MONSE Privacy Policy
(hereinafter referred to as the “Policy”)
Last updated: 10/05/2021
Definitions
MONSE – a device used for monitoring the household of the Monitored Person. It consists of the following components: control unit, motion sensors, SOS button, and door sensor.
MONSE mini – a GPS tracker and SOS voice communicator used for monitoring the Monitored Person outside the Monitored Area. When the SOS button is pressed, it enables geolocation of the Monitored Person via an SMS location message and a subsequent voice call to three (3) pre-specified phone numbers (authorized contacts). The use of MONSE mini is optional and serves as a supplementary device to MONSE.
Customer – a legal entity or self-employed individual who orders the MONSE/MONSE mini service and pays for the services. The Customer enters into a contractual relationship with the Company. For the purposes of these Policies, the Customer must be a legal entity or self-employed person registered under Slovak law.
Monitored Person – the individual whose movement and condition are monitored through the MONSE/MONSE mini service. The Monitored Person also enters into a contractual relationship with the Company and explicitly consents to the processing of their personal data and provides the required information in a designated field in the online store. The MONSE/MONSE mini service is primarily intended for independently living seniors (persons over 62 years old). However, the Monitored Person must be at least 18 years old and legally competent. If the Monitored Person’s legal capacity is limited or revoked, or if the Monitored Person acts through a legal representative, registration and consent for processing such personal data require court approval authorizing the legal acts performed by the legal representative.
Change of Monitored Person – the substitution of the monitored individual with another person. This is only possible with prior written consent from the Company based on a separate Agreement on the change of the Monitored Person. The new Monitored Person is fully subject to these Privacy Policies, the General Terms and Conditions of the MONSE service, and the Contract. Typically, changing the Monitored Person also results in a change of the Monitored Area.
MONSE Service – a service that allows monitoring of the movement and condition of the Monitored Person using a Global Positioning System (GPS) device and wireless sensor networks installed in the Monitored Person’s household.
MONSE Application – a web interface for initial setup of MONSE/MONSE mini, managing alarms, notifications, and system changes. The application provides an overview of the entire MONSE/MONSE mini system, including alarm history.
Personal Data of the Monitored Person – the following data are processed for the Monitored Person: name and surname (or nickname), address, email, phone number, SIM card phone number for MONSE mini (GPS tracker), and verification code.
In the case of the Monitored Person, additional personal data are processed, which will be collected from the Global Positioning System (GPS) device and the control unit of the sensor networks, motion sensors, door and window sensors, SOS alarm button, and fire sensor, including the following data:
a) Coordinates necessary to determine the location of the Monitored Person (latitude, longitude) and location estimated based on the body temperature of the Monitored Person through motion PIR sensors. The Monitored Person must voluntarily provide the above data, with the understanding that this data may be:
- Provided to a third party who manages, processes, and stores data on behalf of the Company for monitoring the Monitored Person through the Global Positioning System (GPS) and monitoring the Monitored Person using wireless sensor network technologies via PIR sensors, as well as data necessary to identify the Monitored Person;
- Used by the Company for the purpose of creating databases and analyzing the individual movement patterns of the Monitored Person;
- Utilized for special algorithms that enable monitoring of the Monitored Person’s activities both inside and outside the home, such as reduced or no physical activity of the Monitored Person, failure to visit usual locations within specified intervals, leaving the home, open entrance doors during nighttime hours, CO2 leakage (from heating devices within the Monitored Person’s home), entering risk zones (e.g., railway station), requests for assistance, or leaving the home without the GPS sensor.
Personal Data of the Customer
In the case where the Customer is a legal entity or self-employed person (sole proprietor), the following personal data of the natural persons representing and acting on behalf of the Customer are processed: full name, address, email, phone number, job title, bank account number of the Customer (for payment of the MONSE/MONSE mini service or related contractual payments), and the Customer’s login name and password for the MONSE Application.
Personal Data of the Authorized Contact
Includes full name, phone number, and email address. If access rights have been granted to the Authorized Contact by the Customer and/or the Monitored Person, then also the Authorized Contact’s login name and password for the MONSE Application are processed.
