Privacy Policy

Our mission here at Supervaisor (we/us/our) is to do good with data. We do it by contributing to traffic safety with Your help. We will do our best to be a reliable partner for You and the community.

First off, general overview of what we do with the data while pursuing our mission to improve traffic safety.

Supervaisor and our mission is to improve traffic safety. We do it by:

  • allowing Users to send us their video recordings of possible traffic situations and offences;
  • feeding these videos along with time and location data into our deep learning AI system that helps us to identify high-risk areas and vehicles; and
  • sharing the results of our analysis and general statistics with our users, vehicle fleet operators, insurance companies, public authorities and others whose decisions can actually make traffic safer.

We also want to make sure that all data that gets to us is safe and people’s privacy is respected. That is why all videos uploaded go through anonymization layer meaning we automatically blur the faces of all Traffic Participants captured on videos, including drivers and pedestrians. Thus, the videos we use do not contain Personal Data. However, if a there is Personal Data within the data we process, i.e. a person is identifiable from the video or if there are Special Categories of Personal Data visible on the video, we do not process such video if we do not have legal grounds for processing and we will delete such data or video immediately.

For Personal Data that we do process (e.g. User’s) we have taken upon ourselves to adhere to rules and principles set out in this Privacy Policy.

Here are the contents of this Privacy Policy in a nutshell chapter by chapter

Supervaisor SaaS Landing Page Template uses visitors' data for the following general purposes:

  • 1.1 DEFINITIONS: Here you can find explanation to capitalised words.
  • 1.2 GENERAL PROVISIONS: General Provisions tell you who the controller of Personal Data is and when the Privacy Policy applies
  • 1.3 PRINCIPLES: Here you find the principles that are always followed by Supervaisor while Processing your Personal Data.
  • 1.4 COMPOSITION OF PERSONAL DATA: Here you find information on how we collect Personal Data.
  • 1.5 COMPOSITION, PURPOSES AND BASES FOR PROCESSING OF PERSONAL DATA: Here you find out for which purposes and under which bases we can Process your Personal Data.
  • 1.6 DISCLOSURE AND/OR TRANSFER OF USER DATA TO THIRD PERSONS: Here you find information on when we may transfer your Personal Data to our cooperation partners.
  • 1.7 SECURITY OF PERONAL DATA PROCESSING: Here you find a description of how we will protect your Personal Data and where you can find information on the storage periods of Personal Data.
  • 1.8 PROCESSING OF THE PERSONAL DATA OF CHILDREN: The Services of Supervaisor are not targeting Children.
  • 1.9 RIGHTS OF DATA SUBJECTS: Your Personal Data belongs to you, and here you find information on the rights you have in protecting your Personal Data.
  • 1.10 EXERCISING OF RIGHTS AND FILING OF COMPLAINTS: Here you find information on how to receive explanations or how and to where a complaint should be filed.
  • 1.11 COOKIES AND OTHER WEB TECHNOLOGIES: Here you find information on the types of Cookies or other technologies we use and how you can control the use of such technologies.
  • 1.12 CONTACT DETAILS AND INFORMATION: Here you find our contact details.
  • 1.13 OTHER TERMS AND CONDITIONS: Here you find information on the validity of and amendments to the Privacy Policy.
  • 2. DEFINITIONS
  • 2.1 Data Subject is a natural person about whom Supervaisor has got information or data enabling to identify the natural person. Data Subjects are, for example, the Users, Visitors, Traffic Participants and cooperation partners, as well as the employees who are natural persons and whose personal data are held by Supervaisor.
  • 2.2 Privacy Policy is this text which sets out the principles for Personal Data Processing by Supervaisor.
  • 2.3 Personal Data is any information concerning an identified or identifiable natural person.
  • 2.4 Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject, such as collection, recording, organisation, structuring, storage, alteration and disclosure, enabling an access to, retrieval, consultation, use, transmission, cross-checks, alignment or combination, restriction, erasure or destruction of Personal Data, irrespective of the manner of performing these operations or the means exploited.
  • 2.5 User is any natural or legal person that uses or has expressed a desire to use the Services of Supervaisor.
  • 2.6 Traffic Participant is any person that is captured on a video created by Users in a traffic situations, such as pedestrians and drivers.
  • 2.7 Terms of Service set forth the terms and conditions applied to the usage of Supervaisor’s Service.
  • 2.8 Website means the website of Supervaisor: https://www.supervaisor.com/.
  • 2.9 Visitor is any person using the Website of Supervaisor.
  • 2.10 Child is a person who is under 13 years of age in the context of Personal Data Processing upon provision of information society services in the Republic of Estonia.
  • 2.11 Services are any services and products offered by Supervaisor and it includes any (mobile) applications and content within the Services.
  • 2.12 Cookies are the data files sometimes recorded in the device of a Visitor of the Website.
  • 2.13 Person who is responsible for data protection at Supervaisor is the person who monitors the implementation of the Personal Data Processing principles at Supervaisor and who can be contacted by the Data Subject in case of a complaint.
  • 2.14 Sales Channels are the means used by Supervaisor for communicating with a Data Subject, devices created for selling the goods and providing the services, including e-mail, telephone, public and social media, various chat lines, individualised and interactive advertisements and other tools on the Websites and elsewhere.
  • 2.15 Special Categories of Personal Data means Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the cases of processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Special categories of data include personal data relating to criminal convictions and offences or related security measures based, however we have assessed that data relating to acts of the Traffic Participant may only become such a data after there is a decision by a competent authority of the court establishing criminal conviction or offence.

