This privacy policy was last updated on April 24, 2018.

Philips Dictation Hub provides dictation transfer options to predefined destinations, such as email or ftp server and other services (“Services”) to users around the world. This privacy policy is meant to help you understand our privacy practices when you use our Services, including what data we collect, why we collect it, and what we do with it, as well as your individual rights.

Philips Dictation Hub uses personal data collected or processed in the Philips Voice Recorder Application.

This privacy policy applies to personal data collected or processed by the Device and/or the App, which is controlled by or under control of Speech Processing Solutions GmbH or any of its affiliates or subsidiaries (”SPS”, “our”, “we” or “us”).

Please also read our Cookie Notice and Terms of Use, which describe the terms under which you use our Services.

What personal data are collected and for which Purposes

We receive or collect personal data, as described in detail below, when we provide our Services, including when you access, download, install the Device or the App, or use our Services. These data include emails, first name, last name, company, country, operating system, operating system language, ftp server information, smartphone type, Philips Voice Recorder version and the reseller information. We may require to use this personal data to perform the Services requested by you as a contractual necessity, to operate, provide, improve, customize, support, and market our Services based on our legitimate interest, or to comply with a legal obligation to which we may be subject. If you do not want us to collect and process your personal data, you may not be able to use the Services.

Before we use personal data for other purposes than to fulfill our contractual obligations, we will inform you and ask your explicit consent. You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before withdrawing your consent.

Sensitive personal data

We ask that you not send us and you not disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise to us.

Account data

We collect your personal data when you create an account. The personal data we collect may include your username, name, email address, country, language, location and password.

The personal data collected is used to be analyzed by our Google Analytics account in order to improve our services. After having subscribed to Philips Dictation Hub, we will send you a welcoming email to verify your email and inform you of your Philips Dictation Hub subscription. Your email will be used to communicate with you in response to your inquiries, to send you strictly service-related announcements, or direct marketing communication in case you have opted-in. 

Device data

We may collect device-specific information when you install, access, or use the Device. This includes information about your Device, including the unique user device number. We also collect session and usage data, which is related to your use of the Device. 

The data collected is used for analysis purposes by our Google Analytics account and to improve our products.

Location Data

When you allow access to location data, we may collect the geographic location of your mobile device. You can at any time block geo-location collection through the settings of your mobile device.

• Your device location data will be used to be analyzed by our Google Analytics account in order to improve our services. 
• When you make use of the ‘Find SPS near you’ functionality on the Support Page, you are requested to share your location data with SPS. If you use our location features, based on your location data, you will be directed towards a store near you, or to the consumer care contact details for your country.

Transactional information

If you pay for our Services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment.

Customer support

You may provide us with information related to your use of our Services, including your interaction with SPS, and how to contact you so we can provide you customer support. We operate and provide our Services, including providing customer support, and improving, fixing, and customizing our Services. We also use your information to respond to you when you contact us.

Combined data 

We may combine your personal data, including account data, other data provided by you, Device data, cookies, location data, data collected during your interactions and usage of the SPS digital channels such as social media, websites, emails, apps and connected products, IP address, cookies, device information, communications you click on or tap, location details, and websites you visit.

The combined data is analyzed and used to provide you with improved services, software and applications, and help us improve the content, functionality and usability of the App, Device and Services as well as to develop new products and services.

If you opt-in to receive promotional communications about SPS products, services, events and promotions that may be relevant to you based on your preferences and online behavior, we may send you marketing and promotional communications via email, phone and other digital channels, such as mobile apps and social media. To be able to tailor the communications to your preferences and behavior and provide you with a more relevant and personalized experience, we may analyze and combine your personal data. You may opt-out and unsubscribe from such communications at any time.

Permissions

The App may request your permission to access your phone or sensors (e.g. camera, Wi-Fi, geo-location, Bluetooth, microphone, camera, photo library, storage, approximate location (network-based), read phone status and identity) or other data (e.g. photos, agenda, or contacts) on your mobile device. 

• We use such data only when it is needed to provide you the Services and only after you provided your explicit consent.
• Sometimes the permission is a technical precondition of the operating systems of your mobile device. In such case, the App may ask your permission to access such sensors or data, however we will not collect such data, unless when it is required to provide you the App Service and only after you provided consent. 

With whom are personal data shared?

