Information regarding Veo’s data protection role
When a customer of Veo Technologies ApS (“Veo”) uses the Veo camera and Veo Platforms as well as the related features and services, the customer will be collecting and processing and potentially sharing personal data in form of video recordings of different sporting events and contact information on users related to the customer.
Whenever personal data is processed, certain data protection legislation applies. In the European Economic Area, this legislation is primarily the EU General DataProtection Regulation, also known as the GDPR. According to the GDPR, it is important to identify who acts as so-called data controller and who acts as data processor in relation to any data processing activity to determine which obligations the concerned parties have.
With regards to the customers use of the Veo camera and the Veo Platforms as well as the various related features and services (which include recording, live-streaming on the Veo Platforms or external sites and platforms (including sharing of personal data by the use of the Veo Partner Program), on-demand accessibility, League-Exchange,Player Profile, analysis and editing of recordings, including the snipping tool) the customer will act as the data controller and Veo will act as data processor. This means that Veo in its role as data processor will refer any questions, comments or enquiries from the data subjects or any other third party (e.g. data recipients receiving personal data via the Veo Partner Program) in relation to these data processing activities to the relevant customer.
A customer who is a natural person– as opposed to legal entities such as sports clubs, organizations, associations, companies, or authorities – may be exempt from GDPR obligations when processing personal data in the course of purely personal or household activities. This is also known as the “household exemption”. The precise scope of this exemption to the applicability of GDPR is narrow and not entirely clear. Activities such as video recording of multiple persons in a public space, streaming to external websites, or disclosure personal data to a larger public group may not qualify for this exemption, even if it is done by a natural person. In situations where a customer may validly invoke this exemption Veo will still act as a data processor and comply with all data processor obligations outlined in the GDPR and in Veo’s data processing agreement. Veo strongly recommend and encourages all customers to comply with the obligations of data controllers under GDPR.
Some services, such as the Veo Partner Program, offer collaboration with and sharing of Content including personal data with third parties. In relation to any customers’ use of any such features and services, Veo still acts as data processor and solely shares or processes the personal data in any other way upon specific instruction from the customers.
Determining the role(s) of the third parties receiving personal data shared by the customers via the Veo Platforms depends on the specific circumstances. Veo, however, has no say and takes no part in such assessments. Therefore, the customers and the relevant third parties are individually responsible for compliance with any applicable data protection legislation, including the GDPR, in this regard.
More information on how to determine the roles and responsibilities in relation to processing of personal data can be found in guidance available on the website of the Danish Data Protection Agency, Datatilsynet (datatilsynet.dk), as well as guidelines available on the website of European Data Protection Board, EDPB (https://edpb.europa.eu/our-work-tools/general-guidance/guidelines-recommendations-best-practices_en). Further, more country-specific legal and regulatory guidance can be found on other local data protection agencies. In general, we recommend all our customers to seek such guidance and if necessary professional legal advice to ensure compliance with the applicable data protection legislation.
Veo does also to some extent process personal data for its own purposes and will in this regard act as data controller. These purposes include Veo’s development optimization of products and features, creation and administration of user profiles on the Veo Platforms, and Veo’s use of personal data for its own marketing purposes. For more information on Veo’s processing of personal data in relation to these data processing activities, please visit Veo’s privacy policy, which is available at veo.co.
For more information on data protection and the GDPR in relation to Veo, please visit veo.co.
Some customers use of the Veo camera and Veo Platforms are governed by general terms and conditions concluded with Veo Technologies Inc. or Veo Technologies Australia Pty Ltd. No processing of personal data is, however, performed by any of these other Veo group companies, but all data processing activities are performed by Veo Technologies ApS who is considered primarily data processor and to some extent data controller. Thus, no other Veo group companies than the Veo Technologies ApS undertake any role or responsibility in relation to the data processing activities. For that reason, any questions, comments or enquiries concerning Veo’s processing of personal data as data controller will be handled by Veo Technologies ApS.
The relationship between the customer and Veo in connection with the processing of personal data is governed by a data processing agreement, which is accessible at veo.co.