational Institution on the Licence Server that allows access to the Application;
AVG: Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EG (”General Data Protection Regulation”);
User or You: Each person who has installed the Application and/or has an Application Account;
Google: Google, Inc., with registered office at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;
Licence Server: the Sensotec Licence Server that controls Application account management: lic.sensotec.be and onestepreaderlic.sensotec.be;
Educational Institution: A person who enters Student Data or Employee Personal Data (such as teachers, IT administrators, etc.) on the Licence Server;
Personal Data: all information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Privacy Laws: the AVG and its implementation laws;
Privacy Regulations: The current privacy regulations;
Sensotec: Sensotec NV, with registered office at Vlamingveld 8, 8490 Jabbeke, Belgium and registered with the Kruispuntbank for Businesses under number 0429.286.663 (RPR Bruges);
Student Data: Personal data of students and/or pupils of an Educational Institution obtained by Sensotec from the respective Educational Institution;
Processing Officer: a natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the Processing of Personal Data;
Processing, Handling or Transfer: any operation or set of operations which is performed upon Personal Data or any set of Personal Data, whether or not by automatic means, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, deletion or destruction of Personal Data;
Processor: a natural person or legal entity, a public authority, an agency or another body that processes Personal Data on behalf of the Processing Officer;
Websites: The following websites managed by Sensotec: www.sensotec.be, www.dyslexie.be, www.anderslezen.be, www.knfbreader.com, www.online-daisy.com, webshop.sensotec.be.

3. For what purposes does Sensotec collect Personal Data?

We collect and process your Personal Data for the following purposes:

To make the Application and Licence Server available to you, including downloading, installing, registering, using, and accessing the Application and Licence Server (account management). Your Personal Data will be processed if the processing is necessary for the performance of an agreement, or in order to take measures, at your request, to conclude an agreement – Article 6, 1.., (b) AVG.
In addition, your Personal Data will also be processed on the basis of your consent – Article 6, 1., (a) AVG.

To administer the Application and Licence Server operationally, block access to it, make further updates available, and improve and/or modify the Application and Licence Server (operational management). Your Personal Data will be processed if the processing is necessary for the performance of an agreement, or in order to take measures, at your request, to conclude an agreement – Article 6, 1.., (b) AVG.
In addition, your Personal Data will also be processed on the basis of your consent – Article 6, 1., (a) AVG.

To answer your questions, handle complaints, troubleshoot problems and communicate with you for purposes related to the Application and Licence Server (service & support). Your Personal Data will be processed if the processing is necessary for the performance of an agreement, or in order to take measures, at your request, to conclude an agreement – Article 6, 1.., (b) AVG.
In addition, your Personal Data will also be processed on the basis of your consent – Article 6, 1., (a) AVG.

To analyse and report on the use of the Application and Licence Server, and to personalise and manage your experience. Your Personal Data will be processed if the processing is necessary for the performance of an agreement, or in order to take measures, at your request, to conclude an agreement – Article 6, 1.., (b) AVG.
In addition, your Personal Data will also be processed on the basis of your consent – Article 6, 1., (a) AVG.

To allow you to register online via the Websites or in person (e.g. at a trade fair) for the following purposes: to attend workshops and information sessions, to request demo versions of the software, to be contacted by us if you are interested in our products or services and to sign up for our newsletters and mailings. Your Personal Data is processed because the processing is necessary for the representation of the legitimate interests pursued by Sensotec, by our affiliated companies or by other third parties (such as, in particular, existing or potential business partners, suppliers, customers, government authorities or courts), except when your interests or your fundamental rights and freedoms outweigh these interests – Article 6, 1., (f) AVG.
In addition, your Personal Data will also be processed on the basis of your consent – Article 6, 1., (a) AVG.

In order to fulfil other legitimate purposes which were communicated to you at the time you provided your Personal Data Your Personal Data is processed because the processing is necessary for the representation of the legitimate interests pursued by Sensotec, by our affiliated companies or by other third parties (such as, in particular, existing or potential business partners, suppliers, customers, government authorities or courts), except when your interests or your fundamental rights and freedoms outweigh these interests – Article 6, 1., (f) AVG.

