Last updated 24.05.2023
Brief:
Syncsense ApS manages 'Personal data (non sensitive)', 'Working data', 'Content data', and 'Usage data' utilising Google Cloud and Amazon Web Services (AWS) for storage and processing. 'Content data' is acquired with clear establishment agreements, highly visible filming crews, and proper participant consents. We ensure data security and GDPR compliance, offering different functionalities based on internet connectivity. A 'data processor agreement' may be unnecessary as we do not handle 'personal health data (sensitive)', and 'Personal data (non sensitive)' is primarily maintained for effective client communication.
Definitions:
Personal health data (sensitive): This form of data is NOT collected.
Personal data (non sensitive): Data that can clearly be linked to a person(s).
(name, contact information and place of employment)
Data controller: Syncsense ApSData processor: Google Cloud (hosted in the European Union)
Lawful basis: Contractual necessity.
Content data: Data that is collected in the course of creating content for our product.
(360 degree video footage and/or pictures)
Data controller: Syncsense ApS
Data processor: Google Cloud (hosted in the European Union)
Lawful basis: Contractual necessity.
Working data: Data that is used or created on a daily basis in the functioning of Syncsense ApS.
(E-mail correspondence, notes from meetings, pictures and videos along with their consent statements)
Data controller: Syncsense ApS
Data processor: Google Cloud (hosted in the European Union)
Lawful basis: Contractual necessity.
Usage data: Data that tells us how/when our technology is being used.
(date, time, session length, choice of VR film, speed, and whether the tablet and/or sensor were used during the session)
Data controller: Syncsense ApS
Data processor: Amazon Web Services (AWS) (hosted in Ireland)
Lawful basis: Legitimate interest.
Client and non-client data
For any data that is identifiable or that can be clearly linked to a person(s), we further differentiate between ‘client data’ and ‘non-client data’. We maintain ‘personal data’ for as long as a client continues to work with us. In the event that a client stops working with us, for whatever reason, their personal data becomes classified as ‘non-client data’.
For ‘non-client data’ we maintain the data in our systems for 5 years, during this time and as part of our commitment to data protection, we ensure that users have the right to access, rectify, erase, object, and restrict the processing of their personal data, in compliance with GDPR guidelines.
‘Usage data’ and 'content data' with and without internet access
With Internet:
When using our VR headset product with an internet connection, the 'usage data' is automatically uploaded to our Amazon Web Services (AWS) back-end. This enables us to provide detailed usage reports for our clients, offering valuable insights into the performance and usage of the equipment. The continuous data flow also allows for real-time monitoring and efficient support for any issues that may arise during the usage of the VR headset. 'Content data' can be downloaded directly from our google cloud and placed in the headsets manually.
Without Internet:
When our VR headset product operates offline, 'usage data' is saved locally. Updates and system maintenance are implemented through mailed SD cards containing new videos and system patches. Clients can independently extract 'usage data' by transferring the .CSV file from the device to our website for auto-generated reports.
Content data creation
Content data is created based on wishes from our community of users, clients and testers. We make every effort, to the best of our ability and understanding, to secure the necessary authorizations from relevant organisations, individuals, and locations. During our filming processes, we take measures to ensure transparency; our crew is easily identifiable with reflective vests, and we set up signage at the beginning and end of our filming routes to inform the public. If any individual who appears in the footage later requests anonymity, we respect their wishes by making them unrecognisable in the final product. We put forth our best efforts to maintain compliance and respect privacy before and during our operations.
Data Processor Agreement:
A ‘data processor agreement’ may be unnecessary, given that ‘personal health data (sensitive)’ is not within our collection scope. We store ‘Personal data (non sensitive)’ primarily to maintain effective communication with our current and prospective clients.
Data transfers:
Data used and generated by Syncsense ApS does not leave the European Union (EU) or the European Economic Area (EEA) at any point.
Data breach:
Any breach in data protection reported to us by our processor(s) will be reported to the appropriate authorities and relevant client(s) or non-client(s) within 72 hours.
Information We Collect:
We collect geo-location and mobile device information when you use our App. We require permissions to access your device's Bluetooth and location services.
How We Use Your Information:
In order for our VR headset to connect to the tablet/phone application, it is necessary for us to gain access to the Bluetooth system of the device and make a request to connect. This is considered a part of the 'geo-location' package. So we only use the 'Geo-location' in order to enable the streaming.
Sharing Your Information:
We share information with your consent, to comply with laws, provide services, protect rights, or fulfill business obligations.
International Data Transfers:
Your data may be transferred and processed in countries other than your own. but never outside the European Union.
Minors:
We don't knowingly collect data from children under 18.
Privacy Rights:
You may review, change, or terminate your account at any time.
Do-Not-Track Controls:
We don't currently respond to DNT signals.
Privacy Notice Updates:
We update this notice as needed to comply with laws.
Contact Us:
Email our data responsible at steen@syncsense.io or mail us at SYNCSENSE ApS, Frederiksborgvej 66, 3.th., 2400 København NV, Danmark.
Review, Update, or Delete Your Data:
To request access, changes, or deletion of your personal information, submit a request form. We'll respond within 30 days.
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