In the framework of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical physiological, genetic, mental, economic, cultural or social identity of that natural person).

“Data Protection Legislation” means Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – “GDPR”), as well as any delegated act in relation to the GDPR, national laws and decrees executing the GDPR and (ii) any similar applicable legislations, laws, rules, or regulations from countries outside of the European Union.

This Privacy Policy explains what and how Piko-Tech collects, processes, uses, stores and protects, and in some cases, shares with third parties, certain Personal Data and usage data related to You when You use the Services as further described in the GTCs.

Piko-Tech respects Your privacy and the way You choose to provide data. Piko-Tech recognizes the need for appropriate protection and management of the Personal Data collected. This Privacy Policy is intended to assist You in understanding what types of Personal Data Piko-Tech may collect and process, how that Personal Data may be used, and with whom the Personal Data may be shared.

Piko-Tech processes Your Personal Data in compliance with this Privacy Policy and the GTCs. When You register with the Services, You acknowledge that this Privacy Policy applies and that Piko-Tech processes Your Personal Data in accordance with and for the purposes specified herein. This Privacy Policy is accessible on the Website and via the app.

The legal basis for the processing of Personal Data are, depending on the type of processing:

• the necessity for the performance of a contract to which the User is party to or the performance of pre-contractual measures taken at the request of the User (in particular, processing that is necessary to perform the Agreement as defined in the GTCs);
• the legitimate interests pursued by Piko-Tech (namely the provision of optimal Services for the Users, in order to meet the needs of these Users, manage their requests and improve the Services as well as ensure the integrity of the processing, learn the habits of its Users in order to better advertise for its products or services and improve the Services, without impeding their rights and fundamental freedoms);
• processing is necessary for compliance with a legal obligation to which the controller is subject; and
• the consent of the User (in particular with respect to the processing of special categories of Personal Data, as specified below).

A table further detailing, for each category of Personal Data, the relevant data subjects and legal basis of processing is provided at the end of this Privacy Policy.

Piko-Tech processes certain Personal Data in the framework of the provision of the Services.

The Personal Data collected and processed by Piko-Tech encompass the following information:

Account Data: (i) Personal Data related to You as provided by You or generated by Piko-Tech during the registration procedure to the Services and the creation of the User account or when updating the latter – processing based on the necessity to use the Services and to perform the Agreement: name, surname, email address, profile picture (optional), age (date of birth), address, voice recognition (optional), languages spoken (optional), gender, mobile and/or fixed phone numbers, in-app notification preferences and password; whether the Subscription Fees have been paid, whether it is a Master Account or a Linked Account and, in the latter case, to which Master Account the Linked Account is related, to which other User account(s) a User account has been Paired, Free Trial Period, User account renewal payment date, last four digits and expiry date of credit card, language selection, and log of acceptance of legal terms; (ii) Personal Data related to Your Children as provided by You or generated by Piko-Tech during the registration procedure to the Services and the creation of the User account or when updating the latter – processing based on the necessity to use the Services and to perform the Agreement: name, surname, profile picture (optional), age (date of birth), address, voice recognition (optional), languages spoken (optional), gender, mobile number (optional); to which Master Account the Linked Account is related;

Medical Data: (Optional – Personal Data related to You or Your children as provided by You during the registration procedure to the Services and the creation of the User account or when updating the latter – processing based on Your consent): blood group, recent blood test report, allergies, hearing or speech disorders, hypertension, diabetes, high blood pressure, heart failure, pulmonary insufficiency, thyroid problems, migraines, back problems, ulcers, gastritis or other problems with stomach, glaucoma, asthma, epilepsy, surgical history (year, surgery, reason, identity and location of the surgeon, details of surgery (e.g. coronary artery bypass graft)), medication habits or prescriptions, problems with anesthesia, smoker and if yes how often, alcohol drinker and if yes sorts of alcohol and how often, history of hematomas or bleeding (and details), transfusion, contact lenses, dental and/or hearing aids, medication and treatment followed (molecule, doses, number of shots), whether You wear external medical devices (such as dental prosthesis, hearing aids, contact lenses or a pacemaker), contraction of STD(s). We also process Your eyes color, stoutness, hair type and color, hip to foot height, weight, height and BMI. All Medical Data is provided and entered by You about Yourself or Your children. The Services do not determine, calculate or assess any Medical Data. You are solely responsible for and attest to the accuracy of all Medical Data You provide;

Level of first aid knowledge Data (Personal Data related to You as provided by You during the registration procedure to the Services and the creation of the User account or when updating the latter – processing based on the necessity to use the Services and to perform the Agreement): level N0 (by default): no first aid knowledge; level N1: basic first aid knowledge (first aid diploma such as the European First Aid Certificate or EFAC); level N2: advanced medical (nurse or doctor); level N3: emergency services (doctor, emergency medical technician (EMT), or nurse). We may also collect and process evidence of your qualifications for screening purposes;

Location Data: (Automatic collection - processing based on the necessity to use the Services and to perform the Agreement - optional): Global Navigation Satellite System data (hereafter “GPS Data”) from Your smartphone (as further specified in section 6);

Video Data: (User activated - processing based on the necessity to use the Services and to perform the Agreement - optional): live caption video and recording of the scene of the accident via the smartphone camera;

Audio Data: (Automatic collection - processing based on the necessity to use the Services and to perform the Agreement - optional): rolling audio recordings of 2 minutes of your environment activated according to Your settings (from the Home Page, in case of incident or in case of disappearance), automatically erased after seven days;

Feedback Data: (User provided data e.g. by email, online forms or through Piko-Tech’s social networks accounts - processing based on Your consent): Your and/or your selected third parties’ feedbacks and comments in relation to the handling of your emergency call by our call center (customer satisfaction survey), or the medical consequences of an Emergency in which You were involved, the date of the emergency, the time and date of submission of answers to the survey, answers to the customer satisfaction survey (incl. reason for call, satisfaction with agent, agent behaviors, resolution, number of contacts), country and/ or region of emergency;

Third Party Data: (Personal Data related to third parties as provided by You during the registration procedure to the Services and the creation of the User account or when updating the latter - processing based on the necessity to use the Services and to perform the Agreement - optional): name, email address and phone number of one or more person(s) to contact in case of Emergency, degree of proximity with such person(s) according to Your settings, whether such person(s) hold(s) a key to Your house, name and emergency telephone number to which Your doctor can be contacted, whether such person downloaded the Z-KUR app or not, whether such person lives with You, Medical Data and age of such person(s) in the context of an Emergency, settings of the Linked Account related to recordings of Audio Data, Video Data and Location Data.

