1. Who This Policy Applies To
This Privacy Policy applies to users of the ESLConnect mobile app, the ESLConnect portal at https://eslconnect.opticon.com/, ESLConnect-related account and authentication flows handled through Opticon's authentication service at https://auth.opticon.com/, and related ESLConnect backend services operated by Opticon Sensors Europe B.V.
It covers personal data, such as account details, and operational ESLConnect data that may be linked to a user, workspace, ESL, or device.
For ESLConnect account, portal, app, support, security, and service operation data, Opticon Sensors Europe B.V. is generally the controller of the personal data described in this Policy. Where a customer, employer, or other organization manages its own workspace users, ESL collections, labels, product workflows, or ESL Web Server environment, that organization may also act as an independent controller for its own use of ESLConnect and for the instructions it gives to its users.
2. Information We Collect
Depending on how ESLConnect is used, Opticon may collect the following categories of information:
- Account and authentication information: such as name, email address, password authentication data handled through Opticon's authentication service, sign-in status, account identifiers, authentication/session data, OAuth/OIDC authorization data, session cookies, security tokens, email confirmation status, password reset requests, and account deletion requests.
- ESLConnect user profile information: such as ESLConnect user identifier, email address, full name, account creation time, last-seen time, active/inactive status, and portal role.
- Workspace information: such as workspace name, workspace owner/admin/member roles, workspace members, invitations, role permissions, ownership transfer status, workspace-level settings, workspace creation/update timestamps, Template Mode enabled status, usage counters, and workspace activity needed to operate the service.
- ESL collection information: such as collection names, collection descriptions, collection membership, user access to collections, ESL membership in collections, and assignment timestamps.
- ESL information stored by the ESLConnect backend: such as ESL MAC addresses, encrypted ESL key records needed to allow authorized users to manage claimed ESLs securely, claim/unclaim status, workspace assignment, claimed-by user, claim time, ESL collection assignment, created/updated timestamps, last-used timestamp, and usage count. ESL variant may be derived from the ESL MAC address for display and sorting purposes.
- Template Mode and ESL Web Server configuration: if Template Mode is enabled for a workspace, ESLConnect stores workspace-level ESL Web Server connection settings, such as host, port, and encrypted API key information. Product data, product attributes, templates, generated template images, product-to-ESL links, and product/template update logic are managed by the connected ESL Web Server and are not stored in the ESLConnect backend.
- Support, diagnostics, and telemetry information: such as app logs, exported diagnostic logs, error reports, crash reports, stack traces, device type, operating system, app version, build number, request metadata, response status, performance/trace data, pseudonymous or hashed operational identifiers, and technical events used to diagnose issues, improve ESLConnect's functionality, reliability, performance, security, and support experience, monitor service health, and provide support.
The ESLConnect app uses Bluetooth to detect and communicate with nearby ESLs. During app use, the app may process nearby ESL information locally, such as battery status, signal strength, connection state, update progress, responsiveness commands, LED locate commands, ESL variant/resolution information, selected Gallery Mode images, overlays, QR codes, barcodes, dithering settings, and preview data. This information is used on the device or during the active Bluetooth session and is not stored as ESLConnect backend account data, except where technical details are included in local logs, exported logs, crash reports, or support material for troubleshooting.
Device permissions. Depending on the user's device, operating system, and the features used, ESLConnect may request access to Bluetooth or nearby devices to detect, connect to, and update ESLs. On some Android versions, location permission may be requested because Android requires it for Bluetooth scanning; ESLConnect does not use this permission to determine, track, store, or transmit the user's physical location. ESLConnect may also request camera access to scan barcodes, QR codes, or Data Matrix codes, and photo library access to let the user select images for Gallery Mode. These permissions are used only to provide the relevant feature and can be managed in the device settings.
ESLConnect is not intended for storing special categories of personal data, such as health information, biometric information, government identification numbers, or other highly sensitive personal information. Users and workspace administrators should avoid entering such information into workspace names, collection names, templates, images, support messages, logs, or other free-text or uploaded content.
3. How We Use Information
Opticon uses information to:
- Create, authenticate, and manage ESLConnect accounts.
- Provide ESLConnect login and account services through https://auth.opticon.com/.
- Automatically create a workspace for new users when they sign up through the ESLConnect app and log in for the first time.
- Operate the ESLConnect portal at https://eslconnect.opticon.com/.
- Allow workspace owners and admins to invite users and manage workspace access, roles, and permissions.
- Claim, unclaim, organize, and securely manage ESLs.
- Assign ESLs to one or more ESL collections and control collection access.
- Provide encrypted ESL keys to authorized users/devices so claimed ESLs can be managed securely.
- Track workspace and ESL usage needed to operate the service.
- Store and provide workspace-level ESL Web Server configuration where Template Mode is enabled.