The above words and expressions are used in the meanings set out above in the Privacy Policy, Terms of Service and in the communication between the parties.

General Provisions tell you who the controller of Personal Data is and when the Privacy Policy applies.
  • 3. GENERAL PROVISIONS
  • 3.1 Supervaisor is the legal person Supervaisor OÜ registry code 14586133, address Tallinna tn 19a-20, 93811 Kuressaare, Saaremaa.
  • 3.2 Supervaisor may process Personal Data as:
    • (1) a controller, while determining the purposes and means of processing;
    • (2) a processor in accordance with the instructions from the controller; and
    • a recipient to the extent to whom the Personal Data are transferred.
  • Please contact privacy@supervaisor.com for information about our processors.
  • 3.3 This Privacy Policy of Supervaisor constitutes an inseparable part of the Terms of Service entered into between Supervaisor and the User. However it also regulates the use of Personal Data by Supervaisor regards to Visitors and Traffic Participants.
  • 3.4 The Privacy Policy shall apply to the Data Subjects, and the rights and obligations set out in the Privacy Policy shall be followed by all the employees and cooperation partners of Supervaisor who come into contact with the Personal Data that are in the possession of Supervaisor.
Here you find the principles that are always followed by Supervaisor while Processing your Personal Data.
  • 4. PRINCIPLES
  • 4.1 The objective of Supervaisor is to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes, and Supervaisor shall always take into account the interests, rights and freedoms of Data Subjects.
  • 4.2 All the processes, guidelines, operations and activities of Supervaisor that are related to Personal Data Processing are based on the following principles:
    • (1) Lawfulness. There is always a legal basis for the Processing of Personal Data, i.e. consent;
    • (2) Fairness. Personal Data Processing shall be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data are Processed, for example via the register of processing operations;
    • (3) Transparency. Personal Data Processing shall be transparent for the Data Subject, including via the User Account created for the very same purpose;
    • (4) Purposefulness. Personal Data shall be collected for legitimate purposes that have been established precisely and clearly, and shall not later be processed in any manner which is in conflict with these purposes;
    • (5) Minimisation. Personal Data shall be adequate, relevant and limited to what is necessary for the purpose of Processing the given Personal Data. Supervaisor shall be guided by the principle of minimum Processing in Personal Data Processing, and as soon as the Personal Data are no longer necessary or are no longer needed for the purposes for which they were collected, the Personal Data shall be deleted;
    • (6) Accuracy. Personal Data shall be correct and shall be updated as necessary, and all reasonable measures shall be taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing shall be deleted or corrected without delay;
    • (7) Limit of storage.Supervaisor shall do its best to make sure that there is no Personal Data on videos used by blurring automatically Traffic Participants’ faces. Personal Data shall be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data are processed. It means that in case Supervaisor wishes to store the Personal Data for a longer period of time than necessary for the purpose of collecting the data, Supervaisor shall anonymise the data in such manner that the Data Subject shall no longer be identifiable. Supervaisor shall store the data that have been received by Supervaisor via a User relationship or any other similar relationship, in accordance with the best practice, and the data processed on the basis of consent generally for as long as the consent is withdrawn;
    • (8) Reliability and confidentiality. Personal Data Processing shall be carried out in the manner ensuring the adequate security of Personal Data, including their protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organisational measures;
    • (9) Data protection by design and by default. Supervaisor shall ensure that all the systems used shall meet the required technical criteria. The suitable data protection measures have been planned upon the renewal or design of every information or data system (e.g. the information systems and business processes are constructed using pseudonymisation, anonymization and encryption).
  • 4.3 Upon Personal Data Processing Supervaisor shall act with the purpose of always being capable of evidencing the conformity to the aforesaid principles and additional information regarding the conformity to these principles can also be requested from privacy@supervaisor.com.
Here you find information on how we collect Personal Data.
  • 5. COMPOSITION OF PERSONAL DATA
  • 5.1 Supervaisor collects, inter alia, the following types of Personal Data:
    • (1) the Personal Data disclosed to Supervaisor by the Data Subject (incl. Users);
    • (2) the Personal Data generated as a result of the day-to-day communication between the Data Subject and Supervaisor;
    • (3) the Personal Data generated upon consumption of Services (e.g. in the use of the Supervaisor’s Service;
    • (4) the Personal Data generated as a result of visiting and using the Website (e.g. the time spent on the Website);
