KNFB Reader Enterprise - Privacy Policy

1. Introduction

This Privacy Policy defines the tasks and responsibilities of Sensotec NV, with registered office at Vlamingveld 8, 8490 Jabbeke, Belgium and registered with the Crossroads Bank for Enterprises under number 0429.286.663 (RPR Brugge) ("Sensotec") and KNFB Reader LLC, a Maryland corporation having its principal office at 200 East Wells Street at Jernigan Place, Baltimore, Maryland 21230, United States (“KNFB”) regarding personal data of users or personal data of individuals which is submitted for processing by site license holders ("Data") collected and processed by Sensotec and KNFB through the KNFB Reader Enterprise License Server ("License Server") and the application KNFB Reader Enterprise ("KNFB Reader"). Sensotec and KNFB sometimes hereinafter referred to as the “Providers”.

The protection of Data is of great importance for the Providers. The Providers respect your privacy and ensure that the Data is processed according to applicable law, in specific (but not limited to) the Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data (the "Privacy Act") and the Children’s Online Privacy Protection Act (COPPA) of the United States.

This Privacy Policy outlines the information collected and Processed, the purpose of the Processing, with whom the Personal Data may be shared, and the choices you can make regarding the use of the Personal Data by the Providers. It also describes the measures taken to ensure the security of the Personal Data and how you can contact the Providers to exercise your rights regarding access, rectification and opposition.

By downloading, installing, or using KNFB Reader and/or by entering Data in the License Server, you confirm to have received, read, understood and accepted the contents of this Privacy Policy. More specifically, you agree that the Providers:

a. May collect and process Data in the manner and for the purposes as outlined in this Privacy Policy;

b. May disclose Personal Data to third parties if it is based on a legal obligation;

c. May provide Student Data or Data about minors to third parties if such disclosure is commissioned or authorized by the respective school, educational institution or supervising entity or if it is based on a legal obligation;

d. Can use analytics solutions (including third-party solutions) in KNFB Reader, the License Server and the Website, which solutions may include but are not limited to Google Analytics and Flurry;

e. Can generate log files to record the activity and performance of KNFB Reader;

f. Can encode Personal Data and merge it with the Data of other users in order to compile statistics relating to the general use of KNFB Reader;

g. Can use cookies and other technologies on its Web site.

If you do not agree with any provision of this Privacy Policy, you should refrain to download, install or use KNFB Reader or to use the License Server. You can at any time oppose against the processing of Personal Data in accordance with this Privacy Policy or withdraw your consent by interrupting the installation of KNFB Reader, by removing KNFB Reader from your device and deleting all your Personal Data on the License Server.

2. Definitions

  • EULA: the End User License Agreement, which governs the registration, use and access to KNFB Reader and the License Server.
  • Google: Google, Inc., having its principal office at 1600 Amphitheatre Parkway, Mountain View, CA 94043, US;
  • License Server: the license server of KNFB Reader located at: https://knfblic.sensotec.be
  • Personal Data:  any information relating to an identified or identifiable natural person;
  • Privacy Policy: the current privacy policy;
  • Student Data: Personal Data of a student/pupil of a school or educational institution obtained from that school/educational institution;
  • KNFB Reader: the application KNFB Reader Enterprise;
  • KNFB Reader Account: the account created by a User on the License Server to get access to a fully functional version of KNFB Reader.
  • User or You: a person who has installed KNFB Reader on his device(s) and/or who has a KNFB Reader Account;
  • Controller of the Processing: a natural person or legal person, an actual association or public board who/which, solely or in conjunction with others, determines the purpose and the means for the Processing of Personal Data;
  • Processes, Processed or Processing: any operation or set of operations which is performed on Personal Data, whether or not by automatic means, such as the collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, compiling, alignment or combination as well as blocking, erasure or destruction of Personal Data;
  • Processor: a natural person, a legal person, an actual association or public authority who/which Processes Personal Data on behalf of the Controller of the Processing, excluding those persons authorized to Process Data under the direct authority of the Controller of the Processing;
  • Website: the website of KNFB Reader: www.knfbreader.com.

3. The Personal Data collected and processed by the Providers

When You download, install or use KNFB Reader and/or when You create or modify a KNFB Reader Account on the License Server, You can provide Personal Data (some of which is mandatory) to the Providers, such as:

  • your user name
  • your first and last name
  • your email address
  • your address
  • your mother tongue
  • your date of birth
  • your password

You agree to provide accurate and current Personal Data, and to update such Personal Data to keep it accurate and current.

The Providers can also automatically collect and thereafter process Personal Data such as:

  • device data: technical data concerning your computer or mobile device which you use to download, install or use KNFB Reader or which you use to access the License Server. This can be the model, the manufacturer, the operating system, the language settings, the device settings, the ID of your device, the IP address…
  • your interaction data with KNFB Reader and the License Server (e.g. usage and frequency of usage)

We do not use KNFB Reader or the License Server to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at support@knfbreader.com. We will delete such information from our files as soon as possible.

