Privacy notice

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.

We collect personal data in connection with your use of our services. The types of data we collect include:

• Contact information: such as name, address, email address, and phone number.
• Technical information: device ID, IP address, and data related to your interaction with our products.
• User data: information about how you use our devices and services, including settings, preferences, and feedback.
• 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.

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.

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.
• Marketing: Sending marketing materials where you have provided consent.
• 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.

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 defence 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.

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.
• 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.

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

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.

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.

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.

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.

If you have any concerns or questions about our use of your personal information, you can contact us at the following information.

You also have the right to lodge a complaint with the Swedish lead supervisory authority, Intergritetsskyddsmyndigheten.

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification process. We will not fulfil your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information.

If we cannot comply with a request, we will explain the reasons in our response. We will use personal information provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or clearly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Additionally, you have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining. Once we receive and confirm your request, we will disclose to you:

• The categories of PI we have collected about you.
• The categories of sources from which we collected your PI.
• The business or commercial purposes for our collecting or selling your PI.
• The categories of third parties to whom we have shared your PI.
• The specific pieces of PI we have collected about you.
• A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
• A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we would explain:
  • The categories of your PI we have sold.
  • The categories of third parties to which we sold PI, by categories of PI sold for each third party.

Except to the extent, we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your personal information that we did not collect directly from you.

We do not sell your personal information as such is defined under the CCPA, and until such time as we change this policy by updating this notice, will treat personal information collected under that policy as subject to a do not sell request.

Notwithstanding anything to the contrary, we may collect, use and disclose your personal information as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honour any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will notify you through a notice on our website homepage.

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: