Last Updated: 4-20-2017
The product-specific details sections provide additional information relevant to particular Permobil products. This statement applies to the products listed below, as well as other Permobil products that display this statement. Products in this statement include Permobil and its subsidiaries’ (TiLite and ROHO) services, websites, apps, software and devices.
What kind of data do we collect?
Permobil and its subsidiaries’ (TiLite and ROHO) collects data to operate and improve our products, provide you with personalized experiences, and to help keep you safe. Personal information is any data that can be used to identify or contact a single person, including but not limited to e-mail addresses, names, addresses, date of birth, health information and telephone numbers.
Some of the most common categories of data we collect include:
Before you may enroll to access our software and apps, you or the group practice(s) with which you are affiliated must first register with Permobil as a clinician, client, dealer or other role indicated on the applicable service (“User Role”). Your User Role is subject to approval by Permobil. Once you have registered and your User Role has been approved, you will receive a username and password.
If you use the products from Permobil and are a client, we collect information on behalf of the clinic or health services provider that you have chosen in order to deliver and maintain services to you, including information about your use of our products. In addition, we may collect protected health information (“PHI”). PHI is information that may be used to identify you (such as your name, social security number or address), and that relates to (a) your past, present or future physical or mental health or condition, (b) the provision of healthcare to you, or (c) your past, present, or future payment for the provision of healthcare. In conducting business, we will receive and create records containing your PHI. Any PHI collected is not combined with data from other services or used for other purposes without your explicit consent. For example, we will not use your PHI to market or advertise our products to you without your consent.
To provide location-based services we may collect, use, and share precise location data, including the real-time geographic location of your wheelchair. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your wheelchair’s approximate location. Detecting location also helps us protect you. For example, if you almost always sign in from Sweden, and suddenly you’re signing in from Canada, we can check to make sure it’s really you. You can turn on or off location services for and manage the location history stored on your device by contacting your dealer or sending an email to firstname.lastname@example.org.
Information from device sensors
As you’d expect from any current device, most of our electric wheelchairs come with sensors—ways for the device to detect the world. The information we may collect from the sensors includes data about your location, wheelchair mileage, battery charge, maintenance information, diagnostic data, and service data about the products that you use and services you receive from Permobil. Information about your use of our products may be collected on behalf of your clinic or health services provider to aid in your specialized treatment. Depending on our product, you may be able to control what sensor data the device and the apps can use by contacting your dealer or sending an email to email@example.com.
Registered and Non-Registered Users
Cookies and Other Technology
As you navigate through and interact with our software or other services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
• Details of your visits to our software and services, including traffic data, location data, logs and other communication data and the resources that you access and use on the products.
• Information about your computer and internet connection, including your IP address, operating system and browser type.
The products may use “cookies” and other technologies such as pixel tags and web beacons. Browser cookies are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. These technologies tell us which parts of our products you have visited and help us alert you to software compatibility issues. They are also used to analyze and improve our products’ design and functionality. If you choose to delete cookies from your device or block them from being stored on your device, please note that the full functionality of the products may not be available to you and you will not be able to login using your User ID.
“Web beacons” are images embedded in a web page or email for the purpose of measuring and analyzing Services usage and activity. Permobil, or third-party service providers acting on our behalf, may use web beacons to help us analyze Services usage.
How We Use Your Personal Information, Product Use Information and PHI
Permobil shares your personal data with your consent or as necessary to provide any product or services you have requested or authorized. We will not use your personal information for purposes other than those listed in this policy unless we obtain your consent first.
From time to time, we may use your personal information to send important notices, such as communications about the services and changes to our terms, conditions, and policies. Because this information is important to your interaction with Permobil, you may not opt out of receiving these communications.
We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, troubleshoot problems and detect and protect against error, fraud, or other illegal activity.
We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services.
Permobil uses your Product Use Information and PHI to:
• Provide your clinic or health services provider with feedback on how and when to use and function the power seat functions of your product such as power tilt, power recline, or power elevating leg rests;
• Provide you with support for your use of various Permobil products;
• Enable our licensors to improve their licensed technology;
• Address clinical outcomes;
• Facilitate your Permobil product’s compliance with clinician protocols;
• Enable clinics and health service providers to track and service their fleet of Permobil products; and
• Implement billing systems for Permobil Products.
Permobil will not sell, rent, transfer, disclose or otherwise permit the use of your personal information or PHI by advertisers or other third-parties for direct marketing purposes.
