Date of last revision: 30 January 2017
ORTEC International BV, a Dutch corporate entity registered in the registry of commerce of Zoetermeer, the Netherlands and all its subsidiaries and affiliated companies, (hereinafter “ORTEC”, “We”, “Our” or “Us”) may process Information (as defined below) of people downloading, registering with, accessing or using an ORTEC software application developed for mobile devices and any other mobile applications that ORTEC may develop and offer in the future, hereinafter collectively the "ORTEC Apps" and individually an “ORTEC App”) in order to provide better services and a better user experience.
You also acknowledge that Your download of, register with, access to or use of an ORTEC App may be subject to an active License Agreement and any conflict between this Policy and the licensing terms and conditions will be determined in favor of the latter.
This Policy may be updated from time to time for any reason. You are advised to consult this Policy regularly for any changes, as Your continued access to or use of an ORTEC App after We make changes to this Policy is deemed to be acceptance of those changes.
If You do not agree with this Policy, You may not download, register with, access or use an ORTEC App.
This Policy applies to Information You provide to Us as well as to Information provided to Us by third parties or that We collect automatically or through cookies and similar technologies when You download, register with, access or use one or more ORTEC Apps.
This Policy classifies those downloading, registering with, accessing or using an ORTEC App (hereinafter “You”, “Your”) as one of the following:
- CUSTOMERS: Natural persons and entities that are ORTEC direct customers and are authorized to use an ORTEC App pursuant to an active License Agreement or under a temporary license if the case, are referred collectively as “Customers” and individually as “Customer”.
- END-USERS: Customers’ business contacts, which may include their own current and prospective clients, members or other third party contacts that use ORTEC Apps to interact with such Customers as well as Customers’ personnel that are assigned an username and password and are authorized by such Customers to use an ORTEC App, are referred to collectively as “End-Users” and individually as “End-User”.
This Policy classifies the Information as “Personal Data” and/or “Non-Personal Data” as the case may be:
This Policy does not apply to:
- Personal Data means any information relating to an identified or identifiable natural person. An identifiable natural person is one natural person 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.
- Non-Personal Data / Other Information means any information that does not result in the identification of a natural person.
This Policy will explain:
- Information You provide to or which is collected automatically by third parties, including through any third party application, website or services that may be accessible from ORTEC Apps. If You are an End-User, within the meaning of this article, third parties are understood to be any natural person or legal entity other than You and ORTEC, including Our Customers that You interact with directly and which may collect Your Information on or through ORTEC Apps. We encourage You to familiarize yourself with the privacy policies of such third parties before You interact with it. ORTEC does not exercise any control over the privacy policies of such third party and if You allow such a third party to access Your Information You do so at Your own risk. Consequently, ORTEC declines all liability for the practices of such third party concerning the process of Your Information.
3. WHAT INFORMATION DOES ORTEC COLLECT AND HOW DOES ORTEC COLLECT IT?
- WHAT INFORMATION DOES ORTEC COLLECT AND HOW DOES ORTEC COLLECT IT?
- HOW DOES ORTEC USE YOUR INFORMATION?
- HOW DOES ORTEC DISCLOSE YOUR INFORMATION?
- HOW DOES ORTEC STORE AND PROTECT YOUR INFORMATION?
- WHAT CHOICES YOU HAVE REGARDING YOUR INFORMATION?
- CHILDREN’S PRIVACY
- QUESTIONS OR CONCERNS
- APPLICABLE LAW AND JURISDICTION
Depending on which ORTEC App You download, register with, access or use, ORTEC collects different kind of Information from or about You.
Information You Provide Directly
. When You download, register with, access or use an ORTEC App, You may provide Us certain Information including Personal Data such as Your first and last name, postal address, email address, phone number, mobile device ID, username and password and other information that may identify You. If you download, register with, access or use an ORTEC App, using Your login credentials from one of Your social networking service accounts, We will be able to access and collect certain Information including Personal Data that Your privacy settings on the social networking service accounts permit Us to access.
You may also provide Non-Personal Data, such as information that You provide by filling in forms in an ORTEC App, details of operations You carry out through an ORTEC App, Your search queries on an ORTEC App etc.
If You provide Us with certain Information including Personal Data belonging to another natural person, ORTEC does not assume any responsibility for such transfer of Information towards Us and You are responsible for providing any notices and/or obtaining any consents from such person necessary for ORTEC to process the Information as specified under this Policy.
