FAQ - Frequently asked questions
Blimp Analytics is our people flow monitoring service, consisting of Head- Counter (sensor) and Audience Platform (cloud-based software).
The Head-Counter is a sensor capable of detecting in real time some aggregated and statistical data about people within its range. In its standard version it can detect individuals up to 60 metres away. In its standard version it can detect individuals up to 60 metres away.
Yes. The difference lies in the purpose: video surveillance cameras perform a function of prevention and monitoring of an area; the Head Counter, on the other hand, performs a mere function of counting flows of people and some other parameters for statistical purposes. For this intrinsic purpose, it is not necessary to communicate the device to trade union representatives [See also: Do you need a trade union agreement to install Head-Counter in a shop?]
Yes. In order to obtain statistical data, the Blimp Analytics service acquires images of individuals passing within range via Head- Counter sensors. According to data protection legislation (see Recital 51), images (or snapshots) are configurable as personal data under Article 4(1). The snapshots live, for a few seconds, only and exclusively on the volatile memory of the device, in order to allow the neural network algorithm to execute, which allows the extrapolation of only the statistical and anonymous data mentioned. Once the statistical data has been extrapolated, after a few seconds, the pictures are permanently deleted.
In accordance with the provisions of the Data Protection Authority No. 551 of 21 December 2017, Head-Counters require the posting of a simplified privacy notice, to be displayed in a place accessible to the public (e.g. a shop window display) and a link to an extended privacy notice. If you are unsure where to display the notice, please contact us at privacy@blimp.ai for assistance.
No, the Blimp Analytics Service allows us to monitor streams of people from which we infer general and statistical data without identifying individuals.
Yes, when you use Blimp’s Head-Counters you will be identified as a Data Controller: this is because you will be responsible for determining the purposes and means of the processing of Personal Data collected through the devices.
No. ☺
If you have time, let us explain a little more.
EU Reg. 679/2016 (so-called “GDPR”) defines a list of cases within which the “rights and freedoms” of natural persons could be jeopardised. What the legislation requires is that, where there is even the slightest suspicion of a threat to EU citizens, that the Technology Controller ‘investigate’ what risks might occur and implement solutions to mitigate them. These activities should be done in a process called Data Protection Impact Assessment (“DPIA”).
According to Article 335(3) of the GDPR, there are in particular three cases in which a DPIA should be carried out, namely when:
“a systematic and comprehensive assessment of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based which produce legal effects concerning those natural persons or significantly affect them in a similar way’ (Art. 35(3)(a));
the processing, on a large scale, of special categories of personal data referred to in Article 9(1) or data relating to criminal convictions and offences referred to in Article 10; or (Art. 35(3)(b));
systematic large-scale surveillance of a publicly accessible area. (art. 35(3)(c)).
As Blimp.ai, although we do not operate as a Data Controller, we have conducted and regularly review our DPIA, paying particular attention to all risks and threats that might occur to the rights and freedoms of EU citizens.
We also make our DPIA available to customers, the result of months of work and analysis to identify every smallest element of our services and technology.
Questions about the services
Blimp Analytics is our people flow monitoring service, consisting of Head-Counter (sensor) and Audience Platform (cloud-based software).
The Head-Counter is a sensor capable of detecting in real time some aggregated and statistical data about people within its range. In its standard version it can detect individuals up to 60 metres away. In its standard version it can detect individuals up to 60 metres away.
The Audience Platform is a software dedicated to the visualisation and analysis of data measured by Head-Counters.
Yes, for saving and displaying statistical and anonymous data sent from individual Head-Counter devices and uses Microsoft Azure cloud computing services.
It is important to clarify that it is not the device that is cloud-based but the Analytics Platform alone.
Head-Counters can be installed both outdoors (squares, streets, etc.) and indoors (e.g. shops, company premises, etc.).
We carry out six-monthly checks with specific regard to the Camera Sensor and the local memory of the Main Board, in order to ascertain any malfunctions, equipment unavailability or fraudulent access attempts. For this purpose, maintenance activities are recorded in the maintenance log.
Questions on Privacy and Data Security
No, the Blimp Analytics Service allows us to monitor streams of people from which we infer general and statistical data without identifying individuals.
Yes. In order to obtain statistical data, the Blimp Analytics service acquires images of individuals passing through the range via Head-Counter sensors. According to data protection legislation (see Recital 51), images (or snapshots) are configurable as personal data under Article 4(1). The snapshots live, for a few seconds, only and exclusively on the volatile memory of the device, in order to allow the neural network algorithm to execute, which allows the extrapolation of only the statistical and anonymous data mentioned. Once the statistical data has been extrapolated, after a few seconds, the pictures are permanently deleted.
The legal basis of processing for the Blimp Analytics Service is legitimate interest (Art. 6 c. 1 lett. f of the GDPR).
The legitimate interest of the Data Controller is one of the conditions (legal basis) under the Data Protection Legislation for processing personal data.
If the processing is based on legitimate interest, the data subject’s consent is not required, provided, however, that the interests or fundamental rights and freedoms of the data subject (especially if the data subject is a child) do not prevail, taking into account the data subject’s reasonable expectations based on the relationship with the data controller (see Recital 47 of the European General Regulation). In this sense, a so-called balancing of interests is necessary.
