eLK Reader – Privacy Policy

Last updated: September 2026

This policy describes how the eLK Reader mobile application (“App”) developed by DIGITAL CONTROL d.o.o. handles personal data.

1. What the App Does

eLK Reader is an Android and iOS applicati

• Digitally signing PDF documents using a card (eLK) via NFC
• Reading personal data from the ID card via NFC
• Card activation, PIN management, card stfication of digital signatures

2. Data Controller

DIGITAL CONTROL d.o.o.
Knjaza Danila 78A
81000 Podgorica
Montenegro
Email: info@digitalcontrol.me

3. Data Collected by the App

a) Data read from the electronic ID card

• Full name, surname
• Date of birth, sex, nationality
• Document number, date of expiry
• Personal identification number (JMBG)
• Facial photograph
• Signature image
• Digital certificate information (issuer,

b) Camera data:

The App uses the device camera for scannin Camera images are processed in real-timeon the device and are not stored, recorded, or transmitted.

c) Biometric data:

The App may use device biometrics (fingerprint, face unlock) for app lock on launch. Biometric data is handled
entirely by the device operating system. Tore, or transmit biometric data.

d) PDF documents:

Users add PDF documents for digital signincally on the device.

e) Anonymous usage statistics:

The App sends anonymous, aggregated statis(which operation was started and whether it succeeded), without any identifier of the user or the device. Details are in Section 7.

4. How Data Is Processed

All processing of card data, documents and camera images occurs locally on the user’s device.

• Card data is read directly from the ID card chip and displayed on screen. It is not transmitted to any
server.
• Signed PDF documents are stored locally. Users can save or share them at their own initiative.
• Camera images are processed on the devicare sent externally.
• PIN, PUK, and CAN codes are used only during the card communication session and are not stored.
• The only information that leaves the dev statistics described in Section 7, whichcontain no personal data and no identifier.

5. Data Storage

• Card data (name, photo, JMBG) — stored in device cache until app cache is cleared
• Signed PDF documents — stored in devetes them
• PIN / PUK / CAN — temporary memory only, duration of card session
• Camera images — temporary memory onl not saved
• Biometric data — managed by the device operating system, not by the App
• Unsent usage statistics — kept in thtil sent, for at most 7 days; deletedimmediately if statistics are switched off

6. Data Sharing

The App does not transmit any personal data to external servers.

No card data, documents, images or codes are sent to Digital Control d.o.o. or to any third party. The only
data sent from the device is the anonymousd in Section 7, which are received byDigital Control d.o.o. and are not shared with or sold to anyone. They are not used for advertising or for
tracking across apps or websites.

7. Anonymous Usage Statistics

To see whether the App works reliably and ems, the App sends anonymous usagestatistics to Digital Control d.o.o.

What is sent:

• Which operation was started: signing, batch signing, card activation, card check, PIN management or signature
verification
• Whether the operation succeeded or failed and, if it failed, a technical error code (for example: wrong PIN,
card removed too early, card not detected,
• App version, operating system version and phone model
• Whether an old or new generation ID card
• The calendar date of the event (no exact time)
• A random, temporary session number that is running, so that events of one sessioncan be related; it is not stored and cannot identify you or your device

What is never sent:

• Any device, install or user identifier (no advertising ID, no account, no persistent ID)
• The name, content or size of any documen
• Your name or any other data read from the ID card (personal identification number, document number, MRZ,
photograph, signature, certificate serial
• PIN, PUK or CAN codes
• Your IP address is not stored

Because no identifier of any kind is sent,linked to you or to your device, and events from different days cannot be connected to each other.

Where the data is stored: on a server operated by Digital Control d.o.o. on Cloudflare infrastructure, with
data stored in Western Europe. Cloudflare,r, transiently processes the IP address of your device in order to deliver the request; we do not store it. Statistics are kept for at most 13 months and
then deleted automatically.

Your choice: usage statistics are swite informed about them on the first launchof the App (and once after updating from an earlier version), and you can switch them off at any time in the
App under Settings → Anonymous usage Postavke → Anonimna statistika korišćenja). When switched off, nothing is sent and any unsent statistics stored on the device are deleted
immediately. Switching statistics off has ction of the App.

Legal basis: our legitimate interest id improving the App. The statistics areanonymous and are not personal data.

8. Permissions Required

• NFC — communicating with the electronic ID card
• Camera — scanning the ID card for da
• Storage — storing and accessing PDF documents
• Internet — sending the anonymous usa Section 7; not used for any other data

9. Children’s Privacy

The App is not intended for use by childreingly collect personal data from children.

10. User Rights

Card data, documents and images never leavno server-side personal data to access,rectify or delete. The usage statistics we receive contain no identifier, so they cannot be attributed to a
person or a device and therefore cannot beeleted on request; you can stop theircollection at any time as described in Section 7.

Users have full control over locally stored data:

• Delete documents via the App or device Settings
• Clear app cache via device Settings
• Switch off usage statistics in the App Settings
• Uninstall the App to remove all locally

For any question or objection regarding ththis policy you can contact us at theaddress in Section 12.

11. Changes to This Policy

We may update this policy from time to time.

The latest version will always be available on this page.

Continued use of the App constitutes acceptance of any updates.

12. Contact

For questions about this privacy policy or the App:

DIGITAL CONTROL d.o.o.
Knjaza Danila 78A
81000 Podgorica, Montenegro
Email: info@digitalcontrol.me