    • (5) the Personal Data received from third persons, especially the videos, however Supervaisor aims that prior to processing videos or data within, the videos are stripped of personal Data;
    • (6) the Personal Data created and combined by Supervaisor.
Here you find out for which purposes and under which bases we can Process your Personal Data.
  • 6. COMPOSITION, PURPOSES AND BASES FOR PROCESSING OF PERSONAL DATA
  • 6.1 Supervaisor shall Process Personal Data only on if there is a legal basis for Processing. Legal bases for Processing of Personal Data include but are not limited to legitimate interests or an agreement between the Data Subject and Supervaisor or consent.
  • 6.2 Supervaisor shall Process Personal Data on the basis of consent precisely within the limits, to the extent and for the purposes determined by the Data Subject.
  • 6.3 Upon entry into and performance of an agreement, Personal Data Processing may be additionally provided for in the Terms of Service or specific agreement, but Supervaisor may Process Personal Data for the following Purposes:
    • (1) in order to take steps at the request of the Data Subject prior to entering into the agreement;
    • (2) to identify the User to the extent required by due diligence;
    • (3) to perform the obligations to the User regarding the provision of its Services;
    • (4) to communicate with the User;
    • (5) to ensure the performance of the payment obligation of the User (if applicable);
    • (6) to submit, realise and defend claims.
  • 6.4 For the entry into an employment agreement, the Processing of the Personal Data of a job applicant by Supervaisor based on the entry into the agreement and legitimate interest shall include:
    • (1) Processing of the data submitted by the job applicant to Supervaisor for the purpose of entering into an employment agreement;
    • (2) Processing of the Personal Data received from the person indicated as the referee by the job applicant;
    • (3) Processing of the Personal Data collected from state databases and registers and public (social) media.
  • In case a job applicant is not selected, Supervaisor shall store the Personal Data collected for the entry into an employment contract for two years in order to make a job offer to the job applicant in case a suitable position becomes vacant. When two years have passed after the submission of a job application, the Personal Data of the job applicant who was not selected shall be deleted.
  • 6.5 Legitimate interest means the interest of Supervaisor in the management and direction of its business in order to be able to achieve its goals. Supervaisor shall Process Personal Data on a legal basis only after careful consideration in order to ascertain the legitimate interest of Supervaisor, based on which the Personal Data Processing is necessary and is in compliance with the interests and rights of a Data Subject (after carrying out the so-called three-step test). In particular, Personal Data Processing may take place on the basis of a legitimate interest for the following purposes:
    • (1) for provision of Services and accepting and processing Videos from Users regarding Traffic Participants;
    • (2) for ensuring a trust-based relationship with a User, for example Personal Data Processing that is strictly necessary to determine the ultimate beneficiaries or to prevent fraud (if applicable);
    • (3) for the administration and analysing the User base to improve the availability, selection and quality of Services and products, and to make the best and more personalised offers to the User upon the User’s consent;
    • (4) for the identifiers and Personal Data collected upon the use of websites, mobile applications and other Services. Supervaisor shall use the collected data for web analysis or for the analysis of mobile and information society services, for ensuring and improving the functioning, for statistical purposes and for analysing the behaviour and using experience of Visitors and for providing better and more personalised Services;
    • (5) for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out User and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
    • (6) for analysing the behaviour of the Users and Visitors in different Sales Channels and on Websites;
    • (7) for monitoring of the service. Supervaisor may record the messages and instructions given in its premises as well as by means of communication (e-mail, telephone, etc.), as well as information and other operations carried out by Supervaisor, and shall use those recordings as needed to evidence instructions or other operations;
    • (8) for network, information and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites, as well as for the measures taken for making and storing backup copies;
    • (9) for developing and improving Supervaisor’s Service;
    • (10) for corporate purposes, in particular for the financial management;
    • (11) for the establishment, exercise or defence of legal claims.
  • 6.6 For performing a legal obligation, Supervaisor shall Process Personal Data to perform the obligations set forth by law or to exercise the uses permitted by law. Legal obligations derive, for example, from adhering to the rules of payment processing and prevention of money laundering.
