Private Policy

1. Introduction
   LVLogics (“we,” “our,” or “us”) is committed to protecting your personal data and respecting your
   privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data
   when you visit our website (lvlogics.com) or use our application and services (collectively, the
   “Services”). This policy is provided in accordance with the EU General Data Protection Regulation (GDPR)
   (Regulation (EU) 2016/679) and the Irish Data Protection Act 2018.
   If you have any concerns about how we handle your data, please contact us before using our
   Services (see Section 12).
2. Data Controller
   LVLogics is the data controller for personal data collected through our website and Services.
   LVLogics [Registered Company Name] [Registered Address, Ireland] Company Registration
   Number: [CRO Number] Email: privacy@lvlogics.com Website: lvlogics.com
3. What Personal Data We Collect
   Data You Provide Directly

• Identity data: name, job title, company name
• Contact data: email address, phone number, postal address
• Account credentials: username, hashed password
• Communications: content of support requests, contact form submissions
• Payment data: billing address and payment method details (card processing is handled
  by our PCI-compliant payment provider; we do not store full card numbers)
• AI processing of your voice recording: When you record a bin reading, BinVoice captures
  a short voice recording and sends only that recording to two third-party AI
  services: OpenAI (its Whisper service), which transcribes your speech to text,
  and Anthropic (its Claude service), which interprets that text into a structured silo
  reading. The result is returned to your device and saved to your SiloSpi account.
• What these providers do with your data: OpenAI and Anthropic act solely as our data
  processors and act only on our instructions. They use your voice recording and its
  transcription only to perform the transcription and interpretation we request. They do
  not use your data to train their models, for service improvement, or for any of their own
  purposes, and they do not retain the voice recording after processing.
• Protection and retention: Your voice recording is discarded immediately after processing
  and is never stored by us. Your location is never sent to these AI services. We confirm
  that OpenAI and Anthropic provide the same or an equivalent level of protection for your
  personal data as set out in this Privacy Policy, and are contractually required to process
  it only on our documented instructions.

Data Collected Automatically

• Technical data: IP address, browser type and version, operating system, device
  identifiers
• Usage data: pages visited, features accessed, actions taken within the application,
  session duration, referring URLs, time and date of access
• Location Data: BinVoice uses your device’s precise location (GPS), when you grant
  permission, to identify the correct facility for a reading. Location is used only for this
  purpose and is not used for tracking across apps or websites.

Data from Connected Devices and Integrations

• Telemetry, sensor readings, and facility data transmitted from IoT devices or third-party
  integrations you connect to our platform (e.g., monitoring devices, industrial sensors)
  This operational data is processed solely to provide the Services you have requested.

4. Lawful Basis for Processing
Under GDPR Article 6, we only process your personal data where we have a valid lawful basis.
The basis we rely on for each type of processing is:

Where we rely on legitimate interests, we have assessed that our interests are not overridden
by your rights and interests. You may request details of that assessment by contacting us.

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of
processing carried out before withdrawal.

5. How We Use Your Personal Data
We use the personal data we collect to:

• Register and manage your account and authenticate your identity
• Provide, operate, maintain, and improve our Services
• Process transactions and send related communications (receipts, invoices)
• Send administrative and security communications necessary for the operation of the
  Services
• Respond to your enquiries and provide customer support
• Analyse usage to improve functionality, performance, and user experience
• Detect, investigate, and prevent fraudulent or unlawful activity
• Comply with our legal and regulatory obligations
  We do not sell, rent, or trade your personal data to any third party for their own marketing
  purposes.

6. How We Share Your Personal Data
We share personal data only in the following limited circumstances:
Service Providers (Data Processors): We engage trusted third-party vendors who process data
on our behalf under written data processing agreements compliant with GDPR Article 28. These
include hosting providers, payment processors, email delivery services, and analytics providers.
They may only process your data on our documented instructions.
Professional Advisers: Lawyers, auditors, and insurers where necessary in the course of
services they provide to us.
Regulatory and Legal Authorities: We may disclose personal data to the Data Protection
Commission (DPC), law enforcement, courts, or other authorities where required by law or legal
process, or where necessary to protect the rights, property, or safety of LVLogics, our users, or
others.
Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may
be transferred. We will notify you in advance and your rights under this policy will continue to
apply.
We do not share your personal data with any third party for their own independent marketing or
commercial purposes.

7. International Transfers of Personal Data
LVLogics is based in Ireland and your data is primarily stored and processed within the
European Economic Area (EEA).

