document

Legal status of the embed.cam service and applicable regulation

version 1.0 from 09.10.2026 enru permalink to this version

Reference translation. The binding text is the Russian version at /legal/status; in case of any discrepancy the Russian text prevails.

1. Why this document exists

embed.cam works with video, which puts it in contact with several regulated areas at once: telecommunications, information technology, personal data and intellectual property. Corporate customers, their lawyers and rightsholders regularly ask us the same questions — on what basis does the service operate without a licence, and which registers is it entered in?

This document answers those questions once and publicly: what the service actually does, which legal regimes apply to it and which do not, with citations to the specific provisions. We think a position stated openly and with references is more honest than silence.

This document is informational. It is not an offer and does not modify the User Agreement; in case of any discrepancy the Agreement prevails.

2. What the service actually does

embed.cam is software provided as remote access. The user connects their own video source (an IP camera, a recorder or a server), the service pulls the signal from it once, converts it into formats a browser understands, and shows it to the viewers the user has chosen.

Properties that matter for legal classification:

  • The signal belongs to the user. The operator does not choose what the camera films, where it points, or who may watch. The user makes all of those decisions.
  • There is no recording. Video is delivered in real time and is not stored. The exceptions — one still preview image per camera, and a temporary cache for the duration of a session when casting to TV devices — are disclosed in cl. 8.4 of the User Agreement and in section 4.3 of the Privacy Policy.
  • There is no messaging between users. The service has no chats, comments, private messages, forums, public profiles or user correspondence of any kind.
  • There is no face recognition. The service applies no biometric identification technology.
  • There is no advertising. The service shows no ads and is not monetised by them.

3. Infrastructure

The operator does not own communications networks or server hardware. The Service runs on the cloud platform of a Russian provider — TIMEWEB.CLOUD LLC (ООО «ТАЙМВЭБ.КЛАУД», INN 7810945525), which the operator uses under its public offer (section 6 of the Privacy Policy). The duties imposed on hosting providers by Art. 10.2-1 of Federal Law No. 149-FZ fall on that provider, not on the operator.

The service's servers and the databases holding personal data are located in the Russian Federation (Art. 18(5) of Federal Law No. 152-FZ of 27.07.2006).

Data travels between the user's equipment, the service and the viewer's device over third-party networks operated by licensed telecommunications operators, whose services the parties obtain independently and at their own expense.

The rightsholder of the software is a Russian person; the software was developed in-house.

4. The operator is not a telecommunications operator and provides no telecommunications services

Provisions. Under Art. 29 of Federal Law No. 126-FZ of 07.07.2003 "On Communications", a licence is required for the paid provision of telecommunications services. Under Art. 2(12) of the same law, a telecommunications operator is a person providing telecommunications services under a licence. Under Art. 2(24), a communications network is a technological system comprising communications facilities and lines. The list of telecommunications service names is established by Government Decree No. 1875 of 25.11.2025.

Why this does not apply to us. The operator has no communications network: it owns no communications facilities or lines, and its computing capacity is rented (section 3). The operator enters into no telecommunications service contracts, has no subscribers and allocates no subscriber numbers. The subject matter of the contract with the user is the grant of a right to use software (section 10), not the receipt and transmission of telecommunications messages. During the period announced as free, the service is provided free of charge, whereas it is the paid provision of telecommunications services that is subject to licensing.

Conclusion. No telecommunications licence — including a telematics services licence — is required for the service, and the operator holds none.

5. The activity is not a licensed activity

The list of activities requiring a licence is set out in Art. 12 of Federal Law No. 99-FZ of 04.05.2011 and is exhaustive. Software development and the grant of rights to use software are not in it.

A separate note on private security activity, since video surveillance is associated with it. Under Art. 3 of Law of the Russian Federation No. 2487-1 of 11.03.1992, a security service means guarding premises, including the design, installation and maintenance of technical security equipment and/or responding to its alarm signals. The service guards nothing, designs and installs no security equipment, generates no alarm events and takes no response measures; the operator runs no monitoring station.

The service is not a security system, a burglar alarm, a means of preserving evidence or a safety system, and must not be used as the sole means of protecting property, life or health (cl. 10.2 of the User Agreement).

6. The operator is not a hosting provider

Provisions. Under Art. 2(18) of Federal Law No. 149-FZ of 27.07.2006, a hosting provider is a person engaged in providing computing capacity for hosting information in an information system permanently connected to the internet. The duties of a hosting provider, including notifying Roskomnadzor and entry in the register, are set out in Art. 10.2-1 of the same law.

Why this does not apply to us. The operator does not provide computing capacity — it consumes it, being itself a customer of a cloud platform provider (section 3). Users are not given a virtual or dedicated server, file storage, space to host a website, or the ability to publish arbitrary information. Users are granted the right to use software for its intended function: to connect their own source and display its signal.

Conclusion. The duties under Art. 10.2-1 of Federal Law No. 149-FZ do not apply; no hosting provider notification is filed.

7. The operator is not an organiser of information dissemination

Provision. Under Art. 10.1 of Federal Law No. 149-FZ, an organiser of information dissemination is a person ensuring the operation of information systems and/or programs that are intended for and/or used for the receipt, transmission, delivery and/or processing of electronic messages of users of the internet.