Personal Data of the Entitled Contact
Includes full name and the login name and password of the Entitled Contact for the MONSE Application.
Monitored Area of the Monitored Person – represents the space where the movement and condition of the Monitored Person are monitored through the MONSE Service. In the case of the Monitored Person, data related to the Monitored Area are also processed, such as the size of the Monitored Area – (studio, 1-bedroom, 2-bedroom, 2-bedroom with kitchenette, 3-bedroom, 3-bedroom with kitchenette, 4-bedroom, 4-bedroom with kitchenette).
Verification Code – a unique identifier used to verify the identity of the Monitored Person and is necessary for activating the MONSE Service in the Monitored Area of the Monitored Person. The verification code is sent exclusively to the Monitored Person directly, provided that the Monitored Person has given consent to these Privacy Policies and has also granted the Company consent to process their personal data in the form of a written declaration via electronic means (by ticking a specific box during the registration of the MONSE/MONSE mini Service).
Authorized Contact – a pre-designated phone number in the MONSE mini device. In case of emergency, pressing the SOS button on the MONSE mini allows a voice call to be made to 3 (three) authorized contacts, which are dialed in the order they are stored in the MONSE mini device (i.e., if the first authorized contact does not answer, the call is automatically forwarded to the second authorized contact, and if this contact does not answer, the third authorized contact will be called). This call is preceded by geolocation of the Monitored Person via an SMS message with the location, which is sent to the authorized contacts.
GPS – Global Positioning System, used to locate the Monitored Person.
PIR – Passive Infrared motion sensor.
Fixed Internet Connection – internet connection via a fixed network from an internet service provider.
Connection via LAN Cable – connection to a wired LAN network that enables internet access.
SIM Card for MONSE mini (GPS Tracker) – is a subscriber identification card used to identify the user in the mobile network, through which the Monitored Person can use the SOS emergency button, perform geolocation via an SMS message with location, as well as make an emergency voice call. The SIM card remains the exclusive property of the Company.
Geolocation – technology that allows determining the position of the Monitored Person on the Earth.
Authorized Contact – a natural person to whom the Customer and/or the Monitored Person has provided their access credentials to the MONSE Application.
Customer Service – a service provided to customers consisting of advice and solutions to problems, questions, or suggestions that customers may have regarding the MONSE/MONSE mini Service.
Price List – contains prices of MONSE/MONSE mini products and services.
Control Unit – the main computing unit that processes data from individual sensors. The control unit is part of the MONSE device. Upon termination of the Contract Duration, the control unit remains the property of the Company.
Motion Sensor(s) – technical device(s) that respond to changes in the Monitored Area of the Monitored Person. The motion sensor(s) are part of the MONSE device.
- Introductory Provisions Operators
Trade name: Aliter Technologies, a.s.,
Address: Trade Center II Building, Mlynské nivy 71, 821 05 Bratislava,
Contact details: Tel: +421 255 646 350, E-mail: aliter@aliter.com
Aliter Technologies, a.s. is a business company headquartered at Turčianska 16, 821 09 Bratislava, Company ID (IČO): 36 831 221, registered in the Commercial Register of the Slovak Republic, Section: Sa, Insert number: 5375/B.
(hereinafter referred to as “Aliter Technologies, a.s.”).
Trade name: MONSE, s.r.o.
Address: Kováčska ulica 16, 900 42 Dunajská Lužná
Contact details: Tel: +421 0902 601 392, E-mail: info@monse.sk
MONSE, s.r.o. is a business company headquartered at Turčianska 16, 821 09 Bratislava - Ružinov city district, Company ID (IČO): 51 899 531, registered in the Commercial Register of the Slovak Republic, Section: Sro, Insert number: 130970/B.
(hereinafter referred to as “MONSE, s.r.o.”).
