AV1 Privacy Statement

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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), depending on the contracting entity of your agreement.

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 any personally identifiable information from the AV1 user. Usage data is collected and made available for the customer in AV1 Admin for monitoring and reporting purposes only. Anonymized  aggregated usage data is used internally for product improvement and communicating AV1 success stories.

Customer data

When you (school, organisation, municipality or a child's parents) enter into an 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 email 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 the AV1 Solution, a direct stream is sent from the classroom between the AV1 Device and the 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 AV1 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, and not users, 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
• Phone or tablet information, such as device type and operating system version
• Crash reports from the AV1 App

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. 

If the user consents, the AV1 App also collects anonymous analytics on how the app is used. Consent can be withdrawn at any time in the AV1 App settings.

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. 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 and the outcomes of usage for different user groups and purposes. 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’ attendance and reintegration into school and social belonging. We also rely on our legitimate interest in analyzing aggregated data to improve and further develop the AV1 Solution. This information is only linked to the AV1’s allocation number and cannot be used by us to identify the user. All data is anonymized after the completion of any allocation to an individual user.

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.

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 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.

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The robot can be turned off

If it is not appropriate to use AV1 at a given time, and you do not want the user to have the ability to connect to the AV1 Device, 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 Device, they use a one-time keyword. Then, he/she creates a secret PIN.  The terms of the AV1 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 in case of breach.

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The connection between the AV1Device and the AV1 App is uniquely linked to the user device, typically a pad. The user can only be connected with one device at a time, and must use a new one-time keyword if they change device. They then lose access to the original device.

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End-to-end encrypted video stream

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The video-stream is end-to-end encrypted, and it is only possible to access the stream for the AV1 App user. Neither No Isolation nor anyone else can access and decrypt the live 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. It is not possible to take a screenshot or make recordings during a streaming session.

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. 

If there are repeated attempts by users to record or take screenshots of the live stream, in  violation of the terms of use for the AV1 App, No Isolation has the right 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 AV1 Solution to our users and customers:

• 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. 

In addition, No Isolation uses the following systems for administrative and customer support purposes that will contain selected customer information: 

• 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.
• 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

All data processing for delivering the AV1 Solution through AWS is done in the EU, at the AWS data center in Frankfurt. We do not process customer data in connection with the AV1 Solution outside the EU, and will never send customer data in relation to the AV1 Solution outside the EU without the written, express consent of our customers, or in the case of a legally binding court order. 

Some of our processors for support and administrative purposes use sub processors 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
Address: Pilestredet 28, 0166, Oslo, Norway

No Isolation Ltd
Company number: 11744705
Address: 201 Borough High Street, London, England, SE1 1JA

No Isolation GmbH
Company number: HRB 262445
Address: Innere Wiener Str. 11, 81667 München, Germany

E-mail: privacy@noisolation.com