Cyclomedia and privacy

Cyclomedia's Privacy Policy

In this privacy policy, Cyclomedia Technology B.V. (hereinafter ‘Cyclomedia’) explains how it deals with the privacy of your personal data, i.e. the data that you provide us with or the data that we possibly record by taking photographs from public roads. Do you wish to know how we deal with the personal data that you provide us with, for instance, through our website? Please click here for more information. For specific information about the use of cookies on our website, please see our Cookie policy.

Processing of personal data you provide us with

We respect the privacy of visitors to our website, or persons who contact us in other ways, for instance through e-mail. We see to it that the personal data you provide us with is treated confidentially and in accordance with the requirements set by the General Data Protection Regulation (‘GDPR’).

Purpose of the data processing

Your personal data are processed by us for the purpose of concluding and performing agreements in respect of Cyclomedia's services, and for managing the resulting contacts, which includes activities aimed at expanding our customer database. If you complete a form on our website, or send us an e-mail, the data that you provide us with will be kept as long as is necessary in view of the nature of your request. These data are not provided to third parties, unless it is essential for the performance of the agreement or if we are obliged to do so by law.

In addition, general visiting details are recorded on our website. In this context, in particular your computer's IP address, any username, the time of the request and the data that your browser sends, can be recorded and used for statistical analyses of visiting and clicking behavior on the website. We use this to optimize the functioning of the website, for instance. We try to anonymize these data as much as possible and do not provide them to third parties. Please refer to our Cookie policy to learn how we deal with cookies in this context.

Storage and security

Cyclomedia stores the personal data that we receive from you no longer than necessary in relation to the purposes of data processing. As long as these data are stored by us, we make sure that these data are only accessible to those who need these data in executing the purposes of the data processing. Furthermore, we have multiple measures in place to prevent access to the data by unauthorized persons.

Your rights

If we process your personal data, you can request access, rectification, erasure, , restriction of processing and portability of this data. In addition, you can raise objections to the use of your personal data. You can do this in writing: by e-mail to [email protected], through the contact page on our website, or by post to the following address:

Cyclomedia Technology B.V.
Van Voordenpark 1b
5300 CE ZALTBOMMEL, the Netherlands

If you request access, we may ask you to prove your identity, in order to prevent abuse. Should the personal data processed by us contain errors, you can request us to change or remove these data. In addition, you can inform us in writing if you do not appreciate being approached by us with information about our products and services.

You have the right to lodge a complaint with the Dutch Data Protection Authority.

Privacy statement for job applicants

In this privacy statement, Cyclomedia Technology B.V. (hereinafter 'Cyclomedia') describes how the company secures your personal data, that is, the data you provide us with during the recruiting process or data we receive from third parties (recruitment agencies).

We respect the privacy of job applicants. We will ensure that the personal information you provide us with is treated confidentially and in accordance with the requirements in the General Data Protection Regulation. By submitting your application, you give your consent to Cyclomedia to process your personal data and record it in our database. We will treat your personal data confidentially, and will only use it for the job application process with Cyclomedia. We will not transfer your data to third parties, unless we are legally required to do so.

Cyclomedia retains personal data of job applicants during and after the recruitment process. After the recruitment process, the data will be retained for a maximum of one year. After this, the personal data will be erased from Cyclomedia's system. On your request, we will erase your personal data before that time.

By submitting the job application data you agree with this privacy statement.

This privacy statement will be updated regularly to comply with amendments in the privacy law. We therefore reserve the right to amend this privacy statement.

If you have any questions regarding this privacy statement, you can send an e-mail to [email protected]. For all other questions about the selection and recruitment process, we refer to the website.

Processing of personal details in our photography from the public road

Cyclomedia produces Cycloramas (360-degree panoramic photographs) taken from the public road and makes use of public geometric and land-registry data. It is permitted to take photographs from public roads. The street level photographs may also record personal data, on the basis of which Cyclomedia conducts its activities in accordance with the requirements of the General Data Protection Regulation (‘GDPR’). In the street level images collected by Cyclomedia, faces and license plates are made unrecognizable by 'blurring'. The blurred images are stored in a database and are made available to Cyclomedia's customers via a closed online platform.