These Privacy Policies are used by Aliter Technologies, a.s. and MONSE, s.r.o. (Aliter Technologies, a.s. and MONSE, s.r.o. hereinafter jointly referred to as the “Operators”) to protect the personal data of the data subjects processed by the service provider in the operation of the MONSE/ MONSE mini Service. The MONSE/ MONSE mini Service is an emergency social service primarily intended for monitoring the activities of an independently living senior or a person with health disadvantages (hereinafter also the “Monitored Person” or “user”), using wireless sensor network technologies (hereinafter also “MONSE” or the “MONSE/ MONSE mini Service”).
The consent of the Monitored Person to the processing of personal data is provided in a separate form upon registration for the MONSE/ MONSE mini Service at the website https://monse.sk/, which the Monitored Person has personally given in the form of a written declaration via electronic means, i.e., by ticking a separate box during the registration of the MONSE/ MONSE mini Service.
The user may also be the Client, i.e., the person who ordered the MONSE/ MONSE mini Service and will pay the price for the MONSE/ MONSE mini Service (hereinafter also the “Client”). The Client’s consent to the processing of personal data is provided in a separate form upon registration for the MONSE/ MONSE mini Service. The Client and the Monitored Person are two different persons in terms of the definition of the term “Monitored Person.” For the avoidance of doubt, the Monitored Person and the Client are data subjects.
Aliter Technologies, a.s. is responsible for the development of the MONSE software and operates the necessary IT infrastructure. MONSE, s.r.o. is a subsidiary of Aliter Technologies, a.s., which primarily handles the sale of the MONSE Service and related customer service. Due to their mutual cooperation in providing the MONSE/ MONSE mini Service, Aliter Technologies, a.s. and MONSE s.r.o., as Operators, process personal data and are equally responsible for the processing of this personal data. The Privacy Policies are available on the website monse.sk. The data collected and processed on the Operators' website is processed exclusively on the territory of the Slovak Republic.
The responsible person is Mr. Ervin Haramia, contact details: e-mail: gdpr@monse.sk. The role of the responsible person is to ensure the proper execution of binding legal regulations concerning the collection and processing of personal data.
- Purpose of Personal Data Processing
The processing of the Client’s and the Monitored Person’s personal data is necessary for the registration of the MONSE/ MONSE mini Service and for the conclusion and fulfillment of the Contract for the Provision of the MONSE/ MONSE mini Service. In the case of the MONSE Service, these personal data are collected via various Motion Sensors located in the Monitored Person’s Monitored Area (e.g., information about movement within the household, door opening data, and indoor temperature data), and in the case of the MONSE mini Service, also outside the Monitored Area of the Monitored Person (e.g., location data determined via GPS).
The processing of the Client’s personal data is also necessary for:
- fulfilling payment obligations and enabling payment for the MONSE/ MONSE mini Service,
- handling complaints related to the MONSE/ MONSE mini Services,
- handling complaints related to the equipment used to provide the MONSE/ MONSE mini Service (control unit, motion sensors, tracker).
The processing of personal data is also necessary to fulfill the legal obligations of the Operators as stipulated by applicable legislation, including but not limited to:
- Act No. 431/2002 Coll. on Accounting,
- Act No. 222/2004 Coll. on Value Added Tax,
- Act No. 595/2003 Coll. on Income Tax,
- Act No. 250/2007 Coll. on Consumer Protection,
- Act No. 102/2014 Coll. on Consumer Protection in the Sale of Goods or Provision of Services Based on a Distance or Off-Premises Contract,
- Act No. 22/2004 Coll. on Electronic Commerce.
The processing of the Client’s and Monitored Person’s personal data is also carried out based on the consent of these data subjects for the purpose of using their personal data for marketing purposes, including providing information about products, services, and activities of the Operators. This includes the identification and contact details of the Client and the Monitored Person provided during the registration for the MONSE/ MONSE mini Service on the website https://eshop.monse.sk/, as well as any subsequent changes to such data, to the extent of name, surname, telephone number, email, and address—provided that the Client and Monitored Person gave their consent during the registration process for the MONSE/ MONSE mini Service, in accordance with the Contract for the Provision of MONSE/ MONSE mini Services.
