Data Privacy Policy

About these terms.

Last modified: 25.5.2018

Hocoma ("Hocoma" or "We") respects your privacy and is committed to protecting it through our compliance with the practices described in this notice.

This notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website or conducting any business transactions via our website regardless of the country you are located in.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites and we encourage you to read the privacy notice of every website you visit.

Please read this notice carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change from time to time. Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.

 

Data we may collect about you.

We collect and use different types of data from and about you including:

  • Personal data that you voluntarily provide to us when you register on the website or conduct a transaction via our website as well as personal data with respect to the processing of your orders. These personal data items include: Title, first and last name, date of birth, gender, eMail address, username and password, shipping and billing address (including zip code, town and country), phone and fax number, type and quantity of ordered products, order number, order date, order status, date and time of the delivery, order value, currency, payment information such as credit card number and expiration date, returns, and offers to you (collectively hereinafter referred to as “business-related data”).
  • Data concerning your use of our website such as your IP address, what products you looked at and which products you put in your cart (collectively hereinafter referred to as “usage-related data”).
  • Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic, statistical, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
  • Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

If we combine or connect non-personal, technical, or demographic data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

 

How we collect data about you

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us information about yourself by filling in forms or by corresponding with us by phone, e-mail, or otherwise. This includes information you provide when you create an account, subscribe to our service, search for a product, place an order, provide us with your contact details, and when you report a problem with our Website.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions, and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies. See Cookies and automatic data collectionbelow.
  • Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment, and delivery services.

 

Cookies and automatic data collection technologies.

 Our website uses only first party session cookies and permanent cookies to collect and save certain types of data from you.

A cookie is a small dataset that the website sends to your computer and that is stored on your computer's hard drive. When you pull up our website, the cookies that were saved on your computer send information to the party that placed the cookie. Session cookies are necessary to ensure, for example, that you remain logged in while visiting our website . These cookies are removed from your computer when you close the browser. Permanent cookies remain on your computer after you close the browser, but you can delete them at any time via your browser settings. To learn more about how cookies work, please visit: www.allaboutcookies.org.

Our website uses session cookies to store the selected products in the cart and to ensure that you stay logged in during your session, if you logged in on the website as a registered user. Session cookies store the relevant information together with your IP address and cookie ID. Session cookies are business-related cookies and are necessary in order for the website to function properly.

Our website may also use permanent cookies to remember your login information so you don't have to re-enter this information whenever you visit the website or to remember your selected country and language so that you land on the preferred country store in preferred language.

 

How we use your personal data. 

We collect, process and use your personal data in order to:

  • Present our Website and provide you with the information, products, services, and support that you request of us.
  • Send information and respond to your inquiries and/or other requests or questions.
  • Process your orders, your payments and to communicate with you in connection with your order.
  • To send you customized marketing messages or invitations to review our products (provided you gave your consent, if required),
  • To process returns, customer queries and recall actions.
  • Meet our obligations and enforce our rights arising from any contracts with you, including billing or collections or complying with legal requirements.
  • Fulfil the purposes for which you provided the data or that were described when it was collected.
  • Notify you about changes to our Website, products, or services.
  • Ensure that we present our Website content in the most effective manner for you and for your computer.
  • Administer our Website and conduct internal operations, including troubleshooting, data analysis, testing, research, and statistical and survey purposes.
  • Improve our Website, products or services, marketing, or customer relationships and experiences.
  • Protect our Website, employees, or operations.

We may use non-personal data for any business purpose.

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

 

Disclosure of your personal data.

We may share your personal data with:

  • Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as or service providers that assist us in processing your credit card payments and delivery service so your order can be processed and delivered). We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.

We may also disclose your personal data to third parties:

  • In the event that we sell or buy any businesses or assets, in which case we may disclose your personal data to the prospective seller or buyer of such businesses or assets.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, where one of the transferred assets is the personal data we hold.
  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce or apply our terms of use and other agreement
  • To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
  • To fulfill the purpose for which you provide the data.
  • For any other purposes that we disclose when you provide the data.

We may share non-personal data without restriction.

 

Consent to personal data transfer.

We are based in Switzerland. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. In such cases, we make sure that the recipients of your personal data maintain an adequate level of data protection.

By submitting your personal data or engaging with our Website, you consent to this transferring, storing, or processing.

 

Your personal data use choices.

 Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates or plug-ins enabling third-party features. If you follow a link to any third-party website or engage with a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

 

Accessing, correcting, deleting, and objecting to processing of your personal data.

You can access, review, and change your personal data by logging into the Website and visiting your account profile page.