We may use your Personal Data when this is necessary in order to comply with a legal obligation. Your Personal Data will be processed because the processing is necessary to comply with a legal obligation incumbent on Sensotec – Article 6, 1., c) AVG.

4. To whom can Sensotec disclose Personal Data?

We will not sell or otherwise disclose your Personal Data, except as described below or with your prior express consent.

It may be necessary to share your Personal Data:

in the case of a merger, acquisition, sale of assets, joint venture or any other transaction which results in a change in the ownership structure, in whole or in part, of Sensotec; or in the event of a company reorganisation, bankruptcy, insolvency proceedings, or similar circumstances, if such proceedings are permitted under the applicable law and were carried out in accordance with the applicable provisions;
with third party service providers acting on our behalf and under our instructions (as Processors), for example, to manage servers and store backup information. These third parties can only use the data for the above-mentioned purposes and under the specific instructions from Sensotec. Any other use is prohibited. By default, we will provide the Sensotec Authorised Distributor, from whom you obtained your Application (subscription) licence, with access to the Personal Data you provided Sensotec.

Sensotec will not disclose your Personal Data to other third parties without your prior express consent, unless required to do so by law or court order. In particular, Sensotec can share your Personal Data in the following circumstances:

to comply with a court order, or the order of a competent authority, or in other cases permitted or required by law;
to respond to an emergency, or to otherwise protect the rights, property, and safety of third parties, Users, or the public.

These recipients may be located in countries other than the country where the Personal Data was originally collected. Your personal data will mainly be transferred within the European Economic Area or to other countries recognised by the European Commission because they have the same level of Persona Data Protection.

Nevertheless, such consignees may be located in countries that do not provide an adequate level of protection from AVG’s point of view. In that case, Sensotec will take all necessary measures to ensure that transfers from the European Economic Area are adequately protected as required by the GCPSC. For example, Sensotec will base such transfers on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, adopted codes of conduct together with binding and enforceable obligations on the recipient, or recognised certification mechanisms, together with binding and enforceable obligations on the recipient.

Only a limited number of people within Sensotec will have access to your Personal Data on a “need-to-know” basis (e.g. sales staff, the legal department, the finance department, the IT department, the accounting manager, as well as certain managers with delegated powers).

5. What Personal Data can Sensotec collect or process?

Information you provide

When you download, install or use the Application and/or when you create or modify an Application Account through the Licence Server, you will be prompted to provide the following (optional) information to Sensotec: user name, password, surname and first name, e-mail address, language, national registration number, address, country, telephone/mobile number, supervisor (yes/no), supervisor position, organisation, year of birth.

In addition, you are asked to provide the following (optional) information to Sensotec when you register via the Websites or in person to attend workshops and information sessions, to request demo versions of the software, to be contacted by us if you are interested in our products or services and/or to sign up for our newsletters and mailings: surname and first name, e-mail address, language, address, country, telephone/mobile number, gender, position, interest, how you heard about Sensotec.

Automatically collected information

Subject to your consent, if required by law, we and our third party service providers may use certain technologies that collect and provide information about how the Website, the Application and the Licence Server are used. Such information may consist of:

device data: technical data relating to your computer, mobile device or other device on which you download, install or use the Application or from which you access the Licence Server and the Website, including the model, manufacturer, operating system, language settings, device settings, device identifier, IP address used, and browser type;
interaction data with the Application: profile settings, activated spelling and correction rules, spelling corrections and/or predictions made, use (including frequency) of the Application and the Licence Server.

Such information cannot generally be linked to you individually, but if it is, we will treat it as Personal Data in accordance with these Privacy Regulations.

Some information is collected through the use of cookies when you visit the Websites or the Licence Server, or when you download, install or use the Application. Sensotec uses cookies and similar technologies as described in our cookie policy available at [www.sensotec.be/cookies]. By clicking on the [”OK”] button on the Sensotec cookie banner, you agree to our use of cookies and similar technologies in line with your current cookie settings and our cookie policy [www.sensotec.be/cookies]. If you do not agree to our use of cookies, you must set your browser settings accordingly. You can withdraw your consent at any time and change your choice by changing your browser settings. If you disable the cookies we use, this may affect your user experience on the Websites, Licence Server and/or Application.

