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Photo on Demand Privacy Notice

Applied from August 18, 2022


Elotec AS (the “Provider”) takes your privacy seriously and does its best to treat your data with the highest level of security and confidentiality ensuring. In addition to the Policy available at (the “Privacy Policy”), this privacy notice (the “Notice”) describes how Provider interacts with your personal data, what data it will process, and what third parties may have access to your data when you use a feature of the Provider’s application named Photo on Demand (the “PhoD”). 


This Notice is an integral part of (an addendum to) the Privacy Policy and the terms of services available at [link to the TOS landed on the website] (the “Agreement”), and the Notice is hereby incorporated thereto by reference. Since this Notice supplements the Privacy Policy with regard to the PhoD-feature functionality, we kindly ask you to refer to the Privacy Policy to find general information, where the data is stored and how long Provider retains it, what technical measures Provider employs to protect your personal data, what data privacy rights you have as a data subject, and other information required by applicable data privacy laws.


Your data controller is the Provider. You may reach out to the controller with contacts described in section 3.1 hereof. We may also use some data processors to deliver the technical solution and our services to you.


Provider may, from time to time and owing to any changes in the PhoD functionality, supplement, amend, or replace this Notice. All changes, including the way in which they will be performed, are subject to rules, as Privacy Policy outlines. 




1.    Photo on Demand Feature; Permissions


1.1.    The PhoD function appears in Provider’s systems with the relevant update of the Provider’s application. The feature allows users to take pictures using detectors supporting photo verification at any time when devices are armed or not. The PhoD feature provides an opportunity to find out the situation at the facility, check the cause of the alarm, or ensure the safety of your premises.


1.2.    The PhoD is deactivated by default. In order to enable this function, a hub administrator or an authorized hub user only may choose the relevant feature in the Provider’s application setting bar. 


1.3.    There are some categories of hub users that may interact with the PhoD:

a.    Hub Administrator. It may manage a hub privacy settings, enable and disable the PhoD at any time, assign or revoke a right to use PhoD and access the pictures to other users of a hub, allow a third party to have access to the PhoD’s data, and request taking of pictures, takes photos at any time (when a hub is armed or not), view pictures taken by other users, see Users and their privacy permissions, determine which users can take and view photos on demand, which system detectors can be used to take photos on demand when a user can take photos on demand: at any time or when a device is armed, and disable any Hub User’s assignment or account;

b.    Hub User. By default, it has no access to either use of the PhoD and taken pictures or settings of PhoD. A Hub User may never enable or disable the PhoD feature otherwise, as with permission granted by a Hub Administrator. If a Hub Administrator grants to a Hub User relevant permission, a Hub User may be able to:

i.    Manage Privacy Permissions. If a Hub Administrator chooses, it can allow (or prohibit) other Hub Users to enable and disable the PhoD at any time. A Hub Administrator may also null this right at any time;
ii.    Assign/Add New Users. If a Hub Administrator chooses, it can allow (or prohibit) other Hub Users to add or delete new users and assign a certain scope of rights to them. A Hub Administrator may null or amend any of these rights at any time;
iii.    Take Photos on Demand. If a Hub Administrator chooses, it can allow (or prohibit) other Hub Users to request from the Provider’s application to take photos of premises. A Hub Administrator may restrict this permission by time (allow to take pictures only when a hub is armed only), by territory (allow access to chosen detectors (cameras) only), by action (allow to request taking a photo without a right of access to such a photo). A Hub Administrator may null or amend any of these rights at any time;
iv.    Access to Photos. If a Hub Administrator chooses, it can allow (or prohibit) a Hub User to see photos taken by such a user or by other Hub Users. There are some additional facts: (1) photos taken on demand are available only to users who have the right to take photos on demand at the time of the shooting; (2) if they obtain the right to photos on-demand, users cannot view the photos taken before this right was obtained; (3) users who have lost the right to photos on demand can view the photos taken by them when they had such a right. A Hub Administrator may null or amend this right at any time. Still, when a Hub User (including a Hub Administrator) requests to take a photo, all Hub Users receive a notification that someone took a photo of premises; however, other users may not access such a photo until they have relevant permission. 


1.4.    The Hub Administrator is obliged to receive the explicit consent of all Hub Users, including other Hub Administrators, prior to (a) enabling the PhoD feature and (b) granting any permissions to any persons. The Hub Administrator must not allow access to nor request from Provider to give such access to or transfer to any entity personal data of any user of a Hub before such a user grants its unambiguous permission to the Hub Administrator. 


