Privacy Policy
How we manage your personal data.
Privacy and Security Policy
The trust of our users in VISUALFY’s services depends on our ability to watch over and protect their personal data, either when they visit our website or install our application on their mobile device, or home device, following the provisions of the European Regulation on Personal Data Protection (679/2016), Law 03/2018 of December 5, as well as the rest of the Spanish and Community legal system. The following information about our Privacy Policy reflects our commitment to maintain and ensure secure business relationships through the protection of personal data, guaranteeing the right to privacy of each of the users of our services. In this document we explain how we use the personal data of the users of the web portal, the application.
Definition of Personal Data
By “Personal Data” we mean any information that identifies or allows the identification of a person. This includes, among others, first name, last name, postal and e-mail address
Processing And Purposes Of The Data Collected
Any personal data you provide when visiting our website or during the provision of services will be treated in accordance with data protection regulations and will only be collected, processed and used for lawful, legitimate and informed purposes.
Below we detail all the purposes for which we collect information:
- To be able to register in our mobile application and use it.
- To become a user and get information about news, events, user benefits, etc. before anyone else.
- So that you can report us suggestions for improvement, both for our application, our website, as well as for the products developed by Visualfy.
- To be able to report information to our system for a better adjustment of the product when you are a user of it.
- To be able to send your request for financing our products to the bank that provides the service, in case you want to acquire it with financing.
- To respond to your request for information or inquiry
VISUALFY will inform all users of the optional or mandatory nature of the collection of certain personal data, except in the fields where otherwise indicated. However, failure to provide such data may prevent VISUALFY from providing all the services linked to such data, releasing us from any liability for the non-provision or incomplete provision of these Services. According to the RGPD, we have established a system of acceptance of policies depending on the purpose for which we require or are provided the data, so that, in the event that we want to use a form for more than one purpose we will request your express permission separately.
We will only process personal data in cases where it is necessary to carry out the requested service (answer your query, purchase a product, subscribe to newsletter…) or when you give us your express consent to do so, unless there is a legitimate interest for processing or legal requirement.
It is the user’s obligation to provide truthful data and keep them updated, so VISUALFY reserves the right to exclude from the services and proceed to the cancellation of the service to any user who has provided false data, without prejudice to any other legal actions. Finally, the user shall not include, in those spaces enabled as “free text fields”, any personal data which may be qualified within those data for which a medium or high level of protection is required (by way of example and not limited to those data related to ideology, religion, beliefs, trade union membership, health, racial origin and/or sexual life), without prior notice to VISUALFY, as defined by the regulations in force. Neither may they be used to infringe the rights to honour and privacy of third parties. Any such information provided will be deleted.
Do We Use Information From Minors?
VISUALFY’s services are only directed to persons who are 14 years of age or older. In addition, from VISUALFY we strongly recommend that if you are a minor but between 14 and 17 years old (inclusive), please read carefully together with your parents or legal guardians the information contained in this privacy policy and in the terms and conditions of use so that you can ask us the appropriate questions before accepting them.
According to the regulations on personal data protection, a person over 13 years of age (i.e. from the age of 14) is capable of accepting or not the processing of their personal data, although they will not have the legal capacity to carry out acts with legal significance (such as purchasing one of our products themselves). Therefore, the purchase is intended only for persons legally capable of entering into a legal transaction such as the purchase of our products.
Permissions Required For The Mobile Application To Work
The Visualfy app requires the acceptance by the user of certain permissions, which do not involve the processing of personal data:
The user must complement the reading of the license of use together with the present point, since next we detail the permissions that the mobile application needs for its correct operation:
Network communication: The purpose of this permission is to communicate with the VISUALFY server.
Storage: This permission is necessary to save in the internal memory of the cell phone the files required to run the application, such as storing VISUALFY configurations.
Phone calls: This permission allows us to read the phone ID and status in order to make use of the Android notification system to, for example, create an alert when there is a missed call. In no case VISUALFY will access or save the list of calls to the contacts in the phonebook.
System Tools: This permission disables the keypad lock and prevents the phone from going into idle mode to display VISUALFY alerts.
Hardware controls: This permission only allows us to make use of the Android vibration system for alerts.
