Tobii Dynavox Logo

Privacy Notice for Tobii Dynavox Clinical & 
Beta Programs

General Privacy Policy for Dynavox Group AB (Publ) – last updated on the 1st of November
2024. 

California residents – please refer to “Privacy Notice for California Residents” below.

We appreciate the trust you place in us by choosing our communication and accessibility solutions. As we embark on this journey together, your privacy and data security are of utmost importance to us.

Tobii Dynavox, part of Dynavox Group AB and its affiliates ("we," "us," or "our"), is committed to safeguarding your privacy. This Privacy Notice outlines how we collect, process, and protect your personal data when you interact with us, use our products and services, or visit our website.

Please note that this policy only covers Dynavox Group AB (Publ)’s use of personal data. Sometimes, other companies buy or license our technology and use it to handle personal data as part of their service offering. In such cases you should refer to the privacy policies of those respective businesses.

Thank you for choosing us!

1. Who are we? 
Tobii Dynavox, a part of Dynavox Group AB and its affiliates ("we," "us," or "our"), is dedicated to providing accessible communication solutions while safeguarding your privacy. Dynavox Group AB acts as the Data Controller for the personal data collected from you when you use our products and services or interact with our website. 

For questions about this Privacy Notice or how we handle your personal data, please contact us at dataprivacyteam@tobiidynavox.com

2. What Personal data do we collect?
We collect personal data in connection with your use of our services. The types of data we collect include:
Category Data
Contact Information:
  • Name
  • Birth year
  • Age
  • Email
  • Location (Country/State/City)
  • Type of tester (End User, Caretaker/Assistant, Professional (BM only))
Technical Information: data related to your interaction with our products.
  • Current device IP
  • IP address
  • Input method(s)
  • Current software(s)
  • Type of testing (Software(s), New devices, Learning supports)
User Data: information about how you use our devices and services, including settings, preferences, and feedback
  • Comfort level with using communication device or software (1 – Getting started, 3 – Efficient in communication, 5 – Explore and adapt independently) (Not applicable to Professionals for BM)
  • Comfort level with using Boardmaker type software (1 – Getting started, 3 – Efficient, 5 – Teaching others) 
  • Technical ability rating (1 – Lost, 3 – I know what I am doing, 5 –Teaching 
    others)
  • Testing type (Surveys, Focus groups, Remote interaction, On-location interaction)
Health Data (where applicable): if you use our assistive technologies, we may process health-related data only to the extent necessary to provide the service. 
This processing is done based on explicit consent
  • Diagnosis 
  • Health Care information

3. Data Collection from Third-Party Sources
In addition to personal data, you provide directly, we may collect information from third-party sources to enhance our services or provide a more personalized experience. For example, if you interact with us through social media or other platforms, we may collect personal data from those services in accordance with your privacy settings on those platforms.

4. Why do process your Personal Data?
We process personal data to deliver, maintain, and improve our products and services, as well as to 
comply with legal obligations. Specifically, we may process your data for:

  • Service Delivery: Ensuring our products and services function correctly and meet your needs.
  • Product Improvement: Analyzing usage to enhance our products and customer experience.
  • Legal Compliance: Complying with legal obligations and protecting our interests in cases of fraud prevention, security, and other legitimate interests.

Legal Basis for Processing: We process personal data based on the following lawful grounds:

  • Performance of a Contract: Processing necessary to fulfill our contractual obligations to you.
  • Consent: Where you have given explicit consent, particularly for sensitive data.
  • Legitimate Interests: Legitimate Interests: For purposes such as fraud prevention, ensuring network and data security, and improving our products and services. We ensure these interests do not override your privacy rights by balancing our interests with your expectations.
  • Legal Obligations: When required by law to process data, such as for regulatory compliance.

5. Data Sharing and Transfers
We may share personal data with trusted third parties to support our business operations, including
but not limited to: 

  • Service Providers: Partners who help us operate and improve our products and services.
  • HealthCare Providers: Such as Recommenders, Insurance Companies and other similar institutions to assist with the funding or evaluation process of our Products.
  • Affiliates within Dynavox Group: For administrative and customer support purposes.
  • Legal Authorities: When required by law, we may share data in compliance with legal obligations or for the defense of legal claims.

