document

embed.cam Personal Data Processing Policy

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

1. General

1.1. This Policy defines how personal data is processed and protected in the embed.cam service (the "Service") and is issued pursuant to Art. 18.1(2) of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" ("Law No. 152-FZ").

1.2. Personal data operator: individual entrepreneur Andrei Androsov (Андросов Андрей Евгеньевич), ОГРНИП 314392609200172, ИНН 392201476857, address 236016, Калининградская обл., г. Калининград, ул. Клиническая, д. 19А, кв. 119, email support@embed.cam.

1.3. Person responsible for organising personal data processing (Art. 22.1 of Law No. 152-FZ): individual entrepreneur Andrei Androsov (Андросов Андрей Евгеньевич), email: support@embed.cam.

1.4. The Policy applies to all personal data the Operator receives from Users of the Service and from visitors to embed.cam.

1.5. Terms are used with the meanings given in Law No. 152-FZ.

2. Two different processing situations — worth understanding

2.1. embed.cam is the operator of account data: the email address, authentication data and service records listed in section 4. The Operator determines the purposes and answers to the data subjects for them.

2.2. The User is the operator of stream content. The video stream, the images of persons appearing in frame, and the names and email addresses of recipients the User adds for restricted-link access are processed by embed.cam on the User's instruction (Art. 6(3) of Law No. 152-FZ) on the terms of section 8 of the User Agreement. The operator of that data — determining its purposes and answering to those data subjects — is the User, who aimed the camera, chose what it films and decided who may watch.

2.3. If you believe a stream in the Service infringes your rights (including your right to your image or to privacy of personal life), write to support@embed.cam. The Operator will consider it under the procedure in the Acceptable Use Policy and may suspend access to the stream concerned.

3. What the Service does not do

These statements are material to the scope of processing:

3.1. The Service does not record, archive or store video. The stream is relayed to Viewers in real time and not saved. Exceptions are disclosed in cl. 4.3.

3.2. The Service does not use facial recognition and does not process biometric personal data. Under Art. 11(1) of Law No. 152-FZ an image of a person is biometric personal data only where it is used by the operator to establish the identity of the subject; the Service establishes no identity, builds no biometric templates and matches images against no database. Using the Service to identify individuals is prohibited to the User by cl. 5.5 of the User Agreement.

3.3. The Service does not keep records of Viewers: it builds no visit logs, creates no Viewer profiles and does not store information about their devices in the database. View statistics are aggregate counters with no per-Viewer data. For technical logs, see cl. 4.3.1.

3.4. No third-party analytics, advertising pixels or third-party counters are used on the site or on viewing pages.

3.5. Personal data is not used for advertising, profiling, solely automated decision-making, or machine-learning training.

3.6. Personal data is not sold and not disclosed to third parties other than as described in sections 6 and 7.

3.7. The Service has no exchange of electronic messages between users: no chats, comments, private messages, forums or public profiles. Email is sent only by the Operator to the User and is transactional. The legal consequences of this are set out in section 7 of the legal status document.

4. What data is processed

4.1. Account data (operator: embed.cam)

| Data | Purpose | Legal basis | |---|---|---| | Email address | sign-in identifier, address confirmation, account recovery, service notices | Art. 6(1)(5) of Law No. 152-FZ (performance of the contract); the subject's consent | | Password hash (the password itself is not stored) | authentication | performance of the contract | | Address-confirmed flag, failed sign-in counter, lockout expiry, session-version marker | account protection, prevention of password guessing, session revocation | performance of the contract; Art. 19 (security) | | Two-factor secret (encrypted) and hashes of recovery codes | second authentication factor — only if the User enables it | consent | | External provider identifier (Yandex ID, VK ID) and the email address it supplies | sign-in via an external provider — only if the User chooses it | performance of the contract; consent | | Interface language, role, preferences, registration date | interface operation, support | performance of the contract | | Support action log (who, when, on which account and on which object — e.g. a camera or a dashboard screen) | control of support access, incident investigation | the Operator's legitimate interests; Art. 19 |

4.2. Data processed on the User's instruction (operator: the User)

| Data | Note | |---|---| | Camera name, labels, schedule | text entered by the User | | Source address, including the camera's login and password | stored encrypted (AES-GCM); returned masked in the UI and API; decrypted only to connect to the Source | | Preview image — one still frame per camera | may contain images of people; overwritten on refresh; deleted with the camera | | Viewing links (identifier, quality, expiry, open counter) | knowledge of the link is sufficient for access | | Name and email address of a restricted-link recipient | third-party data entered by the User | | Video stream | relayed in real time, not stored |

4.3. Technical information

4.3.1. IP addresses are used in memory for request-rate limiting (protection against password guessing and excessive load) and are not written to the database. An IP address may be recorded in the technical logs of server software — including records of sign-ins and failed sign-in attempts — for security and incident analysis. Such logs are kept on the Service's servers in the Russian Federation, are not used to identify Viewers, and are overwritten as the logs rotate.

4.3.2. Aggregate metrics: number of views, peak concurrent viewers, traffic volume, number of connection drops — per day and per camera, with no per-Viewer data.

4.3.3. Cookies — strictly necessary only; see the Cookie Policy.

4.3.4. Media server cache: during television casting (HLS/Chromecast) stream fragments are held temporarily for the duration of the session and are not retained afterwards.

