General Information about the App
Bayer has contracted Sony Nordic, a branch to Sony Europe B.V. (NL),a company based on Torshamnsgatan 20, 164 40 Kista, Sweden to provide a solution, Nimway System application (“App”), that enables employees to find and book available work and meeting space in Bayer AB’s office (Berzelius väg 35, Solna) (“Office”), locate colleagues and make oneself found in the office. The Application (“App”), when enabled, can send the user smart notifications based on the users interests, such as up-coming meetings.
With the help of the user’s smartphone's Bluetooth and Bluetooth transmitters in the Office, the user’s personal data is sent to Sony via the App to allow the user to use the different features of the App. Users will only be located if they are present at Office working spaces that have Bluetooth transmitters and when they have allowed the App to locate them. For privacy reasons, sanitary areas and resting and relaxation areas do not have Bluetooth transmitters which would enable to locate the user.
In order to use the features of the App, which allows user to find and book available meeting rooms and receive reminders about upcoming meetings, the user needs to give the App an access to the user’s calendar in Microsoft 365.
The use of the App is completely voluntary. If you wish to use the App and its different features, your personal data will be processed by Sony. In order to use the App and its’ functionalities, you need to agree to the terms and condition provided by Sony.
If you do not wish to make your presence known and available in the office via the Nimway solution, you can at any time disable the location services in the App or delete the App. Any concerns about the use of the App or processing of the data should be directed to the Data Privacy Manager at Bayer AB (see contact details below) or Human Resources at Bayer AB. For technical questions concerning the App and the functions in the office, please contact your local Bayer IT support. Find more information about how your data is being processed when using the App from the Privacy Statement.
This application Nimway Solutions (hereinafter the “App“) is provided by Sony Nordic. Bayer AB is acting as a data controller of the personal data processed in the App (hereinafter “us“ or “we“). For further information regarding the provider of the App, please refer to Sony‘s imprint here.
A. Handling of personal data
In the following we wish to provide you with information on how we handle your personal data when you use this App. Unless otherwise indicated in the following chapters, the legal basis for the handling of your personal data is your employment contract with Bayer (Art. 6(1)(b) General Data Protection Regulation)
Your personal data will be processed in order for Bayer employees to find you and for you to find other employees and to provide aggregated information on the usage of the office to Bayer for optimal use of office.
I. Using the Nimway App
1. Accessing the App
In order to make available to you the services of our App, it will transfer the following information to us, every time you use our App:
To protect our legitimate interests, Sony will store such information for a limited period of time in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to the servers (Art. 6(1)(f) General Data Protection Regulation).
2. Registration and login
In order to be able to use the App, you need to first register an account with Sony, where you are able to determine your personal login credentials that you need to use to log into the App. For this registration and subsequent login procedure, Sony collects the following information about you:
Sony processes this personal data in order to provide you with access to the Nimway App and the service therein. They are automatically deleted in case you deactivate your user account.
3. Access to your device’s interfaces
In order for the App to function properly, Sony needs to access and use the following interfaces of your mobile device for the following purposes:
For the search your colleague function; to be able to show your colleagues where you are in the office and thereby be able to search for them The location data is also used to created aggregated statistics on the use of the different office areas which will be provided to Bayer upon request on an aggregated level.
For the function to reserve meeting rooms and for App to send you push up notifications the App needs access to your calendar. The location data is also used to create aggregated statistics on the use of the different office areas which will be provided to Bayer upon request on an aggregated level.
4. Use of Location Service
The Bluetooth function and location services on the smart phones need to be activated on both the user trying to search for a colleague and the colleague being searched for. When searching for someone, your location will be automatically shared with the person you are looking for. When tapping the search notification, you will see the location of the person who searched for you. It is not possible to search for someone else unless you share your own location. If you attempt to do so, a notification will pop up with quick access to enable the location sharing setting. If the initial search attempt is not successful in locating your colleague, Nimway will keep looking for another 10 min. Nimway will notify you if your colleague becomes available during this time period. If someone searches for you while you have disabled location sharing you will receive a notification informing you that your location hasn´t been shared, but also the possibility to turn on your location sharing again.
II. Retention times
Your user profile (name, contact data, user name, user ID, access token, smart phone unit name, profile picture, log file) and your user account status
Data is stored until the user account is deleted by the user
Information about your calendar meetings
Maximum of two (2) days from collection of data
Your location in the office
Stored in a pseudonymized format a maximum of fourteen (14) days from collection of data
Your User app usage
Your User IP address
Stored in a pseudonymized format for a maximum of one (1) year from collection of data
III. Bayer’s access to the data
Bayer will not have access to the personal data in the App. Sony Nordics will make aggregated statistics available to Bayer, for the sole purpose of understanding how the Office is used in order to improve the office and the usage of office spaces. These statistics may consist of total number of users on each office floor, heat maps of stationary points of the users, segmentation of employees such as long time desk users, nomads and frequent meeting attendee. The statistics are collected on a general and aggregated level, so your specific usage of different office locations or your usage of the App will not be disclosed to Bayer.
IV. Transfer of personal data for commissioned processing
For the processing of your personal data we will to some extent use specialized service contractors. Such service contractors are carefully selected and regularly monitored by us. Based on respective data processing agreements, they will only process personal data upon our instruction and strictly in accordance with our directives.
V. Processing of personal data outside the EU / the EEA
Your personal data will in part also be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”), which may have a lower data protection level than European countries. In such cases, we will ensure that a sufficient level of protection is provided for your personal data, e.g. by concluding specific agreements with our contractual partners (copy available on request), or we will ask for your explicit consent to such processing.
B. Information regarding your rights
The following rights are in general available to you according to applicable data privacy laws:
- Right of information about your personal data stored by us;
- Right to request the correction, deletion or restricted processing of your personal data;
- Right to object to a processing for reasons of our own legitimate interest, public interest, or profiling , unless we are able to proof that compelling, warranted reasons superseding your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defense of legal claims;
- Right to data portability;
- Right to file a complaint with a data protection authority;
- You may at any time with future effect withdraw your consent to the processing of your personal data. For further information please refer to the chapters above describing the processing of personal data based on your consent.
If you wish to exercise your rights, please address your request to the contact indicated below. (à C.).
For any questions you may have with respect to data privacy, please write an e-mail to firstname.lastname@example.org or contact our company data protection officer at the following address:
Data Privacy Manager
Berzelius väg 35, Solna
D. Amendment of Privacy Statement
We may update this Privacy Statement from time to time. Updates to the Privacy Statement will be published in the Nimway App. Any amendments become effective upon publication linked in the App. We therefore recommend that you regularly visit the app to keep yourself informed on possible updates.
Last updated: 2019-10-02