This is the privacy statement applicable to the use of our websites in the domain assistiveware.com and services (as specified herein), as offered by AssistiveWare B.V. (hereinafter also: “we” or “us”).

We value your privacy and process your personal data (i.e. information relating to an identified or identifiable natural person) in accordance with the General Data Protection Regulation 2016/679 (GDPR) and specific national laws and regulations as may be applicable, such as the Children’s Online Privacy Protection Act of 1998 (“COPPA”). In this privacy statement we will explain which types of personal data we collect, for which purposes and how we protect such data to the best of our abilities.

This privacy statement applies to personal data processed through use of the AssistiveWare website, the AssistiveWare Account or other electronic communications sent through or in connection with AssistiveWare. For the AssistiveWare applications, please consult the relevant privacy statement applicable to such individual applications.

  1. Identity and contact

    AssistiveWare B.V.
    Laurierstraat 193
    1016 PL Amsterdam
    the Netherlands
    E: legal@assistiveware.com

  2. Types of personal data and processing purposes

    When you access and use our website or services, we will collect and process personal data in the ways as explained in more detail here below:

    1. Applications

      For our application see the application specific privacy statements:

    2. AssistiveWare’s websites

      When using our websites, we will process your IP-address and traffic related data such as application version, device information, application settings and application usage statistics. This data is not linked to the person using the product, nor can it be used to disclose the identity of the user. We use this data to analyse the use of our website, to resolve any malfunctions and to test and improve the user-friendliness of our website. We do this by using Google Analytics, MixPanel, and HotJar in an anonymized way.

    3. AssistiveWare Account

      When you register for an AssistiveWare account in order to make use of one or more of our AssistiveWare applications, we collect and process the personal data you provide, such as your name, email address, country of residence.

      In the event you create an account on behalf of a school/university or care institution, we may also ask for additional (predominantly optional) information, such as name and type of the organization, your role within the organization, license or certification information.

      The legal basis for processing these types of personal data can be found in (the preparation of) providing you access to our application(s), providing a license to our application(s), and/or consent.

    4. Support

      When you create a support request, either via our website, via Intercom, or through one of our applications, we collect the personal data you provide, such as name, email address and potentially other (contact) details you voluntarily provide to us. This information will be used to contact you and/or follow up on a support request. In specific cases the issue data may be shared with our product development team to resolve software related issues. It will not be shared with third parties and/or used for other purposes.

      The legal basis for processing these types of personal data can be found in the execution of our agreement with you regarding the use of the applications or consent (e.g. depending on the context of home versus school use).

    5. Newsletter

      When you opt-in for our newsletter or make use of our products or services, we may occasionally keep you informed about updates in our products and services or other relevant developments in that regard. The processing of personal data in this regard occurs on the legal basis of having a legitimate interest to keep you informed of new releases or updates of our applications or services and potential new solutions or tools, or on the basis of consent should you sign up for receiving the newsletter. You may at any time withdraw previously given consent or unsubscribe from receiving newsletters from us by clicking the ‘unsubscribe’ link in the email.

    6. License sales

      The sales of licenses on our website is handled by Bright Market, LLC doing business as FastSpring. Your privacy is primarily governed by their privacy statement, see https://fastspring.com/privacy...;

      AssistiveWare will receive, process and store a subset of the data collected by FastSpring. The legal basis for processing these types of personal data can be found in (the preparation of) providing you with access to the applications, and the support thereof.

  3. Minors

    AssistiveWare recognizes the importance of protecting the privacy of minors. Because our applications are intended for people in need of augmentative and alternative communication, in many cases this includes minors. Our applications have been setup by default in such a way that:

    • We let the device administrator or team admin control the collection and use of the user generated data of the minor via the AssistiveWare applications, in particular by making them responsible for providing the various types of data, and for selecting the individuals with whom such user (generated) data may be shared or not;
    • We limit the collection and processing of personal data of minors as much as possible, in any event no more than is necessary to make reasonable use of the minimum features in the applications.
    • In the event our applications are being used by schools and/or universities, we shall only act as ‘processor’ and adhere to the instructions of the school and/or university.

  4. Personal data we share with third parties

    We will never sell your personal data to third parties, nor will we use or share your personal data for third party advertising, -profiling or -marketing purposes. Your personal data will only be shared with third parties in the following circumstances:

    • where applicable or relevant in connection with the AssistiveWare application, with authorized individuals;
    • where we engage external suppliers, service / hosting providers, support members or advisors for the benefit of our service performance ("(sub-)processors");
    • (government) authorities or organizations to whom we must disclose certain personal data on the basis of a legal obligation.

    Where applicable, we have concluded data processing agreements and/or confidentiality agreements with service providers or third parties involved in connection with the use of the applications, wherein we only permit them to process personal data subject to and in accordance with specific instructions.

    The personal data will be collected and processed through servers located in the European Economic Area (EEA) and in the United States of America (USA). In the event personal data under the responsibility of AssistiveWare as the ‘controller’, is being transferred to countries or third parties outside the EEA, we will take into account the statutory requirements in relation thereto. This may for example include the existence of EU standard contractual clauses.

  5. Protection and retention of personal data

    We have taken adequate technical and organizational measures to protect your personal data against loss and the unauthorizedaccess or misuse thereof. Amongst others we use encryption and SSL for security. We also have two-factor authentication (2FA) where applicable, access management, and we have internal guidelines for our personnel regarding the use and processing of personal data and what to do in the event of a data breach.

    We retain your personal data no longer than is necessary for the purpose for which we have collected the personal data, or in correspondence with an applicable statutory retention term. You may at all times request the removal of your personal data. We will respond to such request within the statutory timeframe.

  6. Your rights

    You have the right to request access to or the amendment, deletion or data transfer of your personal data. You may also submit a request to restrict or object to certain data processing. You furthermore have the right to withdraw any previously provided consent. This may result in the inability to make further use of our products or services.

    You may direct any requests or complaints regarding the processing of your personal data to us via the contact details as provided in this privacy statement. We will respond to such requests within the applicable statutory timeframes. For completeness, we also note that you have the right to submit a complaint with the relevant data protection authority in your country of residence.

  7. Changes

    We reserve the right to unilaterally amend this privacy statement to ensure compliance with the GDPR and/or other applicable data protection laws. It is recommended that you consult this privacy statement on a regular basis in order to be aware of any potential changes. Your continued use of our products or services after changes to the privacy statement will deemed to be your acceptance of such changes.

This privacy statement was last updated in October 2023.