Summary
The Smart Counter mobile application processes the camera image, photographs and the results of counts solely on the device. It has no server of its own, no user account, no analytics and no advertising, and it sends nothing of what it records to the Provider or to anyone else. The Provider processes personal data only when you contact it or when it handles your purchase, complaint or withdrawal from the contract.
1The controller
The controller is Esentra, s.r.o., with its registered office at Levočská 7711/47, 080 01 Prešov, Slovak Republic, company ID (IČO): 47 183 721, registered in the Commercial Register of the Prešov District Court, Section Sro, Insert No. 28128/P (the “Provider”). In matters of personal data protection, contact it at info@esentra.sk or in writing at the address of its registered office.
2Data that stay on the device
The camera image is processed in the device’s working memory and discarded once evaluated. The Application does not recognise faces, vehicle registration numbers or the identity of persons, creates no biometric data and uses neither the microphone nor location services.
The Application’s private storage holds the results of counts (times, kinds of objects, directions and numbers), the photographs of counts in a picture, the data you enter yourself (name of the place, note) and the Application’s settings, including the record of accepting the terms of use and of Smart Counter Pro. A video recording chosen for processing is copied temporarily and removed after processing.
These data leave the device only if you export or share them yourself, or as part of the Android system backup in your Google account; the photographs of counts are not part of the backup. You delete them in the Application, by clearing its data or by uninstalling it.
The Application uses the permissions for the camera, vibration and purchases through Google Play; internet access is used solely by the Google Play Billing library when making and verifying a purchase. On Android 12 and older it also uses storage reading to open a file you choose yourself.
3The User’s responsibility
The Provider has no access to the data on the device, does not receive them and does not determine the purposes or means of their processing. In relation to them it is neither a controller nor a processor under Regulation (EU) 2016/679 (the “GDPR”) and is not responsible for their processing.
The GDPR does not apply to a natural person who uses the Application solely for personal or household purposes (Article 2(2)(c) GDPR). Whoever uses the Application in the course of business, in the exercise of official authority or for an organisation is the controller of the personal data that the camera records or that the processed photographs and video recordings contain, and alone is responsible for fulfilling all obligations under the GDPR, in particular for the legal basis of the processing and for informing the data subjects.
4Data processed by the Provider
The Provider processes personal data only for these purposes:
- communication with you – e-mail address, name and the content of the message; the legal basis is the legitimate interest in replying to the message, or performance of a contract (Article 6(1)(f) and (b) GDPR); the data are kept for 12 months after the matter is handled;
- complaints, withdrawal from the contract and the assertion of legal claims – the data from your submission and the order number; the legal basis is a legal obligation and legitimate interest (Article 6(1)(c) and (f) GDPR); the data are kept for 4 years after the matter is handled;
- records of purchases – the order data made available by Google Play (order number, product, date, payment status, country), without payment data; the legal basis is performance of a contract and legal obligations in accounting and taxation (Article 6(1)(b) and (c) GDPR); the data are kept for 10 years.
Providing the data is voluntary; without contact details, however, the Provider cannot reply or handle your submission. The recipients of the data are the provider of the Provider’s e-mail and hosting services, the Provider’s accounting, tax and legal advisers, and public authorities where the law so provides. Payment is processed by Google as an independent controller under its own policy (policies.google.com/privacy).
5Your rights
In relation to the data processed by the Provider, you have the right of access (Article 15 GDPR), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), portability (Article 20), the right to object (Article 21) and the right to lodge a complaint with a supervisory authority (Article 77). Send your request to info@esentra.sk; the Provider replies within one month. The Provider does not hold the data stored on your device and therefore cannot provide, rectify or erase them.
The supervisory authority is the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), Galvaniho 7/B, 821 04 Bratislava (www.dataprotection.gov.sk).
6Final provisions
The Application is not intended for persons under the age of 18. The Provider may change this policy; the current wording with its effective date is available in the Application and on the website smartcounter.esentra.sk.