Where we engage service providers located outside the EEA (for example, cloud infrastructure
or analytics providers), we ensure that adequate safeguards are in place in accordance with
GDPR Chapter V, including:

• Transfers to countries with an EU adequacy decision (e.g., the UK under the current
  adequacy framework)
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Other appropriate safeguards as permitted under GDPR
  You may request details of the specific safeguards applied to any international transfer by
  contacting us.

Data Retention
We retain personal data only for as long as necessary for the purposes set out in this policy, or
as required by applicable law.

• Account data: Retained for the duration of your account and for up to 12 months after
  closure, to allow for reactivation and to resolve any outstanding issues
• Financial and billing records: Retained for 7 years as required by Irish tax and
  accounting law
• Support and communication records: Retained for up to 3 years
• Technical and usage logs: Retained for up to 12 months
• Marketing consent records: Retained until consent is withdrawn and for a reasonable
  period thereafter as evidence of consent
• Voice Recordings: Retained only for as long as necessary to provide the requested
  service (e.g., processing the reading) and for legal compliance, after which they are
  securely deleted.
  When data is no longer required, it is securely deleted or anonymised.

9. Cookies and Tracking Technologies
Our website uses cookies and similar technologies. In accordance with the ePrivacy

Regulations (SI 336/2011) and GDPR, we will request your consent before placing any non-
essential cookies.

Categories of cookies we use:

• Strictly necessary cookies: Essential for the website and application to function
  (session management, authentication, security). No consent required.
• Analytics cookies: Help us understand how visitors interact with our website (e.g.,
  pages visited, time on site). Used only with your consent.
• Functional/preference cookies: Remember your settings and preferences. Used only
  with your consent.
  You can manage your cookie preferences at any time using the cookie settings tool on our
  website, or by adjusting your browser settings. Withdrawing consent for non-essential cookies
  will not affect essential functionality.
  For more detail on the specific cookies we use, please see our Cookie Policy [link].

10. Your Rights Under GDPR
As a data subject under GDPR, you have the following rights. These rights are not absolute and
may be subject to limitations in certain circumstances.

• Right of Access (Art. 15): Request a copy of the personal data we hold about you and
  information about how it is processed.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete
  personal data.
• Right to Erasure / “Right to be Forgotten” (Art. 17): Request deletion of your personal
  data where there is no compelling reason for us to continue processing it.
• Right to Restriction of Processing (Art. 18): Request that we restrict processing of your
  personal data in certain circumstances.
• Right to Data Portability (Art. 20): Receive your personal data in a structured,
  commonly used, machine-readable format and transmit it to another controller, where
  processing is based on consent or contract and carried out by automated means.
• Right to Object (Art. 21): Object to processing based on legitimate interests or for direct
  marketing purposes. Where you object to direct marketing, we will cease processing
  immediately.
• Rights Related to Automated Decision-Making (Art. 22): We do not carry out solely
  automated decision-making, including profiling, that produces legal or similarly
  significant effects. If this changes, we will update this policy and provide appropriate
  information.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw
  it at any time. This will not affect the lawfulness of processing before withdrawal.
  How to Exercise Your Rights
  To exercise any of these rights, please contact us at privacy@lvlogics.com or by post at the
  address in Section 12. We will respond within one month of receipt of your request. We may
  need to verify your identity before processing your request. There is no charge for exercising your
  rights unless requests are manifestly unfounded or excessive.

11. Right to Lodge a Complaint
If you believe we have not handled your personal data in accordance with applicable law, you
have the right to lodge a complaint with the Irish supervisory authority:

Data Protection Commission (DPC) 21 Fitzwilliam Square South Dublin 2, D02 RD28 Ireland
Website: dataprotection.ie Phone: +353 (0)761 104 800
You also have the right to seek a judicial remedy. We would, however, appreciate the
opportunity to address your concerns before you contact the DPC, so please contact us in the
first instance.

12. Data Security
    We implement appropriate technical and organisational measures to protect your personal data
    against accidental loss, unauthorised access, disclosure, alteration, or destruction. Measures
    include:

• Encryption of data in transit (TLS/HTTPS)
• Encryption of data at rest
• Access controls and role-based permissions
• Regular security assessments
• Staff training on data protection obligations

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms,
we will notify the DPC within 72 hours and, where required, notify you without undue delay.

13. Contact Us
    For any questions, concerns, or requests relating to this Privacy Policy or our data practices,
    please contact:

Data Controller Contact LVLogics [Street Address] [City, County, Eircode] Ireland
Email: privacy@lvlogics.com Website: lvlogics.com

Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices,
technology, legal requirements, or other factors. We will notify you of material changes by
posting the updated policy on our website and updating the “Last Updated” date at the top of
this page. Where required by law, we will seek your consent to changes. We encourage you to
review this policy periodically.