PRIVACY AND LEGAL NOTICE STATEMENT OF DORO AB
This sets forth the Privacy and Legal Notice Statement (“Privacy Notice”) of Doro AB, a company organized under the laws of the Kingdom of Sweden with company registration number 556161-9429 at the Swedish Companies' Registration Office (Bolagsverket) (“Doro,” “us,” “we” or “our”), having its corporate headquarters located at Magistratsvägen 10, S-226 43 Lund, Sweden, concerning how Doro with collect, store, disseminate, and resolve any disputes regarding personal information between Doro and you (“you/r” or “user”) under this Privacy Notice. At times, user and Doro are referred to herein, each, when separately, as a “Party,” or when collectively, as the “Parties.”
By using the Doro Software, or any of Doro’s associated software applications, such as “My Doro Manager” or “My Doro Manager for Relatives” (collectively, “My Doro Manager” or “Application”), currently located at www.mydoromanager.com (“the MDM Site”), or by accessing the Doro Software through its web portals www.dorousa.us, www.doro.com or any other by Doro localized regional web portal (the “Site”), and/or using any of the services accessible through the Site, the MDM Site, or otherwise (the “Services”), or by establishing an account on Doro's associated software applications, (the “Account”), you agree to be bound by the terms and conditions of this Privacy Notice, whether or not you ultimately ever use the Doro Software, any of Doro’s associated software applications, the MDM Site, the Site, establishing an Account, or use any of our Services.
Doro respects the privacy of its users and has developed this Privacy Notice to demonstrate its commitment to protecting the privacy of its users. This Privacy Notice discloses the privacy practices of Doro and what information we may collect via the MDM Site, the Site , how we may collect it, with whom we may share it, and certain other matters related to such information, including the choices you may have regarding our collection, use, and disclosure of such information. This Privacy Notice also applies to all personal information received by Doro in the United States of America from the European Economic Area (“EEA”), and from Switzerland, in any format, including electronic, paper or verbal.
You are solely responsible for, and assume all liability, regarding the accuracy and truthfulness of all information and content you provide, publish, post, transmit, communicate, or otherwise make or fail to make available through any or all of the MDM Site, and/or the Site, and/or the Services (collectively, “the Content”).
1. Information We May Collect
When using our MDM Site and/or our Site, and/or our Services, we may collect personal information such as your name, address, telephone number, email addresses, photographs, images, voices, texts, biometric information, and other personally unique or identifying information (“Personal Information”). If you transact business with us, we may collect and retain certain financial Personal Information about you, such as your payment method, credit card number(s), type of credit card, expiration date, card verification value (e.g., CVV or CVV2), and any other related financial information. We may collect, retain, and/or use in the normal course of our business, Personal Information you enter into your Content regarding your medical history or the medical history from other persons.
We may use Personal Information to respond to requests you may make of us, and from time to time, we may refer to Personal Information to better understand your needs and how we can improve our websites, products, and services. We may also enhance or merge Personal Information with data obtained from third-parties for the same purposes. Any other information, such as statistical information, related to, or, transferred by you, or derived by us, in connection with your visiting or subscription use of our MDM Site, or Site, or Services, may be included in databases owned and maintained by Doro or its representatives.
You have the option to not provide some or any of your personal identifiable information or to opt-out entirely (see below). But if you do so, we may not be able to provide you with some or all of the Services.
Our MDM Site and/or Site may also gather Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet Service Provider (“ISP”) so you can access the Internet. Depending on your individual circumstances, it is possible that your IP address may constitute Personal Information because some ISP entities do not change your IP address over time. We use your IP address to report aggregate information on use and to help improve the MDM Site and/or Site and/or our Services.
2. Correction and “Opt Out” Procedures
We grant users reasonable access to Personal Information that we hold about you. We take reasonable steps to permit users to correct, amend, or delete Personal Information that is demonstrated to be inaccurate or incomplete. We also offer users the opportunity to opt-out at any time of whether their Personal Information is disclosed to any non-agent third-party, or used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the user. To request access or opt-out, such request shall be in writing, in English, and shall be delivered personally to an officer or director of Doro by prepaid overnight courier service (such as Federal Express, United Parcel Service, DHL, and the like), facsimile, or email as follows:
Attention: Software & Privacy Compliance Designee
SE-226 43 Lund
Fax: (+46) 46 280 50 01
Please note that you may still continue to receive our Services while we are updating our databases.
3. Information About Others
We may collect and retain Personal Information about other people and/or things that you provide to us, such as their names, images, photographs, voices, sounds, addresses, medical information, biometric information, email addresses, texts, and phone numbers, and the like. You represent you have the necessary permissions and rights to submit such Personal Information to us.
4. United States—Switzerland and European Union Safe Harbor
For Personal Information we receive from the EEA or Switzerland, Doro has committed to handling such Personal Information in accordance with the Safe Harbor Principles. Doro’s Safe Harbor certification can be found at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://export.gov/safeharbor/
Where Doro collects or sends Personal Information directly to or from individuals in the EEA or Switzerland, this Privacy Notice informs you and them about the purposes for which we collect and use Personal Information about them, the types of non–agent third-parties to whom we disclose that information, the choices and means we offer users for limiting the use and disclosure of Personal Information, and how to contact us. This Privacy Notice shall be posted on the MDM Site, and/or Site, and provided when individuals first submit Personal Information to us to register, or as soon as practicable thereafter, and in any event before we use or disclose the Personal Information for a purpose other than that for which it was originally collected.
If we receive Personal Information from our subsidiaries, affiliates or other entities in the EEA or Switzerland, we shall use and disclose such Personal Information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.