Consent to the processing of personal data for marketing purposes may be withdrawn by the Client or the Monitored Person at any time, by sending an email to: gdpr@monse.sk.
- Legal Basis for Personal Data Processing
- Article 6(1)(a) of Regulation (EU) 2016/679 of the European Parliament and of the Council (the “GDPR”) – Processing based on the data subject’s consent for the purpose outlined in these Privacy Principles.
- Article 6(1)(b) GDPR – Processing is necessary for the performance of the Contract for the Provision of MONSE/ MONSE mini Services concluded between MONSE, s.r.o. as the controller and the Client and the Monitored Person.
- Article 6(1)(c) GDPR – Processing is necessary for compliance with the legal obligations of the Controllers.
- Article 6(1)(f) GDPR – Processing is necessary for the purposes of the legitimate interests pursued by the Controllers.
- Legitimate Interests of the Controllers
The processing of personal data is also necessary for the legitimate interests of the Controllers, specifically for the purposes of:
- Monitoring proper fulfillment of the Contract for the Provision of MONSE/ MONSE mini Services (including verifying proper delivery of the devices necessary for providing these services),
- Exercising the rights and legally protected interests of the Controllers (in pre-litigation, judicial, or enforcement proceedings),
- Obtaining information to improve the services provided by the Controllers,
- Delivering targeted advertising and offers from the Controllers (promotion of products and services),
- Testing the new web interface of the MONSE application,
- Ensuring IT security and protecting the property of the Controllers,
- Verifying the Client’s fulfillment of contractual obligations,
- Contacting and communicating with the Client,
- Offering products and services of the Controllers,
- Supporting business activities and marketing, conducting marketing surveys, satisfaction surveys, and sending information about new products and services of the Controllers,
- Gathering information for improving the handling of customer feedback related to the MONSE/ MONSE mini Service.
Recipients or Categories of Recipients of Personal Data
The Controllers provide the personal data of the Client and the Monitored Person to the following recipients or categories of recipients:
- Administrator of the website at https://monse.sk/,
- Administrator of the MONSE application,
- Provider of accounting and tax consulting services, accounting services, auditing services, legal services,
- Provider of courier and delivery services,
- Provider of banking services,
- Provider of telecommunications services,
- Members of the statutory bodies of Aliter Technologies, a.s. and MONSE, s.r.o., and employees of the Controllers,
- Providers of information system administration and technical infrastructure services, in cases where they manage internal systems for personal data administration.
The Controllers do not process or store any health-related data of the Monitored Person, as these represent a special category of personal data and cannot be technically collected through the devices used (Motion Sensors/ MONSE mini).
The Controllers only store data that is necessary for the proper functioning of the MONSE/ MONSE mini Services. The Controllers undertake to make every effort to adopt all available measures to ensure the protection of the data in order to prevent any risk of loss, theft, damage, or misuse.
Access to the MONSE/ MONSE mini Customer Area
The user receives a password, which can be used with their email address to access the customer area. The user can change the password at any time and is the sole owner of it. The user agrees to keep the password confidential and remains solely responsible for any use of their profile.
The user has access to and the ability to modify essential parts of their personal data in the dedicated personal and private interface of the MONSE/ MONSE mini platform via the MONSE application.
The Client and the Monitored Person have the right to access, rectify and/or delete, restrict, and object to the processing of their personal data for marketing purposes by sending an email to: gdpr@monse.sk.
Personal Data Collected and Processed in Connection with MONSE/ MONSE mini Services
- For a Client who is a legal entity / sole trader: the following data of individuals representing and acting on behalf of the legal entity / sole trader are processed: full name, address, email, phone number, bank account number (if payments are made for MONSE/ MONSE mini Services or under the Service Agreement), username and password for the MONSE Application.
- For the Monitored Person: processed data include: full name (or nickname), address, email, phone number, SIM card number used in the MONSE mini GPS Tracker, and verification code number. Additional data from GPS and sensor devices are processed, such as:
- Coordinates necessary for determining the location of the data subject (latitude, longitude),
- Location based on the person's body temperature via PIR motion sensors.