Absolutely not. The system is not developed to keep track of people’s movements, let alone monitor their activities. Head-Counter technology simply makes an assessment of the amount of people present in a given place at a given time by extracting some statistical data.
Yes. The difference lies in the purpose: video surveillance cameras perform a function of preventing and monitoring an are; the head-counter, on the other hand, performs a mere function of counting flows of people and some other parameters for statistical purposes. For this intrinsic purpose, it is not necessary to communicate the device to trade union representatives [See also: Do you need a trade union agreement to install Head Counter in a shop?].
No, images that are taken remain in the volatile memory of the device only for the time of processing by the algorithms and are promptly deleted as soon as the process is finished.
No, the images only remain in the devices for the time needed to extract the necessary statistical data (a few seconds). No images are sent for storage in the cloud.
In accordance with the provisions of the Data Protection Authority No. 551 of 21 December 2017, Head-Counters require the posting of a simplified privacy notice, to be displayed in a place accessible to the public (e.g. a shop window display) and a link to an extended privacy notice. If you are unsure where to display the notice, please contact us at privacy@blimp.ai for assistance.
It is a concise document containing essential information about the processing of data. It is possible to issue a simplified notice while keeping a cross-reference to the full notice on the site.
It is a concise document containing essential information about the processing of data. It is possible to issue a simplified notice while keeping a cross-reference to the full notice on the site.
No. It is however advisable, but not obligatory, to inform employees of the presence of this technology and to provide clarification, if requested, on how it works.
Head-Counters adopt high-level and stringent IT security measures: these include automatic deletion of images without storage, strict criteria for the choice of access passwords, encryption of information, blanking of images during maintenance activities and many others.
Yes, but only to perform maintenance operations, in a very limited manner and if authorised. All access, protected by credentials, is tracked by means of a logbook.
Yes, every operation performed on Head-Counter devices generates a log file that tracks the activities.
The device has an armoured casing to prevent disassembly and tampering. In addition, the device is equipped with warranty seals to verify any tampering attempts.
Blimp.ai is the Data Controller, while the Customer (the business implementing Blimp.ai’s technology) is the Data Controller.
The Data Controller is the “natural or legal person, public authority, service or other body which alone or jointly with others determines the purposes and means of the processing of personal data” (See Art. 4(7) GDPR). Personal Data means “any information relating to an identified or identifiable natural person (“data subject”) […]” (See Art. 4(1) GDPR).
The Data Controller is the natural or legal person, public authority, service or any other body that processes personal data on behalf of the data controller.
A DPIA (Data Protection Impact Assessment), also known as a Data Protection Impact Assessment, is a document required by Article 35 of the European General Data Protection Regulation (Reg. EU 679/2016, also known as ‘GDPR’) in certain cases. It aims to map all processing of personal data that may ‘pose a high risk’ to the rights and freedoms of natural persons, citizens of the European Union.
The DPIA must be prepared by the Data Controller.
Blimp.ai will be able to see the photographs collected by Head-Counters but not the personal data because the photographs arrive already blurred on the face, making identification impossible. The Data Controller must contractually appoint Blimp S.r.l. as Data Processor. The Data Processor is the natural or legal person, public authority, service or other body that processes personal data on behalf of the Data Controller (see Art. 4 (8) GDPR). This is the reason for the presence of “Annex B – Appointment of the Data Processor” in the Terms of Service.
No. ☺
If you have time, let us explain a little more.
EU Reg. 679/2016 (so-called “GDPR”) defines a list of cases within which the “rights and freedoms” of natural persons could be jeopardised. What the legislation requires is that, where there is even the slightest suspicion of a threat to EU citizens, that the Technology Controller ‘investigate’ what risks might occur and implement solutions to mitigate them. These activities should be done in a process called Data Protection Impact Assessment (‘DPIA’).
According to Article 35(3) of the GDPR, there are in particular three cases in which a DPIA should be carried out, namely when:
“a systematic and comprehensive assessment of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based which produce legal effects concerning those natural persons or significantly affect them in a similar way’ (Art. 35(3)(a));
the processing, on a large scale, of special categories of personal data referred to in Article 9(1) or data relating to criminal convictions and offences referred to in Article 10; or (Art. 35(3)(b));
systematic large-scale surveillance of a publicly accessible area. (art. 35(3)(c)).
As Blimp, although we do not operate as a Data Controller, we have conducted and reviewed our DPIA on a regular basis, paying particular attention to all risks and threats to the rights and freedoms of EU citizens.
We also make our DPIA available to clients, the result of months of work and analysis to identify every smallest element of our services and technology.
The reaction of a DPIA, for Blimp.ai’s services, is highly recommended. As a Data Controller it is your responsibility to do the writing and each DPIA must be designed and modelled according to the specific implementation case.
As your provider we can give you some instructions via a DPIA template that you can complete individually.
If you need further information, please do not hesitate to contact us at privacy@blimp.ai
No, this is not necessary. All risks have been mapped and there is no need for a prior consultation. To receive information about our DPIA, please do not hesitate to contact us at privacy@blimp.ai.
Yes. Our DPO can be contacted at privacy@blimp.ai.
