California residents – please refer to “Privacy Notice for California Residents” below.
California residents – please refer to “Privacy Notice for California Residents” below.
Please note that this policy only covers Tobii Dynavox AB’s use of personal data. Sometimes, other companies buy or license our technology and use it to handle personal data as part of their service offering. In such cases you should refer to the privacy policies of those respective businesses.
Depending on which Services you use, we process different kinds of information from or about you.
Personal data and other information you (and others) give us. We collect the information that you (and others) give us when using our Services. For example:
Personal data and other information which is automatically collected about you when you use our services.
We also collect information automatically when you are connected to our Services. Depending on how you access and use our Services, we collect information such as:
Third parties may also collect information about you through the Services, or receive information collected about you through the Services, as described below.
We use the information as set out below and to provide our Services to you and our partners.
We use the information we collect to provide you with our Services. For example, we use this information to:
We also use the information that we collect to understand, develop and improve our Services. For example, we use the information to:
We use the information that we collect to send you promotional messages and content and otherwise market to you on and offer our Services. We also use this information to measure how users respond to our marketing efforts. If you would like to opt out of receiving marketing emails, then you can always do so by follow the instructions implemented in every such promotional message.
We use the personal data that we collect to help promote safety and security on and off our Services, such as by investigating suspicious activity or breaches of our terms or policies and protecting our or others’ rights or property.
To provide and support our Services, information that we have about you is shared in certain circumstances. The following can see information about you when you and others use our Services.
You can interact with third-party content, games, apps and other experiences through our Services. We may share information about you with these partners so they can provide you with the experiences that you've requested.
We share the information that we collect with vendors, service providers, researchers and other partners, who work at our direction to support the Services (such as hosting our Services, fulfilling orders, facilitating payments, analysing the way people use our Services, processing credit card payments, providing customer service or sending electronic communications for us).
In the event that the ownership of Tobii Dynavox AB (Publ) (or any portion of our assets) changes as a result of a merger, acquisition or in the event of a bankruptcy, information from or about you or your device may be transferred to another company.
We share information with law enforcement or in response to legal requests in the circumstances outlined in Section 7 below.
We also share de-identified or aggregate data with others. “De-identified data” means information where we have removed identifiable data such as your name and other data that could reasonably be used to identify you. “Aggregate data” is data that has been combined with other data so that it doesn’t identify any specific person. For example, we provide developers with aggregated statistics about the number of people from a particular region that use our Services, so developers can create content tailored for people in that market.
Some of the content, marketing and functionality on our Services may be provided by third parties that are not affiliated with us. For example, we work with companies that help us provide content within the Service that you purchased.
We store data that identifies you until it is no longer necessary for us to do so, for example when you delete an account with us. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, we may retain certain purchase information for accounting and tax purposes even after you have deleted your account.
When you delete an account with us, we delete or anonymize the data you provided us with and the data we collected during your use of the Services. Neither you nor we will be able to restore such deleted or anonymised data.
We share information globally, both internally within the Tobii Dynavox AB (Publ) and externally with our partners to fully provide the Services you are entitled to receive based on the Service you have purchased or subscribed to and/or otherwise are entitled to receive. Information controlled by Tobii Dynavox AB (Publ) will be transferred or transmitted to, or stored and processed in the United States, China and/or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary for us to globally operate and provide our Services to you. We utilize standard contract clauses approved by the European Commission and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EU/EEA to the United States and other countries.
The Data Protection Officer for Tobii Dynavox AB (Publ) can be contacted at firstname.lastname@example.org. You also have the right to lodge a complaint with the Swedish lead supervisory authority, the Datainspektionen, www.datainspektionen.se.
The legal ground for processing personal data varies depending on the types of data and the situation. The legal grounds we rely on at Tobii Dynavox AB (Publ) are the following:
Under the General Data Protection Regulation, you have the right to:
You have the right to obtain from Tobii Dynavox AB (Publ) a confirmation of whether or not personal data concerning you is being processed, and if that is the case, a right to access information including, but not limited to, the purpose of the processing and the categories of personal data that Tobii Dynavox AB (Publ) has concerning you. By your request, Tobii Dynavox AB (Publ) is required to provide you with a copy of undergoing processing of your personal data.
If it comes to your knowledge that certain personal data of yours which is being processed by Tobii Dynavox AB (Publ) is inaccurate, you have the right to obtain a rectification and, in some cases, a right to have incomplete data completed.
If the legal ground for a processing of personal data is based on either (i) consent or (ii) fulfilment of a contract between you and Tobii Dynavox AB (Publ), you have a right to receive data which you have provided us in a commonly used and machine-readable format and have the right to transmit such data to another controller.
You have the right to obtain from Tobii Dynavox AB (Publ) the erasure of your personal data when, for example, (i) the data no longer is necessary in relation to the purpose for which it was collected, (ii) if you withdraw a consent, (iii) if you object to the processing and there are no overriding legitimate grounds for the processing, or if (iv) the personal data have been unlawfully processed.
You have the right to restrict Tobii Dynavox AB (Publ) from processing your data when, for example, (i) you contest the accuracy of the personal data, or (ii) if Tobii Dynavox AB (Publ) no longer needs certain data for the purposes of the processing.
Find out more about these rights, and how you can exercise them by either contacting Tobii Dynavox AB (Publ) at email@example.com or obtain information from the appropriate supervisory authority.
The data controller responsible for your information is Tobii Dynavox AB (Publ) which you can contact by e-mail at firstname.lastname@example.org or by post at:
Attn: Data Protection Officer
Tobii Dynavox AB (Publ):
115 50 Stockholm
Effective Date: January 1, 2020
This California Privacy Notice (this “notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to Tobii Dynavox AB (Publ)’s (“Company” “us” “we” our”) other privacy policies or notices.
To aid in readability, in some places we have abbreviated or summarized CCPA terms or language. Terms defined in the CCPA that are used in this notice shall have the same meaning as in the CCPA.
For more information on this notice or your California privacy rights, email us at email@example.com or, write to us at: Att: Data Protection Officer, Tobii Dynavox AB (Publ), Löjtnantsgatan 25, 115 50 Stockholm, Sweden.
We have collected the following categories of personal information from consumers within the last twelve (12) months:
This may include but is not limited to a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, citizenship status or other similar identifiers.
This may include information such as: physical characteristics or description, signature, telephone number, employment.
This may include, but is not limited to browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.
As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as personal information and we reserve the right to convert, or permit others to convert, your personal information into deidentified data or aggregate consumer information.
Subject to restrictions and obligations of the CCPA, our vendors may also use your personal information for some or all of the above listed business purposes. Our vendors may themselves engage services providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an additional business purpose for which we are providing you notice.
We may share personal information with third parties for a business purpose. In the last twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the last twelve (12) months, we have not sold any personal information.
We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification process. We will not fulfil your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information.
If we cannot comply with a request, we will explain the reasons in our response. We will use personal information provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or clearly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Additionally, you have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining. Once we receive and confirm your request, we will disclose to you:
Except to the extent, we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your personal information that we did not collect directly from you.
We do not sell your personal information as such is defined under the CCPA, and until such time as we change this policy by updating this notice, will treat personal information collected under that policy as subject to a do not sell request.
Notwithstanding anything to the contrary, we may collect, use and disclose your personal information as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honour any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will notify you through a notice on our website homepage.
If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
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