The personal information we collect allows us to keep you posted on Permobil’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out at any time by contacting your dealer or sending an email to firstname.lastname@example.org.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Permobil’s products, services, and customer communications. We only use the minimum amount of personal data necessary for performing these tasks and in most cases, we only use data that has been de-identified or pseudonimized.
Learn how each of our products use your data
Website and software
Our website and software use limited data to depending on your use of the product. Limited data may be collected from you or your clinician or healthcare provider as needed to provide you with a personalized experience, improve service reliability, combat spam or other malware, or improve features and functionality of the website or software. We do not use your data for any advertising or similar commercial purposes without your explicit consent.
Virtual Seating Coach
The Virtual Seating Coach service (the “VSC service”), collects and processes personal information, including but not limited to e-mail addresses, names, addresses, dates of birth, telephone numbers, health information and information about how the VSC service is used. This information is necessary for the VSC service to function properly and for your healthcare provider to specialize your health services and treatment.
Fleet Management collects and processes personal information, including but not limited to e-mail addresses, names, mailing addresses, dates of birth, telephone numbers, health information and information on your use of the app. This information is necessary for it to function properly and for your clinician or health care provider to be able to provide services and manage your treatment.
The Connected Chair collects and processes personal information, including but not limited to e-mail addresses, names, mailing addresses, dates of birth, telephone numbers, health information and information on your use of the chair. This information is necessary for it to function properly and for your clinician or health care provider to be able to provide services and manage your treatment.
The 3D Scanning Roho Capture app collects and processes personal information, including but not limited to e-mail addresses, names, mailing addresses, scanned images, and certain health information. This information is necessary for it to function properly and for your clinician and/or health care provider and/or Permobil to be able to provide products and services necessary to meet your prescribed seating and positioning needs.
Disclosure to Third-Parties
Permobil may share your personal information and product use information with your clinic or health services provider and with Permobil’s dealers who sell Permobil products and services.
Permobil may share your personal information and product use information with third-parties who provide services to Permobil, such as information processing, customer data management, customer research and other similar services. We will require these third-parties to protect your information.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Permobil to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. When we receive information requests, we require that it be accompanied by the appropriate legal documents such as a subpoena or search warrant. We believe in being as transparent as the law allows about what information is requested from us. We carefully review any request to ensure that there’s a valid legal basis for it. And we limit our response to only the data law enforcement is legally entitled to for the specific investigation.
We will not transfer data originating in the EU to third parties unless they have a written agreement with us that requires them to protect your information as required by the global self-regulatory frameworks discussed in this policy. We will only transfer data to our agents, dealers, clinicians or third party service providers (such as accountants, attorneys, consultants, and other service providers) who need the information in order to provide services to or perform activities on our behalf, including in connection with the delivery of services or products, management, administration, or legal responsibilities. We acknowledge our liability for such data transfers to third parties.
Permobil may provide your product use information in a format that does not include your name to Permobil’s licensors, such as Universities who developed technology used in the products, in order to enable them to improve their technology.
Access to User Information and Your Right to Delete Your Account
The information maintained for each user assigned a User ID can be reviewed and modified by the Registered User. The accuracy of Registered User data is the responsibility of the Registered User. If you would like to cancel your account, you may do so by emailing email@example.com. When you request cancellation of your account, we may retain your account information, subject to the terms of this Policy and our legal obligations. Following cancellation or termination of your account, Permobil may continue to utilize de-identified historical data associated with your use of the products. We will respond to requests to access or delete your personal data within 30 days.
We use industry-standard technologies, such as firewalls, encryption techniques, and authentication procedures, among others, designed to protect the security of your data and to protect Permobil accounts and systems from unauthorized access, however, we do not represent or warrant that your data will be 100% secure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Permobil does not represent, warrant, or guarantee that your personal information, product use information, or PHI will be completely protected against unauthorized access, loss, misuse, or alterations and does not accept any liability for the security of the information.
We comply with the Children’s Online Privacy Protection Act of the United States and similar laws around the world where applicable to Permobil products. We do not knowingly collect personal information from children without proper parental consent. If you believe that we may have collected personal information from someone under the age of thirteen (13),or under the applicable age of consent in your country, without parental consent, please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and address the issue promptly.
Your California Privacy Rights
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of Personal Information to third-parties for their direct marketing purposes. To make such a request, please contact us at: firstname.lastname@example.org.
California law requires that we disclose how Permobil responds to web browser “Do Not Track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information (as that term is defined in California law) about a consumer’s online activities. Our Services does not currently support “Do Not Track” codes. That is, Permobil does not currently respond to or take any action with regard to “Do Not Track” requests.
Information Transmitted Through Other Means
All such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.