Data protection for Altra
The Altra app is offered to you by the respective nursing home or senior living community (“nursing home”). If you register via Altra, receive or send messages, the nursing home is responsible for this data processing and uses Altra Health limited as a so-called processor. This means that Altra Health limited processes this data exclusively on behalf of and in accordance with the requirements of the nursing home. In addition, Altra Health limited collects certain personal data on its own responsibility, regardless of the respective nursing home. We inform you about this data processing in this data protection declaration. You can access this information at any time at https://help.altra.ie/en/articles/5050699-data-protection-privacy-policy-for-altra-family
1. Responsible body / contact / data protection officer
The responsible body for the processing of data described in this data protection declaration is:
Altra Health limited, 69 Marlborough Road, Donnybrook, D04X3C3
If you have any questions or suggestions about data protection, you can also send us an email at [email protected].
You can contact our data protection officer at [email protected].
2. Collection and use of your data
If you send us inquiries via our contact form, chat support or by e-mail, your details from the contact form, including the contact details you provided there (name, e-mail address, messages) or the details from your e-mail, will be processed for the purpose of processing the request is saved and used. We collect this data in order to be able to receive and process your request, Art. 6 Abs. 1 lit. b GDPR. If we process your data, as described above, for the purpose of receiving and processing your inquiries, you are contractually obliged to provide us with this data. Without this data, we are not able to receive and process your inquiries. We save your inquiries for a period of 12 months after your inquiry has been fully processed, In order to be able to understand in the case of further inquiries from you whether there have been technical difficulties with the app in the past and to be able to process your request optimally. If we are legally obliged to do so, we can also save your request beyond this period. In this case, however, your request will only be stored and used for the purpose of legal storage.
Our app uses the following permissions:
Take photos / make videos
Record sound / voice messages
4. Automated individual decisions or profiling measures
We do not use automated processing processes to bring about a decision or profiling.
5. Transfer of data
In principle, your personal data will only be passed on without your express prior consent in the following cases:
This data is passed on on the basis of our legitimate interest in combating abuse, prosecuting criminal offenses and securing, asserting and enforcing claims and that your rights and interests in the protection of your personal data do not outweigh your interests, Art. 6 Para. 1 lit . f GDPR or based on a legal obligation according to Art. 6 Para. c GDPR.
We rely on contractually affiliated external companies and external service providers ("processors") to provide the services. In such cases, personal data is passed on to these processors in order to enable them to continue processing. These processors are carefully selected by us and regularly checked to ensure that your rights and freedoms are protected. The contract processors may only use the data for the purposes specified by us and are also contractually obliged by us to treat your data exclusively in accordance with this data protection declaration and German data protection laws.
In detail, we use the contract processors listed below. Insofar as personal data is transferred to third countries in this context, we ensure that this is done in accordance with the requirements of Art. 44 ff GDPR. DPAs with the service providers we use who have their headquarters in the USA are listed below. The DPAs contain so-called standard contractual clauses. The standard contractual clauses are agreements adopted by the European Commission. If the processor signs such a standard contract, it undertakes to comply with European data protection standards.
Provision of server services, cloud hosting - Amazon Web Services EMEA, 38 avenue John F. Kennedy, 1855 Luxembourg, Luxembourg. Server location: Ireland for Irish clients, London for UK clients, Paris for French clients, etc.). https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/
Provision of email & SMS services - SendGrid, Inc.1801 California Street, Suite 500, Denver, CO 80202. https://www.twilio.com/legal/data-protection-addendum
Provision of in-app messaging services (push) - Google Firebase. Google Building Gordon House, 4 Barrow St, Grand Canal Dock, Dublin 4, D04 V4X7. https://firebase.google.com/terms/data-processing-terms#1.-introduction
Provision of chat support, knowledge base, help centre - Intercom, Inc. (Intercom R&D Unlimited Company), 55 2nd Street, 4th FloorSan Francisco, California 94105. https://www.intercom.com/help/en/articles/1385437-how-intercom-complies-with-gdpr
The transfer of data to contract processors takes place on the basis of Art. 28 Para. 1 GDPR, alternatively on the basis of our legitimate interest in the economic and technical advantages associated with the use of specialized contract processors, and the fact that your rights and interests in the protection of your personal data do not predominate, Art. 6 para. 1 lit. f GDPR.
As part of the further development of our business, the structure of Altra Health limited may change, as the legal form is changed, subsidiaries, parts of companies or parts of the company are founded, bought or sold. In such transactions, the customer information is passed on together with the part of the company to be transferred. Whenever personal data is passed on to third parties to the extent described above, we ensure that this is done in accordance with this data protection declaration and the relevant data protection laws.
Any transfer of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances if necessary and your rights and interests in the protection of your personal data do not outweigh your interests, Art. 6 Para. 1 lit. f GDPR.
6. Deletion of your data
We delete or anonymize your personal data as soon as it is no longer required for the purposes for which we collected or used it in accordance with the preceding paragraphs. As a rule, we store your personal data for the duration of the usage or contractual relationship via the app plus a period of 7 days in which we keep backup copies after deletion, unless this data is for legal reasons or for criminal prosecution or are needed longer to secure, assert or enforce legal claims. If data has to be kept for legal reasons, it will be blocked. The data is then no longer available for further use.
