- What personal information we collect from you and for which purpose (Section 3 and 4)
- The measures to safeguard the access to and the security of your Personal Data (Section 5)
- Your rights to access, rectify, erase your Personal Data and object to the processing of your Personal Data (Section 8).
Epihunter provides the Epihunter Application, a set of tools and applications for people with epilepsy and their relatives and caregivers to improve their quality of life. The Epihunter Application consists of the Epihunter Platform, the Epihunter Mobile Applications and the Epihunter Dashboard (each as defined hereinafter and collectively the "Application"). The Platform is the engine of the Application and interacts with and transmits data between the Mobile Applications and Dashboard. In addition, the Platform also analyses and stores data. The Dashboard is an online tool with the sole intention to display, add and store your data. The Mobile Applications interacts with third-party EEG headsets and the user to capture, analyze and display data and forward it to and receive it from the Platform.
The Results (as defined hereinafter) are automatically transferred to the Dashboard through the Platform.
Epihunter is committed to protecting the privacy of all of its users Personal Data and providing a secure, user-controlled environment for the use of the Products in accordance with the the Belgian Privacy Law of 30 July 2018 on privacy protection in relation to the processing of personal data; and the EU Regulation of 2016 (‘GDPR’) concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC. At the same time, you also share responsibility for maintaining privacy and security for example, by not allowing any third party to use your personal account on the Epihunter Mobile Application and Epihunter Dashboard. Epihunter asks all users to be responsible for safeguarding any authentication information and to immediately notify Epihunter of any unauthorized use of your personal Account.
- "Account" means your account registered through the registration process on the Epihunter Mobile Application or Epihunter Dashboard
- "Application" means the (i) Epihunter Platform; (ii) Epihunter Mobile Application and (iii) Epihunter Dashboard
- "Epihunter Dashboard" means the dashboard made available to the users, located at my.epihunter.com
- "Epihunter Mobile Application" means the mobile application (i) which the user has to download on its mobile device and (ii) is intended to record (via third-party EEG headsets and user input), display, analyze, store and transmit your epilepsy data
- "Epihunter Platform" means the platform on which the Epihunter Mobile Application and the Epihunter Dashboard are connected and collectively function. Depending on the user profile different application functions can be made available
- "Products" means the Application, Website and Documentation
- "Results" means the raw EEG data and the results of the analysis by the Epihunter Platform of the EEG data recorded by the User through the Epihunter Mobile Application
- "Insights" means the data collected via the application and rendered in an optimal way by the Epihunter Platform through the Epihunter Mobile Application and Epihunter Dashboard.
- "Third Parties" means any natural or legal person or entity other than Epihunter
- "Website" means the website available at www.epihunter.com
3. Information we collect
We may collect several types of personal information from the users of our Products, and store it on your mobile device and/or our server such as:
- Contact information (e.g. your name, postal address, e-mail address, and mobile or other telephone number)
- The profile data provided by you on your account such as your name and profile picture
- Information in helpdesk support inquiries
- Patient demographics such as date of birth and gender
- Information about your device, such as its model, unique device identifier and operating system version
- Information collected by manual input by the Application, such as seizure onset, etc.
- Payment information such as transaction identifiers and summary information that does not include credit card or bank account numbers (we do not collect or store financial account information)
- Information from third party EEG devices such as EEG signals, headset identification, etc.
- Video and audio information, as recorded by the mobile application
- Web behavior information such as information related to how the users use the Products (e.g. browser type, domains, page views) collected through cookies and other automated technology (cfr. Section 6 "Cookies").
Hereinafter collectively "Personal Data".
We shall store your Personal Data on our servers located in the European Economic Area (AWS - Frankfurt - Germany).
We would like to draw your attention to the fact that Personal Data consisting of patient medical data is also protected by medical secrecy rules.
4. How do we use your Personal Data
Epihunter (i) collects, (ii) uses, (iii) maintains and (iv) may share your Personal Data provided by you or collected by us with its affiliates, parent companies or other related companies for all purposes necessary to ensure the proper functioning and operation of the User accounts and/or the proper functioning of the Products.
