AV1 Privacy Statement
This privacy statement applies to No Isolation’s role as controller in the course of processing personal data.
The data controller is No Isolation AS (Norway), No Isolation GmbH (DACH) and No Isolation Ltd (UK) jointly. No Isolation AS is the main responsible and contact point.
AV1 is developed with privacy as a basic principle. We collect as little data as possible and have taken a number of security measures to protect the data we process.
Learn more about which personal information we collect, what security measures we take and which rules apply when individuals, organisations and schools or municipalities purchase AV1.
Personal data
Briefly explained: We collect name and contact information data belonging to our Customers. We do not store personally identifiable information from the AV1 user. Usage data is shared with the customer for communication and support purposes. Aggregated, non-identifiable usage data is used internally for product improvement and communicating AV1 success stories.
Existing customers
When you (school, organisation, municipality or a child's parents) conclude a subscription agreement with us, we collect and process the following personal data relating to you:
- Name
- Phone number
- E-mail address
- Delivery address
- Content of communication
- If you belong to an organisation, your workplace and work title
The information is stored for the duration of the customer agreement in order to administer the customer relationship we have with you, and to fulfil our contractual obligations. Bookkeeping data is stored longer in order to comply with national bookkeeping regulations.
Potential customers
We may, from time to time, obtain professional contact details from licensed business database providers to reach out to organisations that may benefit from the AV1 solution. Where relevant, we disclose the vendor’s name in our communication. In such cases, we process the following information:
- Name
- Work e-mail address
- Work phone number (if available)
- Job title and the organisation
The purpose of this processing is to inform relevant organisations about the availability, functionality, and benefits of the AV1 solution. The legal basis is our legitimate interest in promoting our product and our services.
We retain prospect contact details for 12 months, or until you unsubscribe or object to the communication, whichever occurs first.
Livestream data
While using AV1, a direct stream is sent from the classroom between the AV1 and a separate AV1 app that the child uses. During this stream, audio and video data are transmitted from the robot to the AV1 app, and audio data can be transmitted from the AV1 app to the robot.
The stream is end-to-end encrypted, which means that it is not possible for anyone other than the user of the app to access what is happening in the classroom. The audio and video data from the stream cannot be stored, either by No Isolation, the user, or any third party.
As we only collect personally identifiable information relating to customers, we do not know who the user of the AV1 app is, only the entity that has purchased the AV1 device.
Metadata
The following metadata is collected during the livestreams:
- Date and time of livestream transmission
- Wireless network information
- Connection Strength
- Cellular Network Information
- Battery level and strength
This metadata supports the operation of AV1 by helping us and our customers diagnose technical issues, in line with our contractual obligations. In addition, aggregated metadata is used internally for our legitimate interests in improving the performance of AV1 and the services we provide.
Usage data and allocation reasons
Customers can access usage data insights through AV1 Admin (for example session duration and frequency per AV1 and across a fleet, feature interactions (such as camera movements, hand raise, or volume adjustments), utilisation percentages, development of usage over time, and app events during streams. We may use this data together with customers to analyze usage patterns and support the use and effectiveness of the AV1. Customers may also disclose allocation reasons, such as the purpose for which an AV1 is used, to better understand how different user groups interact with the AV1 units. Usage statistics and allocation information may also be aggregated by No Isolation to identify general patterns of use and improve our services.
The processing of usage data and allocation reasons is based on the legitimate interests of our customers, end users and us in ensuring that the AV1 solution is used effectively to support the end users’ re-integration into school and social life to the highest extent. We also rely on our legitimate interest in analyzing aggregated data to improve and further develop the AV1 and related services. This information is only linked to the AV1’s allocation number and cannot be used by us to identify the user. All data is detached from a specific allocation number and customer profile when a subscription is terminated or when a new end user is assigned.
Only technical personnel at No Isolation subject to the duty of confidentiality have access to the information mentioned above. The information is never disclosed to third parties, unless it is subject to mandatory law. If disclosure is required, No Isolation will notify affected data subjects unless prohibited by that law.