7. Data security
Data security is a key issue for us. We take suitable technical and organizational measures to ensure an appropriate level of protection when processing personal data. Our processes for developing and operating our app are in accordance with the latest international data security protocols.
8. Your rights as a data subject
8.1 Right to information
You have the right to request information from us at any time about the personal data relating to you processed by us within the scope of Art. 15 GDPR. To do this, you can submit an application by post or email to the address given above.
8.2 Right to correct incorrect data
You have the right to request us to correct the personal data concerning you immediately if it is incorrect. To do this, please use the contact addresses given above.
8.3 Right to cancellation
You have the right, under the conditions described in Art. 17 GDPR, to request that we delete your personal data. In particular, these requirements provide for a right to erasure if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection or the existence of an obligation to erase under Union law or the law of the member state to which we are subject. For the period of data storage see also section 7 of this data protection declaration. In order to assert your above right, please contact the contact addresses given above.
8.4 Right to restriction of processing
You have the right to demand that we restrict processing in accordance with Art. 18 GDPR. This right exists in particular if the correctness of the personal data is disputed between the user and us, for the period that requires checking the correctness and in the event that the user requests restricted processing instead of deletion with an existing right to deletion; also in the event that the data is no longer required for the purposes we are pursuing, but the user needs it to assert, exercise or defend legal claims and if the successful exercise of an objection between us and the user is still disputed. In order to assert your above right, please contact the contact addresses given above.
8.5 Right to data portability
You have the right to receive the personal data relating to you that you have provided to us in a structured, common, machine-readable format in accordance with Art. 20 GDPR. In order to assert your above right, please contact the contact addresses given above.
8.6 Right to Object
You have the right, for reasons that arise from your particular situation, to object at any time to the processing of personal data relating to you, which, among other things, is based on Art. 6 Para. 1 lit. e or f GDPR takes place, to file an objection according to Art. 21 GDPR. We will stop processing your personal data unless we can demonstrate compelling legitimate reasons for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
8.7 Right to complain
You also have the right to contact a competent supervisory authority if you have complaints. The supervisory authority responsible for Ireland is for example: Data Protection Commission,21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland. https://forms.dataprotection.ie/contact
9. User Content
9.1 Definition: “User Content” means any content that users upload, post or transmit (collectively, “Post”) to or through Altra including, without limitation, any text, comments and other works subject to protection under the laws of Ireland or any other jurisdiction, including, but not limited to, patent, trademark, trade secret, and copyright laws, and excludes any and all Altra Content.
9.2 Screening User Content: Altra offers end users the ability to submit User Content to or transmit User Content through Altra. Altra does not pre-screen any User Content, but reserves the right to remove, disallow, block, or delete any User Content in its sole discretion. Altra does not guarantee the accuracy, integrity, appropriateness, availability, or quality of any User Content, and under no circumstances will Altra be liable in any way for any User Content.
9.3 You Must Have Rights to the Content You Post: You represent and warrant that: (i) you own the User Content Posted by you on or through Altra or otherwise have the right to grant the license set forth in this policy; (ii) the Posting and Use of your User Content on or through Altra does not violate the privacy rights, publicity rights, copyrights, contract rights, intellectual property rights, or any other rights of any person, including, but not limited to, the rights of any person visible in any of your User Content; (iii) the Posting of your User Content on Altra will not require us to obtain any further licenses from or pay any royalties, fees, compensation, or other amounts or provide any attribution to any third parties; and (iv) the Posting of your User Content on Altra does not result in a breach of contract between you and a third party. You agree to pay all monies owing to any person as a result of your Posting your User Content on Altra.
9.4 Waiver of Rights to User Content: By Posting User Content to or through Altra, you waive any rights to prior inspection or approval of any marketing or promotional materials related to such User Content. You also waive any and all rights of privacy, publicity, or any other rights of a similar nature in connection with your User Content, or any portion thereof. To the extent any moral rights are not transferable or assignable, you hereby waive and agree never to assert any and all moral rights, or to support, maintain, or permit any action based on any moral rights that you may have in or with respect to any User Content you Post to or through Altra.
9.5 Objectionable Conten
t. You agree not to Post any User Content to Altra that is or could be interpreted to be (i) abusive, bullying, defamatory, harassing, harmful, hateful, inaccurate, infringing, libelous, objectionable, obscene, offensive, pornographic, shocking, threatening, unlawful, violent, vulgar, or in violation of any applicable laws (including laws related to speech); or (ii) promoting any product, good, or service, or bigotry, discrimination, hatred, intolerance, racism, or inciting violence (including suicide) (collectively, “Objectionable Content”). The Posting of any Objectionable Content may subject you to third party claims and none of the rights granted to you in this policy may be raised as a defense against such third party claims. If you encounter any Objectionable Content on Altra, then please immediately report the content using the Report Content feature on the app or email [email protected]. Altra in its sole discretion may take any actions it deems necessary and/or appropriate against any User who Posts Objectionable Content on Altra.