You may also send us an email at support@valedotherapy.com to request access to, reception, correction, or deletion of any personal data that you have provided us with, or to restrict or object to the processing of your personal data. In your request, please include your name, email, and postal address, as well as your specific request and any information we may need in order to process your request.

You have the right to withdraw your consent any time, it being understood that this will not affect the lawfulness of processing based on your consent prior to your withdrawal. Please note that we can only delete your personal data by also deleting your user account. We may refuse a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information's accuracy.

 

Data security.

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse and unauthorized access, use, alteration, or disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

 

Changes to our privacy notice.

We will post any changes we may make to our privacy notice on this page. Please check back frequently to see any updates or changes to our privacy notice.

 

Contact information.

Questions, comments, and requests regarding this privacy notice and our privacy practices are welcome and should be addressed to

Hocoma AG

Attention: Valedo Therapy Website

Industriestrasse 4

CH-8604 Volketswil

Switzerland

Phone: + 41 43 444 22 00

E-mail: support@valedotherapy.com

Christina Wagner is our appointed privacy representative.

 


 

Data Privacy Policy – Valedo Application

Hocoma greatly values the trust our customers have in us. To earn your trust, we respect your privacy when we handle any personal data associated with using the Valedo application. This data privacy policy describes who is responsible for collecting, processing and using the personal data that we collect from you, which types of personal data we collect, and what we do with this data.

I. Responsible authority

The collection, processing and use of the data collected from you when you use the Valedo app is managed by Hocoma AG, Industriestrasse 4, CH-8604 Volketswil, Switzerland (“Hocoma”). The data processing is therefore, at least partially, carried out in Switzerland.

II. Type of data

The Valedo application contains an application named “Flurry Analytics” http://www.flurry.com/. This application specifically collects, processes and/or uses the following data: Application version, platform, SDK version, time stamp, API key (app ID), app version, device ID, iOS ID for advertising, iOS ID for seller, Media Access Control (MAC) address, international mobile equipment identity (IMEI), model, manufacturer and operating system version of the device, start and end of the application, operating time of the device, location (specific location that uses a specific language), mobile network code, mobile country code, time zone, network status (Wi-Fi etc.), storage, hard drive, CPU, and information regarding battery use. Flurry executes a hash function with respect to the iOS device ID, MAC address and IMEI, but not with respect to the platform device ID such as the iOS ID for advertising, Android ID and Blackberry PIN. The hash function converts these IDs into a value or key that replaces the original ID. This device ID (if available), IMEI (if available), MAC address (if available) and platform are converted to a Flurry ID. Flurry may use any combination of the data collected by the software agent to identify an End User’s device. Flurry offers the possibility to opt out of its service (currently at https://developer.yahoo.com/flurry/end-user-opt-out/).

In addition, the individual user-specific exercise generated and personal Facebook profile (public profile, friend list and email address) data is not transmitted to a central location such as Hocoma.  If correctly entered by the user, gender and date of birth is collected by Flurry analytics. The user is under no obligation to enter correct data.

III. Recipient category

The Valedo application transmits the Flurry Analytics data via Flurry, Inc. 360 3rd St. Ste. 750, San Francisco, CA 94107, USA. The non – user specific data processing is therefore, at least partially, carried out in the USA.

Please note that the backup and restore functions use your cloud – iCloud or Google services depending on your mobile device –and the functions to share the reports operate locally on your mobile device, e.g. use your email. We do not receive those data. It is your choice whether you want to use these functions.

IV. Purpose of the collection, processing and utilization

Unless otherwise stated, we collect, process and use the above defined Flurry data to find out how users interact with the Valedo application (e.g. which button is clicked most frequently? Which games are played? How often is the Valedo app activated?) and how the Valedo app works on various devices (e.g. How often does the Valedo app crash and which function causes this? etc.).

V. Amendments to the data privacy policy

To improve the service we provide to you, it may become necessary to amend this data privacy policy as part of the continued development of our Valedo and other product applications, among others, due to the implementation of new technologies or introduction of new services. We reserve the right to amend or supplement the present policy, as required. We will publish such amendments here. You should therefore periodically activate the Valedo application to ensure your knowledge of the current data privacy policy.

VI. Contact information

If you have questions about this data privacy policy or if you would like to submit a complaint about Hocoma's data handling, please contact us using the following contact options:

eMail: support@valedotherapy.com
Mailing address: Hocoma AG, Valedo, Industriestrasse 4, CH-8604 Volketswil
Phone: +41 43 444 2200
Fax: +41 43 444 2201

Christina Wagner is our appointed privacy representative.