This is the privacy policy of Nobi. Our (company and contact) information can be found in article 3 below.
We attach great importance to your privacy and data protection. We therefore take all appropriate measures to protect your data processed by or through Nobi, in accordance with the applicable data protection legislation, including the General Data Protection Regulation (GDPR).
This privacy policy applies to the processing of your data by Nobi through the Nobi lamp, the Nobi platform and/or the related services.
In this privacy policy we explain what data we process of you, how we do it, why we do it, on what basis we do it, what rights you have and with whom we can share your data. We strive to inform you as transparently as possible.
We recommend you carefully read this privacy policy. You can consult this policy at any time under the "Privacy Policy" section on the Nobi platform.
Important! If you are unable to read and/or understand this privacy policy or if you do not understand certain aspects in this privacy policy or do not understand them well enough, please seek assistance from a family member, trusted contact or health care provider who can provide you with further information.
For additional questions or requests, you can also always email privacy@nobi.life.
A video with a simple and concise explanation of how the Nobi lamp works and the data it processes can be found at: https://www.nobi.life/product.
This privacy policy does not cover the privacy policies, statements or terms and conditions of third parties, including those of our client such as the care facility, nursing home, hospital or healthcare institution, or any other (care) facility of which you are a resident or care recipient (hereinafter referred to as the "Care Facility") and which may be the controller, if applicable. You may have to read our privacy policy together with the privacy policy of the Care Facility.
Nobi may modify this privacy policy. It is therefore important that you consult it regularly. The most up-to-date version can always be found on the Nobi platform. Any changes will be communicated via the Nobi platform, the website, by email or through other electronic channels. This privacy policy was last amended on December 12, 2023.
This privacy policy is subject to Belgian law. Only the courts of Antwerp (Antwerp division(s)) have jurisdiction in the event of a dispute.
We are (Nobi). We are the so-called "controller" to use a difficult word. This means that we determine the purposes and means of processing and guarantee the lawful and correct processing of your data as a user of our Nobi lamp, the Nobi platform and the associated services.
With regards to the processing of personal data of the Nobi users of Care Facilities, we act as a processor on instruction and on behalf of the Care Facility (which, where applicable, is the controller). We conclude a data processing agreement with the Care Facility, outlining guarantees for appropriate technical and organizational measures to protect the personal data of Nobi users for which the Care Facility is responsible. If you would like more information on this subject, please contact the Care Facility or us at privacy@nobi.life.
Legal form: Private limited liability company (besloten vennootschap)
(Company) name: Nobi
Headquarters:
Generaal Lemanstraat 47 box 5
2018 Antwerp
Company number (CBE): 0849.279.441
Email:
privacy@nobi.life
Hyperlinked website:
https://nobi.life
Our Data Protection Officer can be contacted at privacy@nobi.life.
We process your personal data in the context of the purchase, installation and use of the Nobi lamp, the Nobi platform and/or the associated services of Nobi. Personal data includes all information related to you and on the basis of which you can be identified as a natural person or are identifiable. Individual pieces of data, that, when combined together, can lead to your identification are also considered to be personal data.
Below, you will find a comprehensive overview listing, for each category of data subjects (end user, other user, or Care Facility), the categories of personal data we process, for what purposes, how, and on what basis this occurs. The purposes, legal grounds, and methods of collection/processing are then further explained in articles 4.3 and 4.4 below.
(i) The end user of the Nobi lamp (e.g. care-dependent, resident or otherwise):
(ii) Other user/administrator of the Nobi platform such as the end user's trusted contact or healthcare provider:
(iii) (Appointees of) the Care Facility:
When Nobi processes your data for "your use of Nobi", it refers to: the use of the Nobi lamp, the Nobi platform, and our services by the end user (care recipient/person in need of care or resident), other users (family member, trusted contact, or caregiver), and the Care Facility for the purposes as described in more detail below.
First and foremost, the Nobi lamp is intended for the care of vulnerable adults or those in need of care, namely to help them grow old carefree and happily by enabling them to continue living wherever they want. The Nobi lamp is designed to support people in need of care who live independently or residents of a Care Facility in the context of fall prevention (by using the smart light). The Nobi lamp also supports the caregivers/staff of the Care Facility in the context of caring for the residents. Nobi does this by providing preventive care (fall prevention), detecting a fall via the Nobi lamp (fall detection), and notifying caregivers or family members of this fall so that the person in need of care can be assisted as quickly as possible.
More information can be found at https://www.nobi.life/.
In other words, the care of the Nobi user and fall prevention are the primary purposes of processing your personal data.
Furthermore, we can process your identification details to contact you, process the questions or complaints you may have, and provide you with necessary information about our Nobi lamp, the Nobi platform, our services, our website, or other information related to our activities or services.
We also process your personal data to provide our (platform) services to you, to enable you to access the Nobi lamp and the Nobi platform, to create accounts and profiles for you, and to facilitate communication between the Nobi user(s), family members, trusted contacts, and/or caregivers. For example, through the Nobi Platform, we can send you status and update messages, emails related to the Nobi Lamp and the Nobi Platform, including confirmations, welcome emails, push notifications, and emails related to your use of the Nobi Lamp and the Nobi Platform.
