Smart Bear Privacy Policy
This privacy policy forms part of the Terms of Use of Smart Bear (also referred to as “we”, “us”, “our” or “Service”).
The purpose of this Privacy Policy is to inform you of the details of how Smart Bear processes your personal data.
ABOUT Smart Bear
Smart Bear (also referred to as “Smart Bear”, “we”, or “Service”) is a mobile application for the provision of care services for the elderly.
DEFINITIONS
"Services" means any product or other service that is operated by Smart Bear.
"Users", “you”, “your” or similar terms means any individual who has an account with Smart Bear.
"GDPR" means the General Data Protection Regulation.
Terms not defined in this Privacy Policy or Smart Bear Terms of Use will have the meaning given in the GDPR and the Greek Data Protection Law (Law 4624/2019).
ABOUT THE ORGANIZATION RESPONSIBLE FOR Smart Bear
Responsible for the operation of Smart Bear and counterparty to this privacy policy is Athens Technology Center.
Address: 10 Rizareiou Str. Athens, Greece
PC: GR15233
Tel: +30 210 6874400
Email: privacy@atc.gr
ABOUT THE APPLICABLE LAW
The handling and protection of the personal data processed by Smart Bear is governed by the terms hereof and the provisions of GDPR and Greek law on the protection of individuals with regard to the processing of personal data (Law 4624/2019).
ABOUT THE DATA COLLECTED ABOUT YOU
Information you provide through our Mobile Application
You provide your password and email to register and access the Smart Bear mobile application.
Information you provide through our Mobile Application Services
When you use our Mobile Application you provide data such as your location and your camera.
Information you provide through our support channel or direct communication
Through our support channel (Feedback sent though the Smart Bear application, emails sent at info@atc.gr) or direct email communication you provide us with data about yourself and about the case for which you are contacting us.
Information on how you use our Application
When you visit and interact with the Smart Bear application, we collect certain information in the background in order to optimize and improve the Smart Bear Services. This includes log data, data from connected devices, logins and time stamps.
ABOUT THE PURPOSES FOR WHICH YOUR DATA WILL BE PROCESSED
Smart Bear processes your personal data to deliver you services offered through the Smart Bear Application. Specifically, we may use information we receive to:
Create your account;
Collect and analyze data such as:
WHEN WE MAY SHARE YOUR PERSONAL DATA
Except as provided in this Privacy Policy, we will never use the provided personal data for any other purpose than to enable the use of the Application by you.
We may only share information we have collected about you:
(1) where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights;
(2) if we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Policy or inform you that you are covered by a new privacy policy).
(3) we may also disclose information to our sub-contractors and service providers in order to facilitate the operability and functioning of the Application. We work with third-party service providers for hosting the Application services. If we transfer your personal data to a service provider in order to fulfill a task, we will make sure that the service provider only processes the data based on our instructions and by guaranteeing the same safeguards as we do. To this effect, we have bound our data processors with data processing agreements concluded pursuant to Article 28 of the GDPR and, where such processor reside outside of the EEA, we have concluded Standard Contractual Clauses (model clauses) approved by the European Commission (2010/87/EU) with such processors, or (with respect to US-based companies) verified that these processors have an active Privacy Shield certification. In particular, we use the following third party contractors:
SECURITY
Appropriate and detailed security policies, rules, and technical measures are implemented to protect your personal data that are used by the Application and are stored from improper or unauthorised access.
All employees and data processors, who have access to and are associated with the processing of personal data, are obliged to respect the confidentiality of your personal data. Our Data Protection Policy ensures that all processes we follow are fully compliant with the GDPR provisions.
We are also reviewing our data protection processes regularly in order to make sure that we protect your data in the best possible way. If we use sub-contractors and service providers to fulfil a specific task based on your data, we will make sure that the partner has similar state-of-the-art data protection processes in place.
ABOUT YOUR RIGHTS
Smart Bear respects all your rights and takes all steps necessary to ensure their protection. Under the General Data Protection Regulation [Articles 15-21], you have a number of important rights. In summary, those include the following rights:
Right of access: You have the right to be aware and verify the legitimate nature of the processing. So, you have the right to access your personal data and receive additional information about how we process it.
Right to rectification: You have the right to study, correct, update or modify your personal data by contacting Smart Bear.
Right to erasure: You have the right to request deletion of your personal data when we process it with your consent or in order to protect our legitimate interests. In all other cases (such as, where there is a contract, obligation to process personal data legally required, or public interest), this right is subject to specific restrictions or shall not exist, as the case may be.
Right to restriction of processing: You have the right to request a restriction of the processing of your personal data in the following cases: (a) when the accuracy of the personal data is contested and until the accuracy is verified, (b) when you oppose the deletion of your personal data and request the restriction of their use instead, c) when personal data are not needed for processing purposes, they are however required for the establishment, exercise, or defense of legal claims, and (d) when you object to the processing and the decision on your objection to processing is pending.
Right to object to processing: You have the right to object at any time to the processing of your personal data where, as described above, the processing is based on the legitimate interests we pursue as data controllers, as well as, for the purposes of direct marketing and consumer profiling, if applicable.
Right to data portability: You have the right to receive your personal data free of charge in a format that allows you to access, use, and edit them with commonly used editing methods. You also have the right to ask us, in case it is technically feasible, to transmit the data directly to another controller. Your right to do so exists for the data you have provided to us and is processed by automated means based on your consent or for the execution of a relevant contract.
Right to withdraw your consent: In cases where processing is based on your consent, you have the right to withdraw it without affecting the lawfulness of processing based on consent prior to its withdrawal.
If you would like to exercise any of those rights, please:
Address: 10 Rizareiou Str. Athens, Greece
PC: GR15233
Tel: +30 210 6874400
Email: privacy@atc.gr
RETENTION PERIODS
We retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy and/or any Services agreement, unless a longer retention is required by law (e.g. for tax or accounting purposes or due to other legal requirements) or storing of the data is needed for the establishment, exercise or defence of Smart Bear legal claims; in such case, we will store only the data necessary for the enforcement of our claims or our defence for the period necessary in the given case and not exceeding the statutory limitation periods.
CHANGES TO THIS POLICY
We reserve the right to change this Privacy Policy. We will provide notification of material changes through the Smart Bear Service prior to the change taking effect. Your continued use of the Application after the update has become effective indicates that you have read, understood, and agreed to the new version of this Policy.
CONTACT INFORMATION
For more information or if you have any query regarding our Privacy Policy, please contact us at privacy@atc.gr