ENTERA™ Privacy Policy
Last Update: March, 2022
INTRODUCTION
C2RO Cloud Robotics Inc. (“C2RO” also referred to as “we” or “us”) understands and respects the importance of any information it collects on an identified or identifiable individual (“Personal Information”) using its ENTERA AI-powered video analytics solution (“ENTERA”). C2RO has developed the present privacy policy (“Notice”) to describe ENTERA’s Temporary Processing (as defined below) of Personal Information in compliance with Canadian federal and provincial data protection legislation (“Privacy Laws”).
This Notice also describes the data protection rights an individual whose Personal Information is processed by ENTERA (“Data Subject” or “you”) may exercise and how to exercise them.
This Notice does not cover the processing of Personal Information by any C2RO technology other than ENTERA. If you are interested in C2RO data protection practices as they relate to these technologies or in C2RO’s Generic Privacy Policy, please check www.c2ro.com/privacy-policy.
Some provisions may exceed regulatory requirements. In such circumstances, C2RO has full discretion with respect to its application.
We invite you to contact our CPO with any questions concerning this or any other C2RO data protection notice.
WHO WE ARE
C2RO is an AI enterprise software company based in Montreal, Canada. It offers Privacy-aware AI video analytics for physical spaces using proprietary edge-cloud AI and computer vision technologies. C2RO’s product, ENTERA™, provides businesses with a scalable and robust analytics tool for data-driven decision making, ensuring safety measures, and helping them transform their physical facilities into engaging and immersive environments for visitors. C2RO solutions are built for scale and reuse existing surveillance cameras while being compliant with the most restrictive data privacy regulations in the world.
C2RO has developed ENTERA, a technology that temporarily collects images generated by video surveillance cameras installed in a particular premise and extracts meta-data concerning a Data- Subject’s age-group and gender to generate anonymized and aggregated statistics (“Temporary Processing”). ENTERA takes less than 5 minutes to process and destroy any Personal Information. Video images are fully anonymized by permanently deleting Data Subject faces and randomly altering the resulting silhouette to eliminate all uniquely identifying biometric information. No uniquely identifying template is ever generated and once the anonymization and aggregation process is complete not even C2RO has access to any identifying information. The ENTERA Privacy Policy altered data is then sent to an AI modelling system that generates anonymized and aggregated statistics concerning the number of either men or women belonging to a given age group – by 5- year cohorts – in a particular location on an hourly basis (“Logistical Statistics”). These Logistical Statistics help our clients understand the presence and movement of people belonging to certain age-groups and genders in and through their premises. This means that after the Temporary Processing is completed all Personal Information is permanently destroyed ensuring that it cannot be further used, stored, or transferred.
C2RO assumes full responsibility for the information ENTERA processes and has appointed a Chief Privacy Officer (“CPO”) located in Canada and a Data Protection Officer (“DPO”) located in Europe to oversee the compliance of C2RO and ENTERA with the Privacy Laws.
C2RO CONTACT DETAILS
TO CONTACT C2RO DATA PROTECTION OFFICER (EUROPE)
Dr. Gérard HAAS
HAAS AVOCATS
32, rue la Boétie 75008 PARIS FRANCE
T: (+33) 156-436-880
E: dpo@c2ro.com
TO CONTACT C2RO CHIEF PRIVACY OFFICER
(NORTH AMERICA)
55 Mont-Royal W., Unit 970 Montréal, Québec
H2T 2S5
T: (+1) (438) 771-5367
THE PERSONAL INFORMATION ENTERA TEMPORARILY PROCESSES
ENTERA Temporarily Processes the following Personal Information:
Biometric data
Video images captured by a surveillance camera installed on a client’s premises. This information is sensitive personal information and may include information about racial or ethnic origins and religious beliefs; and
Physical Access Data
Information relating to a Data Subject’s visit to a client’s premise;
Please note that ENTERA is designed not to process, Temporarily or otherwise, Personal Information on minors, employees, or individuals for whom a sufficient aggregation situation does not exist.