Other Data: (Automatic collection - processing based on the necessity to use the Services and to perform the Agreement): list of contact persons, type of transport (car, bike, walk, etc.), type of Emergency, communication of an Emergency the Z-KUR app would not have detected, communication of information in case of unexpected activation of the app, content of the question sent to us, evaluation of Your priority order to intervene in the context an Emergency, logs of intervention in the context of an Emergency, PSAP intervening in the context of an Emergency, where applicable, contact details of relevant PSAPs in your vicinity and, only for US residents, the fact that You opted-out of the class action waiver described in Article 11 of the GTCs

Personal Data related to Your and Your children’s use of the Services (“Service Data” –automatic collection – processing based on our legitimate interests): ID of the device You or Your children use to access the Services (MAC address), data on when You or Your children use the Services and for how long, app pairing number and QR code (if any), information related to Your and Your children device’s operating system and type, logs and other data related to Emergencies and other messages/communications sent via the Services (i.e. date and time of issuance, recipient as the case may be, and content) as well as functionalities available to You and Your children, depending on your location (as some functionalities may not be available in some countries).

A table further detailing, for each category of Personal Data, the relevant data subjects is provided at the end of this Privacy Policy.

By providing Personal Data about any third party (such as family members), You warrant that You have (i) obtained their prior consent (or have the legal authority to consent on their behalf, e.g. in relation to Your children), (ii) informed them of the existence of this Privacy Policy and (iii) secured all the necessary permissions to disclose such Personal Data and allow it to be used for the Services.

Where applicable, Piko-Tech will send an SMS and/or email or will display an in-app notification to such third parties to inform them of the processing of their Personal Data and/or Linked Account activation request.

The Personal Data that are processed may also include GPS Data, as specified in section 4, defined as data processed in an electronic communications network or by an electronic communications service and indicating the geographical location of the device of an end-user using a publicly accessible electronic communications service. GPS Data processed are the geographical data provided by the GPS system to identify the exact location of the end-user’s device. By authorizing the Services to access Your device’s GPS Data which you can do according to Your app settings, You consent to the processing of such GPS Data for the purposes of performing the Services, such as identifying the location of the User, and communication of such location to the emergency and/or security services, when such user or the Services report an Emergency. GPS Data will not be processed for longer than necessary for such purpose, and will not be processed for purposes other than those specified in section 10 of this Privacy Policy. You have the opportunity to withdraw Your consent to the processing of Your GPS Data by disabling the geolocation function on Your device and/or in the Z-KUR app and you also have the possibility to choose how long You want Piko-Tech to retain your GPS Data. PLEASE NOTE HOWEVER THAT DEACTIVATING GPS DATA WILL SIGNIFICANTLY AFFECT THE CORRECT PROVISION OF THE SERVICES AND/OR THE EFFICIENCY OF THE Z-KUR APP WITH RESPECT TO THOSE FUNCTIONALITIES BASED ON LOCATION AND/OR MAY SEVERELY IMPEDE THE RESPONSE OF FIRST AID OR EMERGENCY RESPONDERS.

Piko-Tech also has (where applicable) the ability to use network-based techniques utilized through the carriers network infrastructure to identify the location of a mobile device (triangulation technique). This feature does not use the devices GPS and will only be activated if requested by PSAP in case of an Emergency.

Under certain Data Protection Legislation, “special” categories of personal data are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

As described in section 4 of this Privacy Policy, Piko-Tech collects and processes the Medical Data that You can freely decide to provide to Piko-Tech. Medical Data are considered as "special" Personal Data by certain Data Protection Legislation, deserving special attention and protection. Your Medical Data is processed exclusively in order to provide the most complete information possible to the PSAP and to identify quickly and efficiently the care to be provided in the event of an Emergency. The communication of Your Medical Data and that of Your relatives is not mandatory in the context of the use of the Services and YOU CAN DECIDE FREELY NOT TO COMMUNICATE SUCH MEDICAL DATA, IN WHICH CASE THE EFFECTIVENESS OF THE SERVICES WILL HOWEVER BE DRASTICALLY REDUCED.

Medical Data will be saved only if You have expressly consented to the validation of the data by clicking on the "Save & Next", "Save" or "Save Changes" button.

Your collected Medical Data, if any, will be transferred from Your device – in an encrypted form – to Piko-Tech’s server, for onward transfer to PSAP solely in case of an Emergency affecting You and reported through the Z-KUR app.

Piko-Tech does not allow anyone under the age of 18 to create a Master Account (as defined in the GTCs). If You wish to share Personal Data from underage persons, You acknowledge that You have the necessary permission to share such Personal Data and Piko-Tech reserves the right to ask You for proof that You exercise parental authority over or are the legal guardian of these underage persons.

You undertake to provide us with an accurate representation of Your age and to avoid re-registering with a different age after being previously rejected due to age restrictions, as the case may be.

In the event that the parental authority must be exercised by both parents, Piko-Tech will send an email asking the second parent to provide evidence of parental authority/legal guardianship, authorize the processing and confirm the accuracy of the Personal Data provided. Upon receipt of such authorization, Piko-Tech will send a confirmation by email to the second parent. The parent’s consent can be revoked at any time without justification.