Purpose of the data processing and lawfulness

Cyclomedia takes photographs from the public road in order to map the environment and has a legitimate interest to process potentially visible personal data in street level photographs pursuant to article 6.1 sub f GDPR. This legitimate interest includes the freedom to conduct a business as included in Article 16 of the Charter of Fundamental Rights of the EU and the resulting interest in being able to best serve its customers, other stakeholders and society as a whole. The data processing purposes consist of recording and processing street level photographs in a database in order to – under stringent conditions- make these photographs available to public and private organizations.

The image material collected by Cyclomedia provides a better understanding of the outdoor space and thus contributes to a social interest in better understanding and absorbing the increasingly complex and rapidly changing environment. In order to arrive at future-proof solutions for current themes in the field of climate change (e.g. the amount of green space in urban areas), mobility (e.g. parking facilities for electric vehicles), livability (e.g. type of buildings and green areas) and safety (e.g. escape routes during incidents or events), a transparent, accurate and complete overview of the outdoor space is necessary. In short, the interests of society as a whole benefit from the data processing carried out by Cyclomedia. A number of examples illustrate the importance of the use of street level photographs by Cyclomedia's customers:

• Municipalities: performance of public duties relating to the outdoor space, where it is necessary for them to have an unambiguous picture of this outdoor space. This enables the municipality to serve its citizens better, among other things by means of more adequate enforcement, improvement in communication with citizens and efficient execution of tasks.
• Control rooms, the police and the fire brigade: virtual investigation of the environment before actually responding to incidents or calamities or before arresting people. This is not only in the interest of the control room, fire brigade and police, but also in the interest of local residents.
• Network managers: digitalization of home connections (such as gas pipelines) to improve safety for residents during the construction and maintenance of these home connections.
• Infrastructure companies: construction and management of telecom networks, such as fibre optic and 5G networks that serve a social interest and that can be better prepared and realized through visual inspection and analysis of the entire outdoor area by means of Cyclomedia images.
• Housing corporations: visual inspection of the outside of buildings in order to obtain a clear indication of the state of maintenance and the liveability of the related buildings, which serves the interests of residents and local residents.

In order to be able to visualize the outdoor space on a large scale, thoroughly and in high quality and to be able to offer this (blurred) image material to customers in a database via a closed platform, it is necessary to process the (personal) data that is visible from the public road. This is necessary in order to be able to generate an overview of the outdoor space in such a way that it is comparable to what a person observes when he or she physically visits the same location.

In addition, the processing of certain data, which may sometimes be regarded as personal data (including houses), is necessary in view of the purpose for which these images are used, such as:

• Municipalities for e.g. purposes of:
• Exercising property related taxes;
• Registration of addresses and buildings;
• issuing and enforcing various permits, such as building permits, entrance permits, felling permits and advertising signs;
• inspection of building plans;
• verification of development plans;
• (re)development of municipal areas.
• Municipalities, provinces, water boards and other source holders for the purposes of digital mapping, such as the Key register Large-scale Topography (in Dutch: Basisregistratie Grootschalige Topografie, BGT) in the Netherlands.
• Land Registry for the management digital maps;
• Police forces for the purpose of observation and preparation of arrests;
• Housing corporations for the construction, conversion, management and maintenance of buildings;
• Network suppliers for the planning, realization, maintenance and repair of home connections;
• Engineering companies for assessing the impact of a project on existing buildings.

The interests of Cyclomedia and third parties, including society as a whole, are weighed by Cyclomedia against the interests and the fundamental rights of data subjects in relation to the protection of personal data. It plays a role in this respect that virtually all data visible on the imagey cannot be regarded at all or only as insensitive (personal) data that is already visible in the outdoor space. As a result, the potential adverse consequences and risks for any data subjects involved are minimal.

In addition, Cyclomedia has put in place various safeguards to prevent and limit any undesirable consequences for data subjects as much as possible. One of these measures concerns 'blurring': because faces and license plates are not relevant to the purpose of the processing, Cyclomedia uses an advanced software tool developed in-house that automatically detects faces and license plates in the images and makes them unrecognizable.

Cyclomedia's images are not publicly available. In addition, customers only gain access to Cyclomedia's visual material after the raw data has been blurred by Cyclomedia's software tool. Further, customers are not granted access to the entire dataset, but only to the relevant geographical areas within the imagery database, which they need for their own purposes.

Cyclomedia is of the opinion that its interests in combination with the interests of its customers in principle outweigh the invasion of the privacy of data subjects, also because Cyclomedia has taken measures to minimize this infringement, as further explained under 'Storage and security'.

