Privacy and responsible use
Emogg Analytics is designed from the first sensor so that privacy is not an option but a technical consequence: nothing is stored, no one is identified and every result is an aggregated reading of the whole.
Principles
Principles
No images or videos are stored
Processing happens live, in temporary memory. Once the data point is obtained, the image is gone: no file, no footage, no stored frame.
Aggregated and anonymous data
The output of each session is a collective metric of the audience. There are no individual scores or profiles: only the reading of the whole.
No personal identification
The system detects the presence of people but recognizes no one: it builds no templates, runs no comparison against identity databases and singles out no person.
How it works inside
The technical description of the processing is the foundation of our compliance analysis. This is exactly what the solution does:
The sensor sends each frame to volatile memory. It is never written to any storage.
A neural network locates areas with a high probability of containing a person. It creates no facial mesh and no identity template.
A second neural network infers indicators of the audience's non-verbal response over each detected area, in milliseconds.
Results are aggregated across the whole audience. The output is a collective, anonymous metric: no image, no video and no individual score remains.
Legal framework
Our compliance analysis applies the definitions of Regulation (EU) 2016/679 literally, following the interpretation of the Spanish DPA (AEPD), the European Data Protection Board and CJEU case law.
Emogg Analytics does not process "biometric data for the purpose of uniquely identifying a natural person" (Art. 9.1 GDPR), because the system neither pursues nor enables the unique identification or authentication of anyone.
The GDPR itself (Recital 51 and Art. 4.14) states it: a photograph only falls into the special category when the processing enables unique identification. Emogg builds no templates and compares no faces against identity databases.
Since the Article 9 prohibition does not apply, the processing is governed by the GDPR's general regime: legitimate interest or consent, managed by the client as data controller.
This page does not constitute legal advice. Formal legal documentation is prepared with specialised counsel.
European AI Act
Emogg Analytics is not a solution for analysing individual people in workplace or educational settings — uses that the European AI Act places under a reinforced regime or restricts outright.
The solution is dedicated to objectively measuring content, spaces and experiences from aggregated audience data. Its data structure is neither designed for nor allows decisions about individual people.
Design guarantees
No identification: no templates are built and no comparison is run against identity databases.
People detection, never identity recognition.
No persistence: no images, frames or crops are kept.
Aggregated, anonymous output: a session metric with no individual scoring.
Content-measurement purpose: the system cannot be used to decide about people.
EU infrastructure: processing takes place within the European Union.
Audience signals are never used to train models.
Responsible use
In every project the client acts as data controller: they inform attendees, establish the appropriate legal basis and define the signage of the space. Emogg provides the technology, supporting documentation and a deployment designed to make compliance the easy path.
They have measured with Emogg
Frequently asked questions
Tell us about your case and we will walk your team through the technical and legal detail.
