EShare App Privacy Policy

Effective Date: September 1, 2024 (Updated for GDPR/DSGVO Compliance)

1. Introduction and Who We Are

Welcome to the EShare application (the "Application"), developed by EShare Technology Co., Ltd. ("EShare," "we," "us," or "our"). We value your privacy and are committed to protecting your personal data in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR / DSGVO) if you are in the European Economic Area (EEA), UK, or Switzerland.

Roles in Data Processing (Controller vs. Processor):

Individual Users (B2C): Where you download and use the Application directly as an individual, EShare acts as the Data Controller for personal data processed in connection with your use.
Enterprise and Educational Deployments (B2B / Higher Education): Where the Application and its Cloud Management solution are deployed by an organization, campus, or educational institution, that organization acts as the Data Controller. EShare acts as a Data Processor (Auftragsverarbeiter) pursuant to Article 28 of the GDPR. In such cases, our processing is governed by our Data Processing Agreement (DPA / AVV) with the respective organization.

2. What Personal Data We Collect, Why, and Retention Periods

To provide and improve our Application and its functionalities, we process the following categories of data in accordance with GDPR principles of purpose limitation and data minimization:

Data Category	Examples	Purpose of Processing	Legal Basis (GDPR)	Retention Period (Art. 13(2)(a))
Network and Device Information	IP address, MAC address, SSID network details.	To enable device discovery by client devices, facilitate network connection, and display accurate network info.	Art. 6(1)(b) (Contract Performance) Art. 6(1)(f) (Legitimate Interest)	Retained only during active network session; license validation logs retained for contract duration.
Location Data	Approximate location derived from network data (Wi-Fi network scanning).	To scan for nearby Wi-Fi networks and enable client devices to discover the receiver display.	Art. 6(1)(b) (Contract Performance)	Processed transiently in real-time. Not permanently stored.
Device Identifiers	Device model, operating system (OS) version, unique device identifiers.	Essential for app operation, troubleshooting, software updates, compatibility, and license verification.	Art. 6(1)(b) (Contract Performance) Art. 6(1)(f) (Legitimate Interest)	Retained for the duration of the active software license/subscription.
System and Usage Data	System logs, performance metrics, crash reports.	To monitor application performance, diagnose issues, and improve software stability.	Art. 6(1)(f) (Legitimate Interest)	Deleted or aggregated/anonymized within 90 days.
Media Data (Screen & Audio)	Screen captures, camera feeds, microphone input (e.g., during BYOM or screen mirroring).	To transmit live media from client devices to the receiver device as explicitly initiated by the user.	Art. 6(1)(b) (Contract Performance)	Zero Storage: Processed transiently in real-time memory. Never stored or recorded on EShare servers.
USB Device Data	Data read from/written to connected USB presentation dongles.	To manage connected presentation dongles to facilitate screen sharing initiated by the user.	Art. 6(1)(b) (Contract Performance)	Processed only while the USB dongle is actively connected.
Application List	List of installed applications on the receiver device.	To allow users to view and launch applications remotely from a client device when initiated.	Art. 6(1)(b) (Contract Performance)	Cached locally during active session; not transmitted to external cloud servers.

Special Categories of Data: We do not collect or process sensitive personal data (e.g., health data, biometric data, racial or ethnic origin) as defined under Article 9 of the GDPR.

3. Operational Architecture: Local vs. Cloud Services

Local Network Operation by Default:

After initial license activation, the core screen casting, BYOM, and media sharing functionalities of EShare operate strictly within your Local Area Network (LAN/WLAN) via direct transmission. In this standard operating mode, no presentation content, audio, or video leaves your internal network or passes through external cloud infrastructure.

Cloud-Based Features (Opt-In / Manual Initiation):

External cloud server interactions take place only for licensing handshakes or when specific remote features are explicitly activated by an administrator or user, such as:

Remote fleet administration via the EShare Cloud Management portal.
Wide-area network (WAN) multi-screen broadcasting across separate subnets.
Internet-based Webcasting features.

4. How We Use Your Information

We process personal data only for lawful purposes, including:

Provide and Maintain the Application: Delivering core presentation and device discovery functionalities (Legal Basis: Art. 6(1)(b) GDPR).
Support and Troubleshooting: Responding to technical inquiries and diagnosing crash issues (Legal Basis: Art. 6(1)(b) & Art. 6(1)(f) GDPR).
Security and Stability: Protecting the application, our infrastructure, and users against unauthorized tampering or abuse (Legal Basis: Art. 6(1)(f) GDPR).
Legal Compliance: Complying with applicable statutory, tax, or regulatory requirements (Legal Basis: Art. 6(1)(c) GDPR).

5. Permissions and Device Access

The Application requests permissions necessary to perform its intended functions (e.g., Local Network/Wi-Fi access for discovery, Camera/Microphone for BYOM conferencing). Permissions can be managed via your operating system settings. Revoking certain permissions may disable associated features.

6. Data Hosting, Sharing, and International Transfers

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

Server Location for European Users

For users and institutions located within the European Economic Area (EEA), UK, and Switzerland, all cloud management services and backend infrastructure are hosted in certified, secure data centers physically located in Frankfurt am Main, Germany (European Union).

Third-Party Service Providers (Sub-Processors)

We engage trusted third-party providers (e.g., enterprise cloud hosting infrastructure, crash report telemetry). These providers process data strictly as data processors under binding contractual agreements in compliance with Article 28 GDPR.

7. Your Data Protection Rights Under GDPR

Subject to statutory conditions under Articles 15–22 GDPR, you have the following rights:

Right of Access (Art. 15 GDPR): Request a copy of your personal data processed by us.
Right to Rectification (Art. 16 GDPR): Request correction of inaccurate or incomplete data.
Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR): Request deletion of your personal data.
Right to Restriction of Processing (Art. 18 GDPR): Request restriction of processing under certain legal grounds.
Right to Data Portability (Art. 20 GDPR): Request delivery of your data in a structured, commonly used format.
Right to Object (Art. 21 GDPR): Object to data processing based on legitimate interests (Art. 6(1)(f)).
Right to Withdraw Consent (Art. 7(3) GDPR): Withdraw consent at any time without affecting prior lawful processing.

To exercise these rights, please contact our privacy team at privacy@eshare.io. We respond to all verified requests within one month.

8. Technical and Organizational Security Measures

We implement appropriate technical and organizational measures (TOMs) in accordance with Article 32 of the GDPR to ensure a level of security appropriate to the risk. These measures include TLS/AES encryption during transmission, role-based access restrictions, network segmentation, and regular security vulnerability assessments.

9. Children’s Privacy

Our Application is not directed at children under the age of 16 without parental or institutional consent. We do not knowingly collect personal data from minors. In school environments, deployments are managed under the authorization and direction of the respective educational institution.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect technological or legal updates. Material changes will be published directly on our website or notified via in-app notifications. The effective date at the top indicates when the policy was last revised.

11. Contact Us & Data Protection Officer

If you have any questions, wish to request an Auftragsverarbeitungsvertrag (AVV / DPA), or wish to exercise your GDPR rights, please contact our Data Protection Team:

EShare Technology Co., Ltd.

Data Protection & Compliance: privacy@eshare.io

General Support: support@eshare.io

Website: https://www.eshare.io