Piko-Tech does not knowingly solicit or collect information from anyone under the age of thirteen (13) and the Services is directed at persons 18 years of age or older. If You are under the age of eighteen (18), please do not attempt to register for a Master Account or provide any Personal Data to Piko-Tech. If You are under the age of eighteen (18), You may only use the Services via a Linked Account and with the consent of your parent(s) or legal guardian. If You are the parent or guardian of a child under the age of eighteen (18), or the legal age of contract majority, and have authorized Your child to use your mobile device, computer or provided a mobile device or a license to use the Services via a Linked Account to such child, Piko-Tech urges You to instruct Your child never to give out his or her real name, address, phone number, email address or other personally identifying information while using the Services, unless explicitly required due to an Emergency. Piko-Tech recommends that the Internet browsing behavior of any child should be carefully supervised by a responsible adult at all times. There are no applications or devices in the Services which allow for the verification of Your age. All information used to create a Master Account will be treated as information given by an adult.

If Piko-Tech discovers that Personal Data of a child under 13 has been collected without parental or guardian consent, Piko-Tech will take reasonable steps to delete such Personal Data, which may require Piko-Tech to delete the child’s account or Services access. If You are a parent or guardian of a child under the age of 13 and become aware that Your child has provided Personal Data to Piko-Tech without Your authorization and consent, please contact us at myprivacy@pikotechnologies.net.

Piko-Tech may take Your Personal Data and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to You (de-personalizing your information). Given the nature of this information, there are no restrictions under this Privacy Policy upon Piko-Tech’s right to aggregate or de-personalize Your Personal Data, and Piko-Tech may use and/or share with third parties the resulting non-personally identifiable information in any manner in Piko-Tech’s sole discretion.

Additionally, in order to contribute to medical research and with Your consent, Piko-Tech collects and anonymizes certain data relating to the progress of Your possible convalescence after the Emergency reported via the Services. Such anonymized data cannot identify You or be linked to You. With the anonymized data, Piko-Tech can gather information after an Emergency/deceleration/gyrocompass movement and compare the importance of deceleration or gyrocompass movement with the type of internal injuries. Piko-Tech may deal with third party providers to collect and analyze this non-personal data.

Since none of these data will allow anyone to identify You, Piko-Tech may share this anonymous data with third parties only for those medical research purposes. You can choose not to share those anonymized data in Your settings.

Piko-Tech collects and processes Personal Data related to You solely for the purposes indicated in this Privacy Policy. The main purposes for which Piko-Tech processes Your Personal Data are:

• to perform the Services and to manage the contractual relationship between You and Piko-Tech;
• to create, identify, verify and manage the Master Account (and the Linked Account(s), if any), set the preferred language, control Your access rights;
• to contact You and answer to Your queries, correct assignments of access and functions, identify use/misuse of the Services;
• to provide You with informative content related to health (which is not marketing content);
• to contact the first-aid Users closest to the accident site and the emergency services;
• to contact You and/or your selected third parties in order to enable medical feedbacks on the consequences of an Emergency;
• to send You SMS or emails to collect your authorization in relation to processing of Personal Data of children where applicable;
• to improve the Services;
• to provide data to payment providers;
• to provide customer service and support regarding the Services;
• to notify you about changes to the Services;
• to monitor the usage of the Services;
• to detect, address and remedy technical issues with the Services; and
• to comply with administrative, regulatory and legal requirements

To the greatest extent possible, Piko-Tech shall process aggregate data (which is data that does neither identify You nor can be linked to You, such as statistic data), pseudonymized or anonymized data, rather than Personal Data, when the purposes of such processing can be achieved in the same way.

Piko-Tech may use Your Personal Data for new purposes which are as yet unforeseen in this Privacy Policy, either on the basis of an applicable statutory permission or of Your consent. In any event, prior to using Your Personal Data for other purposes, Piko-Tech will inform You about the changes to this Privacy Policy and, in case of consent-based activities, Piko-Tech will offer You the possibility to accept or not participation to these changes.

Piko-Tech may also disclose or use Your Personal Data:

• to comply with any applicable law or legal process, including in response to judicial, administrative, or governmental subpoenas, warrants or orders served on Piko-Tech;
• when Piko-Tech believes it is necessary to protect and defend Piko-Tech’s rights or property, to enforce the provisions of this Privacy Policy and/or any other Piko-Tech terms and conditions or agreements, including the GTCs, to guard against fraud, and/or to prevent harm to Piko-Tech, its Users, its customers, its providers and any other person or entity;
• in the event of a change of ownership, corporate sale, acquisition, merger, reorganization, sale of assets, or dissolution or similar event; or
• when a petition for relief is filed under any applicable bankruptcy laws for or against Piko-Tech or if Piko-Tech becomes subject to an order of appointment of a trustee or receiver.

Piko-Tech reserves the right to release and/or use all information contained within Piko-Tech’s databases, access logs or other records concerning You, including Your Personal Data, if you violate this Privacy Policy, the GTCs, and any Piko-Tech terms and conditions, or other rules, policies, notices, agreements or guidelines, or if You intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity, including but not limited to hacking, even without a subpoena, warrant or other court order, and to release such information in response to court and governmental orders, civil subpoenas, discovery requests and as otherwise required by law and/or to initiate Piko-Tech’s own legal proceedings. Piko-Tech cooperates with law enforcement agencies in identifying those who may be using the Services (or any part thereof) for illegal activities. Piko-Tech also reserves the right to report any suspected illegal activity to law enforcement individuals or to entities for investigation or prosecution.

The Personal Data of a child under the age of thirteen (13) that has been provided by a User in compliance with this Privacy Policy will not be transferred by Piko-Tech except in the event of an Emergency.

You have the right to access to Your Personal Data and the Personal Data You have entered for any Third Party, as collected and processed by Piko-Tech, and to request their rectification or erasure (as the case may be) in the event that they would be inaccurate or unnecessary. You have the right to restriction of processing or to object to the processing as well as the right to data portability.

