Privacy Policy
Last updated: 29 October 20261. Who We Are (Data Controller)
DSJ Holdings MB ("CONCAM", "we", "us", "our") is the data controller responsible for your personal data processed through the CONCAM platform.
- Company: DSJ Holdings MB
- Registration No.: 306983891
- Address: Spaudos g. 9, LT-05132 Vilnius, Lithuania
- Email: info@concam.lt
2. Scope and Applicable Law
This Privacy Policy covers all personal data we process in connection with the CONCAM construction site monitoring platform (the "Service"). We process personal data in accordance with:
- EU General Data Protection Regulation (GDPR) — Regulation 2016/679
- Republic of Lithuania Law on Legal Protection of Personal Data
- Norwegian Personal Data Act (Personopplysningsloven), implementing the GDPR via the EEA Agreement
- Swedish Data Protection Act (Dataskyddslagen 2018:218)
- The national data protection laws of other EU/EEA countries where our clients are based
3. What Data We Hold and Why
3.1 Account Data
When you create an account or are invited to the platform, we hold your name, email address and the organisation you belong to. Sign-in is handled by our identity provider (see Section 6), which also keeps the technical records needed to run your sessions.
3.2 Client Contact Data
For each construction project we record the client representative's name, email address, phone number, company and the project location. We use these details only to administer the contract and to contact the client about the service.
3.3 Site Imagery and Blurring
The platform holds (a) photographs taken at set intervals by fixed cameras installed on site, (b) drone photographs uploaded by the client and (c) 360° images uploaded for site walks. Any of these may incidentally show workers, visitors or other people on site. The site operator is responsible for on-site notices and for informing the people concerned as required by national law. All imagery is stored on EU infrastructure and is encrypted at rest with keys held only by us.
People and selected areas in camera photographs can be blurred automatically before anyone sees them. Blurring can be switched on for a whole site, for selected cameras and periods, or for a single photograph. It is carried out by our own servers; no third party is involved and no face recognition or identification of any kind takes place. It applies to photographs from cameras we operate; photographs from a third-party webcam linked to a project are shown as they are received. Where blurring is on for a camera, a new photograph is shown only once its blurred version exists, which may delay it by a few minutes. The unedited original is kept, with access restricted to our administrators, for the period set for the project — which can be as short as immediately after the blurred version exists — and is then deleted for good; from that point only the blurred version exists in the live system, and the original leaves all backup copies within the period in Section 5. Automatic blurring may miss a person; signed-in users can report this from the photograph itself (Section 3.4).
3.4 Blur Reports
When a signed-in user reports a person the automatic blur missed, we record who made the report, the photograph concerned, the areas marked, any note typed with it and the time. The report is applied automatically within minutes and may be reviewed by our staff. The previous blurred version of the photograph is kept for a short time so that a mistaken report can be undone (see Section 5).
3.5 Device Identifiers
We hold technical identifiers for the cameras and routers connected to the platform, such as network addresses, device names and a site label, together with their status and connectivity data. These describe hardware, not people.
3.6 Security and Activity Records
To keep the platform and the imagery secure, and to be able to show who accessed what, we record sign-ins, downloads of photographs and archives, visits to shared links (including failed password attempts) and administrative changes made by administrators, for example to projects, devices, organisations or user roles. Each record holds the account concerned where the person was signed in, the time, the IP address, the browser type and an approximate location at city or country level, which we estimate ourselves from the IP address and do not share with anyone. Our web servers also keep standard traffic logs. None of this is used for marketing or profiling. Retention periods are in Section 5.
3.7 Shared Links
For each shared link an administrator creates we keep its identifier, when it was last opened and how many times it has been opened. Anyone holding the link can view the photographs chosen for it; visits are logged as described in Section 3.6.
3.8 Issue Reports
When you report a problem from within the platform, we record the category, your description, the page you were on, basic browser details, your IP address and the time, and your account if you are signed in. We use this only to resolve the problem.
3.9 Consent and Acceptance Records
When you accept our Terms of Service and this Privacy Policy, or make a cookie choice, we record what you accepted or chose, the version concerned, the time, your IP address and browser type, and your account where you are signed in. We also archive the exact text of each policy version in each language, so that we can show what you accepted (GDPR Art. 7(1)).