WHY ENTERA TEMPORARILY PROCESSES YOUR PERSONAL INFORMATION
ENTERA temporarily collects your Personal Information to enable C2RO to provide our clients with anonymized and aggregated Logistical Statistics to help them understand how men and women belonging to certain age-groups move through their premises. In order to provide these anonymized and aggregated Logistical Statistics ENTERA: i) temporarily collects your video image; ii) within 5 minutes, extracts the meta-data concerning your gender and relative age, iii) temporary processing anonymizes and aggregates your Personal Information so that you cannot be uniquely identified and iv) presents the information concerning age and gender demographics to its clients. Only anonymized and aggregated information concerning a person’s age-group and gender is ever communicated to our clients.
HOW ENTERA TEMPORARILY PROCESSES YOUR PERSONAL INFORMATION
ENTERA temporarily collects your Personal Information when you are physically present on one of our client’s premises. Your image is captured by our client’s video surveillance camera and also forwarded to ENTERA. ENTERA extracts meta-data concerning your age-group and gender from these images from which it generates anonymized and aggregated statistics. ENTERA temporary processing anonymizes all video images by deleting the Data Subject’s face and randomly altering the resulting silhouette to remove all uniquely identifying biometric information.
No uniquely identifying template is ever generated and once the anonymization and aggregation process is complete not even C2RO has access to any direct or in-directly uniquely identifying information.
HOW ENTERA LIMITS THE PROCESSING OF YOUR PERSONAL INFORMATION
ENTERA uses Temporary Processing to limit the Personal Information it processes to what is necessary to extract the meta-data required to generate the Logistical Statistics. Temporary Processing lasts no longer than 5 minutes after which your information is anonymized and aggregated and the raw video image that includes your Personal Information is destroyed therefore can no longer identify you.
WHAT THIRD PARTIES HAVE ACCESS TO YOUR PERSONAL INFORMATION
Since ENTERA anonymizes and aggregates the Logistical Statistics derived from the temporary process of your Personal Information before storing them on an external server, it does not transfer Personal Information to any third party.
In addition, we have designed ENTERA to destroy the video image as soon as it has extracted the metadata thereby rendering it impossible for us to either retrieve or communicate to a third party the Personal Information it contains.
However, for the sake of transparency, we wish to inform you that anonymized and aggregated information may be stored outside of Canada on servers provided by MongoDB Atlas (“MongoDB”) unless the data locality is mutually agreed between C2RO and the client. For further information on their privacy practices please check www.mongodb.com/legal/privacy-policy.
We reserve the right to disclose anonymized and aggregated information to appropriate authorities to protect our rights, your safety or the safety of others as well as to investigate fraud, or to respond to a law enforcement request. We may also disclose it to authorities designated by applicable laws such as in conjunction with a subpoena, a government inquiry, litigation, dispute resolution or similar legal process (including lawful access by a foreign court, law enforcement or government agency).
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We have designed ENTERA not to retain Personal Information longer than it takes to generate anonymized and aggregated Logistical Statistics. This time lasts no longer than 5 minutes.
ENTERA, however, stores the anonymized and aggregated Logistical Statistics belonging to a client for the duration of our services agreement with that client on a server provided by MongoDB. Upon termination of this service agreement, the Logistical Statistics belonging to the client will either be made available to the client to retrieve or will be destroyed according to our internal information destruction policy. If, however, C2RO were required to retain the anonymized and aggregated information for longer than is necessary to meet a given legal, accounting or reporting requirement or to assert or to defend itself against a legal claim, we reserve the right to do so.
HOW WE GUARANTEE THE ACCURACY OF YOUR PERSONAL INFORMATION
As ENTERA does not store Personal Information, there is no way for it to become obsolete or require updating.
HOW WE PROTECT YOUR PERSONAL INFORMATION
C2RO is committed to protecting the confidentiality, integrity, availability and privacy of your Personal Information. We designed ENTERA according to the principles of “privacy by design” so as to Temporarily Process Personal information. ENTERA neither stores nor communicates Personal Information.