Your personal data (such as financial data) as a Nobi user or Care Facility is processed in the context of our back office services, customer service/help desk, management of our customer files and users, payments, administration, invoicing, solvency follow-up, and for our accounting purposes.
The above-mentioned data processing is based either on the preparation and/or performance of the contract with you, if you contract with Nobi as a Nobi user or Care Facility or even if you do not contract directly with Nobi, e.g., as a family member, trusted contact, or caregiver, then the data processing is based on our legitimate interests within the framework of the cooperation with you or with the Care Facility, insofar as these interests outweigh your (privacy) rights or interests.
When Nobi invokes its legitimate interests, this primarily includes the care for the user and the purposes in this regard (see above) as well as the provision and performance of the Nobi services that meet your needs. This may also include other legitimate interests of Nobi to the extent that they are permitted by applicable law, such as complying with certain legislation or fulfilling requests or orders of supervisory authorities, optimizing and improving our services (see also below), facilitating our activities, generating aggregated statistics, performing market analyses, building and maintaining collaborations with Care Facilities, direct marketing (see also below), evaluation, simplification, testing, and improving of our (business) processes, monitoring our services and activities, prevention of fraud or other illegal or unlawful use of Nobi, (good) governance within Nobi, (risk) management, protection of our business, shareholders, employees, and customers, network and information security, training and supervision of our employees and staff, application of our policies and procedures, and enforcement of legal claims in the event of disputes in which Nobi would be involved. Whenever Nobi invokes its legitimate interests, it thoroughly balances its interests against your interests, including the protection of your (privacy) rights.
We will require your consent for certain data processing, namely the processing of health data, image and sound recordings, or certain other sensitive data. Such consent will be sought through the Care Facility or through Nobi via a consent form where all necessary information will be provided about the processing of the data in question and its purposes. If Nobi is only a "processor" of the Care Facility that is responsible for processing your personal data, the latter shall be responsible for obtaining your consent, unless the Care Facility can rely on another legal basis in data protection legislation for the data processing.
When processing any health data, Nobi has identified the categories of individuals within Nobi who have access to that data, specifying their capacity/role in relation to the processing and accurately writing this capacity down. Nobi keeps this list available to the Data Protection Authority. Nobi ensures that these designated individuals are bound by a legal, statutory, or contractual obligation to maintain the confidentiality of such data.
We may process your (ordinary) data for the administration of Nobi in order to optimize the Nobi lamp and platform as well as our services. This can be based on our legitimate interests, which may outweigh your (privacy) rights. If necessary, your data will be made anonymous as much as possible. We can, for example, analyze your use of the Nobi lamp and the Nobi platform as well as your use history in order to understand how you use Nobi, which functions you use, what interests you have, solely in order to optimize your user experience and the Nobi services.
Finally, your data (only contact details such as name and email address) can be used for direct marketing. This entails sending information about Nobi, our products and services, or other information that might be interesting or useful to you via our newsletter, emails, or other means. If you are an existing customer or user of Nobi, this is done on the basis of our legitimate interests to do business (insofar as these outweigh your (privacy) rights or interests). If you are not a customer or user of Nobi, this can only be done with your prior consent (e.g., by registering on our website). Your consent is free and can be withdrawn at any time.
When Nobi receives your data directly from you, this is because you provide it, for example, when you purchase or install the Nobi lamp and/or through your registration on the Nobi platform, when you contact Nobi (by telephone, in writing, or via the Nobi platform), or when you provide it to us as a Care Facility (for example, via the Nobi platform).
Certain data of yours are automatically generated and acquired via the Nobi lamp during its use, such as information relating to in/out of bed, in/out of room, fall/not fall, depending on the functionalities of the Nobi lamp that you have activated and only when the Nobi lamp detects something relevant and processes your data or that of other persons in that context for the purposes described above. Certain data, such as images (creation of stick figures), are only processed in the event of a fall and insofar as you have accepted or configured this as a Nobi user through the privacy settings provided in the Nobi platform.
Nobi can also receive certain data indirectly, i.e., through your trusted contact or representative (e.g., if you are unable or unwilling to provide the data to Nobi yourself) or your caregiver/healthcare provider or Care Facility that enters your data on the Nobi platform, again only in function of the purposes described below.
If you are an end user of the Nobi lamp living at home, your data can be exchanged with your family member, trusted person, or representative as designated. That person can also manage your data via an application. If you are an end user and resident of a Care Facility, your data will also be exchanged with the latter and with the designated healthcare provider or employee. The Care Facility has access to your data via the Nobi platform. The caregivers of the Care Facility and/or your caregiver have access to an overview of the activities in the rooms where Nobi lamps are installed; they can view, e.g., statistics, but also have access to your identification details, images, and other data within the framework of the use of the Nobi lamp, this only of course to monitor the use of the Nobi lamp.