Most of the Personal Data You provided us with can be directly accessed, erased and rectified by navigating on the Z-KUR app or your User account.

Otherwise, in order to exercise Your rights, You only have to send a written and signed request to Piko-Tech at the email address myprivacy@pikotechnologies.net or at the postal address PIKO-TECHNOLOGIES SA, Avenue Paul Hymans 126, 1200 Brussels, Belgium, together with a document proving that You are the data subject of the Personal Data.

In general, You also have the right to withdraw Your consent to any processing at any time. This withdrawal of consent does not affect the lawfulness of the processing based on consent made prior to such withdrawal.

Piko-Tech may deliver notifications to Your mobile device (i.e., push notifications). You can disable these notifications by changing the settings on Your mobile device or User account or by deleting the Z-KUR app.

You should be aware that You cannot opt-out of receiving transaction related communications, including regarding purchases, provision of the Services, and customer support.

If You consider that the processing of your Personal Data constitutes a violation of Data Protection Legislation. You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the European Union of Your usual place of residence or any other applicable jurisdiction, Your place of work or the place where the violation occurred.

Transfer of Personal Data to first-aid Users

In the framework of the provision of the Services, and Your use thereof, Piko-Tech may send to first-aid Users (i.e. Users of the Services having agreed to be contacted in the event of an Emergency affecting another User reported on the Z-KUR app, and taking place near their location) the following data, when authorized by Data Protection Legislation: GPS Data, information about the Emergency, name, age range, gender, Your profile picture (if any) and the address of Your home (only in case of an Emergency at Your home) and the list of designated persons that could be involved in the Emergency.

Medical Data will not be sent to first-aid Users.

Transfer of Personal Data to PSAP

Piko-Tech may also send Personal Data and Third Party Data (including Medical Data and information about the Emergency) to PSAP in the event of an Emergency affecting You reported through the Z-KUR app. PSAP will be granted temporary and limited access to those Personal Data and Third Party Data when a specific Emergency has taken place.

PSAP will also be granted access to GPS Data, Level of first aid knowledge Data, and Video Data and first name only from one or more nearby first-aid Users contacted through the Z-KUR app.

Transfer of Personal Data to subcontractors

To provide You with the Services, Piko-Tech may call upon subcontractors and service providers acting on Piko-Tech’s behalf, including in relation to hosting and external payment services, to whom certain Personal Data related to You may be communicated and with respect to which Piko-Tech has taken appropriate measures to ensure the protection of Your Personal Data, in accordance with the Data Protection Legislation.

Piko-Tech is using Stripe Payments Europe Ltd. (a company incorporated under the laws of Ireland - “Stripe”) to process Your payments. When You make payments or conduct transactions through Stripe, Stripe will receive Your transaction information. This information is provided directly from Piko-Tech. The information that Stripe collects will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. Stripe may also receive Your name, email, billing or shipping address and in some cases your transaction history to authenticate You. Stripe’s privacy policies are available at https://stripe.com.

Additional Transfers of Personal Data

Generally, Piko-Tech will not transfer Your Personal Data to third parties, except the transfers (i) authorized under applicable law or (ii) as specified in this section 12 or elsewhere in this Privacy Policy.

You also acknowledge the transfer of Your Personal Data in the event Piko-Tech sells or transfers all or a portion of its business or assets to a third party.

To the extent that this involves the transfer of Personal Data to countries outside of the European Economic Area that would not be considered by the European Commission as ensuring an adequate level of personal data protection, Piko-Tech shall ensure that appropriate contractual measures are put in place in accordance with the Personal Data Legislation. A copy of those appropriate contractual measures can be provided upon request.

Finally, given the nature and purpose of the Services, Piko-Tech may disclose certain of Your Account Data (in particular Your first and last name, email address, mobile phone number) as well as certain of Your Service Data as may be required by law to competent police and judicial authorities in relation to any Emergency reported via the Services.

Piko-Tech will retain Your Personal Data, collected and processed by Piko-Tech in accordance with this Privacy Policy, for the duration of the Agreement as specified in the GTCs and will delete Your Personal Data within six (6) months following the expiry of the Agreement (unless Piko-Tech has a specific legitimate interest in storing Your Personal Data for a longer period, e.g. to the extent the data is required to clarify an alleged infringement of third party rights, to resolve a dispute, or to comply with a legal obligation). Any Personal Data which is contained in Piko-Tech’s or any of its subprocessor’s regular backups will not be deleted, provided that any such Personal Data shall remain subject to the confidentiality and data privacy and security terms and conditions of this Privacy Policy until destroyed.

Notwithstanding the foregoing, Location Data, Audio Data and Video Data will not be kept longer than chosen by You in Your settings.

Piko-Tech has put in place the required security measures in order to protect the Personal Data processed through the use of the Services against accidental or unauthorized destruction, loss as well as illicit or unauthorized modification, use, access and other processing. Piko-Tech takes reasonable steps to maintain the confidentiality of Your Personal Data and protect it from unlawful disclosure. Piko-Tech will not make Your Personal Data publicly available.

Piko-Tech reserves the right to monitor all network traffic in and to the Services to identify and/or block unauthorized attempts or intrusions to upload or change information or cause damage to any of the Services in any manner. Anyone using any of the Services expressly consents to such monitoring.

Please be aware that no data transmission over the Internet or which is stored on a computer or device connected to the Internet can be guaranteed to be 100% secure, so while Piko-Tech strives to protect your Personal Data, Piko-Tech cannot ensure or warrant the security of any information that you voluntarily give to Piko-Tech.

15.1. Cookies

Piko-Tech uses so-called “cookies” on the Website to improve and personalize Your navigational experience. Cookies are pieces of data (small electronic text files) that are stored on the device of the User that contain data of a User or his/her device.

