1.1 We are committed to safeguarding the privacy of our service (Florence website, Florence Facebook bot, Florence Skype
bot and Florence Kik bot) users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, "we", "us" and "our" refer to PACT Care BV. For more information about us, see Section 7 or visit our company website https://pact.care.
1.5 All information you provide to us is stored on a third party secured cloud servers (Microsoft Azure Cloud). We take appropriate steps to maintain the security of your data on our service. The security of your personal information is important to us, but remember that no method of transmission over the internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our service ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system length of visit, page views and website navigation on our website. The usage data on our chatbot may include your user ID associated to your account (depended of Skype, Facebook or Kik). The source of the usage data of our chatbot is provided through the specific platforms (Skype, Facebook or Kik) and on our website through Google Analytics. This usage data may be processed for adapting the chatbot and website experience according to your platform. The legal basis for this processing is consent.
2.3 We may process your account data ("account data"). The account data may include your nickname, gender, year of birth, health goal and time zone. The source of the account data is you. The account data may be processed providing our services and communicating with you through our chatbot. The legal basis for this processing is consent.
2.4 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include feedback data, email (med friends), medication / pill reminder and health tracker related information (including type of reminder/tracker, frequency of data collection) as well as conditions and symptoms searched. The source of the service data is you. The service data may be processed for the purposes of providing our services. The legal basis for this processing is consent.
2.5 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.6 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Retaining and deleting personal data
3.1 This Section 3 sets out our data retention policies and procedure, which are designed to help ensure that
we comply with our legal obligations in relation to the retention and deletion of personal data.
3.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3.3 Your personal data will be retained for as long as is necessary in order to provide you with the services or deal with any specific issues. Once you delete your account the data will be deleted on our servers as well.
3.4 Notwithstanding the other provisions of this Section 3, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.1 We may update this policy from time to time by publishing a new version on our website.
4.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
4.3 We may notify you of significant changes to this policy through our service.
5. Your rights
5.1 In this Section 5, we have summarised the rights that you have under data protection law. Some of the rights are
complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant
laws and guidance from the regulatory authorities for a full explanation of these rights.
5.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
5.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
5.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
5.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
5.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
5.8 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
5.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
5.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
5.11 You may exercise any of your rights in relation to your personal data by written notice to us.
6. Third party services
6.1 Bot Framework: Our chatbot is enabled by Microsoft’s Bot Framework. Bot Framework is a set of web-services that enable
intelligent services and connections using conversation channels you authorize. As a service provider, Microsoft will
create a Bot Framework user profile and receive content you provide to our bot/service in order to enable the service
and to help improve Microsoft services. For more information about Microsoft privacy policies please see their privacy
statement here: http://go.microsoft.com/fwlink/?LinkId=521839. To report abuse when using a bot that uses Bot Framework
to Microsoft, please visit the Microsoft Bot Framework website at https://www.botframework.com and use the Report Abuse
link in the menu to contact Microsoft.
6.3 Furthermore, Florence is enabled by the following APIs:
(a) Google Places API, Google Maps API (Location Finder) and Time Zone API (Time zone detection), for more information about Google privacy policies please see their privacy statement here: https://www.google.com/policies/privacy
(b) Wikipedia (purpose information), https://wikimediafoundation.org/wiki/Privacy_policy
(c) Genderize.io (purpose automatic gender determination)
7. Our details
7.1 This service is owned and operated by PACT Care BV.
7.2 Our principal place of business is at Herengracht 420, 1017BZ, Amsterdam, Netherlands.
7.3 You can contact us:
(a) by post, to the postal address given above;
(b) by telephone +31 20 893 4143;
(c) by email, using info[at]pact[dot]care
7.4 Our data protection officer's contact details are: David Hawig, david[dot]hawig[at]pact[dot]care