eLK Reader – Privacy Policy

Last updated: April 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 application for:

• Digitally signing PDF documents using a Montenegrin electronic ID card (eLK) via NFC
• Reading personal data from the ID card via NFC
• Card activation, PIN management, and card status verification

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 (via NFC):

• 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, validity)

b) Camera data:

The App uses the device camera for scanning the back of the ID card. Camera images are processed in real-time on 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. The App does not access, store, or transmit biometric data.

d) PDF documents:

Users add PDF documents for digital signing. Documents are stored locally on the device.

4. How Data Is Processed

All data processing 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 device in real-time. No images are sent externally.
• PIN, PUK, and CAN codes are used only during the card communication session and are not stored.

5. Data Storage

• Card data (name, photo, JMBG) — stored in device cache until app cache is cleared
• Signed PDF documents — stored in device storage until user deletes them
• PIN / PUK / CAN — temporary memory only, duration of card session
• Camera images — temporary memory only, processed in real-time, not saved
• Biometric data — managed by the device operating system, not by the App

6. Data Sharing

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

No data is sent to Digital Control d.o.o. or any third party. All processing is performed locally on the device.

7. Permissions Required

• NFC — communicating with the electronic ID card
• Camera — scanning the ID card for data input
• Storage — storing and accessing PDF documents

8. Children’s Privacy

The App is not intended for use by children under 16. We do not knowingly collect personal data from children.

9. User Rights

Since no personal data is transmitted to or stored by Digital Control d.o.o., there is no server-side data to access, rectify, or delete.

Users have full control over locally stored data:

• Delete documents via the App or device Settings
• Clear app cache via device Settings
• Uninstall the App to remove all locally stored data

10. 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.

11. 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