Why this does not apply to us. The service is intended to display the video signal of the user's own equipment, and is not intended to deliver messages between persons. The service has no functionality for exchanging messages between users whatsoever: no chats, comments, private messages, forums, public profiles or user correspondence. Email is sent only by the operator to the user and is transactional: address confirmation, account recovery, contractual notices.

In addition, the service does not record video, so it lacks the technical capacity to store message content or produce it on request.

Conclusion. The characteristics of an organiser of information dissemination are absent; no notification is filed and the operator is not entered in the corresponding register.

8. The service is not an audiovisual service, a social network, a news aggregator or a search engine

Provisions, and why they do not apply:

  • Audiovisual service (Art. 10.5 of Federal Law No. 149-FZ) — three conditions must be met simultaneously: access is paid or conditional on viewing advertising; users are in the Russian Federation; more than one hundred thousand users per day. The service shows no advertising, does not compile or curate a body of audiovisual works, and does not reach that threshold. The article also does not apply to resources where material is posted predominantly by users.
  • Social network (Art. 10.6) — dissemination of information via users' personal pages, with more than five hundred thousand users per day. The service has no personal pages, feed or subscriptions.
  • News aggregator (Art. 10.4) and search engine (Art. 10.3) — the service disseminates no news material and performs no search of the network.
  • Recommendation technologies (Art. 10.2-2) — not used.

9. The operator is not a broadcaster and is not registered as mass media

Under Art. 31 of Law of the Russian Federation No. 2124-1 of 27.12.1991 "On Mass Media", television and radio broadcasting are carried out under a broadcasting licence. Disseminating information via a website is not broadcasting, because broadcasting facilities are not used.

The operator neither produces nor edits content, forms no TV or radio channel, and has no schedule or editorial office.

Mass-media status is settled by the statute directly. Under Art. 8 of the same Law, a website may be registered as an online publication — registration is therefore a right, not an obligation — and further: "A website on the internet that is not registered as a mass medium is not a mass medium." The embed.cam website is not registered as a mass medium and is not one.

10. The subject matter of the contract is a right to use software

The User Agreement is a public offer (Art. 437(2) of the Civil Code of the Russian Federation) to grant a simple (non-exclusive) licence to use the embed.cam software for its intended function (Arts. 1235, 1286 of the Civil Code).

Such a contract is concluded by a simplified procedure and is a contract of adhesion (Art. 1286(5), Art. 428 of the Civil Code): consent is given by accepting the terms at registration and beginning to use the software. During the period announced as free, the contract is gratuitous.

This classification is not a formality. The legislator expressly treats the grant of rights to computer programs by way of remote access over the internet as a transfer of software rights (Art. 149(2)(26) of the Tax Code of the Russian Federation), rather than as the provision of telecommunications or hosting services.

11. Liability for content: the operator is an information intermediary

As regards the content of streams, the operator is an information intermediary within the meaning of Art. 1253.1 of the Civil Code. The conditions under which an information intermediary bears no liability are met:

  • The operator does not initiate the transmission and does not determine the recipient. The user connects and switches on the camera; the user creates, distributes and revokes the viewing link.
  • The operator does not modify the material, except for modifications made solely to enable the technological process of transmission — format conversion and bitrate adaptation. Such modifications are expressly permitted by the provision.
  • The operator neither knows nor ought to know that use of protected subject matter is unlawful: video streams are not pre-screened (moderated), and an information intermediary is under no duty to carry out blanket preventive inspection of traffic.
  • The operator takes timely measures upon a rightsholder's statement under Art. 15.7 of Federal Law No. 149-FZ. How to submit a statement, what it must contain and the response time — 24 hours — are set out in section 5 of the Acceptable Use Policy.

Responsibility for the lawfulness of filming, for third parties' rights in their own images (Art. 152.1 of the Civil Code) and privacy (Art. 152.2 of the Civil Code, Art. 137 of the Criminal Code), and for compliance with personal-data law in respect of people appearing on camera, rests with the user (section 5 of the User Agreement).

12. Personal data: no biometric processing

Under Art. 11(1) of Federal Law No. 152-FZ, biometric personal data means information characterising a person's physiological and biological features, on the basis of which their identity can be established, and which is used by the operator to establish the identity of the data subject.

The service applies no face recognition, builds no biometric templates, compares images against no database, and does not establish the identity of people appearing on camera. Accordingly, the requirements of Art. 11 of Federal Law No. 152-FZ and of the legislation on the unified biometric system do not apply to the processing of video in the service.

Using the service to identify individuals is prohibited by the Acceptable Use Policy.

A full description of personal-data processing, including how roles are divided between the operator and the user, is in the Privacy Policy.

13. Website owner details

Published in accordance with Art. 10(2) of Federal Law No. 149-FZ and Art. 9 of Law of the Russian Federation No. 2300-1 of 07.02.1992 "On Protection of Consumer Rights".

Individual entrepreneur Andrei Androsov (Андросов Андрей Евгеньевич) OGRNIP: 314392609200172 INN: 392201476857 Address for correspondence: 236016, Калининградская обл., г. Калининград, ул. Клиническая, д. 19А, кв. 119

Email address for statements under Art. 15.7 of Federal Law No. 149-FZ and for any other enquiries: support@embed.cam

14. Changes to this document

This document may change when legislation, enforcement practice or the functionality of the service changes. The current version is published at the address given in the header; earlier versions remain available at their permanent links.