Location: One of the functionalities of our app is to be able to detect when we are in a building equipped with a Visualfy device, so that it is possible to receive the alerts programmed by the person in charge of the building and allow its accessibility, complying with the regulations. For this purpose, the provider’s location services are used (Google/Apple depending on the type of mobile terminal used). Only non-detailed and anonymized location data will be accessed. The location permissions are requested to the user, who, by accepting, allows either Google or Apple (depending on the device) to share the location data it has with the Visualfy app so that, for example, you can receive a non-acoustic alert related to the alerts programmed in the building you have just entered. To do this, geofence techniques are used. For more information, please visit: Google policies or the Apple support center
How does the VISUALFY HOME and VISUALFY PLACES device work in relation to personal data?
Our Visualfy Home Visualfy Places devices collect the sounds they pick up from their environment. This might lead one to think that they can capture information that can identify or make a person identifiable (i.e. personal data). However, they are not devices designed for that purpose. The algorithm developed by Visualfy allows collecting sounds in the user’s own home/building, and storing the necessary time to be able to translate that sound and categorize it, so that what it does is to detect and translate that sound into a sound category (crying, alarm, etc.).
This process is also carried out in the place where the device is installed, since the equipment incorporates the necessary software to translate these sounds without having to be sent for treatment or processing, except in the training phase, which we will discuss later.
This means that the device carries out a process of anonymization of the information it receives, so that it is not possible today to reverse the process and obtain the sound data again, but only stores categories of sounds and not the sounds themselves.
TRAINING PHASE: Our DSS devices require an initial setup and training phase in your home/building, so that they are able to pick up sounds as reliably as possible. This phase is essential for you to obtain proper performance from the device.
The training phase, in the home devices, is carried out by the user himself: Therefore, during this training phase you can send us the recordings you make to capture those sounds in your home that you want to identify. You will decide the time of the recording, so that you will have full disposal on the sounds you want to capture and send us to analyze them conveniently. In these cases the information will travel encrypted for total security. It will only be decrypted in our facilities to proceed to its analysis and inclusion in our sound database to improve the reliability of the system. In addition, we will carry out an anonymization procedure in the storage to guarantee privacy at all times. During your product registration period in the app, we will remind you of this point so that you can confirm that you have read and are aware of the treatment involved in the use of our product.
This phase does involve a differentiated data processing, where Fusió d’Arts is the data controller. The purpose is to provide the contracted service linked to the DSS Home product. This treatment is essential to adjust your device. In addition, we provide you in advance all the information about it. The data will not be transferred to third parties.
In the case of Visualfy Places, the installation and training phase of the device is carried out by our team of professionals. As it is a device designed to provide service to companies and organizations that request it, Fusió d’Arts will be in charge of the treatment on behalf of the responsible, the client company. In case you are interested in obtaining more information about our Visualfy Places device, you can contact us at https://www.visualfy.com/contact/ and we will assist you.
In the event that, instead of being a customer and you have purchased our device, you are a beta-tester, the applicable privacy policy framework will be the specific one that you were informed and expressly accepted at the time of accepting to test our products. In what is not included in its corresponding privacy policy, this other privacy policy will be applied in a supplementary manner, provided that it does not contravene or conflict with the provisions of the specific privacy policy of the tester.
Duration of treatment
In general, Fusió d’Arts will process personal data for the time necessary to fulfill the purpose for which they were collected or provided.
In the case of use of any of our devices or services, the data will be processed for the duration of the relationship between the parties (use of the services or devices).
Once finalized, the data will be stored for the legally required time to fulfill our accounting obligations, tax, justification of subsidies, etc., which may cover 10 years in the case of certain grants or 15 years in the case of the Civil Code.
Data that may be stored on devices owned by home users (DSS Home) will be managed by the users themselves, who are responsible for it. This data corresponds to the alarm sounds that have been trained, so we are talking about samples of non-human sounds. The data stored on the user’s own device will be stored for a maximum of 10 years, unless firmware updates have to be carried out before then, which involve the deletion of the previous information.
The data reported to Fusió d’Arts for the fine-tuning of the device or for the review of possible errors will form part of a sound bank necessary for the device to become more and more effective.
Legitimization of data processing
The legal basis with which Fusió d’Arts Technology SL will process personal data is as follows:
- Consent of the interested party: In those cases in which information is collected via web forms and the Visualfy app.
- Compliance with the obligations derived from a contract or that the processing is necessary to be able to provide the service (Visualfy Places or in the case of Visualfy Home or some necessary functionalities of the app).
- Legitimate interest: In cases where it is necessary for the improvement of the products or services provided to users and clients (reliability improvement tests, etc.). In these cases, legitimate interest is also combined with the need for processing to be able to provide the requested service in the best conditions of quality and safety.