When a school or educational institution enters Student Data in the License Server, that school or educational institution controls what Student Data is entered. Student Data entered should be limited to information that is relevant to the legitimate educational purpose of improving student performance and to make KNFB Reader available to those students. We will not ask you to enter, and you are instructed not to enter, data about students that is not relevant to this legitimate purpose.

When an institution supervising minor children enters data about such children in the License Server, that institution controls what Data is entered. This Data about minor children is to be limited to information that is relevant to the legitimate purpose of providing the KNFB Reader to such minor children. We will not ask you to enter, and you are instructed not to enter, data about such minor children that is not relevant to this legitimate purpose.

4. The purposes of the collection and Processing of the Personal Data

Your Personal Data are collected and Processed by the Providers for the following purposes:

  • To make available KNFB Reader and the License Server to You, including the downloading, installing, registration, using and access to KNFB Reader and the License Server
  • To operationally manage KNFB Reader and the License Server
  • To answer questions and react to complaints regarding KNFB Reader and the License Server and to communicate with you for purposes related to KNFB Reader and the License Server
  • To block access to KNFB Reader and the License Server
  • To provide you with information regarding relevant products and services of the Providers
  • To make available further updates and upgrades of KNFB Reader and the License Server
  • To analyze and to report on the use of KNFB Reader and the License Server
  • To personalize and improve Your experience with KNFB Reader and the License Server
  • To improve and/or adapt KNFB reader and the License Server
  • To allow the Providers to develop new products and services. You explicitly agree that You will have no claim on and have no right in such newly-developed products or services.

The school, educational institution, or the institution managing minor children that provides Student Data or Data about minor children to the Providers, agrees that the Providers can process that Student Data or Data about minor children for the above purposes.

5. Sharing of the collected Personal Data and information

Unless otherwise stated in this Privacy Policy, the Providers will not disclose or transfer the collected Personal Data to third parties unless you give your prior express consent.

The Providers may share the collected Personal Data with third party service providers in order to perform tasks, to Process Personal Data, in accordance with this Privacy Policy.

The Providers may transmit the collected Personal Data to third party service providers who act as Processors in the name of and on behalf of the Providers (where the Providers act as Controller of the Processing). The Providers require that such Processor only Processes your Personal Data if they are instructed to do so by the Providers and require that they protect the safety and confidentiality of Personal Data, in accordance with this Privacy Policy and the Privacy Act.

We will only disclose Student Data or Data about minor children to authorized employees or representatives of the respective school, educational institution or other institution supervising minor children and will not knowingly disclose the Student or minor child Data to any third person without express written authorization.

Nevertheless, the Providers reserve the right to disclose your Personal Data (i) in response to requests for information from public authorities or regulators, or where otherwise required by law; (ii) to enable a merger, acquisition or sale of part or all of its assets; and (iii) to issue anonymous or aggregated information about the use of KNFB Reader.

For the above purposes, the Providers may transfer your Personal Data to countries other than the country in which it was originally collected. Your Personal Data, however, will only be transferred within the European Economic Area or to countries approved by the European Commission as countries that can demonstrate they have a sufficient level of Personal Data protection. When the Providers transfer your Personal Data to other countries, it will protect this information as described in this Privacy Policy.

6. Security and Confidentiality

The safety and confidentiality of Personal Data is important to the Providers. As Controller of the Processing, the Providers implement appropriate technical and organizational safety measures to protect the safety and confidentiality of your Personal Data. The Providers also ensure that any other third party service provider that is engaged implements appropriate and organizational safety measures to protect the safety and confidentiality of your Personal Data.

The Providers have taken internal and organizational measures to prevent Personal Data from being made accessible to and Processed by unauthorized persons and maintain physical, electronic and procedural safeguards to secure Personal Data.

The Providers apply, if deemed necessary, security measures that are consistent with industry standards to protect Personal Data, such as identification and password requirements and the encryption of data during electronic transmittal.

Only Provider employees who are authorized to handle Student Data or Data about minor children are able to access such data.

The Providers strive to protect privacy and confidentiality of Personal Data by means of suitable safety measures, but the Providers cannot always guarantee the complete safety of the Processing of Personal Data, for instance where the Processing of Personal Data takes place via the internet or other electronic communication platforms.

Your password protects your KNFB Reader Account. You are required to use a unique and strong password, and restrict access to your mobile device.

7. Analysis and Statistics

The Providers may decide to integrate analytics tools into KNFB Reader and the License Server which -- subject to your prior consent where required by law -- third parties providing analyses (such as Google Analytics) will be allowed to collect information on the use of KNFB Reader, your mobile device and the License Server with a view to providing aggregated reports to the Providers to gain insight into the use of KNFB Reader and the License Server and how they can be improved and tailored to your needs.