Some of your data may also be processed by our partners, service providers, or suppliers in connection with the use of the Nobi lamp, the Nobi platform, and our services. This includes, for example, our hosting provider, service provider for notifications to emergency services, mail escalations, software suppliers, companies that provide payment services or other services to us, or other partners or service providers of Nobi. They receive your personal data only if necessary for the services they provide to Nobi in connection with the Nobi lamp and/or the Nobi platform.
With its (sub)processors, Nobi enters into a data processing agreement so that it can guarantee with respect to the Care Facility that it is using an appropriate service provider that processes the personal data in a secure manner on behalf of Nobi. Nobi shall ensure that, together with its (sub)processors and partners, it takes the necessary measures to appropriately integrate the principles of data protection and information security into the Nobi lamp, the Nobi platform, and services of Nobi.
Furthermore, only employees or appointees of Nobi who are authorized to do so have access to your personal data processed through the Nobi lamp. They only have access to the data that is relevant within the scope of our services. These individuals are obliged to maintain strict confidentiality with regards to this personal data.
Finally, other companies may also process your data as part of our business, such as, for example, our accountants, auditors, company auditors, insurance brokers, insurers, legal advisors, attorneys, or other service providers to the extent necessary in the context of their assignment(s) or assistance.
We may be required, by law or in response to a request by supervisory authorities, courts, or government agencies, to provide your information to them or to a third party.
Finally, Nobi ensures that your personal data is not transferred outside the European Economic Area (EEA) or European Union (EU). If Nobi contracts with service providers located outside the EEA/EU, it ensures that the data is hosted within the EEA/EU. If certain personal data is nevertheless transferred from Nobi outside the EEA/EU, Nobi will provide all appropriate safeguards and measures so that the transfer is in accordance with the applicable data protection regulation.
Nobi collects and processes personal data only for the purposes described in Article 4 above. Nobi shall not process or retain your data for longer than necessary for those purposes, unless special legal provisions apply to its retention or processing. Specific retention periods may apply to certain data. In any case, the principle applies that we do not retain your data longer than necessary.
Your data as a Nobi user will generally not be processed for longer than the duration of your use of the Nobi lamp and/or the Nobi platform or the duration of the agreement with Nobi. We may retain certain data for up to 10 years after the end of the contract to the extent necessary to defend our rights or interests in the context of a dispute. In this case, the contractual limitation period corresponds to the retention period.
The images captured by the Nobi lamp of you (recognizable or in stick figure form) are locally stored in the Nobi lamp for a maximum of 30 seconds. Only if a fall incident is detected by the Nobi lamp, a notification is sent to the designated contact person, accompanied or not (depending on the chosen privacy settings) by the image. If the choice is made to include the image (full image or stick figure) with the notification in the event of a fall incident, it will be stored on the Nobi platform for up to 10 days after the incident. Sound recordings or auditory confirmations of the fall are retained by Nobi until the end of the agreement with the Nobi user or Care Facility.
If the "Live view function" of the Nobi lamp is enabled, all images captured throughout the day/night are locally converted to stick figure images in the Nobi lamp, and these images are stored on the Nobi platform for up to 10 days. The Live view function does not generate stick figure images and automatically turns itself off once a person is in bed.
Personal data processed by Nobi in the context of direct marketing will be kept for a maximum of 5 years after the last contact with the customer or prospect in question.
After the expiration of the aforementioned periods, personal data will be deleted or anonymized, unless certain legislation requires a longer period.
When processing personal data for the benefit of the Care Facility where Nobi qualifies as a processor, the duration of the processing as well as the return and/or erasure of personal data at the end of the cooperation shall be regulated in the data processing agreement between Nobi and the customer.
You have the right to information about the processing of your data via the Nobi lamp and the Nobi platform. This is communicated to you via this privacy policy. You can also request additional information from Nobi or from your family members, trusted contacts, and/or healthcare providers at any time.
You also have the right to request:
You may obtain one copy of the requested information free of charge. If you request additional copies, we may charge you a reasonable fee as an administrative cost.
You have the right to obtain a restriction of the processing if you:
You have the right to object to the processing of your data.
You can object to the processing of your data for direct marketing at any time and free of charge.
This can be done simply by letting us know at privacy@nobi.life and/or by unsubscribing on the Nobi platform. You can also unsubscribe via the mailings (an unsubscribe option is provided at the bottom). You will then no longer receive newsletters from us.
You have the right to transfer your data (to another controller). This is only possible if the processing by us is based on your consent or if the processing is performed via automated processes.
If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
You also have the right to file a complaint with the Data Protection Authority (Drukpersstraat 35, 1000 Brussels - T: +32(0)2 274 48 00 - E: contact@apd-gba.be).
The exercise of your rights, as set out above, is always subject to the requirements and conditions as determined by the applicable legislation (such as the General Data Protection Regulation).
To exercise your rights, simply send a request to Nobi at privacy@nobi.life.