Cookies may be either permanent or temporary. Piko-Tech may use both temporary and permanent cookies. A temporary or “session” cookie is placed on your computer or mobile device during your visit to certain parts of the Services and is deleted when you exit your Internet browser, the Z-KUR app and/or turn off your computer or device. A permanent or “persistent” cookie means that the cookie stays on your hard drive or mobile device until you delete it. You can delete Piko-Tech’s permanent cookie at any time by following the instructions contained in your browser’s help file, or by contacting the company providing your browser’s or mobile device’s technical support.

In the framework of the use of the Website, cookies may be placed on Your device to collect both anonymous data and Personal Data related to You as specified in this Privacy Policy.

When You visit the Website for the first time, information on privacy and wording regarding the consent to the use of cookies will appear through a “cookie banner”. If You continue to actively use the Website and do not actively object to the use of cookies, You agree to Piko-Tech’s use of cookies and such consent will be stored in Your browser, so that the information of the “cookie banner” does not have to be repeated on every page of the Website or at Your next connection. In the event that Your consent would no longer be registered in Your browser (e.g. in case of suppression of the cookies), the “cookie banner” will appear again the next time You visit the Website.

Piko-Tech installs and uses certain technically required cookies on Your device which do not require Your prior consent. Other cookies (such as cookies to improve the navigational experience by keeping record of certain data (this avoids You having to reintroduce such data at each connection) and by tailoring the content of the Website to Your preferences) may be installed and used on the basis of Your consent. You may, at any time, delete or block cookies in Your browser parameters. However, in such case, some functionalities of the Website and/or Z-KUR app requiring the use of cookies may no longer be available to You. There are also several services and websites which allow you to visit websites, including the Website, anonymously. Again, You may not be able to access or use all of the content or services available on the Website if you use these anonymizing services or websites. If You change computers or browsers or devices, or use multiple computers or browsers or devices or delete Piko-Tech’s cookies, You will need to repeat this process for each computer, each browser, and each device.

Piko-Tech uses analytics cookies to gather general information on how users use the Website (e.g. which pages they visit most frequently). These cookies do not collect any data that may lead to an identification of the users. All information collected with the aid of such cookies exclusively serves the purpose of understanding and improving the functionality of the Website.

15.2. Log Files

As is true of most websites, Piko-Tech gathers, on the Website, certain information automatically and stores it in log files. This information may include IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or page views.

Piko-Tech uses this information, which does not usually identify individual users, to analyze trends, to administer the Website, to track users’ movements around the Website and to gather demographic information about Piko-Tech’s user base as a whole.

The Website and/or Z-KUR app may include links to other websites which are not subject to this Privacy Policy and whose privacy practices may differ from those of Piko-Tech. If You provide personal information to any of those other websites, the collection and processing of Your information will be governed by such other websites’ privacy policy. Piko-Tech recommends and encourages You to carefully read the privacy policy applicable to these other websites that You visit before disclosing any Personal Data. Piko-Tech assumes no responsibility whatsoever for the Personal Data and privacy practices of such websites.

The app stores (e.g., App Store or Google Play) may collect certain information in connection with Your use of the Services, including Personal Data, geolocational information, and other usage-based data. Piko-Tech has no control over the collection of such information by any third-party app store, and any such collection or use will be subject to such third-party app store’s applicable privacy policy.

Do Not Track Requests: Piko-Tech does not currently have the capabilities to recognize the Do Not Track signals from Internet browsers. Therefore, any selection You make within Your Internet browser will not be applied to the Services. For more information regarding Do Not Track You can visit www.allaboutdnt.org.

Under California Civil Code 1798.83, Piko-Tech currently does not share any Personal Data with third parties for their direct marketing purposes. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of Your Personal Data with third parties. If You reside in California and have provided Your Personal Data to Piko-Tech, You may request information about Piko-Tech’s disclosures of certain categories of Personal Data to third parties for direct marketing purposes. Such requests must be submitted to Piko-Tech at one of the following addresses: myprivacy@pikotechnologies.net.

Within thirty (30) days of receiving such a request, Piko-Tech will provide a list of the categories of Personal Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties, if any. This request may be made no more than once per calendar year. Piko-Tech reserves the right not to respond to requests submitted other than to the address specified in this Section, requests not labeled or sent properly, or requests that do not have complete information.

Users that are Nevada residents may, under Nevada law, opt-out by directing a business that operates a website or online service not to sell or license certain Personal Data that the business has collected or will collect about a Nevada resident. Please note, under Nevada law, Piko-Tech does not sell Your Personal Data to any third party for resale or license. For more information about how Piko-Tech handles and shares Your Personal Data or Your rights under Nevada law, Nevada Users may contact Piko-Tech at myprivacy@pikotechnologies.net.

If You have any question regarding the collection, processing and use of Your personal Data by Piko-Tech or otherwise related to this Privacy Policy, You can contact Piko-Tech by email at myprivacy@pikotechnologies.net. California residents can also contact Piko-Tech by phone at 1-800[PIKOTECH].

You may also contact our Data Protection Officer, The Privacy Office SA (c/o Ms. Sabine Mersch) by mail at Hochstrasse 81, 4700 Eupen, Belgium or by email at DPO@pikotechnologies.net.

