Privacy and GDPR
Last updated: 1st September 2025
VisionR's Scout© does not collect any identifiable information from shoppers. Our clients may make Personal Information available to us from their various loyalty programs. We only analyse this data when the end-user has agreed to third-party sharing.
Who We Are
VisionR is a company limited by shares and registered in the Republic of Ireland.
VisionR Inc. is a company registered in Delaware, USA.
Contact Us
You can contact us at our main business address: 18 Merrion Row, Dublin 02, Ireland. Our Data Protection Officer can be contacted via shane.osullivan@visionr.com.
Our Values
Consumer Privacy, Data Protection and anonymisation are a core concept of VisionR in all our technology. Data Protection by design is implemented in our software which has been designed as a visitor analysis tool by means of completely anonymous meta-data measurements. We do not collect any identifiable information from shoppers.
As part of our ethos of continuous improvement, this Privacy Policy and any associated policies or procedures may be changed in the future. If we make changes, we will provide notice of any proposed changes via a prominent notice on our website before they come into effect.
What We Do
The mission of VisionR is to improve and enhance the offline shopping experience for customers and retailers using actionable anonymised data.
How Do We Obtain Your Data?
VisionR does not collect data that can identify an individual in terms of full identity or in terms of repeated exposures which would arise through recognising that an individual was at a sequence of different locations or visited the same location twice. We use sensors and other supporting devices which assess an image of an individual in order to note certain characteristics of that individual for the purposes of creating statistical data on the types of customers that enters a given premises.
Summary:
We obtain data in one or more of the following ways:
- Coordinate data in frame is assessed by anaylsing where visitors are positioned in a video stream in terms of x & y coordinates. These coordinates are then combined to create a shopper journey through a frame. No images or videos are stored, just bytes of data.
- Demographic data is assessed from visual cues with image processing being performed in real-time, meaning no image is ever stored.
How Do We Use Data
Image Specific Security Protocol
Images taken from a VisionR device are processed in real-time, on the edge (on device) using the latest Machine Learning Embedded Chip, they do not leave the device and are never human readable. Images are only stored in temporary memory, one image at a time, and each image is permanently deleted as the next one is assessed. Hence, no more than one image can be stored in temporary memory at any given time. We store one blurred maintenance image per hour, to ensure all sensor components are functioning correctly. This image is stored for maintenance purposes and is not processed for any other purpose. If a device is unplugged, the image in temporary storage is automatically destroyed. These images are temporary and exist exclusively, meaning not even administrators can view previous images taken while in production mode.
AI and the EU AI Act
Our sensors use AI to estimate age range and gender. Under the EU AI Act, this is a biometric categorisation system. It is not a high-risk system: age and gender are not sensitive attributes under the Act, according to the European Commission's draft guidelines on high-risk classification. We will review this when the Commission adopts final guidelines. Our sensors do not identify people, do not use facial recognition, and do not recognise emotions. Retailers using VisionR inform shoppers that an AI system is in use through a sign at each store entrance, as the Act requires. VisionR staff and our clients' teams are trained on how the system works, in line with the Act's AI literacy requirement.
Categories of Data We Process
We only process anonymous crowd demographic characteristics together with the movement of these demographic characteristics within a premises and whether they are engaging with a given interest point. Examples or descriptions of categories of data provided here are not exhaustive and are for information purposes.
- IT Service Providers
- VisionR uses a range of IT service providers to host our systems, develop and maintain software, and support our internal information management processes.
- Accounting, and Finance Service Providers
- We avail of the services of a number of third parties to support our accounting and payments management processes.
Categories of Recipients
We do not share any of the data collected with third parties. The data is only visible to the client who bought the hardware, and no third parties receive access to the data.
How Long Do We Keep Your Data?
| Data | Retention |
|---|---|
| Camera image | Never human readable, deleted after frame is processed (0.06 seconds) |
| Readings on the device | Until uploaded to the VisionR cloud, outside store opening hours |
| Aggregated, anonymised data | Until the retailer asks us to delete it |
| Calibration images | Up to 6 months |
Where data is stored?
All data is hosted on Amazon Web Services in the Dublin region, Ireland. No data is transferred outside the EU.
Who can see the data?
Only the retailer who uses VisionR can see its data, through the VisionR dashboard or API. We do not sell or share data with any other party. We use service providers to help us run our business:
- IT service providers host our systems, develop and maintain our software, and support our internal information management.
- Accounting and finance providers support our accounting and payments.
Cross-border Data Transfers
There are no cross-border transfers of data.
Keeping Data Safe and Secure
We place great importance on the security of all data associated with our customers. We have security measures in place to protect against the loss, misuse, and alteration of data.
Internal security audits of the entire VisionR system are done on a regular monthly basis, with specific systems being audited on a more frequent basis along with automated alarm monitoring 24/7.
All data is encrypted at rest and in transit using a minimum RSA 1024-bit encryption and in some cases up to RSA 2048-bit encryption.
Your Rights under GDPR
Where VisionR is acting as a Data Controller, you have rights under EU Data Protection law. These rights are:
- A right of access which allows you to request a copy of your data in an intelligible form (Article 15 GDPR)
- A right of rectification which allows you to request a correction of errors or inaccuracies in the data that we hold relating to you (Article 16 GDPR)
- A right to object to processing and to “opt-out” of having your data processed by us on the basis of consent, our legitimate interests or a public interest basis unless we can demonstrate compelling legitimate grounds that over-ride your interests, rights, and freedoms. (Article 21 GDPR)
- A right to erasure in certain specified circumstances. This right does not apply where we are processing data for compliance with a legal obligation, for reasons of public interest in relation to public health, for archiving purposes for historical or scientific research, or where necessary to establish or defend legal claims (Article 17)
- A right to restrict processing in certain circumstances (Article 18)
- Under GDPR individuals also have rights to seek compensation for infringement of their data protection rights under the legislation.
Right to Complain to the Data Protection Commission
You have the right to file a complaint to the Data Protection Commission.
Their contact information can be found online at this link: https://dataprotection.ie/en/contact/how-contact-us