We shall use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the user. We shall take reasonable steps to ensure that Personal Information is accurate, complete, current and lawful. We shall obtain assurances from our agents that they shall safeguard Personal Information consistently with this Privacy Notice. If we have knowledge that any agent is using or disclosing Personal Information in a manner contrary to, or otherwise subverts the spirit and intention of this Privacy Notice, we shall take reasonable steps to prevent or stop such use or disclosure or to prevent any subsequent reoccurrence.
We shall take reasonable precautions to protect Personal Information in our possession, custody and/or control, from loss, misuse, unauthorized access, disclosure, alteration and destruction. Any employee who we determine to be in willful violation of this Privacy Notice may be subject to disciplinary action, up to and including termination of employment, and the imposition of civil liabilities, and/or criminal sanctions under controlling laws.
We shall investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles contained in this Privacy Notice. For complaints and disputes relating to the terms of this Privacy Notice that cannot be resolved, we have agreed to International Center for Dispute Resolution, the international division of the American Arbitration Association, (“ICDR”) for dispute resolution under this Privacy Notice. This mechanism allows users an independent recourse so that each user’s complaints and disputes can be investigated and resolved and damages awarded where the applicable law allows. Users who submit a question or concern to us and who do not receive a satisfactory response from us should contact ICDR online at https://apps.adr.org/webfile/, email, postal mail, or facsimile, as set forth below.
International Centre for Dispute Resolution
A Division of the American Arbitration Association
Case Filing Services
1101 Laurel Oak Road, Suite 100
Voorhees, NJ 08043
Phone: (+1) 856-435-6401
Toll free phone number in the United States: (+1) 877-495-4185
Fax number: (+1) 877-304-8457
Fax number outside the United States: (+1) 212-484-4178
Email box: firstname.lastname@example.org
For any questions or for further information about this program, the ICDR’s International Arbitration Rules and forms, along with additional language versions of the ICDR’s International Arbitration Rules, visit the ICDR’s website at www.icdr.org.
5. Disclosure of Your Personal Information
We may share Personal Information and/or Content with representatives, contractors, or partners of Doro in connection with services that these individuals or entities perform with or for us. These representatives, contractors, and partners are restricted from using Personal Information in any way other than to provide Services to you and/or with Doro. In exigent circumstances where national, state, or company security is at issue, Doro reserves the right to share Personal Information and/or Content with the appropriate governmental authorities under controlling laws. We may also provide Personal Information to third-parties in connection with the sale, assignment, or other transfer of the business of the MDM Site and/or Site in which case we shall require any such buyer to agree to treat Personal Information in accordance with this Privacy Notice.
6. Disclosure By Law
You understand and agree that we may disclose your Personal Information if required by any order of any court, tribunal, or any other governmental body or agency of appropriate jurisdiction, or if we, in our sole discretion, believe that the disclosure of some or all of your Personal Information is warranted to protect our rights or property or to comply with any controlling laws.
7. Cookies and Web Beacons
The MDM Site, and/or Site, and/or our devices, may use a technology known as web beacons that allow the MDM Site and/or Site to collect web log information. A web beacon is a graphic (single-pixel gif) on a web page or in an email message designed to track pages viewed or messages opened. Web log information is gathered when you visit the MDM Site and/or Site by the webserver computer that hosts our MDM Site and/or Site. The webserver automatically recognizes some non-personal information, such as the date and time you visited our MDM Site and/or Site, the pages you visited, the website you were just visiting, the type of browser you are using, the type of operating system you are using, and the domain name and address of your Internet Service Provider (ISP). We may also include web beacons in promotional email messages in order to determine whether messages have been opened or deleted.
8. Administrative Accountability
We are the administrators of the MDM Site and/or Site, and as such, we reserve all rights to randomly check user profiles to ensure that there is no misuse of any “free writing” sections. We, as a company, require you to be respectful and courteous when entering text in these sections, and we shall strictly monitor these sections, and censor or delete any entries at our sole discretion to ensure that our users are acting in complete accordance with our Terms.
Additionally, we as administrators of the MDM Site and/or Site reserve all rights to randomly check the user profiles to ensure that member’s contact information is current according to available market information. If we believe your contact information is not current, we reserve the right to update such contact information, and we shall notify you of such changes to your profile.
9. How We Protect Your Information
We use appropriate and reasonable, market-accepted, security measures to help protect your information from unauthorized access and disclosure by or to other individuals or third-parties. We take protecting your Personal Information very seriously; however, no system can be considered entirely secure. Thus, you should not expect, and we do not warrant or guarantee that your Personal Information shall remain protected and private.
10. Questions or Issues
If you have any questions or issues regarding our Privacy Notice, please contact us as shown in the Correction and “Opt Out” Procedures provision above.
11. Acceptance of Privacy Notice
By checking the electronic signature box on the last page of our Doro Software Terms and Conditions statement located at the Site, or the My Doro Manager Terms and Conditions statement located at the MDM Site, and/or your use of the MDM Site and/or Site, you agree that you are subject to this Privacy Notice. If we, in our sole discretion, decide to change our Privacy Notice in the future, we shall post the changes to the Privacy Notice, as found at www.dorousa.us/legal, as well as posting to any other MDM Site and/or Site area, or contacting you directly through Personal Information you provide us, if we deem circumstances to be appropriate to put you on notice of any changes that could affect the Personal Information that you provide to us through use of the MDM Site, Site, and/or our Services.
12. Effective Date
This Privacy Notice was last revised on, and is effective as of July 17, 2015.