Donations
In some cases where an AV1 has been donated, for example from a foundation or an organisation, there will be a need to keep an overview of whether an AV1 has been used. The overview will then be shared with the foundation or organisation that has donated AV1. The user must be informed of this by the organisation/foundation.
Privacy by design
Briefly explained: To safeguard the privacy of users and those around the robot, and to ensure that video streaming is as secure as possible, we apply a measures to improve inherent privacy by design. Examples are the on/off button, the end-to-end encryption of the live stream, data minimisation steps and prohibitions against misusing the AV1.
The robot clearly shows when the user is connected.
When the user is online, the AV1 lights its eyes and head. This way, people around the AV1 can know when the live stream is active.
The robot can be turned off
If it is not appropriate to use AV1 at a given time, you can turn off the robot with a button on the back next to the charging input.
One user
The first time the user connects to their AV1, they use a one-time keyword. Then, he/she creates a secret PIN. The terms of the app state that parents/others are not allowed to connect to AV1, and it is considered a breach of contract if they do so. No Isolation has the ability to permanently remove the user's access.
The user can only be connected with one device at a time, and must use a new one-time keyword if they are to change device. They then lose access to the original device.
End-to-end encrypted video stream
The video-stream is end-to-end encrypted, and it is only possible to access the stream for the app user. Neither No Isolation nor anyone else can access and decrypt the stream with any measures reasonably likely to be used.
No audio or video data may be stored
It is only possible to use AV1 in real time. This means that you cannot record or store a video stream.
If the user attempts to take a screenshot during streaming, he/she will be warned that it is not allowed, and will be blocked from using AV1. Administrators and school assistants (with permission to unblock) can unblock the AV1 in the Admin portal. For iOs devices, the screenshot saved will furthermore only be a white picture. On Android devices, it is not possible to take a screenshot at all.
It is also not possible to connect the tablet or phone to an external TV or computer monitor to display the video stream. Both screens will then go black, and the user will then be banned from the app. In both cases, the user must contact their administrator or No Isolation’s support team to unlock their access again. No Isolation has the ability to permanently remove the user's access.
Network Overview
Your rights
You have the right to request access, correction, restriction of processing, and deletion of your personal information. You also have the right to complain to the relevant Data Protection Authority.
Processors
No Isolation uses the following processors to deliver the service:
- Amazon Web Services EMEA SARL is a cloud service provider that we use for our servers that process metadata and customer data. The processing takes place in the EU/EEA.
- Google Cloud EMEA Limited provides us with e-mail services for customer support and internal communication purposes. The processing takes place in the EU/EEA.
- Simple Analytics B.V grant is used to get insight on AV1 Admin Portal usage on an aggregated and non-identifiable basis. The processing takes place in the EU/EEA.
- Hubspot Ireland is a CRM provider which we use for managing customer relationships. The processing takes place in the EU/EEA.
- Odoo SA is our ERP system, and provides us with necessary billing and accounting services. The processing takes place in the EU/EEA.
Data sent out of the EU/EEA
Some of our processors use subprocessors who are either located in the USA, or who have engaged sub-processors who are located in the USA. While all our processors are contractually obliged to host data in the EU/EEA, transfers to the USA can occur when strictly necessary for support purposes, or in the case of a legally binding court order.
For transfers to third countries, the legal basis for these would be either the European Standard Contractual Clauses (SCCs) which we have entered into with each of our subprocessors, or an Adequacy Decision where applicable.
Technical measures are in place ensuring that the livestream video or audio data can neither be accessed, transmitted or in any other way made available for anyone else other than the End User. This includes No Isolation’s staff and the company’s processors, making it impossible to transfer such data outside the EU/EEA.
Our contact information
No Isolation AS, company number: 815 716 272
Phone number: +44 20 3695 9242
Address: Pilestredet 28, 0166, Oslo, Norway
E-mail: privacy@noisolation.com