3.10 Contract Acceptance Records
When an administrator of your organisation accepts or declines a contract we have issued through the platform, we record the decision and any comment, the signer's name and position, their confirmation that they may act for the organisation, their account, the exact document and policy versions concerned, the time, and technical details of the signing session (IP address, browser, session). Where we require it, or the signer chooses to provide it, we also keep a document showing the signer's authority — for example a power of attorney or a company register extract — visible only to administrators of your organisation and to us.
3.11 Cookies
We use strictly necessary cookies for sign-in and session management. See our Cookie Policy for details.
3.12 Advertising Measurement and Website Statistics
On our public website only, and only if you accept marketing cookies in the cookie banner, Google Ads receives a click identifier, the page visited, basic browser details and conversion events so that we can measure our advertising. Without your consent no advertising cookies are set and only aggregated conversion counts are sent. No advertising tag runs in the customer portal. Separately, we measure how the public website is used with a cookieless statistics tool on our own EU server: it records the page viewed, the referring site, the browser and device type, the language and the country, stores no IP address and no personal data, and is never loaded in the customer portal or on shared links. It needs no consent.
3.13 Business Contacts We Approach
When we offer our services to construction companies and public bodies, we may contact a named employee by email in their professional role. For this we hold the person's name, job title, work email address and employer, and the construction project they are listed for. These details come from commercial industry databases of construction projects, from public sources such as company websites and tender notices, or from the person themselves. We use them only to contact the person about our services. Everyone we write to can object at any time by replying to the email or writing to info@concam.lt; we then stop contacting them and keep only their address on a list that prevents further emails. On request we tell you which source your details came from.
4. Legal Basis for Processing
| Processing Activity | Legal Basis (GDPR Art. 6) |
|---|---|
| Account management and sign-in | Art. 6(1)(b) — performance of a contract |
| Delivering the platform to clients, including client contact data | Art. 6(1)(b) — performance of a contract |
| Site imagery (construction documentation) | Art. 6(1)(b) or 6(1)(f) — contract, or the legitimate interests of the site operator |
| Blurring of people and areas, and blur reports | Art. 6(1)(f) — legitimate interests (data minimisation under Art. 5(1)(c) and the protection of people photographed) |
| Security and activity records, issue reports | Art. 6(1)(f) — legitimate interests (network and information security, abuse prevention, accountability of access, resolving defects; Recital 49) |
| Consent and acceptance records | Art. 6(1)(c) — legal obligation (demonstrable consent, Art. 7(1)) and Art. 6(1)(f) — legitimate interests |
| Contract acceptance records | Art. 6(1)(b) — performance of a contract, and Art. 6(1)(f) — legitimate interests (evidence of the agreements we rely on) |
| Advertising measurement | Art. 6(1)(a) — your consent |
| Accounting and other legal obligations | Art. 6(1)(c) — legal obligation |
| Contacting business representatives about our services | Art. 6(1)(f) — legitimate interests (offering our services to companies and public bodies); you can object at any time |
5. Retention Periods
- Account data: for the duration of the account, then deleted within 30 days of termination unless the law requires longer.
- Site photography: for the duration of the client contract and 30 days after it ends, unless the client asks for earlier deletion. Where blurring is on, the unedited original of a blurred photograph is kept only for the period set for the project — from zero days upwards — and is then deleted for good; the blurred version is kept for the site-photography period.
- Blur reports: 12 months. The previous blurred version of a corrected photograph is kept for up to 180 days, and never beyond the deletion of that photograph's original.
- Security and activity records: sign-in, download and administrative records for 12 months; shared-link visit records for 90 days; web-server traffic logs for at most 14 days. Records may be kept longer only where necessary to investigate a specific security incident or legal claim.
- Device status and connectivity data: up to 90 days.
- Issue reports: 12 months.
- Project invitations: an invitation sent to an email address without an account is kept until accepted, or 30 days.
- Cookie choice: kept in your browser until you clear it; the record of your choice on our side for 13 months.
- Advertising measurement data: kept by Google according to its own policies — typically 90 days for click identifiers and up to 13 months for advertising identifiers. You can withdraw consent at any time.
