Privacy Policy

This Privacy Policy applies to:

• Visitors to our website
• Users of a Scewo product

2.1 Visitors

Our website can be visited without providing any personal information. We only store access data in our server log files that does not allow us to directly identify individual persons. This includes, among other things, the names of the pages accessed, including the date and time of each access, the amount of data transferred in each case, and the internet service provider through which the respective access takes place. We use this data exclusively to ensure the uninterrupted availability of our website, to analyze the behavior and composition of visitors, and to improve our website.

We collect personal data when a website visitor contacts us, for example via our contact or newsletter form, and provides us with information such as their name and email address. The personal data collected in each case depends on the information requested in the relevant form.

2.2 Users

Since Scewo products are medical devices subject to legal and other regulatory requirements, we are obliged to conduct post-market surveillance. Certain data that we collect from you directly or via the Scewo product during maintenance or through remote access must be provided, as otherwise we would not be able to fulfill our contract with you, ensure the safety of our products, or comply with our legal obligations.

In addition, we process certain further data in order to provide you with the smoothest and most comprehensive service possible and to continuously improve our services and products. You are not required to provide this data. However, providing it enables you to make optimal use of our services and products and allows us to continuously improve them for your benefit.

We process the following data relating to users:

• Telematics log data
  Data relating to the performance, use, operation, or condition of the Scewo product, such as serial number, information on speed and distances, mileage, battery management information, battery charging history, functioning of electrical systems, software versions, camera images, short video recordings of accidents, safety data (including the Anti-Tip System (ATS)), and other data used to identify and analyze the functionality of the product.
• Location data
  Data relating to the continuously updated geographical position of the Scewo product. We process this data in particular to provide support in emergencies and to map stairs that have been climbed.
• Remote maintenance data
  As part of remote maintenance, certain data from your device may be transmitted to us, such as personal settings (contacts or movement history) and the current location of the product. Access to this data within Scewo is restricted to a limited group of persons.
• Data relating to safety analyses
  This includes information about accidents or near-accidents, connection data, software and firmware version data, information about possible circumstances that may disrupt operation, and safety-critical data.
• Maintenance and customer relationship data
  Customer name, serial number, repairs, pending recalls, outstanding invoice amounts, customer requests, and complaints.

We primarily use the personal data we collect in order to comply with our legal obligations, such as post-market surveillance requirements or documentation obligations towards authorities, and to enter into and perform contracts with our customers and business partners. In addition, where permitted and where we consider it appropriate, we also process personal data for the following purposes, in which we (and, in some cases, third parties) have a legitimate interest corresponding to the respective purpose:

• offering and further developing our products, offers, services, websites, and other platforms on which we are present;
• communicating with you or third parties and processing inquiries (e.g. service requests, applications, media inquiries);
• reviewing and optimizing procedures for needs analysis for the purpose of directly addressing customers, as well as collecting personal data from publicly accessible sources for customer acquisition;
• advertising and marketing (including the organization of events), provided you have not objected to the use of your data for these purposes (if we send you advertising as an existing customer, you may object at any time; we will then place you on a suppression list to prevent further advertising);
• ensuring the operation of our business, in particular our IT systems, websites, and other platforms, including fraud prevention.

In exceptional cases, we also process your personal data in order to protect your vital interests or those of other persons, for example if we become aware of an accident and alert the emergency services.

Where you have given us your consent to process your personal data for specific purposes (for example, when registering to receive newsletters), we process your personal data within the scope of and on the basis of that consent, insofar as we require a legal basis and no other legal basis is available. Consent that has been given may be withdrawn at any time. However, such withdrawal does not affect any data processing carried out prior to the withdrawal.

As part of our business activities and for the purposes set out in Section 3, we may also disclose personal data to third parties where permitted and where we consider it appropriate, either because they process the data on our behalf or because they wish to use it for their own purposes. These third parties include, in particular, our partners and service providers (such as partner medical supply stores and local Scewo dealers), as well as processors such as IT providers.

Some of these recipients are located in Switzerland, while others may be located anywhere in the world. In particular, you should expect your data to be transferred to any country in which the service providers we use are located, such as Germany. If we transfer data to a country that does not provide an adequate level of statutory data protection, we ensure an appropriate level of protection as required by law by using suitable contractual safeguards, in particular agreements based on the European Commission’s Standard Contractual Clauses, or Binding Corporate Rules. Alternatively, we rely on statutory exceptions, such as consent, performance of a contract, the establishment, exercise or enforcement of legal claims, overriding public interests, publicly available personal data, or where the transfer is necessary to protect the integrity of the data subjects.