5. Categories of subjects and methods of processing

5.1. Categories of subjects: Users of the Service; restricted-link recipients added by Users; persons appearing in Users' streams (to the extent of cl. 2.2); site visitors.

5.2. Processing is carried out with and without automation and includes: collection, recording, systematisation, accumulation, storage, updating, extraction, use, blocking, deletion and destruction. Special categories of personal data and biometric personal data are not processed.

5.3. Personal data of citizens of the Russian Federation is processed using databases located within the Russian Federation (Art. 18(5) of Law No. 152-FZ).

5.3.1. The Service's servers run on the cloud platform of a Russian provider (cl. 6.1); the Operator owns no server hardware and no communications networks.

6. Services used and disclosure of data

6.1. Infrastructure. The Service runs on the cloud platform of TIMEWEB.CLOUD LLC (ООО «ТАЙМВЭБ.КЛАУД», OGRN 1227800052215, INN 7810945525, Russian Federation; the "Provider"): the Service's servers and databases are hosted there, and service emails are sent through its mail service. The Operator uses the platform under the Provider's public offer. Under that offer, the Provider does not process personal data on the Operator's instruction; the Operator carries out the processing of personal data using the platform and is answerable for it to data subjects.

6.2. Email delivery. A service email is delivered to the mail server that serves the email address the User provided. The User chooses that mail service; the Operator has no contract with it.

6.3. Identity providers Yandex ID and VK ID — only if the User chooses to sign in through them; embed.cam receives an identifier and a confirmed email address. Processing on the provider's side is governed by its own documents.

6.4. Competent public authorities — in the cases and to the extent required by Russian law, on a lawful request.

6.5. No other third parties receive personal data. Payment services are not used in this version, as the Service is provided free of charge; this Policy will be supplemented when paid plans are introduced.

7. Cross-border transfer

7.1. The Operator carries out no cross-border transfer of personal data. The Service's databases and servers, the mail service that sends its emails, and its backups are located within the Russian Federation.

7.2. If the User has given an email address served by a foreign mail service, the email is delivered to that address at the User's choice (cl. 6.2). The Operator does not transfer personal data to foreign mail services on its own initiative and has no contracts with them.

7.3. Because the Operator transfers no personal data outside the Russian Federation, there are no grounds for the notification to Roskomnadzor of an intention to carry out cross-border transfer under Art. 12 of Law No. 152-FZ, and no such notification has been filed.

7.4. Should the Operator later engage a recipient outside the Russian Federation, this Policy will be amended under section 11 and the notification required by Art. 12 of Law No. 152-FZ will be filed before that transfer begins.

8. Retention and destruction

8.1. Account data is stored for the term of the agreement and deleted within 30 calendar days after account deletion or withdrawal of consent, except data subject to statutory retention. Data is removed from backups as they are overwritten on schedule.

8.2. Cameras, viewing links and preview stills are deleted when the User deletes the object concerned and when the account is deleted.

8.3. Restricted-link recipient data is deleted when the User revokes the recipient, or when the link or the account is deleted.

8.4. Aggregate anonymised metrics (counters) may be stored indefinitely, as they do not identify a subject.

8.5. Destruction of personal data is evidenced in the manner prescribed by Roskomnadzor Order No. 179 of 28.10.2022.

9. Data subjects' rights and how to exercise them

9.1. You have the right to: obtain information about the processing of your personal data; require its correction, blocking or destruction where it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose; withdraw consent; and complain to Roskomnadzor or to a court.

9.2. Requests go to support@embed.cam from the account email address, or in writing to the Operator's address. A request must contain the information needed to identify the applicant (to the extent of Art. 14(3) of Law No. 152-FZ).

9.3. Response period: 10 business days from receipt, extendable by up to 5 business days with a reasoned notice.

9.4. Withdrawal of consent and account deletion are handled through the address in cl. 9.2. The Operator completes them within no more than 30 calendar days. The User can also delete the account themselves in the account settings. Withdrawal makes further use of the Service impossible, because processing the email address is necessary for authentication.

9.5. If your personal data reached the Service as part of a User's stream (cl. 2.2), a request to the address in cl. 2.3 will be handled by the Operator within the limits of its authority: the Operator may suspend the stream and shall pass the request to the User as the operator of that data.

10. Security measures (Art. 19 of Law No. 152-FZ)

10.1. The Operator applies legal, organisational and technical measures, including:

• encryption of Source credentials at rest (AES-GCM), storage of passwords only as computationally strong hashes (argon2id), encryption of two-factor secrets;
• transport of data only over a secure connection (TLS);
• isolation between Users at the level of database query structure, which makes one User's access to another's data structurally impossible;
• the ability to revoke all of a User's sessions immediately;
• request-rate limiting and account lockout on password-guessing attempts;
• logging of support actions;
• data backups;
• appointment of a person responsible for organising personal data processing;
• familiarising everyone with access to personal data with the statutory requirements.

10.2. On detecting an incident resulting in unlawful transfer of personal data, the Operator notifies Roskomnadzor within the periods set by Art. 21(3.1) of Law No. 152-FZ (24 hours for the fact, 72 hours for the results of the internal investigation) and, where necessary, informs the affected subjects.

11. Changes to this Policy

11.1. The Operator may amend this Policy. A new version is published at https://embed.cam/privacy with its effective date; earlier versions remain available. The Operator notifies registered Users of material changes by email or through the Service's interface.

11.2. Information about processing not covered here may be obtained on request at support@embed.cam.