Purpose of processing	Legal basis	Categories of Personal Data	Data subjects
Access to medical data for emergency and doubtful events management	Consent	Health data (Alcohol drinker and if yes sorts of alcohol and how often; Allergies or intolerances; Asthma; Back problems; Blood group; BMI; Contact lenses; Contraction of std(s); Dental and/or hearing aids; Diabetes; Epilepsy; Gastritis or other problems with stomach; Glaucoma; Hearing or speech disorders; Heart failure; High blood pressure; Hip to foot height; History of hematomas or bleeding (and details); Hypertension; Medication and treatment followed (molecule, doses, number of shots); Medication habits or prescriptions; Migraines; Problems with anesthesia; Pulmonary insufficiency; Recent blood test report; Smoker and if yes how often; Stoutness; Surgical history (year, surgery, reason, identity and location of the surgeon, details of surgery (e.g. Coronary artery bypass graft)); Thyroid problems; Transfusion; Ulcers; Weight; Whether the users wear external medical devices (such as dental prosthesis, hearing aids, contact lenses or a pacemaker))	Full user Underage user with own App Underage user without own APP
Accounting	Legal obligation	Financial data (Bank account number; Transaction information (date, amount, product/service purchased); VAT number); Identification data	Full user
Application support	Contract	Electronic identification data (Logs of date and time of notifications); Free text field (Category of question: [insert drop-down list of possible questions], free text field); Identification data (First name; Last name); Status of request: pending, closed	Family & Friend (F&F) First aid user (FAU) Free users Full user Underage user with own App
Automatic incident detection	Contract	Geolocation (Geolocation); User's activity at the time of the incident (e.g. walking, cycling, driving, etc.)	Free users Full user Underage user with own App
Communication regarding app functionalities	Legitimate interests	Education & training (First aid level; Level N1: basic first aid knowledge (first aid diploma such as European First Aid Certificate or EFAC); Level N2: advanced medical (nurse or doctor); Level N3: emergency services (doctor, emergency medical technician (EMT), or nurse); Level of First-aid knowledge data: level N0 (by default): no first aid knowledge); Electronic identification data (Logs of notifications sent (with date and time)); Identification data (First name; Last name)	Family & Friend (F&F) First aid user (FAU) Free users Full user Underage user with own App
Customer satisfaction survey	Consent Legitimate interests	Electronic identification data (Date of the emergency; Time and date of submission of answers); Geolocation (Country and/ or region of emergency); Identification data (Email address; First name; Last name); Others (Answers to the customer satisfaction survey (incl. Reason for call, Satisfaction with Agent, Agent behaviors, Resolution, Number of Contacts)); Personal characteristics (Gender; Language)	Full user
Emergency and doubtful events management	Contract	Geolocation (Localisation of the involved users; of the FAU/F&F); Household composition (Potentially informing CC module agent of who is living under the same roof (when FAU/F&F/children are called to verify the situation of accident user at home)); Identification data (Address; Email address; First name; Last name; Phone number/mobile phone); Judicial measures (Guardian of children); Life habits (Life habits); Others (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user; List of contact persons; Live caption video and recording of the scene of the accident via the smartphone camera; Logs of intervention in the context of an emergency; Name and emergency phone number to which a doctor can be contacted; Name, email address and phone number of one or more person(s) to contact in case of Emergency; PSAP intervening in the context of an Emergency; Rolling audio recordings of 2 minutes of the surrounding environment of the user; The details about the accident that occurred; Types of transport (car, bike, walk, ...); Where applicable, contact details of relevant PSAPs in your vicinity; Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not); Personal characteristics (Age range; Eye color; Gender; Hair type and color; Language); Sound recording (Sound recording (phone, digital, analogic))	Full user Underage user with own App
		Geolocation (Localisation of the involved users; of the FAU/F&F); Household composition (Potentially informing CC module agent of who is living under the same roof (when FAU/F&F/children are called to verify the situation of accident user at home)); Identification data (Address; First name; Last name); Judicial measures (Guardian of children); Life habits (Life habits); Others (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user; List of contact persons; Live caption video and recording of the scene of the accident via the smartphone camera; Logs of intervention in the context of an emergency; Name and emergency phone number to which a doctor can be contacted; Name, email address and phone number of one or more person(s) to contact in case of Emergency; PSAP intervening in the context of an Emergency; Rolling audio recordings of 2 minutes of the surrounding environment of the user; The details about the accident that occurred; Types of transport (car, bike, walk, ...); Where applicable, contact details of relevant PSAPs in your vicinity; Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not); Personal characteristics (Age range; Eye color; Gender; Hair type and color; Language)	Underage user without own APP
		Geolocation (Localisation of the involved users; of the FAU/F&F); Identification data (Address; Email address; First name; Last name); Others (Live caption video and recording of the scene of the accident via the smartphone camera; Logs of intervention in the context of an emergency; PSAP intervening in the context of an Emergency; The details about the accident that occurred; Types of transport (car, bike, walk, ...); Where applicable, contact details of relevant PSAPs in your vicinity); Personal characteristics (Gender; Language)	Family & Friend (F&F)
		Geolocation (Localisation of the involved users; of the FAU/F&F); Identification data (Address; Email address; First name; Last name); Others (Live caption video and recording of the scene of the accident via the smartphone camera; Logs of intervention in the context of an emergency; PSAP intervening in the context of an Emergency; The details about the accident that occurred; Types of transport (car, bike, walk, ...); Where applicable, contact details of relevant PSAPs in your vicinity); Personal characteristics (Gender; Language)	First aid user (FAU)
		Geolocation (Localisation of the involved users; of the FAU/F&F); Identification data (Address; Email address; First name; Last name; Phone number/mobile phone); Image recording (Picture of the involved users in order to make available to the FAU to recognize the involved users); Others (Type of emergency accident (traffic roads; bike, ...))	Free users
			Full user
			Underage user with own App
			Underage user without own APP
		Geolocation (Localisation of the involved users; of the FAU/F&F); Identification data (Email address; First name; Last name; Phone number/mobile phone)	First aid user (FAU)
	Medical diagnosis	Others (Type of emergency accident (traffic roads; bike, ...))	Free users
			Full user
			Underage user with own App
			Underage user without own APP
License management	Legitimate interests	Identification data (First name; Last name); Others (Date of expiration of the license; Linked Account related to the Master Account; Reference of the licence; Type of Account owned)	Full user
			Underage user with own App