Certain Information You provide when You download, register with, access or use an ORTEC App, may be stored locally on Your mobile device and is not transmitted to or collected by ORTEC. Although ORTEC does not collect such Information, please be aware that any Information stored on Your mobile device may leave such device through automatic backup processes, manual download and through other means. In addition, Your activities on Your mobile device outside an ORTEC App may result in such Information being transmitted to or otherwise collected by authorized or unauthorized third parties, including through the other Apps You access, the websites You visit, and by parties who may gain unauthorized access to Your mobile device or Information. Any Information stored on Your mobile device or transmitted over the Internet or any data network could be accessed or intercepted by unauthorized third parties. As a result, You acknowledge that ORTEC cannot assure that such Information will remain private and You provide it at Your own risk.
Information We Collect from Third Parties.
ORTEC may receive certain Information about You including Personal Data such as Your first and last name, postal address, email address, phone number, mobile device ID, username and password and other information that may identify You from third parties. If You are an End-User, within the meaning of this article, third parties are understood to be any natural person or legal entity other than You and ORTEC, including Our Customers that You interact with directly and which may provide Us access to their production, development or test environment where Your Information is stored. ORTEC does not assume any responsibility for such transfer of Information towards Us and such third party is responsible for providing any notices and/or obtaining any consents from You necessary for ORTEC to access, use, retain and transfer Information as specified under this Policy
Information We Collect Automatically
. ORTEC may also receive and collect certain Information about You and Your mobile device automatically when You download, register with, access or use an ORTEC App. This Information may include:
Information We Collect Through Cookies and Similar Technologies
- Device Information
ORTEC may collect Information about Your mobile device and internet connection, including the device model, the device's unique device identifier, operating system, device settings, battery and signal strength, Your Internet or mobile service provider, IP address, browser type, mobile network information and the device's telephone number.
- Usage Information
When you download, register with, access or use an ORTEC App, ORTEC may automatically collect certain Information of Your access to and use of the App, including the specific ORTEC App You use, the features of the ORTEC App You use, traffic data, location data, logs and other communication data, date and time of Your use and the resources that You access and use on or through an ORTEC App.
- Location Information
ORTEC may collect Information about Your location including approximate location (network-based) as well as precise location (GPS and network-based). Location data may convey to Us Information about how You use the ORTEC App. Some features of the ORTEC Apps, particularly location-based features, may not function properly if use or availability of location data is impaired or disabled.
- Information and Files stored on Your mobile device
- Find Your accounts
ORTEC Apps do not recognize or save Your account information for any programs. ORTEC Apps only detect whether You have a Google account (or any other account use to download, register with, access or use an ORTEC App) linked with the mobile device which helps Us confirm the state of Google Service and provide You with appropriate application download and update methods.
- Find, read or modify Your contacts
ORTEC Apps do not save or upload Your contacts. Permission to access contact information is used when You search and/or modify contacts from within the ORTEC App.
- Read, modify or delete the contents of your USB storage (example: SD card)
- This permission allows ORTEC Apps to view, modify or delete application data (image, text, audio etc..) stored on Your mobile device.
- Phone call Information
- Directly call phone numbers
ORTEC Apps may use Your mobile device in order to make calls. Depending on Your plan, You may be charged by Your carrier for phone calls. However, such permission is used only when required in order for You to make calls from within the ORTEC App and for verification purposes.
- Read phone status and identity
This permission allows ORTEC Apps to recognize an incoming / outgoing call and to show the caller name while some one is calling.
- Information regarding the calendar of Your mobile device
- Read calendar events plus confidential information
This permission grants ORTEC Apps read access to Your calendar for viewing an already created calendar event. ORTEC Apps do not save or upload any of Your calendar information.
- Add or modify calendar events and send email to guests without owners' knowledge
- This permission grants ORTEC Apps write access to Your calendar for adding new events to it. The possibility to “send email to guests without owners' knowledge” is technically only an implicit consequence of the “write access” permission and is not and will not be done by ORTEC at all.
- Information regarding pictures/videos
- ORTEC Apps may use Your mobile device's camera in order to take pictures/videos and turn ON/OFF Camera Flash. Permission to access Your device’s camera is used only when required and lets You take pictures/videos from within the ORTEC App
- enabling ORTEC App to recognize Your mobile device so You do not have to give the same information several times during one task;
- recognizing that You may already have given a username and password so You do not need to do it for every features of the ORTEC App requested;
- measuring how many people are using ORTEC App, so they can be made easier to use and there is enough capacity to ensure they are fast;
- analyzing data to help ORTEC understand how You interact with ORTEC Apps so ORTEC can make them better.
ORTEC uses two types of cookies: permanent cookies and temporary cookies. Temporary cookies disappear as soon as You log off from ORTEC App. Permanent cookies remain after logging off from the ORTEC App in order to be used on subsequent use of the ORTEC App.
