Patient Privacy Policy

Introduction

 

Welcome to the SHARE Privacy Notice. 

The SHARE (Speech tHerApy scReEning) mobile app (hereinafter: “the App”) is a service provided by Kids Speech Lab (KSL).

We respect your privacy and are committed to protecting your personal data.  “Personal data” means any information relating to an identified or identifiable natural person. 

This privacy policy will inform you as to how we look after your personal data when you use our App and inform you about your privacy rights and how the law protects you. 

This privacy notice aims to give you information on how Kids Speech Lab collects and processes your personal data through your use of the App, including any data you may provide through any of the mentioned means. 

It is expressly prohibited for minors under the age of 13, or equivalent minimum age in the relevant jurisdiction, to create and use their own SHARE Account, unless their parents or guardians provided verifiable consent.

The information provided does not concern other online websites, pages or services that can be accessed via hyperlinks on the above App or website but relate to resources outside the SHARE’s domain.

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE Kids Speech Lab SERVICES.

Who we are 

Depending on the context of personal information you provide, Kids Speech Lab (“Kids Speech Lab”, “we”, “us” or “our” and terms of similar meaning) may be the data controller (“controller”) or data processor (“processor”) of your personal information under this policy. Kids Speech Lab is acting mainly as a controller of User’s Data, personal information submitted to the Services or collected through the Services on behalf of or at the direction of subscribers. The use and/or download of the App by you may be prescribed by your healthcare centre or healthcare professional treating your condition.  In this case the healthcare centre or healthcare professional, who makes the prescription, is the Data Controller for the processing of your Information, and Kids Speech Lab acts as the Data Processor. You understand and agree that Kids Speech Lab may receive and communicate your Information to that healthcare centre or healthcare professional.

Please see the “Contact us” section for our contact details.

Scope of the processing of personal data

We process personal data only to the extent necessary to provide a functional Platform. The processing of personal data takes place regularly only with the consent of the data subject or on the basis of other legal provisions that permit data processing. 

The data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Kids Speech Lab may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

Data Category Data type
Identity information Name
IP-address
[user-ID]
Contact information E-mail address
Other data Health/professional who referred the child
Name of child’s school

Contact information for child’s school

Name of child’s school

Contact information for child’s school

Name of other clinical profs child is attending

Contact information for other clinical profs child is attending

Demographic information Age of child
Health data Standard case history questionnaire
Biometric Data Audio files, unstructured collected by parent
Audio files, structured recorded in the app
Usage data User Agent strings
Session Data
Notes Therapists’ notes

 

We also collect, use and share Aggregated Data such as statistical or demographic. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. 

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your [Identification data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • use our products or services;
  • create an account on our App;
  • give us feedback or contact us. 

Third parties. We may receive personal data about you from third parties, such as Therapists connected to patients’ accounts.

Purposes and Legal Basis

For the cases where Kids Speech Lab is acting as a controller of your Data we have set out below, in a table format, a description of all the ways we may use the personal data and the legal basis which allow us to do it.

 

Purpose/Activity Type of data Legal Basis
Provide user with access to our App and its basic functionalities
  • Identity information
  • Contact information
  • Other data
  • Demographic information
  • Usage data
The processing of patients’ personal data for the  is based on its necessity for the performance of the contract (art. 6 (1) (b) GDPR)
  • Health data
  • Biometric Data
Special categories of personal data (sensitive personal data) about patients’ health are processed based on the necessity of the performance of the service (art. 6 (1) (b) GDPR), on the explicit consent provided when the user created the account (art. 9 (2) (a) GDPR) and on the necessity for the provision of an health care service (Art. 9 (2) (h) GDPR)
Scientific Research
  • Health data
  • Biometric Data
Special categories of personal data (sensitive personal data) about patients’ health are processed based on the legitimate interest of Kids Speech Lab on conducting scientific research (art. 6 (1) (f) GDPR), and on scientific or statistical purposes with appropriate safeguards (art. Art. 9 (2) (j) – 89(1) (Art. 9 (2) (h) GDPR)

Kids Speech Labs only process the minimum amount of personal data that they need to achieve its processing purposes.

OTHER PURPOSES
Manage and Defend Legal Claims

If necessary we may use your personal data to manage and defend legal claims, e.g. in connection with a dispute or a court proceeding. We will in such case process the personal data collected which is necessary in order to manage and defend the legal claim in question. The processing is based on our legitimate interest of managing and defending legal claims. Your personal data is stored for this purpose for such a period as is necessary in order to manage or defend the legal claim.

For this purpose, we may also share certain information with other parties, please see below.

Fulfill Legal Obligations

Finally, we use your personal data to fulfil legal obligations that we have, e.g. accounting requirements or obligations under data protection laws. We will in such case process the personal data collected which is necessary in order to fulfill the legal obligation in question. Your personal data is stored for such a period as is necessary in order to fulfill respective legal obligations. 

For this purpose, we may share your personal data with other parties, see below.

Retention Period

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We restrict access to your personal information to those persons who need to use it for the relevant purposes(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.

Sharing of Personal Data

In general, we do not disclose the Personal Data about you to third parties without your consent or otherwise as specified in this Policy. 