Storage and security

The street level photographs produced by Cyclomedia are stored in order for Cyclomedia to fulfil its purposes of processing and its contractual obligations with customers. Storage of the database of street level imagery collected within European countries takes place within the European Economic Area. In the street level photographs that Cyclomedia records, stores and makes available to her customers via a web application, privacy-sensitive information, namely faces of recognizable persons and/or license plates of cars, are being made unrecognizable (‘blurred’). Cyclomedia has also set up various organizational and technical measures to ensure that unauthorized access to the data can be prevented:

• Storage of the raw visual material - before the execution of the blurring - in a non-open proprietary data format;
• Separate processing of image material and other data;
• Storage on strictly secured servers;
• Restriction of access for individual users via username/password;
• Informing employees of their obligations regarding the lawful processing of the image material and the data derived from this material;
• Establishing a reporting process for security incidents (data breaches).

Information and supervision

Depending on the country in which Cyclomedia captures street level imagery, Cyclomedia uses different types of media to inform the public abouts its activities. Cyclomedia also provides information about current and planned collection projects via its own website.

Cyclomedia has appointed an internal supervisor on the processing of personal data, a Data Protection Officer (DPO). The DPO supervises the adoption and compliance with the GDPR and can be contacted via the contact details below.

Your rights

If you are involved in our photographs as a data subject (for instance, because your house has been photographed or because you think you yourself are visible within our photographs), you can request access, rectification, erasure and restriction of processing. In addition, you can raise objections to the use of your personal data. You can do this in writing: by e-mail to [email protected], through the contact page on our website, or by post to the following address:

Cyclomedia Technology B.V.
Van Voordenpark 1b
5300 CE ZALTBOMMEL
The Netherlands

If you have an access request, we may ask you to prove your identity, in order to prevent abuse.

You have the right to lodge a complaint with the Dutch Data Protection Authority.

We reserve the right to modify our privacy policy. Any changes will be published on this website.

Cyclomedia captures data from the public space in several European countries. Click here for an up-to-date overview of the running data capture projects in Europe.

Cyclomedia Technology B.V. has appointed a Data Protection Officer (DPO)to supervise the adoption and compliance with the GDPR. The DPO can be contacted via the contact details on our website.

Do you have any privacy-related question about our photographic activities from public roads? If so, please consult our frequently asked questions about privacy (see below) or send an e-mail to [email protected].

Frequently asked questions about privacy

• It is possible that photographs have been taken on my private grounds, and I do not want these images to be included in your database. What can I do to have these images removed?

We are only allowed to make recordings from the public road. Recordings that were inadvertently made on private grounds will be removed from our database. You can send your request by e-mail to [email protected].

• What can I do when I suspect I am visible in an image and I do not agree to this? 

In photographs that are currently being recorded by Cyclomedia, faces are made unrecognizable (‘blurred’). If you have any further requests, you can send your request by e-mail to [email protected].

• What can I do if I believe an image contains inappropriate content?

When you believe that an image has inappropriate content, you can send an e-mail to [email protected] with additional information.

• Why does Cyclomedia take photographs?

Cyclomedia takes photographs from the public road in order to map the environment and to - under stringent conditions - make these photographs available to our business clients, in particular authorities and companies. These parties use the photographs, for instance, for purposes of inspection, management and assessment of objects (such as houses, traffic signs, lampposts, trees etc.) in public spaces. The images are employed by users as visual support for the implementation of legislation, maintaining public order and security, the development of building plans, the preparation of work in public spaces, and other purposes. 

• What is recorded by Cyclomedia's cameras?

Cyclomedia uses recording vehicles to take photographs from public roads, so what is visible from the public road is recorded in images. These recordings are processed by Cyclomedia and stored in a database. The images gathered are not real-time and Cyclomedia does not make video recordings.

• How often does Cyclomedia take photographs?

Cyclomedia updates its database of images regularly, in the Netherlands once a year. In other countries where Cyclomedia operates, recording frequency may differ.

• Where can I view photographs made by Cyclomedia?

Cyclomedia's images database is not public, but is made available - under stringent conditions - to authorities and corporate customers. However, if you are involved as a data subject, for instance as the owner of a house, you can request for inspection. You can send your request by e-mail to [email protected].

Do you have any questions or remarks? We like to help you!

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