You will be notified the first time You receive a cookie, and then You decide whether to accept it or refuse it. By continuing to use the ORTEC App in consideration of the above, You expressly authorize ORTEC to use such cookies.
You can also configure the ORTEC App to refuse all cookies; if You do so, however, some areas and features of the ORTEC App may not function properly and/or You may not access some parts of ORTEC App.
To assist Us in improving the ORTEC Apps, We may, directly or through a third party analytics tools, collect analytics data, measure traffic and usage trends for the ORTEC Apps, including the features You use, how often You use the ORTEC Apps, the events that occur within the ORTEC Apps, aggregated usage, performance data and other relevant information which helps Us enhancing, improving and modifying ORTEC Apps. Currently ORTEC uses two analytics tools (i.e. Xamarin Insights and HockeyApp) that answers vital questions about the health of ORTEC Apps and provides comprehensive details on how You interact with ORTEC Apps.
You are not required to provide to ORTEC any Information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, or other sensitive Information in order to use ORTEC Apps.
4. HOW DOES ORTEC USE YOUR INFORMATION?
The Information collected by ORTEC on or through the ORTEC Apps is used by ORTEC for the following purposes:
5. HOW DOES ORTEC DISCLOSE YOUR INFORMATION?
- To allow You to register with an ORTEC App and to maintain such registration (if the case);
- To enable You to access all the features offered by an ORTEC App;
- To provide You the needed maintenance and support services for an ORTEC App;
- To ascertain Your requirements and interests and to provide You with the most suitable products and/or services;
- To combine it with other Information We receive from third parties, to help understand Your needs and provide You with better products and/or services;
- For Our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing and delivering new products and service, enhancing, improving and modifying ORTEC Apps, understanding and analyzing trends in connection with usage of ORTEC Apps, determining the effectiveness of our ORTEC Apps and expanding Our business activities.
- As We have a good faith belief to be necessary or appropriate: (a) under applicable law, including laws outside Your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside Your country of residence; (d) to enforce or apply Our licensing terms and conditions; (e) to protect Our operations; (f) to detect, prevent, or otherwise address fraud, security or technical issues; and (g) to protect against harm to the rights, property or safety of ORTEC, Our Employees, Customers and End-Users or any third party as required or permitted by law.
- Any other purposes associated with the above purposes.
- The collected Non-Personal Data may be used for any reasonable purpose.
- You will have the opportunity to decide whether You authorize ORTEC to use Your Information for a purpose differing from the purpose for which it was originally collected.
We do not disclose Your Information to third parties without Your consent unless otherwise stated under this Policy. The disclosed Information may be transmitted over the internet, via mail, via facsimile, or by any other method which ORTEC determines is appropriate and in accordance with applicable law.
As part of a global group of companies, ORTEC is able to use available technology to efficiently manage Your Information and obtain such Information online or otherwise throughout its international operations. Your Information may be collected through the ORTEC App and subsequently disclose to and be used by a subsidiary and/or an affiliated company of ORTEC as specified under this Policy.
Customer that You Interact with Directly.
With respect to End-Users Information, ORTEC processes the Information under the direction of its Customers and has no direct relationship with the natural persons whose Information it processes. Therefore, if You are an End-User, any Information You provide to Us as well as any Information provided to Us by third parties or that We collect automatically or through cookies and similar technologies when You download, register with, access or use one or more ORTEC Apps may be transferred to the Customer that You interact with directly. Although ORTEC own use and disclosure of Your Information will be in compliance with this Policy, ORTEC cannot and does not take responsibility for the privacy practices of the Customer that You Interact with Directly.
Third Party Business Partners.
ORTEC may also disclose Your Information to Third Party Business Partners who globally support Our business if ORTEC determines that such disclosure is necessary for providing their products or services to You or Us including without limitation developing services, technical infrastructure services (such as hosting services), maintenance and support services. However, these third parties are not authorized by ORTEC to use Your Information for any purpose except as necessary to provide their products or services to You or Us. Where ORTEC has knowledge that such a third party to which ORTEC has disclosed Your Information is using or disclosing such Information contrary to this Policy or to applicable law, ORTEC will take reasonable steps to prevent or stop such use or disclosure.
ORTEC may disclose Your Information for the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of Our business or assets (business deals may include, for example, any merger, financing, acquisition, divestiture or dissolution transaction or proceeding). In the event of an insolvency, bankruptcy, or receivership, Your Information may also be disclosed as a business asset.