As an organization, C2RO employs security safeguards that are customary in the video analytic industry. We have put in place the physical, organizational, and technological measures necessary to protect the confidentiality, integrity and accessibility of the information we process based on its level of sensitivity. Examples of such measures include rigorous personnel training, restricted access to information on a need-to-know basis, encryption of information in transit and well-defined internal policies and practices. We have also implemented a thorough data breach mitigation, response, and notification process.
YOUR RIGHTS AND HOW TO EXERCISE THEM
You have various rights in connection with our processing of your Personal Information such as the rights to access, rectification, objection, restriction, portability and erasure. Given the Temporary Processing of Personal Information by ENTERA to ensure that Personal Information is rapidly anonymized and aggregated, it may be impossible for us to provide you with the remedy you are seeking.
C2RO has implemented an access request procedure and we invite you to contact us with any questions you may have concerning your privacy or our processing of your Personal Information at privacy@c2ro.com.
HOW WE RESPOND TO AN ACCESS REQUEST
C2RO will generally respond to all access requests within 28 days of the receipt of all necessary information. In circumstances where C2RO may not be able to provide access, or if additional time is required to fulfill a request, we will advise you in writing.
C2RO may not release certain types of information to Data Subjects based upon exemptions specified in applicable laws. Where possible, C2RO will sever the information that will not be disclosed and provide the Data Subject with access to the remaining information. Should C2RO be unable to provide access or disclose Personal Information to the Data Subject, C2RO will provide the Data Subject with an explanation, subject to restrictions.
Data Subjects may learn more about the process or obtain assistance in completing an access request by contacting privacy@c2ro.com.
RESOLVING CONCERNS
Any report, concern, complaint or incident of which C2RO becomes aware that involves conduct that may contravene the Notice will be treated confidentially to the extent possible. However, some disclosure may be necessary to adequately address issues raised, aid enquiry and implement solutions, as appropriate.
Incident Reporting and Escalation Process
C2RO takes all potential or actual privacy breaches seriously.
Data Subjects may report their concerns about the collection, use, disclosure, retention or destruction of their Personal Information directly to our CPO or email us at privacy@c2ro.com. Our CPO will engage the appropriate levels of management to assist with a resolution of the issue.
Alternative Actions
While C2RO is committed to resolving all privacy matters internally, nothing in the Notice preludes a Data Subject from contacting the appropriate federal or provincial privacy commissioner.
Prohibition Against Retaliation
C2RO will not retaliate against a Data Subject who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their privacy.
MONITORING/ OVERSIGHT MECHANISM
The C2RO Follow Up Committee conducts periodic reviews of incidents and issues raised by Data Subjects to identify and address systemic problems. The Committee also ensures that C2RO remains compliant with Privacy Laws and that its security technology offers the highest levels of information protection.
ROLES AND RESPONSIBILITIES
C2RO is responsible for communicating this Notice and ensuring that members of the C2RO Team fully comply with all relevant aspects of this Notice.
Board of Directors
C2RO’s Board of Directors ensures that C2RO remains a leader in privacy and data protection. It holds special meetings to address exclusively matters relating to data protection and privacy.
Chief Executive Officer
The Chief Executive Officer ensures that the appropriate and necessary resources are allocated to support global data protection and privacy strategy.
Chief Technology Officer
The Chief Technology Officer is responsible for designing and overseeing the design of C2RO technology according to the principles of “privacy by design”.
Vice-President, Engineering
The Vice-President, Engineering ensures that the designs approved by the Chief Technology Officer are executed according to the principles of “privacy by design”.
MAINTENANCE AND REVIEW
This Policy is effective as of March 1, 2022, and supersedes all prior versions. The next review is scheduled for fall 2023.
C2RO reserves the right to interpret the Policy at its sole discretion and to make changes as it deems appropriate from time to time without the requirement of advance notice.
Privacy Laws continue to evolve and, as a result, this Policy may be amended by C2RO from time to time at the full discretion of C2RO without any prior notice or liability to a Data Subject or any other person. The collection, use, and disclosure of a Data Subject’s Personal Information by C2RO will be governed by the version of this Policy in effect at that time.