- Provide Template Mode access where Opticon has enabled it for a workspace.
- Provide customer support, troubleshoot connection or configuration problems, and investigate errors.
- Monitor service reliability, security, abuse prevention, and operational health.
- Comply with legal obligations and enforce applicable terms or policies.
Some information is required to provide ESLConnect. For example, account information is needed to sign in, workspace information is needed to provide workspace access, ESL claim and key information is needed to manage labels securely, and diagnostic information may be needed to maintain service reliability and investigate faults. If required information is not provided or is deleted, some ESLConnect features may not work or access to the service may be unavailable.
4. Workspaces, Roles, and Access Control
ESLConnect users belong to a workspace. For new users, a workspace is automatically created when they sign up through the ESLConnect app and log in for the first time. Workspaces can be managed in the ESLConnect portal.
Workspace owners and admins can invite users to a workspace and manage workspace access. Workspace owners can manage role permissions for admins and members. Available actions depend on the user's assigned workspace role and permissions.
ESL collections can be used to organize ESLs within a workspace. One ESL can belong to multiple collections. Owners and admins can control which collections regular members can access, and members only see the collections and actions available to them in the app and portal.
Workspace owners and admins are responsible for assigning roles and permissions carefully, inviting only authorized users, removing users who should no longer have access, managing ESL collections appropriately, and ensuring that any data they enter or connect to ESLConnect is lawful and suitable for use in their organization.
Where a customer, employer, or other organization manages its own workspace, users, ESL collections, connected ESL Web Server, product workflows, or displayed content, that organization is responsible for its own use of ESLConnect and for the data it chooses to enter, connect, process, or display.
5. Visibility for Workspace Admins and Opticon Support
Workspace owners and admins can view and manage information for their workspace, including workspace members, invitations, roles, permissions, ESL collections, claimed ESLs, usage information, and relevant configuration settings.
Opticon administrators and support staff may access ESLConnect backend data, such as account metadata, workspace metadata, role and permission settings, ESL collections, claimed ESL MAC addresses, encrypted ESL key records, usage counters, ESL Web Server configuration, logs, and diagnostic information when needed to provide support, maintain service reliability, investigate security or operational issues, or administer ESLConnect.
Live Bluetooth information such as battery status or signal strength is not stored in the ESLConnect backend account data, except where technical details are included in app-side diagnostics, exported logs, crash reports, or support material for troubleshooting.
Opticon does not sell personal data and does not use ESLConnect data for unrelated advertising purposes.
6. Template Mode and ESL Web Server Configuration
ESL Web Server configuration is managed at workspace level in the ESLConnect portal and is shared among members of that workspace where their role allows access.
Template Mode must first be enabled by Opticon for a workspace before it can be used.
Product data, templates, generated template images, product-to-ESL links, and related product/template workflow data are managed in the ESL Web Server. ESLConnect stores the workspace connection configuration needed for authorized workspace access, but does not store that ESL Web Server data in the ESLConnect backend. Depending on the setup, the ESL Web Server may be hosted by the customer or by Opticon.
Where the ESL Web Server is hosted or managed by the customer, the customer is responsible for that environment and the data processed in it, including product data, templates, images, links, access controls, security, retention, and backups, unless a separate agreement states otherwise.
7. Diagnostics, Logs, and Telemetry
The ESLConnect app and backend services may use diagnostics, logs, crash reporting, and telemetry to detect errors, improve ESLConnect's functionality, reliability, performance, security, and support experience, investigate security or operational issues, and provide support.
The mobile app may use crash/error reporting, such as Sentry, for production mobile builds. This can include technical information such as app version, device type, operating system, error details, stack traces, breadcrumbs, and user/account identifiers needed to diagnose issues.
The ESLConnect backend may use logging and telemetry, such as OpenTelemetry-based tracing, to monitor request handling, performance, errors, and service health. Backend diagnostics may include operational context such as request metadata, trace identifiers, response status, timing information, and pseudonymous or hashed identifiers for correlation and troubleshooting. These systems are intended for operational diagnostics and are not used to sell personal data or for unrelated advertising.
9. Legal Bases for Processing
Where applicable privacy law, including the General Data Protection Regulation (GDPR), requires a legal basis for processing personal data, Opticon relies on one or more of the following bases:
- Performance of a contract: to provide ESLConnect accounts, app functionality, portal access, workspaces, ESL management, and support.
- Legitimate interests: to secure ESLConnect, prevent abuse, maintain service reliability, troubleshoot issues, improve ESLConnect's functionality, reliability, performance, security, and support experience, administer workspaces, support customers, protect Opticon's legal rights, and keep appropriate operational records.
- Consent: where specific consent is required, for example certain device permissions or optional functionality. Where processing is based on consent, users may withdraw consent at any time, without affecting processing that already took place before consent was withdrawn.