The Providers may make use of analytics solutions of third parties, particularly but not exclusively Google Analytics and Flurry.

The Providers may make use of log files in order to record the activity of KNFB Reader.

The Providers may also encode your data and combine it with the data from other KNFB Reader Users to compile statistics relating to the general use of KNFB Reader and the License Server, which suggests development of new products and services. The combining of these data always takes place on an encoded and completely anonymous basis. The Providers may also share this aggregated data with its business partners, advertisers and other third parties.

8. Cookies

A cookie is a small file of information that can be stored on your device when you visit the Website or the License Server. The cookie will enable the Providers to recognize your device the next time you visit the Website or License Server.

When visiting the Website or the License Server, your device will automatically receive cookies, with your prior consent if required by law, that are transmitted from the Website or License Server to your web browser. Once You have accepted the usage of cookies on the Website or License Server, your preferences regarding the use of cookies are stored in the form of a cookie for your future visits as long as the cookies are not deleted from your device.

If you wish to withdraw your consent for the use of cookies, where such consent is required, or if you wish to remove or check the cookies placed on your computer, you can usually set your web browser to block or delete certain cookies. Please note that if you choose to block or delete cookies, this may have an impact on your user experience of the Website and it is possible that some parts of it will not work properly.

For more information about the use of cookies and how to block them, please visit www.allaboutcookies.org or www.youronlinechoices.eu. You can always contact the Provider helpdesk if you have questions or comments about the use of cookies

9. Modification of the Privacy Policy

The Providers constantly modify and improve KNFB Reader, the License Server and the Website with updates and upgrades, and therefore reserve the right to modify this Privacy Policy from time to time.

The Providers will report any modification to this Privacy Policy by posting a message on the Website and the Providers will specify on top of the Privacy Policy the date when it was last modified. The amended Privacy Policy shall be deemed available to You on the date it is made available in an update or upgrade of KNFB Reader. You will be deemed to have accepted the Privacy Policy if you check the corresponding box and update or upgrade KNFB Reader. If you don’t agree with the new terms, you can also opt to not update or upgrade KNFB Reader.

The Providers may use your Personal Data for purposes that were not initially described in this Privacy Policy, but the Providers will inform you about these new purposes and, if required by law, you will be offered the opportunity to consent to such new purposes.

10. Access, updating and rectifying Personal Data

You are entitled to access the Personal Data collected about you and Processed by the Providers and you have the right to rectify inaccurate Personal Data. You can always object to the Processing of your Personal Data for commercial purposes.

When you stop using KNFB Reader and you stop your KNFB Reader Account, the Providers will, upon your first request but not unless you ask that this be done, immediately delete and destroy all of your Personal Data resident on your KNFB Reader account or our License Server.

You can exercise your rights by contacting the Provider Helpdesk. When you do this, you will provide proof of your identity and a clear and precise description of the Personal Data that you want to request access to. If you want Data corrected or removed from our Website, you will describe it in detail. Information you want removed will be removed immediately.

11. Opt-out

You may choose to no longer receive information from the Providers regarding their products and services by any means of communication, at any time and free of charge, by following the instructions that we provide or by contacting the Providers in the manner described under article 17 below.

12. Governing Law

This Agreement shall be governed by and construed under the laws of the State of Maryland, excluding its conflicts of law principles. Any suit hereunder shall be brought in the federal or state courts in Maryland and all parties submit to the jurisdiction thereof.

13. Entire Agreement

This Privacy Policy, together with the documents it refers to, in specific the End User License Agreement of KNFB Reader, constitutes the complete and entire agreement between the Providers and the User regarding the use of the KNFB Reader and the License Server.

14. Severability and Headings.

If any of the provisions, or portions thereof, of this Privacy Policy is held by a court of competent jurisdiction to be invalid under any applicable statute or rule of law, the parties agree that such invalidity shall not affect the validity of the remaining portions of this Privacy Policy and further agree to substitute for the invalid provision a valid provision which most closely approximates the intent and economic effect of the invalid provision. Headings used in this Privacy Policy are for reference purposes only and in no way define, limit, construe or describe the scope or extent of such section, or in any way affect this Privacy Policy.

15. Assignment

The User may not assign his rights and obligations under this Privacy Policy to a third party.

16. Non-waiver

No term or provisions hereof shall be deemed waived and no breach excused, unless such waiver or consent shall be in writing and signed by the party claimed to have waived or consented. Any consent by any party to, or waiver of, a breach by the other, whether express or implied, shall not constitute consent to, waiver of, or excuse for any other different or subsequent breach.

17. Helpdesk

For questions, comments or complaints regarding this Privacy Policy, or if you wish to exercise your right to access, correction and objection to the Processing of your Personal Data for any purposes, you may contact the KNFB Reader helpdesk:.

 

Effective Date: September 14, 2016