ORTEC may share Your Information with companies, organizations or individuals outside ORTEC Group if We have a good faith belief that access, use, preservation or disclosure of the Information is reasonably necessary to:
- meet the applicable law, regulation, legal process or enforceable governmental request including law, regulation, legal process or enforceable governmental request outside Your country of residence;
- enforce or apply Our licensing terms and conditions, including investigation of potential violations;
- protect Our operations;
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of ORTEC, Our Employees, Customers and End-Users or any third party as required or permitted by law.
ORTEC may share Your Non-Personal data publicly and with Our partners for example to show trends about the general use of ORTEC Apps.
6. HOW DOES ORTEC STORE AND PROTECT YOUR INFORMATION?
Storage and Processing. ORTEC is a global corporation with operations worldwide (Click here for ORTEC current office locations) and Your Information including Personal Data such as Your first and last name, postal address, email address, phone number, mobile device ID, username and password and other information that may identify You collected through ORTEC Apps may be stored and processed in Your country of residence as well as in other countries or jurisdictions around the world in which ORTEC, its Customer or any Third Party Business Partners maintain facilities. By downloading, registering with, accessing or using an ORTEC App, You consent to the storage and process of Your Information in Your country of residence as well as in other countries or jurisdictions around the world which may not have the same data protection laws as Your country of residence.
Information Retention. We will retain Your Information including Personal Data such as Your first and last name, postal address, email address, phone number, mobile device ID, username and password and other information that may identify You for as long as Your account is active and/or as long as You use the ORTEC Apps and for a reasonable time thereafter in order to comply with Our legal obligations, to resolve disputes and to enforce our agreements.
ORTEC cares about the security of Your Information. However, no security system can be 100% effective and ORTEC cannot guarantee that Your Information will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to keep the safety and security of Your Personal Data. This includes maintaining commercially reasonable physical, electronic and procedural safeguards to preserve the integrity and security of Your Personal Data which was collected through ORTEC Apps both during transmission and once We receive it. For example, as part of those safeguards, ORTEC employs sophisticated technology designed to protect Personal Data during its transmission and prevent transmission errors or unauthorized acts of third parties. Moreover, Our policy is that We limit access to Your Personal Data only to authorized employees and contractors that have a justified need to know such information in order to perform a specific task. Finally, all employees and contractors are bound by a duty of confidentiality and subject to disciplinary actions and/or other sanctions if they fail to meet these obligations.
In the event that any of Your Personal Data which was collected through ORTEC Apps is compromised as a result of a breach of security, ORTEC will promptly notify You and will take any other steps in accordance with any applicable law and regulations.
7. WHAT CHOICES YOU HAVE REGARDING YOUR INFORMATION?
Access to Your Information.
ORTEC acknowledges that You have the right to access Your Personal Data. Upon request, ORTEC will provide You with information about whether ORTEC processes on its own behalf and/or on behalf of a Customer any of Your Personal Data.
If ORTEC processes Your Personal Data on its own behalf and You wish to request to review, correct, amend, delete, limit the use or disclosure of Your Personal Data, please contact Us at email@example.com, Attention: Privacy. We will respond to Your request within a reasonable timeframe.
If ORTEC processes Your Personal Data on behalf of a Customer and You wish to request to review, correct, amend, delete, limit the use or disclosure of Your Personal Data, please contact the Customer that You interact with directly and/or contact Us at firstname.lastname@example.org, Attention: Privacy by providing also the name of the aforementioned Customer and ORTEC will refer Your request to such Customer.
Opt-Out for Information We Collect Through Cookies and Similar Technologies.
Please refer to Your mobile device for instructions on how to delete and disable cookies and other similar technologies. Depending on the type of Your mobile device, it may not be possible to delete or disable cookies and other similar technologies. Moreover, note that disabling cookies and other similar technologies may disable many of the features available through the ORTEC Apps.
Opt-Out for All Information.
ORTEC provides You with the right to opt out and stop all collection of Information by the ORTEC Apps easily by uninstalling the ORTEC Apps (with the prior consent from the Customer that You interact with directly if applicable). You may use the standard uninstall processes as may be available as part of Your mobile device.
8. CHILDREN’S PRIVACY
ORTEC does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons download, register with, access or use an ORTEC App. The ORTEC Apps are not directed at children under the age of 13. In the event that We learn that We have collected Information from a child under age 13 without verification of parental consent, We will delete that Information as quickly as possible. If you believe that We might have any Information from or about a child under 13, please contact Us at email@example.com, Attention: Privacy.
9. QUESTIONS OR CONCERNS
Please direct any questions or concerns that You may have regarding this Policy at firstname.lastname@example.org, Attention: Privacy. Please provide Your name, contact number, email address and all relevant details along with Your question or concern, so that We can review and respond to Your question or concern in an efficient and effective manner.
10. APPLICABLE LAW AND JURISDICTION