Last updated: November 08, 2023
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application refers to F2FA and Falconeye, the software program provided by the Company.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Heru-on Ltd., 7, Balloo Court, Balloo Drive.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: United Kingdom
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Application or the Website or both.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Heruon, accessible from https://heruon.com/contact
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
Information regarding your location
Pictures and other information from your Device's camera and photo library
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.
You can enable or disable access to this information at any time, through Your Device settings.
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, You can contact us:
By email: info@heruon.com
By visiting this page on our website: https://heruon.com
Heruon Limited, registered in England with company number 11366987, has its main office located at The Glade, Bishop's Down Road, Tunbridge Wells TN4 8FS.
For inquiries about privacy rights, questions, suggestions, concerns, or complaints, please reach out to our Data Protection Officer:
Our operations comply with the Data Protection Act 2018 and the UK General Data Protection Regulations (collectively referred to as the DPA).
We offer systems that process personal and special category data to aid in the prevention and detection of crime. Heruon acts as the Data Controller for all the personal data we handle. Our clientele consists of businesses (subscribers) who are required to display signage indicating the use of Falconeye's facial recognition technology on their premises.
The Falconeye Real-Time Alerting system employs facial recognition to promptly notify subscribers when an individual reasonably suspected of involvement in crime—referred to as a Subject of Interest (POI)—enters their property. Subscribers can report new POIs by submitting crime incidents accompanied by formal witness statements that justify the offense and provide reasonable grounds for suspecting the POI. Falconeye reviews each incident to ensure these criteria are met. Subscribers can only access incidents and POI information that they have personally uploaded.
Complaints: If you wish to lodge a complaint, you can contact the Information Commissioner's Office (ICO) at www.ico.org.uk. For more details on the topics mentioned, please visit the ICO website.
The Falconeye system captures facial images from dedicated CCTV cameras at subscriber premises. An AI software application converts these images into biometric data, which is then compared against our database of POIs. If a match is found, the system recommends an alert indicating a potential match.
A human operator reviews this alert to determine its accuracy. If the operator confirms the match, they will follow their organization's procedures, which may range from taking no action to intervening. If the operator believes there is no match, they can dismiss the alert, and the associated data is immediately deleted.
The AI algorithms serve to filter potential matches with high accuracy before human verification.
We collect and store personal data about POIs to prevent and detect unlawful acts. Subscribers submit information about POIs, which we accept only when there are reasonable grounds for suspicion, supported by evidence like personal witness accounts or CCTV footage. Improper data submissions may result in fines or sanctions by the ICO.
Our database includes POI facial images and reasons for suspicion. Facial images captured by CCTV are converted into biometric templates for comparison with our POI database. Alerts are verified by the subscriber before any action is taken. Unverified alerts are deleted within one hour; dismissed alerts are deleted immediately. For system accuracy auditing, CCTV images and non-biometric personal data are retained for up to seven days.
We share limited POI data with subscribers when an alert is generated, including facial images, alert date, match confidence level, a gallery of POI images, offense type, and any warning markers (e.g., violence). This is the minimum data necessary for crime prevention and detection. We exclude individuals under 18 or over 80 unless their actions pose a threat to safety.
Our lawful basis for processing POI personal data is our legitimate interest and that of our subscribers. We adhere to higher compliance standards when processing criminal offense data and using facial recognition technology, classified as Special Category data under the UK GDPR. We process this data as it is necessary for substantial public interest—specifically, the prevention and detection of crime.
POI data is retained for up to 12 months from their last recorded incident. For incidents involving weapons or bodily harm, data is retained for two years. Alerts are stored for 72 hours to allow for auditing.
Before entering a subscriber's premises, you will see signage indicating the use of Falconeye facial recognition. The system detects faces via CCTV, encrypts the images, and converts them into biometric measurements. These measurements are compared against our POI database. If there is no match, the biometric data is deleted instantly. Detected face images are retained for up to seven days to allow for post-event incident reporting.
We process your personal data based on our legitimate interest and that of our subscribers in preventing and detecting unlawful acts. We have taken steps to minimize intrusion on your privacy. Facial recognition technology is considered Special Category data under GDPR. We process this data as it is necessary for substantial public interest—specifically, crime prevention and detection. We do not retain your biometric data beyond the immediate processing, ensuring that tracking is impossible.
Heruon hosts and manages all data processing on its own secure servers, without involving any third-party service providers. These servers are encrypted and safeguarded with firewalls to ensure data integrity and security. Our system architecture is designed to protect sensitive data and ensure compliance with privacy regulations at all times.
Our legitimate interest lies in providing a service that protects our subscribers, their customers, staff, and assets from unlawful acts. Processing personal, special category, and criminal offense data is necessary to effectively identify individuals reasonably suspected of crime and to notify subscribers for appropriate action.
We balance this interest against the rights and freedoms of data subjects by implementing minimal privacy intrusion measures and focusing on individuals reasonably suspected of unlawful acts. We prevent misuse and ensure data quality through strict adherence to our terms and conditions and data sharing agreements with subscribers.
Our privacy notice and clear signage inform individuals about our data processing activities. Falconeye protects individual privacy by only alerting subscribers to the presence of individuals matching those reported for criminal activities relevant to the subscriber.
If you contact us via our website, phone, or by submitting a subject access request, we will retain your data for up to six years to comply with the Accountability Principle of the DPA. Proof of identity documents provided for subject access requests are deleted after verification.
We may use your email and name for marketing purposes only if you have explicitly opted in. This information will not be shared with third parties. You can opt out of marketing communications and request data deletion at any time through our subject access request process.
Records of your communications with us may be stored in our contact management system for up to six years. We may monitor communications to staff members when necessary for business purposes.
Our lawful basis for processing this data is necessity for our legitimate interest in conducting business efficiently. We consider your rights and only use your personal data to facilitate business operations.