This Privacy Notice on Video Surveillance (hereinafter “Privacy Notice”) explains how Bolt Technology OÜ and its group companies (hereinafter “Bolt” or “We”) processes your (hereinafter “You” or Data Subject”) personal data through our video surveillance systems if they are installed in our premises.
1. Personal data we process
The personal data that is processed by the video surveillance system is images and video clips of all persons visiting the premises which are covered with video surveillance.
2. The purposes and the legal grounds for the processing of personal data
Video surveillance is carried out for the following purposes:
The location and positioning of the video cameras takes into account the legitimate expectations of the data subject to their privacy.
Legal basis for processing personal data is legitimate interest.
In some circumstances we are legally obliged to share information with external recipients. For example, under a Court Order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We can also respond to requests, such as those from law enforcement agencies, when we have a good-faith belief that the response is required by law in that jurisdiction or furthers a public interest task, affects users in that jurisdiction, and is consistent with internationally recognised standards. In any scenario, we’ll always satisfy ourselves that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.
Depending on the location of the data subject, the personal data may be disclosed to the Bolt Technology OÜ group companies and partners (local subsidiaries, representatives, affiliates, agents etc). Processing of personal data by Bolt Technology OÜ group companies and partners will occur under the same strict conditions as established in this privacy notice.
We may use external service providers for video surveillance, e.g. a security company. Processing of personal data takes place under the contract concluded with the processor.
We generally do not transfer your personal data outside of the European Union (EU) or the European Economic Area (EEA), nor to such third country or international organization, the level of data protection of which the European Commission has not considered adequate. If your personal data is transferred outside of the EU or EEA, such transfer of personal data will take place only upon appropriate legal basis, and we will take appropriate protective measures.
You have the right to obtain additional information about the transfer of your personal data by sending the relevant request at firstname.lastname@example.org.
4. Your rights
Your right of access
Your right to erasure
Your right to restriction of processing
Your right to object to processing
5. Retention of personal data
We retain the personal data processed no longer than necessary for the purpose for which it was collected. After the retention period, the video is automatically overwritten by new video footage.
In premises where only real-time monitoring is performed, no data is stored through the video surveillance system.
6. Dispute resolution
Disputes relating to the processing of personal data are resolved through customer support (email@example.com) in the first instance. You have the right to contact Bolt's Data Protection Officer (firstname.lastname@example.org). Our supervisory authority is the Estonian Data Protection Inspectorate (www.aki.ee).
7. Making this notice great
We hope you have found this privacy notice easy to understand. We take our responsibilities with your data seriously. We will continue to make changes to this privacy notice as part of our commitment to protecting your privacy and affording you even more transparency.