Communication of your Personal Data to Third Parties
The personal data that the company may collect will not be transferred to third parties, except to fulfill the objective for which they were provided, or to comply with our legal obligations. If at any time it is considered convenient to carry out a communication of certain data to third parties, the user would be informed so that they could accept or deny said communication.
For example, the data you provide through the website or mobile application is hosted on Amazon Web Services servers, a US company but which has its equipment for the EU in EU countries (Ireland in our case) so it is subject to European regulations on the protection of personal data. In addition, it has the most demanding certifications in information security, such as ISO 27001 or the ENS HIGH level.
You can consult their privacy policy and GDPR compliance guarantees at https://aws.amazon.com/es/compliance/gdpr-center/
You can also make use of Google applications that may involve the processing of certain information, as in the case of web/app traffic analysis (Google Analytics). The management of analysis cookies is associated with the configuration made by the user. We recommend that you make a responsible configuration of the cookies that are activated and that you carefully read our cookie policy.
Regarding the security and privacy guarantees of Google services, in this case, Analytics, we attach its privacy and data security policy: https://support.google.com/analytics/topic/2919631?hl=es&ref_topic=1008008
Regarding security, you can download your ISO 27001 certification here.
Security of your Personal Data
VISUALFY has a special concern to ensure the security of your personal data. Your data is stored in our information systems, where we have adopted and implemented security measures, both technical and organizational, to prevent any loss or unauthorized use by third parties and to adapt to European regulations on the protection of personal data.
The entire process of data collection from our website is provided with a security system (encryption) that can be verified by observing that in the address bar the page is secure (a green padlock will be seen followed by https).
Information About the Use of Cookies
By the mere fact of visiting this website or using the VISUALFY services, no personal data that identifies a User is automatically registered. However, we inform you that during navigation through the Website “cookies” are used, small data files that are generated on the Internet user’s computer and that allow us to obtain the following analytical information:
a) The date and time of access to the Web, allowing us to know the busiest hours, and make the necessary adjustments to avoid saturation problems in our peak hours. b) The number of daily visitors to each section, allowing us to know the most successful areas and increase and improve their content, so that users obtain a more satisfactory result and improve the design of the content. c) The date and time of the last time the user visited the Website to carry out analytical and statistical studies on the use of the web. d) Security elements that intervene in the control of access to restricted areas. For more information, visit our cookies policy.
User Rights
All users can exercise the rights of access, opposition, rectification, deletion, portability and limitation to data processing by writing to FUSIÓ D’ARTS TECHNOLOGY, S.L., with C.I.F. ESB98369788, and with address at Av. Diputación, 48, Benisanó 46181, Valencia +34 96 202 70 93 or by sending an email to dpd@visualfy.com. Our data protection delegate is Álvaro Orts Ferrer and has been duly registered as such with the Spanish Data Protection Agency. You can address any query or doubt about privacy to him, although you can also go directly to the AEPD in case of defense of your rights and interests: https://sedeagpd.gob.es/sede-electronica-web/vistas/infoSede/tramitesCiudadano.jsf
Do you not wish to receive information from us or wish to revoke your consent?
Any user can revoke their consent at any time (without retroactive effect). To do this, you must send an email to the address dpd@visualfy.com. When you receive commercial information from us by email, you can also oppose it from said email, by clicking on the link included in it and following the instructions provided.
Exercise of data deletion, account deletion and data deletion:
The exercise of the right to delete data can be carried out by the user by email, providing a copy of your identity document to dpd@visualfy.com.
You can also directly delete your account from our application, which will mean the deletion and deletion of your data. Our mobile application allows the total deletion of personal information from an account: The user must enter their application, in the “account” section where they can configure their profile and have the option to “delete account”. Once this is done, a message will appear indicating the exact date on which they will be permanently deleted, which will be 15 days after marking the option to delete the account.
Once this time has passed, your account, data and configuration thereof, will be permanently deleted and you will not be able to recover them, since we will not have the capacity to do so, given that the deletion will be definitive.
Changes in the Privacy Policy.
Our Privacy Policy may undergo updates, due to changes and legal needs, as well as due to improvements and changes included in the way we offer and provide our services and utilities of the application. Therefore, we recommend that you visit and access our Privacy Policy periodically, to be able to access and know the latest changes that may have been incorporated. In the event that these changes are related to the consent given by the user, in such case a separate and separate notification will be sent to them. If during reading you have any questions or queries about our Privacy Policy or want to exercise any right or action related to your personal data, please contact us at the following email address dpd@visualfy.com
Last updated on 3/03/2023.
Text published on 3/03/2023 Version 5