1. Information about how your personal data is processed

This privacy notice’s goal is to inform you of how Prime Batteries Technology (also known as “Prime Battery” or “we”) and the related PRIME companies handle the personal information of people who visit or work at our offices, factories, and other locations. Your privacy is respected, and the Personal Data we handle about you is adequately protected. All Personal Data processing is done in compliance with the Camera Surveillance Act and the GDPR. The procedures we use to obtain, handle and distribute your personal data are detailed below.

2. What private information will be handled?

When you are in a location where Prime Batteries Technology has security cameras, such as one of our offices, factories, or sites, we may collect and handle your personal data there. Entry points and other strategically important areas typically have cameras there. You will be aware of this before entering the area by using obvious and strategically placed signage. Your “Personal Data” is continuously captured by the cameras, which do not record sound. We don’t use any image-enhancing, face-recognition, or related technology.

3. Why is your personal data being processed?

Your personal data is processed for the following reasons:

  • Keep Prime Battery Technology’s (and its affiliates) employees and visitors in a secure environment by, for example, preventing mishaps and incidents and reducing threats and other dangers at our offices, factories, or sites;
  • Prevent theft, sabotage, espionage, and other illegal acts from occurring to Prime Battery Technology’s (and its affiliates) property;
  • Support and provide recorded information to the judiciary, police, firefighters, or other national civil protection services in connection with formal criminal investigations now underway, accidents, events, or other crises involving Prime Battery Technology or its workers or visitors.

In addition to the primary goals of our video surveillance, a few cameras put in Prime Battery Technology’s sites’ production areas will be utilized to monitor production, improve process efficiency, and operate the connected factory from a control room.

4. What is the legal basis for processing your personal data?

Processing your Personal Data is necessary for a legitimate interest pursued by Prime Batteries Technology. This means that we have carried out a balance of interest test where we have assessed that our interest in processing your Personal Data for each of the purposes described in Section 3 above outweigh the privacy intrusion that you as an employee or visitor may be reasonably exposed to, taking into consideration that (i) you are informed of our processing of your Personal Data before you enter the camera surveillance area, (ii) the processing activities is typically and reasonably expected of you as a visitor and employee, (iii) the processing of Personal Data is limited in terms of technology (no recording of sound and no image enhancing or analysing technology, such as face recognition or super-resolution upscaling, is used), (iv) access to recorded material is strictly limited to a small group of trained handlers within Prime Batteries Technology, tasked to manage surveillance and counter misuse, with strictly limited options to disclose recorded materials, and (v) the retention times of recorded materials are appropriately limited in time, considering the purposes for which they are processed.

5. Who has access to your personal data?

We have implemented appropriate technical and organizational measures to protect your Personal Data against loss or unlawful access etc. The persons with access to your Personal Data are strictly limited to a small group of approved handlers within Prime Batteries Technology. These individuals are assigned to manage surveillance to counter any misuse and have been specifically trained for this purpose. Hence, each person on this team is empowered to follow protocol and Prime Battery Technology’s internal policies firmly. Only such individuals, which strictly need to process your Personal Data following the purposes above, will have access to your Personal Data.

We will only share your Personal Data with suppliers that carry out services on our behalf, such as legal advisors engaged from time to time. Furthermore, we may share your Personal Data in an ongoing formal police investigation relating to Prime Batteries Technology or its employees or visitors. We may also share your Personal Data with civil protection services, such as firefighters or other governmental bodies if requested concerning an emergency, accident or incident.

Your Personal Data will never be transferred to a country outside of the EU/EEA.

6. For how long is your personal data stored?

Your Personal Data will be stored on local dedicated servers (i.e. on-site and separately from other servers) only for as long as necessary for the purposes in Section 3 above for which the Personal Data is processed.

Your Personal Data is deleted:

  • after three (3) days, although processing will typically involve live feed only for the purpose of operating the connected factory from a control room, optimizing process efficiency and monitoring the production process;
  • after seven (7) days when processed to maintain a safe indoor work and visitor’s environment;
  • after thirty (30) days when processed to protect Prime Battery’s assets outdoors (the perimeter protection areas) or indoors as deemed necessary, e.g. at fully automated sections of a factory and high-value or high-security areas; and
  • when legal proceedings and ongoing investigations of criminal activities, emergencies, accidents or incidents (as applicable) have ended or been concluded, or when the recordings are no longer necessary for this purpose.

7. What are your rights?

You are entitled to know what Personal Data we are processing regarding you, and you can request a copy of such data. Note that we may be unable to fully comply with your request if your request will adversely affect the interests, rights and freedoms of other data subjects in such recordings. To the extent applicable to camera surveillance, you are entitled to have incorrect Personal Data regarding you corrected. In some cases, you may request that we delete your Personal Data (if it is no longer necessary for the purpose it was collected). You also have a right to object to specific processing of your Personal Data and request that the processing of your Personal Data is limited.

If you have questions regarding how we process Personal Data concerning you, you are most welcome to contact us at [email protected].

If you have any objections or complaints about how we process your Personal Data, you have the right to complain to The National Supervisory Authority For Personal Data Processing.


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