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)

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: approximate location derived from IP address

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:

Processing Activity	Lawful Basis
Creating and managing your account	Performance of a contract (Art. 6 (1) (b))
Providing and delivering our Services	Performance of a contract (Art. 6 (1) (b))
Processing payments	Performance of a contract (Art. 6 (1) (b))
Sending service and security notifications	Legitimate interests (Art. 6 (1) (f))
Improving and analysing our Services	Legitimate interests (Art. 6 (1) (f))
Marketing communications (where opted in)	Consent (Art. 6 (1) (a))
Analytics and non-essential cookies	Consent (Art. 6 (1) (a))
Complying with legal obligations	Legal obligation (Art. 6 (1) (c))

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.

8. 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

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

14. 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.

Notes for legal review before publishing:

• Insert company CRO number and registered address (Section 2)
• Confirm whether a Data Protection Officer (DPO) is required — mandatory if processing is large-scale, systematic, or involves special category data; if so, add DPO contact details
• Confirm the specific analytics and third-party tools in use and list them in the Cookie Policy (referenced in Section 9)
• If the app processes any special category data (health, biometric, etc.) under GDPR Art. 9, an additional explicit consent basis and section is required
• Verify international transfer mechanisms with any US-based cloud/SaaS providers used (Section 7)
• A solicitor registered in Ireland familiar with the DPC’s guidance should sign off before publication