Automatically collected information in case of product Lezergame
Sensotec is not gathering any information automatically in the app Lezergame.
However, the app uses third party services that may collect information used to identify you. These third parties are Google Play and Unity. These are the links to the privacy policy of these parties:
Google Play
Unity

Automatically collected information in case of product Alinea app

The app will open files from your Google Drive and store documents from the app on your Google Drive. No data will be shared outside of the app. You can read the Google Cloud disclosure here. Sensotec is not gathering any information automatically in the app Alinea. However, the app uses third party services that may collect information used to indentify you. These third party is Google Play. This is the link to the privacy policy of this party: Google Play

6. Is Sensotec responsible for other websites?

Websites may contain references (by means of a hyperlink, banner or button) to other sites that are related to (a specific part of) this Website. This does not mean, therefore, that Sensotec is linked to these websites or their owners.

These websites are not under the control of Sensotec. We are not responsible for the content of these websites and for the products or services offered on these websites, nor for any other use of these websites or for the data processing and privacy practices of these websites. We therefore ask you to always carefully check the privacy regulations of these websites at the time you visit these websites and before you provide Personal Data to these websites.

7. How is your Personal Data protected by Sensotec?

Sensotec takes appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the Personal Data, and against any other unlawful form of Processing as provided for by applicable law. Sensotec shall also require from any service provider or Processor who has provided Personal Data on behalf of Sensotec that he takes the appropriate technical and organisational measures.

However, please note that no electronic transmission or storage of information is 100% secure. Therefore, despite the security measures in place to protect your Personal Data, we cannot guarantee that destruction, loss, alteration, unauthorised disclosure or access will never occur.

8. What are your rights?

Under applicable privacy laws, and subject to the terms and conditions set forth herein, you have the following rights:

the right to access and inspect the Personal Data that Sensotec holds about you;
the right to have your Personal Data corrected;
the right to erasure of your Personal Data;
the right to (temporarily) limit the Processing of your Personal Data;
the right, in certain circumstances and for legitimate reasons, to object to the Processing of your Personal Data (including the right to object, free of charge, to the Processing of Personal Data for the purposes of direct marketing);
the right to the transferability of your Personal Data;
the right to withdraw your consent;
the right to lodge a complaint with the Data Protection Authority.

If you wish to exercise your rights under applicable law, or for further details and questions relating to the data processing activities of Sensotec, you may contact us at any time by sending a written, dated and signed request (together with a copy of your valid identity card or any other valid identity document) to the Sensotec Help Desk as set out in Section 11 of these Privacy Regulations.

9. Can these Privacy Regulations be amended?

Sensotec continuously modifies and enhances the Application, Licence Server and Websites through updates and upgrades. Therefore, to the extent not prohibited by applicable law, Sensotec may amend these Privacy Regulations in whole or in part at any time.

Sensotec will notify any change to these Privacy Regulations by posting a notice in the Websites, Licence Server and Application and will indicate at the top of the Privacy Regulations the date when they were last modified. The amended Privacy Regulations will be deemed to be available to the User on the date on which they are made available in the Application via the update or upgrade. Users are deemed to have accepted the change(s) if they tick the corresponding box and continue to use the Application.

10. How long do we store your Personal Data?

Your Personal Data will not be kept for longer than is reasonably necessary for the purposes stated herein, up to a maximum of ten years after the end of your contractual relationship with Sensotec (if any), unless shorter or longer retention periods apply under applicable law.

11. Who can you contact should you have any queries or requests?

If you have any queries, comments or complaints regarding these Privacy Regulations, or if you wish to exercise your rights under applicable law, please contact the Sensotec Help Desk:
Sensotec NV Help Desk
Vlamingveld 8
8490 Jabbeke, Belgium
E-mail: support@sensotec.be
Website: www.sensotec.be