In certain circumstances we may disclose or share your Personal Data with third parties only in the ways described in this Policy, including as follows:

  • In certain situations, Kids Speech Lab may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Kids Speech Lab may disclose your Personal Data (i) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), (ii) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, (iii) as otherwise required or permitted under any applicable law, rule, or regulation, (iv) in good faith, to protect or defend the rights or property of Kids Speech Lab and other users, and (e) if Kids Speech Lab is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data;
  • third party service providers: we may use third party service providers to provide certain data processing services for us (acting as our authorized data processors). When acting as our authorized data processors, they are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations. 
  • Please note that our Partner(s) will have their own privacy policies which explain how they collect, use, store and process your personal data on their app and through their services. We are not responsible for their privacy statements and we encourage you to read their privacy policies.

We may share anonymous, aggregate or generic data with third parties (such as our partners, advertisers, industry bodies, the media and/or the general public). However, in these situations we do not disclose any information that could be used to identify you personally.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or seek consent for processing. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We keep your data safe adopting the best practices and highest standards in terms of security.

We take various steps to protect your Personal Data from unauthorized access, use or modification and unlawful destruction and disclosure, for example:

  • we adopt encryption technology (such as SSL) to transfer and store your Personal Data; 
  • we limit the access to your Personal Data on a strict need-to-know basis;
  • we put in place physical, electronic, and procedural safeguards in line with industry standards.

Please be aware that, despite our efforts, we do not warrant or guarantee that unauthorized access will never occur as no method of transmitting or storing information is completely secure.

All data handling is GDPR (General Data Protection Regulation) compliant.

Data Storage Location

All information processed and collected to provide our Services outside of the device in which the App is installed is stored on our servers or with cloud service providers managed by us located in Germany.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data processing operations that are carried out via third party providers established outside of the geographical area upon mentioned can be carried out partially or completely in the countries of the respective branch or according to the respective data protection regulations.

A process of personal data outside the EU or the EEA will only take place on the basis of an adequacy decision of the European Commission or, in case of no adequacy decision in place (e.g. USA) in accordance with standard contractual clauses approved by the European Commission.

YOUR RIGHTS

You have certain rights in relation to the use of your personal data. If you wish to exercise your rights, please contact us at: privacy@kidsspeechlabs.com. Kids Speech Labs’s policy is to respond to requests within 2 months of receiving requests. 

You have the right:

TO BE INFORMED

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data, and your rights. This is what we are doing, providing you with the information in this Privacy Policy.

TO ACCESS YOUR PERSONAL DATA

You have the right to request access to your personal data and request a copy of your personal data that we store. If you have created a user account, you can view certain information directly from our Services on your user interface. Otherwise privacy@kidsspeechlabs.com

TO UPDATE YOUR PERSONAL DATA

You have the right to request that personal data that is incorrect or incomplete is corrected or completed. If you have created a user account, you can update certain information directly in your account.

TO WITHDRAW CONSENT

If we rely on your consent to the use of your personal data you have the right to, at any time, withdraw your consent. The consent withdrawal does not affect the legality of the processing carried out previously on the basis of the consent. 

TO DELETE YOUR PERSONAL DATA (RIGHT TO BE FORGOTTEN)

You can at any time request that your user account is deleted. Moreover, under certain circumstances, you have the right to request that your personal data shall be deleted. 

Please note that if you request us to remove your Personal Data, you may not be able to use our Services. 

We may, however, still need to keep your personal data if we are obligated to keep certain data in order to fulfill legal obligations or to manage or defend legal claims.

TO RESTRICT THE USE OF YOUR PERSONAL DATA

You have, under certain circumstances, the right to request that the use of your personal data is restricted. If you have requested restriction of the use of your personal data, please note that you cannot use the App during the time that the use of your personal data is restricted.

TO OBJECT TO THE USE OF YOUR PERSONAL DATA

Certain use of your personal data is based on our or others’ legitimate interest. You have the right to object to the use of your personal data based on a legitimate interest for reasons which concerns your particular situation. In such a situation, we will stop using your personal data where the use is based on a legitimate interest, unless we can show that the interest overrides your privacy interest or that the use of your personal data is necessary in order to manage or defend legal claims.

TO NOT TO BE SUBJECT TO A DECISION BASED SOLELY ON AUTOMATED DECISION-MAKING

You may have the right not to be subject to such type of automated decision-making about you, unless: (a) you gave us your explicit consent to use your personal data to make our decision; (b) we are allowed by law to make our decision; or (c) our automated decision was necessary to enable us to enter into a contract with you.

TO TRANSFER YOUR PERSONAL DATA (DATA PORTABILITY)

You have the right to obtain a copy of certain information that you have provided to us in a structured machine-readable format which allows you to transfer the data to another recipient.

TO LODGE A COMPLAINT

As a data subject, you have a right to lodge a complaint with the competent supervisory authority under the conditions provided in Article 77 GDPR. 

Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use our Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.

UPDATES TO THIS POLICY

We may modify and revise this Policy from time to time. Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. 

Any changes we make to our Privacy Policy in the future will be posted on this page, and where appropriate, notified to you by email or notifications via the App. We therefore encourage you to review it from time to time to stay informed of how we are processing your data.

CONTACT US

If you have questions, suggestions, or concerns about this Policy, or about our use of your Personal Data, please contact us at privacy@kidsspeechlabs.com.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. For the purposes of the relevant data protection legislation, our data protection officer is Shona D’Arcy.