SPS may disclose your personal data to third party service providers, business partners, or other third parties in accordance with this privacy policy and/or applicable law.

Service providers

We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services.

We may share your personal data with the following service providers:

• IT and Cloud Providers
  These service providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or provide the Services. 

• "ViaWest (Flexential)" and "Kapsch BusinessCom" Service Providers
  These providers deliver specific services for Philips Dictation Hub such as hosting servers.

SPS requires its service providers to provide an adequate level of protection to your personal data similar to the level that we provide. We require our service providers to process your personal data only in accordance with our instructions and only for the specific purposes mentioned above, to have access to the minimum amount of data they need to deliver a specific service, and to protect the security of your personal data.

Other third parties

SPS may also work with third parties who process your personal data for their own purposes. Please read their privacy policies carefully as they inform about their privacy practices, including, what type of personal data they collect, how they use, process and protect them.

If SPS shares personal data with a third party that uses your personal data for their own purposes, SPS will ensure to inform you and/or obtain your consent in accordance with applicable laws before we share your personal data.

SPS sometimes sells a business or a part of a business to another company. Such a transfer of ownership could include the transfer of your personal data directly related to that business, to the purchasing company. All of our rights and obligations under our privacy policy are freely assignable by SPS to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your personal data to any of our affiliates, successor entities, or new owner.

Cross-border transfer

Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer (if any) of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data. 

If you are located in the EEA, your personal data may be transferred to our affiliates or service providers in non-EEA countries that are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, such as United States, we have put in place adequate measures, such as our Binding Corporate Rules for Customer, Supplier and Business Partner Data and/or standard contractual clauses adopted by the European Commission to protect your Personal Data. You may obtain a copy of these measures by following the link above or by contacting privacy@speech.com. 

How long do we keep your data?

We will retain your personal data for as long as needed or permitted in light of the purpose(s) for which the data is collected. The criteria we use to determine our retention periods include: (i) the length of time you use the App and Services; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Your choices and rights

If you would like to submit a request to access, rectify, erase, restrict or object to the processing of personal data that you have previously provided to us, or if you would like to submit a request to receive an electronic copy of your personal data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at privacy@speech.com. We will respond to your request consistent with applicable law.

In your request, please make clear what personal data you would like to access, rectify, erase, restrict or object to its processing. For your protection, we may only implement requests with respect to the personal data associated with your account, your email address or other account information, that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that if you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, of our Services anymore.

We protect your personal data

We take seriously our duty to protect the data you entrust to SPS against accidental or unauthorized alteration, loss, misuse, disclosure or access. SPS uses a variety of security technologies, technical and organizational measures to help protect your data. For this purpose we implement, among others, access controls, use firewalls and secure protocols.

The files are sent via a secure https connection to the Philips Dictation Hub. In addition, AES encryption can be activated (please contact your reseller to activate encryption). 

In case of FTP dispatching, we also offer SFTP (FTP over SSH). Please contact support@speech.com in order to activate this option. 

Special information for parents

While the Services are not directed to children, as defined under applicable law, it is SPS policy to comply with the law when it requires parent or guardian permission before collecting, using or disclosing personal data of children. We are committed to protecting the privacy needs of children and we strongly encourage parents and guardians to take an active role in their children’s online activities and interests.

If a parent or guardian becomes aware that his or her child has provided us with his or her personal data without their consent, please contact us at privacy@speech.com. If we become aware that a child has provided us with personal data, we will delete his/her data from our files.

Local specific information: Your California privacy rights (US Only)

California Civil Code Section 1798.83 permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and like to make such a request, please visit our privacy website.

Changes to this privacy policy

Our Services may change from time to time without prior notice to you. For this reason, we reserve the right to amend or update this privacy policy from time to time. When we update this privacy policy, we will also update the date at the top of this privacy policy.

We encourage you to review regularly the latest version of this privacy policy. 

The new privacy policy will become effective immediately upon publication. If you do not agree to the revised notice, you should alter your preferences, or consider stop using our Services. By continuing to access or make use of our Services after those changes become effective, you acknowledge that you have been informed and agree to the privacy policy as amended.

Contact us

If you have any question about this privacy policy or about the way in which SPS uses your personal data, please contact us at privacy@speech.com. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.

Speech Processing Solutions GmbH
Gutheil-Schoder-Gasse 8-12
A-1100 Vienna
Austria