- Business contacts we approach: 12 months after our last contact, unless a business relationship begins; an objection is kept for as long as needed to honour it.
- Acceptance of the Terms and this Policy: for the life of your account and up to 10 years after its deletion, where needed to establish, exercise or defend legal claims (GDPR Art. 17(3)(e)); superseded acceptances for 3 years.
- Contract acceptance records, including any authority document: for the life of your organisation's account and up to 10 years after its deletion, where needed to establish, exercise or defend legal claims (GDPR Art. 17(3)(e)).
- Backups: encrypted backups are kept on a separate EU system; content deleted from the live system leaves all backup copies within 45 days.
6. Third-Party Processors
| Processor | Purpose | Location | Safeguard |
|---|---|---|---|
| Clerk Inc. | Sign-in and account management | United States | EU-US Data Privacy Framework; Standard Contractual Clauses; data processing agreement |
| Hetzner Online GmbH | Hosting and storage | Germany (EU) | EU jurisdiction; data processing agreement |
| Google Ireland Limited / Google LLC | Advertising measurement on our public website, with your consent | Ireland (EU) / United States | EU jurisdiction / EU-US Data Privacy Framework and Standard Contractual Clauses; Google Ads data processing terms |
| Teltonika Networks UAB | Connectivity management of the on-site routers | Lithuania (EU) | EU jurisdiction; data processing agreement |
| Hostinger International Ltd. | Email and domain services | EU | EU jurisdiction; data processing agreement |
| UAB „Rivilė“ | Accounting and invoicing (billing contact details of client organisations) | Lithuania (EU) | EU jurisdiction |
Our processors use sub-processors of their own. Our identity provider, for example, uses US-based services for bot protection, email delivery, user-record search and event delivery. Each processor publishes its current list, and we provide it on request at info@concam.lt.
We do not sell, rent or share your personal data with any other third party for marketing purposes.
7. International Data Transfers
Account and sign-in data is processed by our identity provider in the United States under the EU-US Data Privacy Framework, with the European Commission's Standard Contractual Clauses as a fallback (GDPR Art. 46). Site imagery and all other personal data stay on EU infrastructure.
8. Your Rights
Under the GDPR and applicable national laws, you have the following rights:
- Right of access (Art. 15): Request a copy of the personal data we hold about you.
- Right to rectification (Art. 16): Request correction of inaccurate data.
- Right to erasure (Art. 17): Request deletion of your data where there is no legitimate basis for continued processing.
- Right to restriction (Art. 18): Request that we limit how we use your data.
- Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
- Right to object (Art. 21): Object to processing based on legitimate interests.
- Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
Security and accountability records may be kept where the law allows it (GDPR Art. 17(3)); on request we pseudonymise such records instead of deleting them.
To exercise any of these rights, including data access requests, data export, or account deletion, contact us at info@concam.lt. All requests are handled manually by our team and we will respond within 30 days in accordance with GDPR Article 12.
9. Right to Lodge a Complaint
If you believe your personal data is being processed in breach of applicable law, you have the right to lodge a complaint with the supervisory authority in your country of residence. Our primary supervisory authority is:
State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija — VDAI)
https://vdai.lrv.ltResidents of other EEA/EU countries may also lodge complaints with their local supervisory authority (e.g., IMY in Sweden, Datatilsynet in Norway/Denmark, Tietosuojavaltuutettu in Finland, Datu valsts inspekcija in Latvia, AKI in Estonia, UODO in Poland).
10. Security
We protect personal data with encryption in transit and at rest, authenticated and role-based access, secured camera connections and hardened, monitored infrastructure. Access to a project's imagery is decided by the client's own administrators, who choose which people may view it; sign-ins, downloads and visits to shared links are recorded as described in Section 3.6.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of it, in accordance with GDPR Article 33. Where the breach is likely to result in a high risk to your rights, we will also notify you directly without undue delay, as required by Article 34.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated to registered users by email or via a notice in the client portal at least 30 days before they take effect. The "Last updated" date at the top of this page reflects the most recent revision.
12. Contact
For any privacy-related queries, please contact our data protection contact at: info@concam.lt