We may transfer personal data outside the European Economic Area (EEA) only when adequate protections are in place, such as Standard Contractual Clauses, ensuring your data receives the same level of protection as within the EEA. 

6. How long do we retain your data?
We retain personal data only as long as necessary to fulfill the purposes outlined in this Privacy 
Notice, considering legal, regulatory, or contractual obligations. For instance:

  • Account Information: Retained as long as your account is active and for a period afterward to comply with legal requirements.
  • Usage Data: Information about how users interact with apps and systems, including usage statistics, access logs, and system activity. This data is retained for 6 months to 2 years, depending on the purpose (e.g., improving service, security monitoring). We ensure data is only kept for the specified purpose and no longer than necessary. We anonymize or aggregate data where possible to increase privacy.
  • Communication Data: Data related to communications between users and the organization, including messages, call recordings, videos, and images. Varies based on user needs but typically between 1-5 years. Data critical for user communication could be retained longer, subject to user consent.
  • Health Data: Retained only for the duration necessary to deliver assistive services, subject to your consent. Once personal data is no longer required, it will be securely deleted or anonymized to ensure continued privacy.

Once data is no longer required, we securely delete or anonymize it, in line with data protection 
regulations.

7. Your rights
You may wish to exercise a right to obtain information about yourself or to correct, update or delete that information. Some of these rights may be subject to some exceptions or limitations in local law. Please note your rights and choices vary depending upon your location. We will take reasonable steps to verify your identity, and we will respond to your request to exercise these rights within a reasonable. subject to the below for specific categories of person.

Under the General Data Protection Regulation (GDPR), you have the following rights regarding your 
personal data:

  • Access: You have the right to request access to the personal data we hold about you.
  • Rectification: You may request that we correct inaccurate or incomplete personal data.
  • Erasure: You have the right to request that we delete your personal data under certain conditions.
  • Restriction of processing: You may request that we limit the processing of your personal data in certain circumstances.
  • Data portability: You may request a copy of your personal data in a structured, commonly used format.
  • Objection: You may object to the processing of your personal data in certain situations, such as for direct marketing purposes.

To exercise any of these rights, please contact us at dataprivacyteam@tobiidynavox.com 

Find out more about these rights, and how you can exercise them by either contacting Tobii Dynavox AB (Publ) or obtain information from the appropriate supervisory authority. Please see chapter 11.2 for contact information. 

8. Children’s Privacy
Many of our products and services are intended for children under 13 years of age, and we do not knowingly collect personal data from children under this age without verifiable parental consent. If we discover that we have inadvertently collected such data, we will delete it promptly. If you believe that we have collected data from a minor, please contact us at dataprivacyteam@tobiidynavox.com 

9. Data Security
We prioritize the security of your personal data. To prevent unauthorized access, loss, or misuse, we use a combination of technical and organizational measures, including encryption, access controls, and secure servers, to protect your information. These measures are continuously reviewed to ensure they meet evolving security standards.

10. Changes to Privacy Notice.
We may update this Privacy Notice periodically to reflect changes in legal or regulatory requirements, 
or our practices. In case of significant changes, we will notify you as appropriate, such as through 
email notifications or website updates. Please check our Privacy Notice periodically for the latest 
information on our practices

11. How to contact us. 
If you have any concerns or questions about our use of your personal information, you can make a contact to us at our request page or at the following contact information.
Website: www.tobiidynavox.com
Email: dataprivacyteam@tobiidynavox.com
Postal Address: Löjtnantsgatan 25, 115 15, Stockholm, Sweden
Attn: Data Privacy Team
The Data Privacy Team for Dynavox Group AB can always be contacted at dataprivacyteam@tobiidynavox.com. You also have the right to lodge a complaint with the Swedish lead supervisory authority, Intergritetsskyddsmyndigheten