Management of Family & Friends list	Contract	Identification data (Email address; First name; Last name; Phone number/mobile phone); Profiles (Possession of a key of the house; Possession of an App)	Family & Friend (F&F)
Management of FAU registration and status	Consent	Consumption habits (OS and device); Electronic communication data (Password); Electronic identification data (Application pairing number (if any); Data on when the users uses the application and for how long; Log of acceptance of legal terms); Identification data (Address; Date of birth; Email address; First name; Language; Last name; Phone number/mobile phone); Image recording (Profile picture (optional)); Others (House location; In-app notification preferences; Status of the account (free); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not); Personal characteristics (Gender)	First aid user (FAU)
Management of free user account	Contract	Consumption habits (OS and device); Electronic communication data (Password); Electronic identification data (Application pairing number (if any); Data on when the users uses the application and for how long; Log of acceptance of legal terms); Identification data (Address; Date of birth; Email address; First name; Language; Last name; Phone number/mobile phone); Image recording (Profile picture (optional)); Others (House location; In-app notification preferences; Status of the account (free); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not); Personal characteristics (Gender)	Free users
		Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not	Family & Friend (F&F)
Management of Linked Account	Consent	Sound recording (Voice recognition)	Full user
	Contract	Consumption habits (OS and device); Electronic communication data (Password); Electronic identification data (Application pairing number (if any); Data on when the users uses the application and for how long; Log of acceptance of legal terms); Geolocation (House location; Picture of the house); Eye color; Hair type and color; Height; Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Date of birth; Email address; First name; Language; Last name; Phone number/mobile phone); Image recording (Profile picture (optional)); Others (Contact person in case of emergency; Free trial period; In-app notification preferences; Linked Account related to the Master Account; Name and emergency phone number to which a doctor can be contacted; Status of the account (free trial or paid subscription); Types of transport (car, bike, walk, ...); User account renewal payment date; Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not; Whether the subscription fees have been paid); Personal characteristics (Gender); Sound recording (Voice recognition)	Full user
		Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Email address; First name; Language; Last name; Phone number/mobile phone); Others (Contact person in case of emergency; Name and emergency phone number to which a doctor can be contacted; Types of transport (car, bike, walk, ...); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not)	People to contact in case of emergency
Management of Master Account	Contract	Consumption habits (OS and device); Electronic communication data (Password); Electronic identification data (Application pairing number (if any); Data on when the users uses the application and for how long; Log of acceptance of legal terms); Financial data (Last four digits and expiry date of credit cart); Geolocation (House location; Picture of the house); Eye color; Hair type and color; Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Housing characteristics (Floor); Identification data (Address; Date of birth; Email address; First name; Language; Last name; Phone number/mobile phone); Image recording (Profile picture (optional)); Others (Contact person in case of emergency; Free trial period; In-app notification preferences; Linked Account related to the Master Account; Name and emergency phone number to which a doctor can be contacted; Status of the account (free trial or paid subscription); Types of transport (car, bike, walk, ...); User account renewal payment date; Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not; Whether the subscription fees have been paid); Personal characteristics (Gender; Height); Sound recording (Voice recognition)	Full user
		Geolocation (House location; Picture of the house); Eye color; Hair type and color; Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Date of birth; First name; Language; Last name); Image recording (Profile picture (optional)); Others (Contact person in case of emergency; Free trial period; Linked Account related to the Master Account; Name and emergency phone number to which a doctor can be contacted; Status of the account (free trial or paid subscription); Types of transport (car, bike, walk, ...); User account renewal payment date); Personal characteristics (Gender; Height); Sound recording (Voice recognition)	Underage user without own APP
		Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Email address; First name; Language; Last name; Phone number/mobile phone); Others (Contact person in case of emergency; In-app notification preferences; Name and emergency phone number to which a doctor can be contacted; Types of transport (car, bike, walk, ...); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not)	People to contact in case of emergency
Management of parental consent	Legal obligation	Identification data (First name; Last name); Others (Parental consent (1), logs of date and time of consent and/or consent removal, username of parent (1), email address of parent (1), confirmation email to parent (1); Parental consent (2), logs of date and time of consent and/or consent removal, username of parent (2), email address of parent (2) , confirmation email to parent (2))	Underage user with own App
			Underage user without own APP
Management of underage user account with own app	Contract	Consumption habits (OS and device); Electronic communication data (Password); Electronic identification data (Application pairing number (if any); Data on when the users uses the application and for how long); Eye color; Hair type and color; Height; Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Date of birth; Email address; First name; Language; Last name; Phone number/mobile phone); Image recording (Profile picture (optional)); Others (Contact person in case of emergency; Free trial period; In-app notification preferences; Linked Account related to the Master Account; Name and emergency phone number to which a doctor can be contacted; Status of the account (free trial or paid subscription); Types of transport (car, bike, walk, ...); User account renewal payment date; Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not; Whether the subscription fees have been paid); Personal characteristics (Gender)	Underage user with own App
		Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Email address; First name; Language; Last name; Phone number/mobile phone); Others (Contact person in case of emergency; In-app notification preferences; Name and emergency phone number to which a doctor can be contacted; Status of the account (free trial or paid subscription); Types of transport (car, bike, walk, ...); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not)	People to contact in case of emergency
Management of underage user account without own app	Contract	Eye color; Hair type and color; Height; Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Date of birth; First name; Language; Last name; Voice recognition); Image recording (Profile picture (optional)); Others (Contact person in case of emergency; Name and emergency phone number to which a doctor can be contacted; Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not); Personal characteristics (Gender)	Underage user without own APP
		Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; First name; Language; Last name); Others (Contact person in case of emergency; Name and emergency phone number to which a doctor can be contacted; Types of transport (car, bike, walk, ...); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not)	People to contact in case of emergency
Management of underage user account without own app	Contract	Eye color; Hair type and color; Height; Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; Date of birth; First name; Language; Last name; Voice recognition); Image recording (Profile picture (optional)); Others (Contact person in case of emergency; Name and emergency phone number to which a doctor can be contacted; Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not); Personal characteristics (Gender)	Underage user without own APP
		Household composition (Degree of proximity with the people to contact in case of emergency, whether such persons lives with the main user); Identification data (Address; First name; Language; Last name); Others (Contact person in case of emergency; Name and emergency phone number to which a doctor can be contacted; Types of transport (car, bike, walk, ...); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not)	People to contact in case of emergency
Medical file management	Consent	Health data (Alcohol drinker and if yes sorts of alcohol and how often; Allergies or intolerances; Asthma; Back problems; Blood group; BMI; Contact lenses; Contraction of std(s); Dental and/or hearing aids; Diabetes; Epilepsy; Gastritis or other problems with stomach; Glaucoma; Hearing or speech disorders; Heart failure; High blood pressure; Hip to foot height; History of hematomas or bleeding (and details); Hypertension; Medication and treatment followed (molecule, doses, number of shots); Medication habits or prescriptions; Migraines; Problems with anesthesia; Pulmonary insufficiency; Recent blood test report; Smoker and if yes how often; Stoutness; Surgical history (year, surgery, reason, identity and location of the surgeon, details of surgery (e.g. Coronary artery bypass graft)); Thyroid problems; Transfusion; Ulcers; Weight; Whether the users wear external medical devices (such as dental prosthesis, hearing aids, contact lenses or a pacemaker)); Identification data (First name; Last name); Personal characteristics (Gender)	Full user
			Underage user with own App
			Underage user without own APP
Medical research	Consent	Electronic communication data (Sensors data (gyroscopy, accelerometer, ...)); Electronic identification data (Consent of user for medical research and related log (date and time of consent and of potential consent withdrawal)); Health data (Health Data regarding the consequences of an accident or regarding the medical conditions (health data of the profile); Type of internal injuries due to the accident)	Free users
			Full user
			Underage user with own App
Notification of disappearance	Legitimate interests	Geolocation (Geolocation); Identification data (Clothing and accessories worn (i.e. t- shirt color; pants color); Eye color; First name; Hair type and color; Height; Is the user accompanied ?; Language; Last name; Medical problems or distinctive features; Moment of disappearance; Photo of the day; Profile picture (optional); Stoutness)	Free users
			Full user
			Underage user with own App
		Geolocation (Geolocation); Identification data (First name; Last name)	Family & Friend (F&F)
			First aid user (FAU)
Recruitment of Family & Friends	Consent	Geolocation (Geolocation); Identification data (Email address; First name; Last name; Phone number/mobile phone); Others (Exchanges with F&F; Logs of acceptance of F&F to be deployed in an incident (Y/N/no answer); Whether the people to contact in case of emergency hold a key to the house, whether such person downloaded the app or not)	Family & Friend (F&F)
Research & development	Legitimate interests	Electronic identification data (Data on when the users uses the application and for how long; Logs of intervention in the context of an emergency); Geolocation (Geolocation); Health data (Data related to the general health condition of the users before any accident; Health injury related to an accident); Identification data (Logs and other data related to emergencies (i.e. Date and time of issuance, recipient as the case may be, and content)); Others (Communication of an emergency the application would not have detected (when it has happened; activity concerns (bike; car; ...); the type of accident; additional information on the context of the accident); Communication of information in case of unexpected activation of the app; Evaluation of the user priority order to intervene in the context of an emergency; Service intervening in the context of an emergency; Type of emergency; Types of transport (car, bike, walk, ...)); Sound recording (Sound recording (during an accident or a disappearance - max 2 minutes))	Family & Friend (F&F)
			First aid user (FAU)
			Free users
			Full user
			Underage user with own App
Securization of user data	Legitimate interests	Log Files	Family & Friend (F&F)
			First aid user (FAU)
			Free users
			Full user
			Underage user with own App
Statistics	Legitimate interests	Logs of acceptance of the use of the sensors data; Sensors data (gyroscopy, accelerometer, ...)	Family & Friend (F&F)
			First aid user (FAU)
			Free users
			Full user
			Underage user with own App
Statistics related to the use of the application	Legitimate interests	Electronic identification data (How long a user stays on a feature of the app); Others (Log Files; Number of click on separate features)	Family & Friend (F&F)
			First aid user (FAU)
			Free users
			Full user
			Underage user with own App
Testing of the application	Consent	Electronic identification data (Logs (date/time stamps) of entry into test; Logs (date/time stamps) of post-test survey completion; Time and date of submission of answers); Financial data (Individual applicable promo code); Identification data (Email address; First name; Last name; Test ID (Alpha, Beta, etc.)); Others (Answers to the customer satisfaction survey (incl. Reason for call, Satisfaction with Agent, Agent behaviors, Resolution, Number of Contacts); Completion rate; Post-test survey completion (Y/N); Questions and answers to survey); Personal characteristics (Gender)	Testers
Training of FAU	Consent	Education & training (First aid level; Level N1: basic first aid knowledge (first aid diploma such as European First Aid Certificate or EFAC); Level N2: advanced medical (nurse or doctor); Level N3: emergency services (doctor, emergency medical technician (EMT), or nurse); Level of First-aid knowledge data: level N0 (by default): no first aid knowledge); Identification data (First name; Last name); Others (Logs of interaction with the notifications)	Free users
			Full user
User support	Contract	Electronic identification data (Application pairing number (if any); Data on when the users uses the application and for how long; Log of acceptance of legal terms); Identification data (Address; Date of birth; Email address; First name; Language; Last name; Phone number/mobile phone; Voice recognition)	Family & Friend (F&F)
			First aid user (FAU)
			Free users
			Full user
			Underage user with own App
			Underage user without own App
User survey	Legitimate interests	Electronic identification data (Logs of date/time stamp of completion of survey); Identification data (First name; Last name); Questions and answers; Status of request: pending, closed; Survey ID	Family & Friend (F&F)
			First aid user (FAU)
			Free users
			Full user
Web analytics	Consent	Electronic identification data (analytics; Log Files); Others (Flash LSOs; Web Beacons)	Web visitors
	Legitimate interests	Electronic identification data (analytics; Log Files); Others (Flash LSOs; Web Beacons)	Web visitors