We typically use “cookies” and similar technologies on our websites that enable us to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website. If you visit this website again, this allows us to recognize you, even if we do not know who you are. In addition to cookies that are used only during a session and deleted after your visit to our website (“session cookies”), cookies may also be used to store user settings and other information for a certain period of time, for example two years (“persistent cookies”). However, you can configure your browser to reject cookies, store them only for a single session, or delete them prematurely. Most browsers are preset to accept cookies. We use persistent cookies to better understand how you use our offers and content and to show you offers and advertising tailored to you. This may also take place on websites of other companies; however, these companies do not learn from us who you are, even if we ourselves know, as they only see that the same user who visited a certain page on our website is also on their website. Some cookies are set by us, while others are set by contractual partners with whom we cooperate. If you block cookies, certain functions, such as language selection, shopping carts, or ordering processes, may no longer work.

Where permitted, we also include visible and invisible image elements in some of our newsletters and other marketing emails. When these are retrieved from our servers, we can determine whether and when you opened the email. This allows us to measure and better understand how you use our offers and to tailor them to you. You can block this in your email program; most email programs are preset to allow you to do so.

By using our websites and consenting to receive newsletters and other marketing emails, you agree to the use of these technologies. If you do not wish to consent to this, you must configure your browser or email program accordingly.

We may use Google Analytics or comparable services on our websites. These are services provided by third parties that may be located anywhere in the world. In the case of Google Analytics, the provider is Google LLC in the USA, www.google.com. These services enable us to measure and evaluate the use of our website on a non-personal basis. Persistent cookies set by the service provider are also used for this purpose. The service provider does not receive any personal data from us and does not retain IP addresses, but may track your use of the website, combine this information with data from other websites you have visited that are also tracked by the service provider, and use these insights for its own purposes, for example to manage advertising. If you have registered directly with the service provider, the service provider will also know your identity. The processing of your personal data by the service provider is the responsibility of the service provider and is governed by its privacy policy. The service provider only provides us with information about how our respective website is used and does not provide us with any information about you personally.

We also use so-called plug-ins from social networks such as Facebook, Twitter, or Instagram on our websites. These are visible to you, typically through the corresponding symbols. We have configured these elements so that they are deactivated by default. If you activate them by clicking on them, the operators of the respective social networks may register that you are visiting our website and which page you are visiting and may use this information for their own purposes. The processing of your personal data is then the responsibility of the respective operator and is governed by its privacy policy. We do not receive any information about you from the operator.

We process and store your personal data for as long as necessary to fulfil our contractual and legal obligations or otherwise for the purposes pursued by the processing. This may, for example, cover the entire duration of a business relationship, from initiation and performance through to termination of a contract, and beyond that for as long as required by statutory retention and documentation obligations.

Personal data may therefore be retained for the period during which claims may be asserted against our company and insofar as we are otherwise legally required to retain it or legitimate business interests require it, for example for evidentiary and documentation purposes.

As soon as your personal data is no longer required for the purposes mentioned above, it will generally be deleted or anonymised where possible. Shorter retention periods of twelve months or less generally apply to operational data, such as system logs and other log files.

We take appropriate technical and organizational security measures to protect your personal data against unauthorized access and misuse, including IT and network security solutions, access controls and restrictions, as well as encryption of storage media and data transmissions.

You have the right to access, rectify, or delete your personal data. In addition, depending on the data protection law applicable to you, you may have the right to restrict data processing, object to our processing of your data, and request the disclosure of certain personal data for transfer to another party (so-called data portability). Please note, however, that we reserve the right to invoke the limitations provided for by law, for example if we are required to retain or process certain data, have an overriding interest in doing so (where we are entitled to rely on such interest), or need the data to assert claims. If any costs arise for you, we will inform you in advance. We have already informed you in Section 3 about the possibility of withdrawing your consent. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as early termination of the contract or additional costs. In such cases, we will inform you in advance unless this is already regulated contractually.

Exercising these rights generally requires you to clearly prove your identity, for example by providing a copy of an identity document where your identity is otherwise unclear or cannot be verified. To exercise your rights, you can contact us at the address specified in Section 1.

Every data subject also has the right to enforce their claims through the courts or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

We may amend this Privacy Policy at any time without prior notice. The current version published on our website shall apply. Where the Privacy Policy forms part of an agreement with you, we will inform you of any changes by email or by other appropriate means if we have your contact details.

This Privacy Policy is valid from: 03.09.2020