Include Ltd from Solin, Croatia, with its registered address at don Frane Bulića 183a, VAT number: HR87239495136 (hereinafter referred to as Include) is the manufacturer of Smart city solutions, in particular, but not exclusively Steora smart benches (models: “Steora Classic”, “Steora City” and “Steora Cyclo”), Terra waste (models: “Terra Public Can”, “Terra Residential Bins” and “Terra Residential Dumpster” ) and Aerys air quality monitoring system (models: “Aerys P”, “Aerys G” and “Aerys X”).

Following Privacy policy is referring to Steora smart benches (models: “Steora Classic”, “Steora City” and “Steora Cyclo”) (hereinafter referred to as Product).

Products are purchased and installed on sight by their legal owners (such as cities, municipalities, corporations or individuals) thus Include doesn’t have any ownership over the Products once they are shipped from our warehouse.

All privacy issues regarding Products are the responsibility of their legal owners. Include can’t guarantee that Products are unchanged once they are shipped and ownership was transferred to legal owners.

Products are equipped with built-in sensors and features that are collecting an extensive amount of data. Most of the collected data are non-personal.

Some collected data are stored locally on the Product and are permanently deleted after a certain time. Data that are sent to the server can be accessed by Products legal owner via the Solos platform, only with an original activation code received by legal owners with the purchased Product.

The following information are giving a detailed insight into what data may be collected via built-in sensors and features on Products that are unchanged from their original setup.

1. Built-in sensors and features that may collect personal data

AI-powered camera

Standard equipment: No
Available for: Steora City
Description: Counting foot traffic and estimating the pedestrian’s gender. Pre-trained CNN is used to extract visual features of pedestrians. Tracking with assigned ID is used as a part of foot traffic counting. AI software doesn’t use facial recognition, LFR or any other type of recognition that would capture personally identifiable characteristics of the individuals. CCTV is not available, nor is any other type of video storage. Once the frame is processed it is immediately permanently deleted. The final output sent to the server is a JSON file structured as the following example: {“counter”: 1, “gender”: ”M”, “accuracy”: 80}. Data are anonymized in such a way that it is impossible to link them to an identifiable individual.

NFC reader

Standard equipment: No
Available for: Steora Cyclo
Description: Some Steora Cyclo benches may be equipped with an NFC reader as a security feature required for opening toolholder box where the Air compressor, DC charging plugs, AC sockets and Hand tools are fitted. Toolholder box doors are opened once the NFC reader is tapped with NFC enabled smartphone. Depending on the smartphone security level, the NFC reader could obtain and locally store smartphone UID (unique identifier) as a vandalism precaution. Collected UIDs are not sent to the server but are temporarily locally stored.

Wi-Fi hotspot

Standard equipment: No
Available for: All models
Description: The system is equipped with OpenDNS for users’ protection from accessing dangerous or unwanted domains. While the device is connected to the Wi-Fi hotspot, a MAC address is temporarily locally stored. Once the device disconnects from the Wi-Fi the MAC address is permanently deleted. Other personal or device data are not collected. During the connection time, the Wi-Fi system doesn’t monitor visited IP addresses or URLs. For more information about OpenDNS privacy please visit opendns.com. Note: as mentioned in the heading, Include Ltd. isn’t the legal owner of the product you are using. We can’t guarantee that system was not changed once it was shipped. For more information regarding Wi-Fi privacy please contact the product owner.

2. Built-in sensors and features that are collecting environmental and other non-personal data

AC sockets

Standard equipment: Yes
Available for: Steora Cyclo
Description: Counting the number of charged e-bikes by detecting energy consumption increase. AC socket is a regular 110/220V socket without communication capabilities.

Air compressor

Standard equipment: Yes
Available for: Steora Cyclo
Description: Counting the number of times when the air compressor was working for a certain duration at a certain pressure. Aggregated data are sent to the server at certain time intervals.

Air Quality Sensors

Standard equipment: No
Available for: All models
Description: Monitoring NO, NO2 and O3 gases several times per minute and reporting to the server at certain time intervals.

Battery status

Standard equipment: Yes
Available for: All models
Description: BMS tracks battery level and reports to the server at certain time intervals.

Bike holder

Standard equipment: Yes
Available for: Steora Cyclo
Description: Ultrasonic sensor between bike racks recognizes the long-lasting presence of the object at a certain unchanged distance and counts it as a parked bike/scooter. Aggregated data are sent to the server at certain time intervals.

DC charging plugs

Standard equipment: Yes
Available for: Steora Cyclo
Description: Counting the number of charged e-scooters by detecting energy consumption increase. The charging controller recognizes e-scooter battery voltage to provide optimal charging parameters. The controller doesn’t have the capability to collect any data from or about the e-scooter.

Energy production

Standard equipment: Yes
Available for: All models
Description: Voltage and current sensors are calculating the energy produced from each PV module several times per minute. Aggregated data are sent to the server at certain time intervals.

Flowerpot

Standard equipment: No
Available for: Steora City and Cyclo
Description: The soil moisture sensor inside the flowerpot monitors moisture level which is reported to the server at certain time intervals.

GPS

Standard equipment: Yes
Available for: All models
Description: Each bench is equipped with GPS that provides location data immediately after installation or on request. Location data is reported to the server.

Hand tools

Standard equipment: Yes
Available for: Steora Cyclo
Description: Counting the number of times when hand tools were used by detecting their extraction out of the toolholder. Aggregated data are sent to the server at certain time intervals.

Noise sensor

Standard equipment: No
Available for: All models
Description: Monitoring ambient noise level several times per minute and reporting to the server at certain time intervals. The noise sensor doesn’t have the capability to work as a microphone or to record sounds.

Particulate matter sensor

Standard equipment: No
Available for: All models
Description: Monitoring PM1, PM2.5 and PM10 particles several times per minute and reporting to the server at certain time intervals.

PHT sensor

Standard equipment: Yes
Available for: All models
Description: Ambient temperature, humidity and pressure are collected and reported to the server at certain time intervals.

Seating sensor (users counter)

Standard equipment: Yes
Available for: All models
Description: Mechanical deformation sensor is used to recognize the presence of a person sitting on the bench. Aggregated data are sent to the server at certain time intervals.

USB chargers

Standard equipment: No
Available for: All models
Description: Counting the number of charged devices by detecting energy consumption increase. Communication protocol only recognizes the type of charging controller inside the device. USB doesn’t have the capability to collect or recognize the model of a device, IMEI or any other personal data that could be collected by using AT commands.

Wireless chargers

Standard equipment: Yes
Available for: All models
Description: Counting the number of charged devices by detecting energy consumption increase. The base station doesn’t activate unless a compatible device has been placed on it. The station determines this by sending an intermittent test signal to check if a Qi-compliant device is present. The mobile device responds to this ping by communicating the received signal strength. The base station doesn’t have the capability to collect any data about or from the device.

Last edited on: 09.04.2022.