These data may be:
- Provided to a third party managing, processing, and storing data for monitoring the Monitored Person via GPS and PIR sensor networks,
- Used by the Controllers to build a database and analyze the Monitored Person's movement paths,
- Used for special algorithms to monitor activities in and outside the home, such as reduced or no movement, missed usual locations, leaving the home, open front door at night, CO2 leakage (e.g., from a heating appliance), entering risk zones (e.g., a railway station), help requests, leaving home without a GPS sensor.
- Also processed: details about the Monitored Area (e.g., apartment size and layout like 1kk, 2+1, 3kk, etc.).
- For an Authorized Contact: full name, phone number, email address. If access rights have been granted by the Client and/or Monitored Person, also username and password to the MONSE Application.
- For an Entitled Contact: full name and username and password to the MONSE Application.
Compliance and Rights of the Data Subject
Personal data are processed in accordance with the GDPR and the Slovak Act No. 18/2018 Coll. on Personal Data Protection, as amended. Controllers do not provide personal data to third parties, except:
- A selected delivery company for goods or service delivery,
- State authorities in case of inspection,
- A data processor based on a contract under the Personal Data Protection Act.
All employees of the Controllers are obligated to maintain confidentiality regarding personal data.
Data Subject Rights under Slovak Law (§ 19 et seq. of Act No. 18/2018 Coll.):
- Right to information,
- Right to request access to personal data (§ 21),
- Right to rectification of personal data (§ 22),
- Right to erasure of personal data (§ 23),
- Right to restriction of processing (§ 24),
- Right to object to processing (§ 27),
- Right to data portability,
- Right to lodge a complaint with the supervisory authority regarding the processing of personal data.
Retention of Personal Data
Personal data is stored for archival purposes for a period of 4 years from the date the user account is deleted on monse.sk.
Automated Decision-Making and Profiling
Information regarding the existence of automated decision-making, including profiling (and details about the procedure used, its significance, and anticipated consequences for the data subject):
The websites of Aliter Technologies, a.s. and MONSE, s.r.o. record the user's IP address, time spent browsing the websites, and referral source.
Cookies are text files stored on the user’s device and are also used to measure website traffic and adapt content display. Thanks to these files, higher quality content can be offered, which constitutes the legitimate interest of the Controllers.
Some cookies are managed by third parties (e.g., YouTube, Google, etc.).
Users can delete or adjust cookie settings at any time in their browser settings. If a user wants to reject cookies, this must be done via browser configuration.
Email Marketing Consent
If the data subject has consented to the processing of personal data in the e-shop for email marketing purposes, they have agreed to receive marketing emails at their provided email address.
Personal data used for email marketing (first name, last name, email address) will be processed for 4 years. These data will not be shared with third parties.
For the purposes listed under Section 4 of this Policy, consent is required (i.e., separate consent from the Client and from the Monitored Person). If such consent has been provided, the data subject was informed that:
- The consent is voluntary,
- The data subject can withdraw consent at any time by emailing: gdpr@monse.sk.
Once consent is withdrawn, the Controllers will no longer process the personal data for email marketing purposes.
For the purposes listed under Sections 2.1, 2.2, 2.3, and 4.1, no consent is required, as other legal bases for processing have been identified.
Information on Legal or Contractual Requirements for Providing Personal Data
- For purposes under Sections 1 and 2.2, providing personal data and its processing by the Controllers is necessary to fulfill the Service Agreement for MONSE/ MONSE mini.
If the data subject does not provide their data, the Controllers will not be able to conclude the contract or provide the service. - For purposes under Section 3, personal data processing is necessary to fulfill the legal obligations of the Controllers, as outlined in applicable laws (refer to Section 2.3 for examples).
- For purposes under Section 1, the data subject is not required to provide personal data and may object to its processing.
If the data subject exercises this right (Section 4.1), their data will no longer be processed unless there are compelling legitimate grounds (e.g., ongoing legal proceedings). - For purposes under Section 4, the data subject is not required to provide personal data. If they do consent, they may withdraw it at any time, as described in Section 2.4.1 of this Policy.
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