- Legal obligations: where Opticon must retain or process information to comply with applicable law.
11. Data Security
Opticon uses reasonable technical and organizational measures to protect account, workspace, ESL, configuration, and diagnostic data.
ESL communication uses secured key-based communication. ESL keys are handled through ESLConnect backend services and are used to prevent unauthorized access to claimed ESLs.
Some sensitive actions, such as transferring workspace ownership or making account-related changes, may require fresh re-authentication before they can be completed.
Users are responsible for protecting their account credentials, keeping their devices reasonably secure, using appropriate device locks and operating-system updates, and ensuring that workspace roles and permissions are assigned carefully.
No method of transmission or storage is completely secure. Opticon cannot guarantee that ESLConnect, user devices, networks, third-party services, or connected ESL Web Server environments will be free from unauthorized access, interruption, loss, or misuse.
12. Data Retention
Opticon keeps account, workspace, ESL, configuration, and diagnostic data for as long as needed to provide ESLConnect, support users, maintain security, comply with legal obligations, resolve disputes, and operate the service.
Retention periods may depend on the type of data, the user's account status, workspace status, the need to keep claimed ESLs and encrypted key records available to authorized workspace users, support and troubleshooting needs, backup cycles, audit and security requirements, and legal obligations.
For example, account and workspace data is generally retained while the account or workspace remains active, ESL claim and key records are retained while needed for authorized workspace users to manage claimed ESLs, and diagnostic logs are generally retained for a limited operational period for security, reliability, and troubleshooting.
Backup copies may persist for a limited time until they are overwritten or deleted according to Opticon's normal backup processes. Workspace or ESL data may remain available to the workspace where it is needed for ongoing workspace operation, even if an individual user leaves the workspace or deletes their account.
13. Account Deletion and Workspace Ownership
Users can start the account deletion flow from within the ESLConnect app through the Account page, through the public account deletion page at https://eslconnect.opticon.com/account-deletion/, or directly through Opticon's authentication service at https://auth.opticon.com/Identity/Account/DeletePersonalData. The Account page also provides workspace information and sign-out functionality.
Account deletion is handled through Opticon's authentication service and may affect access to other linked Opticon services using the same account.
Account deletion removes, anonymizes, or disables ESLConnect account data where possible. If the user belongs to a workspace, deletion may also involve workspace-removal steps so that the workspace can continue to operate for remaining members where applicable.
Some non-account records may be retained where required by law or needed for legitimate security, audit, dispute-resolution, workspace-operation, or other operational reasons. If a user is or was part of a workspace, workspace data may remain available to that workspace where needed for continued workspace operation. This may include ESLs assigned to the workspace, ESL assignment and claim status records, collections, role settings, usage data, and ESL Web Server configuration.
If a user is the owner of a workspace with other members, account deletion may require transferring workspace ownership first.
14. International Transfers
The ESLConnect backend service is hosted on Microsoft Azure, and the ESLConnect PostgreSQL database is hosted on Neon by Databricks. ESLConnect data may be processed in the European Economic Area and, where service providers are used, in other countries. Where required, Opticon uses appropriate safeguards for international transfers, such as contractual protections or other lawful transfer mechanisms.
15. User Choices and Rights
Depending on applicable law and the user's role in a workspace, users may be able to:
- Sign out from the ESLConnect app.
- Start the account deletion flow from the Account page, through https://eslconnect.opticon.com/account-deletion/, or through https://auth.opticon.com/Identity/Account/DeletePersonalData.
- Access, correct, or update account and workspace information.
- Manage workspace users, ESL collections, role permissions, ESLs, and ESL Web Server configuration in the portal where their role allows it.
- Request access, correction, deletion, restriction, portability, or objection regarding personal data, where applicable law provides those rights.
- Withdraw consent where processing is based on consent, for example by changing device permissions in the operating system or disabling optional functionality where available.
- Lodge a complaint with a competent data protection supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens. Users in the European Economic Area may also contact the supervisory authority in their country of residence, place of work, or place of the alleged infringement.
- Contact Opticon with privacy questions or data requests.
Opticon may need to verify the user's identity and account relationship before responding to privacy requests. Some requests may be limited where information is needed for security, legal compliance, dispute resolution, audit records, legitimate business operations, or continued workspace operation.
ESLConnect does not use personal data for automated decision-making or profiling that produces legal effects or similarly significant effects for users.
16. Children
ESLConnect is primarily intended for business and professional use and is not directed to children.
17. Changes to This Policy
Opticon may update this Privacy Policy when ESLConnect changes, when new features are added, or when legal or operational requirements change. The latest version will be made available through the ESLConnect portal, the app, or the relevant app store listing.
18. Contact
For privacy questions, support requests, or data protection requests, contact:
2132 XV Hoofddorp
The Netherlands
VAT No. NL008701325B01