This is the privacy statement of Camenai B.V. (hereinafter “Camenai”) with regard to photos collected from public roads using Camenai applications. These photos of the outdoor area may contain personal data, under which the General Data Protection Regulation (“GDPR”) applies. In this privacy statement, we explain how we deal with the protection of personal data in these photos.

Recognizable faces and license plates that are visible in the photos are made unrecognisable by means of “blurring” for privacy reasons. The blurred photos are stored in a database and processed via a closed online platform. Relevant data for managing the outdoor space that is visible in the photos (such as the condition of the street furniture and the presence of litter) is analyzed by Camenai. The photos and analyses of the outdoor area are then made available to Camenai's relevant customers via a dashboard (hereinafter “Outdoor Space Dashboard”).

Camenai only processes personal data in accordance with applicable privacy laws and regulations and in line with this Privacy Statement.

whom is responsible pre the processing of personal data?
According to the GDPR, the controller is the party that, alone or jointly with others, determines the purposes and means of processing personal data. The controller has various obligations under the GDPR. Camenai regularly fulfills the role of data controller with regard to collecting the footage, processing this footage and making it available via the Outdoor Space Dashboard.

Insofar as Camenai determines the purpose and means of collection and processing jointly with another party, there is a joint processing responsibility. This is the case, for example, when Camenai and a customer agree that the Camenai application will be used to take photos of the outdoor area to detect litter and where the customer in question uses the Camenai application to collect these images, Camenai further processes these images and applies a litter detection algorithm to this footage. In this situation, the activities of both Camenai and its customers are inextricably linked and goals and resources are jointly determined in the interests of both Camenai and its customers. Insofar as there is such a joint processing responsibility, Camenai will lay down the agreements with its co-controller (s) in an appropriate agreement in accordance with the GDPR.

The processed footage is provided by Camenai on the Outdoor Space Dashboard. In this regard, Camenai has an independent processing responsibility for managing the database and providing the images. Customers who subsequently use the footage via the Outdoor Space Dashboard in their own work processes are also independently responsible for processing.

For some activities, Camenai instructs third parties to carry out (part) of the image processing, possibly also providing personal data to these parties. Such third parties are “Processors” of Camenai under the GDPR. Examples include third parties that collect images on behalf of Camenai or partners who analyze images automatically. Agreements are made with these processors about the careful and safe processing of personal data that are laid down in a processing agreement.

There may also be a situation where Camenai only processes images on behalf of another organization and where Camenai does not process these images for its own purposes nor has any influence on how this happens (other than simply providing an application that provides this). In these situations, the responsibility for processing lies entirely with Camenai's client and Camenai acts as a “Processor”. The agreements in this regard are laid down in a processing agreement to ensure the safe processing of personal data.

Goal of the computing and lawfulness
Camenai takes photos of the outdoor space to visualize the environment and analyse this environment to improve the management of the outdoor space. Camenai has a legitimate interest in processing potentially visible personal data in street photos on the basis of article 6.1 sub f GDPR. This legitimate interest includes the freedom to conduct business as set out in Article 16 of the EU Charter of Fundamental Rights and the resulting interest in providing the best possible service to its customers, other stakeholders and wider society. The processing purposes include the registration and processing of photos of the outdoor area in a database in order to further analyze these photos - under strict conditions - and to make the photos and the results of the analysis available to public and private organizations.

The footage collected by Camenai provides a better insight into outdoor space and thus contributes to a social interest in better understanding the increasingly complex and rapidly changing environment and detecting problems in time. To achieve adequate management of outdoor space in connection with:

Improving mobility (e.g. parking pressure);
Improving the quality of life (e.g. litter monitoring, weed detection);
The consequences of climate change (e.g. water drainage barriers);
Increasing safety (e.g. road surface quality, visibility markings and road signs); and
Other public responsibilities
a transparent and up-to-date view of the outdoor space is essential. In short, the interests of society as a whole benefit from the data processing carried out by Camenai.

In order to efficiently and effectively analyze outdoor space through large-scale recording and analysis of outdoor space, the capture of (personal) data that is visible from public roads is unavoidable. After all, this recording of the outdoor space is necessary to generate such an overview and insight into the outdoor space in question, so that it is comparable to what a person observes if he or she were to physically visit the same location.

The interests of Camenai and third parties, including society as a whole, are weighed by Camenai against the interests or fundamental rights and rights of data subjects in relation to the protection of personal data. This plays a role in the fact that almost all data that is visible on the footage cannot be considered at all or only as insensitive (personal) data that is already visible in outdoor space. As a result, the potential adverse consequences and risks for any stakeholders are minimal.

In addition, Camenai has taken various safeguards to prevent and limit any unwanted consequences for those involved as much as possible. One of these measures concerns “blurring”: because faces and license plates are not relevant to the purpose of processing, Camenai uses an advanced software tool that automatically detects faces and license plates in the images and makes them unrecognisable.

Camenai's footage is not freely accessible. In addition, customers only get access to Camenai's footage after the raw data has been bleached. Furthermore, customers do not have access to the full dataset, but only to the relevant geographical areas within the image database that they need for their own purposes.

Camenai believes that its interests combined with the interests of its customers in principle outweigh the invasion of the privacy of those involved, partly because Camenai has taken measures to minimize this infringement, as further explained under “Save and secure”.

Save and securing
Camenai's photos are kept in order to meet the purposes of processing and its contractual obligations with customers. The database of street photos collected within European countries is stored within the European Economic Area.

In the photos that Camenai collects, stores, analyzes and makes available to its customers via the Outdoor Space Dashboard, privacy-sensitive information, namely faces of recognizable people and/or car license plates, is made unrecognizable (“blurred”). Unblurred footage is deleted after the blurring has occurred.

Camenai has also set up various organizational and technical measures to ensure that unauthorised access to the data can be prevented, such as:

Separate processing of images and other data;
Storage on highly secure servers;
Encrypted storage on the collection equipment;
Limiting access for individual users via username/password and, where under our own control, multi-factor authentication;
Providing information to employees about their obligations with regard to the lawful processing of the images and data derived from this material;
Setting up a reporting process for security incidents (data leaks).
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Provision of information and surveillance
Through its own website, Camenai provides information about collection projects. Insofar as there is a joint responsibility for processing the images, those involved are (also) informed via that party's website.

In addition, Camenai has appointed a personal data processing supervisor, a data protection officer (FG). Within Camenai, the DPO supervises the application and compliance with the GDPR and can be reached via the contact details below.

thine rights
As a data subject to our photos (for example, because your home has been photographed or because you suspect you are in our photos yourself), you can request us to view, rectify, delete and restrict the processing of your data. In addition, you can object to the use of your personal data. To do so, please contact us in writing: by email at privacy@camenai.com, via the contact page or by post at the address below:

Camenai
Europalaan 400
3526 KS Utrecht

If you submit a request for inspection, we may - in order to prevent abuse - ask you to demonstrate that you are actually the person concerned in relation to the request (such as the owner of a home that you want to see).

Insofar as your request relates to processing carried out by Camenai under joint responsibility with another party, your request will also be forwarded to that party and will be dealt with in consultation. If your request falls under the responsibility of another party, Camenai will forward your request to that party for processing. In such cases, Camenai will inform you about this.

Camenai is careful with the processing of your personal data and is committed to adequately dealing with any requests or concerns. If you are of the opinion that this is not going satisfactorily, you have the right to file a complaint with the Data Protection Authority.

We reserve the right to change our Privacy Statement. Changes will be published via this website.