These purposes may include (collectively the "Purpose"):
- Creating and managing your Account to use the Application;
- Providing information and allowing the Users access to the Products;
- Diagnosing technical problems and managing technical support and processing inquiries concerning the Products;
- Contacting the Users by phone, email, text message or push notifications (if they are enabled) to (i) verify your account (ii) for information and operational purposes such as account management, instructions, alerts, reminders, customer service, system maintenance and others
- Contacting the Users to (i) communicate about, and organize your participation in market research or (ii) obtaining testimonials;
- Commercializing the Application;
- Performing data analyses (including anonymization and aggregation of Personal Data) and using and sharing the resulting data to third parties for commercialization purposes;
- The operation, evaluation and improvement of the Products (including the development of additional products and/or services, enhancing and improving the current Products, analysis of our Products, quality control activities and performing internal business functions such as accounting and auditing);
- Protecting against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
Furthermore, you agree that Epihunter is free to access, retain, and disclose Personal Data in the following events:
- In order to be in compliance with any applicable legislation or regulations;
- If a law enforcement authority or other government official requests so;
- The investigation of any suspected or actual fraudulent or illegal activity and
- To protect your or our safety and/or rights.
By using the Application, you acknowledge and explicitly agree that we may disclose certain information to vendors and service providers who help us provide the Products. Examples of these vendors and service providers include entities that process credit or debit card payments and provide analytics and web hosting services.
By using the Application, you acknowledge and explicitly agree that we may disclose certain information to providers that build profiles to improve the diagnostic capabilities of the Application. We will not share your information without your permission.
By using the Application, you acknowledge and explicitly agree that, with your permission, we will share some health-related information, with third party devices and services, such as Apple health and Google Fit. If you connect your Epihunter account to a third-party device or service, you may be asked to share your information with that application. We will not share your information without your permission.
You furthermore understand and agree that the technical processing and transmission of the Products, including your Personal Data, may involve (i) transmissions over various networks; and (ii) modifications to conform and adapt to technical requirements of connecting networks, or devices.
Epihunter shall take appropriate administrative, technical and organizational measures against unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use. Upon written request, Epihunter can provide you with a list of people of Epihunter that may have access to your Personal Data.
These people have entered into confidentiality agreements prior to having been granted access to your Personal Data. In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, Epihunter is required by law to notify the user if the breach is likely to affect your privacy.
The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Products (such as usage, activity logs and click-throughs), and dates and times of visits. Log data is deleted on a regular basis.
More information about cookies set by third parties:
- Google AdSense
- Google Analytics
- Google Tag Manager
7. Disclosure to Third Parties
We may also share Personal Data with Third Party service providers who help us to provide, understand, commercialize and improve our Products. We do not authorize these Third Party service providers to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such Third Party service provider with only the Personal Data they need
to perform their specific function.
8. Your rights
Right of access - If you are concerned or have any questions about your Personal Data, you have the right to request access to the Personal Data which we hold or process about you. We will then provide you with information about the data that are being processed and on the source of those data.
Right of rectification and right of erasure You have the right to request us free of charge to correct, erase or block any inaccuracies in your Personal Data if such Personal Data would be incomplete, inaccurate or processed unlawfully.
Right to not be subject to automated individual decision making You have the right to request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
You may also lodge a complaint with a supervisory authority in case of breach of the applicable privacy laws by Epihunter.
9. Data retention
Please note that we retain your Personal Data even if you temporarily stop using the Application until you permanently delete the Application on your mobile device and notify us thereof. Upon notification, we may retain and continue to use and disclose your Personal Data to Third Parties exclusively on a fully anonymized basis.
10. Third Party websites or applications
You acknowledge and agree that certain content or services provided by Third Parties may be made available to you through the Products. You agree that such linked content or services may have their own privacy policies for which Epihunter cannot be held responsible. Epihunter does not in any way review or endorse the privacy practices of such Third Parties.
epihunter NV, Kempische Steenweg 311/1.02, 3500 Hasselt, Belgium