2.    Personal Data and Third-Party Access


2.1.    Owing to the nature of the PhoD and following to Hub Users acts, Provider may process the following personal data of users in the course of performing the PhoD feature: (a) names and IDs of users of a hub where the PhoD is enabled; (b) permissions granted to such users and their roles (Administrator or User); (c) photos taken by users; (d) logs of the PhoD: who took a photo, when a photo is taken, what detectors (cameras) were used to take a photo; (e) metadata of pictures: detector (camera) ID, name, size, date, and format of an image, number of images, etc. 


2.2.    By enabling the PhoD option in the Provider’s application, a Hub Administrator allows and directs the Provider to process personal data listed in sections 2.1(a)-(b) hereof to provide the Provider’s services as described in the Agreement. By taking a photo or empowering a Hub User to take pictures, a Hub Administrator allows and directs Provider to process personal data listed in sections 2.1(a)-(e) hereof. By enabling the PhoD option in the Provider’s application or adding new Hub Users, a Hub Administrator allows and directs Provider to deliver event notifications to all Hub Users when a photo is taken by any user. By empowering a Hub User to have access to taken photos, a Hub Administrator allows and directs Provider to deliver such photos to Hub Users with the relevant access permission. 


2.3.    If you use security, guardian, installation, etc., services of third parties, you may allow them to use your PhoD features. If you grant them such permission (or order the Provider to do so), the company(es) will have full access to your data listed in section 2.1 hereof, and they will be able to take photos whenever they want and for purposes that may differ from the performance of their services to you. Notwithstanding the fact that you will receive a notification each time when the company(es) take a photo, and you can restrict access to the PhoD features at any time, please consider that you cannot undo the act of access to your data that has already occurred. By adding a third party (whether yourself or with the help of the Provider) as an entity empowered to use your PhoD features, you acknowledge, agree on, confirm, and claim that: (a) you order from the Provider to allow such a third party has access to your PhoD features, literally, take photos and monitor the activity in your premises, (b) you order from the Provider to transfer your personal data outlined in the Privacy Policy, and section 2.1 hereof to such third party; (c) you assessed and agree with all associated risks; (d) such a third party is a controller (with respect to services it provides to you) of the personal data (i) received from the Provider and (ii) received in the course of the PhoD use by that third party, and it is not a processor engaged by the Provider. This also means that the Provider cannot request (owing to lack of power) such an entity to delete your data or stop processing of your data; (e) the Provider never gives any accesses to your data nor transfer it to any third parties without your knowledge; (f) no third parties have access to your data nor can manage any of the equipment or its portions by default without your permission; (g) the Provider does not select nor choose recipients of the personal data, so it may not (and does not) warrant the safety of the data when they are transferred to such third parties; (h) the Provider is not associated with such third parties and has no influence on them; (j) you bear all risks associated with the data transfer and waive any and all possible claims, compensations, etc., related to such transfer.


2.4.    Please note that if (a) you grant to Hub Users permission to take photos or a right of access to photos or (b) direct the Provider to give access to any of the PhoD features to third parties (security, guardian, or installation services company, etc.), it may be associated with certain risks for privacy of yours and some other people. The Provider does not recommend granting access to any of the PhoD functionality to any person without a reasonable need or a need that may not be satisfied in another way. Still, if you want to allow other persons to use your PhoD functionality and have access to photos, the Provider strongly recommends assessing all the risks at first. 


2.5.    If you want to restrict access of other users or third parties to your PhoD functionality, you may do it via the setting bar in the Provider application or with a help of the Provider’s Support team at Please note, that the Provider has no power to make either other users or any third parties that have already accessed your data to delete such data. If you want to restrict such persons from processing of your data or make them delete your data, please contact them directly.


3.    Miscellaneous 


3.1.    If you have any further questions about this Notice, you may contact us at


3.2.    For the sake of clarity, this Notice does not include any representations, warranties, or technical statements, whether explicit or implied, on the functionality, uninterrupted use, the accuracy of either the PhoD feature or of any of the Provider’s products. The Provider does not guarantee any specific results in the use of the PhoD. The Provider provides any description of the PhoD or any other products for illustration purposes only; the only goal of such description is to refer to the relevant products and provide you with the context of this Notice. Please refer to the applicable technical documentation to get information on how the PhoD or the products work.

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