  • 6.7 In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected, or is not based on the consent given by the Data Subject, Supervaisor shall carefully assess the permissibility of such new Processing. In order to determine whether the Processing for the new purpose is in compliance with the purpose for which the Personal Data were originally collected, Supervaisor shall take into consideration, inter alia, the following:
    • (1) any link between the purposes for which the Personal Data were collected and the intended further purposes Processing;
    • (2) the context of collecting the Personal Data, in particular regarding the relationship between the Data Subject and Supervaisor;
    • (3) the nature of the Personal Data, in particular whether any special categories of Personal Data, or Personal Data related to criminal convictions and offences are processed;
    • (4) possible consequences of the intended further processing for the Data Subjects;
    • (5) existence of appropriate protection measures which may consist in, for example, encryption and pseudonymisation.
Here you find information on when we may transfer your Personal Data to our cooperation partners.
  • 7. DISCLOSURE AND/OR TRANSFER OF USER DATA TO THIRD PERSONS
  • 7.1 Supervaisor cooperates with persons, to whom Supervaisor may transfer data regarding the Data Subjects, including their Personal Data, in the context and for the purposes of co-operation.
  • 7.2 Such third persons may be Supervaisor’s IT partners, persons, authorities and organisations intermediating or providing (electronic) mail services, marketing partners, companies carrying out User satisfaction surveys, credit registers, provided that:
    • (1) the respective purpose and the Processing are lawful;
    • (2) the Personal Data Processing is carried out in accordance with the guidelines of Supervaisor and on the basis of a valid agreement;
    • (3) the data regarding the respective processors are disclosed to the Data Subjects.
  • 7.3 Supervaisor shall transfer Personal Data to outside the European Union only if there is sufficient protection in the respective country; if protection measures have been agreed upon (e.g. binding internal rules of the group or standard data protection clauses); the Data Subject has given a clear and informed consent for such transfer; the transfer is clearly required by an agreement entered into with the Data Subject; the transfer is not repeated, it concerns only a limited number of Data Subjects; it is necessary for protecting the legitimate interests of Supervaisor which are not overridden by the interests, rights or freedoms of the Data Subject, and if all the circumstances related to the transfer have been assessed and suitable protection measures have been established to protect the Personal Data, or if there is some other legal basis therefor. Supervaisor shall inform the Data Protection Inspectorate of the transfer based on a legitimate interest.
Here you find a description of how we will protect your Personal Data and where you can find information on the storage periods of Personal Data.
  • 8. SECURITY OF PERONAL DATA PROCESSING
  • 8.1 Supervaisor shall store the Personal Data strictly only for the period required. The Personal Data with an expired storage period shall be destructed using the best practice and in accordance with the procedure established for this purpose by Supervaisor.
  • 8.2 Supervaisor has established guidelines and procedural rules for ensuring the security of Personal Data by both organisational and technical measures.
  • 8.3 Supervaisor has taken different technical measures to ensure maximum privacy and safety to Users including the following:
    • (1) All the videos uploaded go through an anonymization layer that blurs the faces of Traffic Participants;
    • (2) both dashcam and mobile phone audio are turned off by us;
    • (3) location data is only captured during active reporting, disabling any use of location tracking of our Users outside of their reported events;
    • (4) no automated video recording happen –footage is only received through active intent from the User.
  • 8.4 In case of an incident related to Personal Data, Supervaisor shall take all necessary measures to mitigate the consequences and hedge any relevant risks in the future. Inter alia, Supervaisor shall register all the incidents and shall inform the Data Protection Inspectorate and the Data Subject directly (e.g. by email) or in public (e.g. via the news) in prescribed cases.
The Services of Supervaisor are not targeting Children.
  • 9. PROCESSING OF THE PERSONAL DATA OF CHILDREN
  • 9.1 The Services of Supervaisor, including the information society services, are not targeting Children.
  • 9.2 Supervaisor does not knowingly collect any information on persons under 13 years of age, i.e. Children, and in case of any respective informed activity we shall act on the basis of the requests of a parent or guardian.
  • 9.3 In case Supervaisor finds out that it has still collected Personal Data from a Child or regarding a Child, Supervaisor shall use its best efforts to discontinue the Processing of the respective Personal Data.
Your Personal Data belongs to you, and here you find information on the rights you have in
  • 10. RIGHTS OF DATA SUBJECTS
  • 10.1 Rights related to consent:
    • A Data Subject will always be entitled to inform Supervaisor about his or her wish to withdraw the consent for the Personal Data Processing.
  • 10.2 A Data Subject has also the following rights upon Personal Data Processing:
    • (1) Right to receive information i.e. the right of a Data Subject to receive information regarding the Personal Data collected about him or her.
    • (2) Right of access to data which, inter alia, includes the right of a Data Subject to a copy of the Processed Personal Data.
    • (3) Right to rectification of inaccurate Personal Data. A Data Subject will be able, inter alia, to correct inaccurate data.
    • (4) Deletion of data i.e. in certain cases a Data Subject will be entitled to demand the deletion of Personal Data, for example if the Processing is carried out only on the basis of a consent.
    • (5) Right to demand restriction of Personal Data Processing. This right is created, inter alia, in case the Personal Data Processing is not permitted under law or if the Data Subject challenges the accuracy of the Personal Data. A Data Subject will be entitled to demand the restriction of the Personal Data Processing for a period enabling the processor to check the accuracy of the Personal Data or if the Personal Data Processing is unlawful but the Data Subject does not request the deletion of the Personal Data.
    • (6) Right to data portability i.e. a Data Subject shall have, in certain cases, the right to receive the Personal Data in a machine-readable format, and to take these data along or transfer them to another controller.
    • (7) Rights related to automated Processing mean, inter alia, that a Data Subject will have the right to object, on grounds relating to his or her particular situation, at any time to Processing of Personal Data concerning him or her, based on automated decision-making. Supervaisor doesn’t use automated decision making at this moment. We will inform you if that will change. You have the right to avoid any decisions based on automated Personal Data Processing if they can be classified as profiling;
    • (8) Right to the assessment of a supervisory authority on whether the Processing of the Personal Data of the Data Subject is lawful;
    • (9) Compensation for damage.
Here you find information on how to receive explanations or how and to where a complaint should be filed.
  • 11. EXERCISING OF RIGHTS AND FILING OF COMPLAINTS
  • 11.1 Exercising of rights. A Data Subject will be entitled to address Supervaisor using the contact details set out in section 12 in case of any question, request or complaint related to Personal Data Processing.
  • 11.2 Filing of complaints. A Data Subject will be entitled to address a complaint to Supervaisor, to the Data Protection Inspectorate or to a court if the Data Subject is of the opinion that his or her rights have been infringed in Personal Data Processing. The contact details of the Data Protection Inspectorate are available on the website of the Data Protection Inspectorate: http://www.aki.ee/.
Here you find information on the types of Cookies or other technologies we use and how you can control the use of such technologies.
  • 12. COOKIES AND OTHER WEB TECHNOLOGIES
  • 12.1 Supervaisor may collect data regarding the Visitors of the Websites and other information society services by using Cookies for this purpose (i.e. small pieces of information stored by the Visitor’s browser on the hard disk of the computer of any other device of the Visitor) or other similar technologies (e.g. IP address, equipment information, location information) and process these data.
  • 12.2 Supervaisor uses the collected data to enable the provision of the Service in accordance with the habits of a Visitor or User; to ensure the best Service quality; to inform the Visitor and User about the contents and give recommendations; to update advertisements and make marketing efforts more efficient; and to facilitate logging in and protection of data. The collected data shall also be used for counting the Visitors and recording their using habits.
  • 12.3 Supervaisor uses session Cookies, persistent Cookies and advertising Cookies. A session Cookie is deleted automatically after every visit; persistent Cookies shall remain upon repeated use of the Website, and advertising Cookies and third party Cookies are used by the Websites of the partners of Supervaisor which are connected with the Website of Supervaisor. Supervaisor does not control the generation of those Cookies, therefore information on these Cookies can be obtained from third persons.
  • 12.4 As to the Cookies, Visitors agree with the use of Cookies on the Website, in information society service devices or the web browser.
  • 12.5 Most of the web browsers allow Cookies. Without fully allowing Cookies, the functions of the Website are not available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser, settings of the information society service and platforms for making such privacy more efficient.
Here you find our contact details.
  • 13. CONTACT DETAILS AND INFORMATION
  • 13.1 The contact details of Supervaisor that are important for a Data Subject:
Here you find information on the validity of and amendments to the Privacy Policy.
  • 14. OTHER TERMS AND CONDITIONS
  • 14.1 Supervaisor will be entitled to unilaterally amend this Privacy Policy. Supervaisor shall inform Data Subjects about amendments on the website of Supervaisor, by e-mail or by other means.
  • 14.2 The latest amendments and entry into force of the Privacy Policy:

Last updated 25.10.2019

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