1. Who we are (Data Controller)

Geneina International B.V.

A private limited liability company (Besloten Vennootschap) incorporated in the Netherlands.

Website: https://www.geneina.org

Contact email: privacy@geneina.org

For the purposes of the GDPR, Geneina International B.V. acts as:

• Data Controller for website, account, and administrative data

• Data Processor for customer operational and sensor data processed through GeneinaOS

2. Scope of this Privacy Policy

This Privacy Policy applies to:

• Visitors to our website

• Users of GeneinaOS

• Customers using Geneina sensors, controllers, or SaaS services

• Business contacts, partners, and investors

• Any individual whose personal data is processed by Geneina

It does not apply to third-party websites or services that may be linked or embedded within our website or platform.

3. Categories of data we collect

3.1 Website and communication data

When you visit our website or contact us, we may collect:

• Name

• Email address

• Company name

• Job title

• Phone number

• Message content

• IP address

• Browser type and version

• Device and operating system

• Referring URLs

• Date and time of access

3.2 Comments

When visitors leave comments on the site, we collect:

• The data shown in the comments form

• The visitor’s IP address

• The browser user agent string

This data is collected to support spam detection, moderation, and website security.

An anonymized string (hash) created from your email address may be provided to the Gravatar service to check whether you are using it.

Gravatar’s privacy policy: https://automattic.com/privacy/

Once approved, your profile picture may be visible publicly in the context of your comment.

3.3 Media uploads

If you upload images to our website or platform:

• You should avoid uploading images with embedded location data (EXIF GPS)

• Visitors may be able to extract such data from publicly accessible images

• Geneina is not responsible for metadata embedded by users

3.4 GeneinaOS platform and account data

When using GeneinaOS, we may process:

• User account details (name, email, role, permissions)

• Authentication and access logs

• Platform configuration data

• User preferences and interface settings

• Audit and security logs

3.5 Sensor, device, and operational data (GeneinaOS)

GeneinaOS processes non-personal operational data, including but not limited to:

• Environmental sensor data (temperature, humidity, light, EC, pH, irrigation events)

• Equipment telemetry and system status

• Time-series data generated by connected devices

• Farm or facility configuration parameters

• Usage metrics and performance indicators

Geneina does not require personal data about farm workers, consumers, or third parties to provide its services.

4. Purpose and legal basis for processing

We process data only where a lawful basis exists under GDPR.

Where consent is required, it may be withdrawn at any time.

5. Cookies

5.1 Comment cookies

If you leave a comment, you may opt in to cookies storing your name, email address, and website for convenience. These cookies last one year.

5.2 Login cookies

Temporary cookies are used to check browser compatibility.

Login cookies last two days; screen preference cookies last one year.

“Remember Me” extends login to two weeks.

5.3 Content editing cookies

If you edit or publish content, a cookie storing the post ID is saved for one day.

You can manage cookies via browser settings. Non-essential cookies require consent where applicable.

6. Embedded content from third-party websites

Articles or pages may include embedded content (e.g. videos, maps, images).

Embedded content behaves as if you visited the third-party website directly.

These third parties may collect data, use cookies, and track interactions according to their own privacy policies.

Geneina has no control over such third-party processing.

7. GeneinaOS, SaaS services, and sensor data processing

7.1 Provision of services

GeneinaOS processes sensor and operational data solely to deliver contracted services, including:

• Monitoring and visualization

• Alerts and notifications

• Analytics and recommendations

• Performance tracking

• System optimization

This processing is strictly necessary to perform our contractual obligations.

7.2 Machine learning, analytics, and research use

Geneina is a research-driven company. Where data is used beyond direct service delivery:

• Data is anonymised and aggregated

• Direct identifiers linking data to a specific customer, site, or operation are removed

• Data is processed only at a statistical or abstracted level

Anonymised data may be used to:

• Train and improve machine learning models

• Develop predictive and optimization algorithms

• Improve platform accuracy, robustness, and reliability

We do not:

• Share identifiable operational data

• Benchmark identifiable customers

• Reconstruct individual customer strategies

• Commercialize customer-specific data

7.3 Confidentiality, trade secrets, and IP protection

Geneina explicitly recognizes that customer operations contain confidential information and trade secrets.

We therefore commit that:

• Customer SOPs, growing methods, parameters, and configurations are treated as strictly confidential

• Such data is never shared with other customers or competitors

• Data is not sold or licensed for third-party commercial use

• Internal access is limited to authorized personnel on a strict need-to-know basis

Geneina’s internal policies and contracts enforce confidentiality obligations aligned with Dutch and EU law.

8. Data security measures

Geneina implements technical and organizational safeguards consistent with industry best practices and Dutch DPA expectations, including:

• Role-based access control (RBAC)

• Strong authentication mechanisms

• Logical separation of customer environments

• Secure cloud infrastructure

• Encryption in transit and, where applicable, at rest

• Continuous monitoring and access logging

• Incident detection and response procedures

• Regular internal reviews of security practices

While no system can guarantee absolute security, we take all reasonable measures to protect customer data.

9. Data sharing and subprocessors

We do not sell personal or operational data.

Data may be shared only with trusted subprocessors necessary to operate our services, such as:

• Cloud hosting providers

• Infrastructure and monitoring services

• Security and logging providers

• Professional advisors

All subprocessors:

• Are bound by GDPR-compliant Data Processing Agreements

• Act only on our documented instructions

• May not use data for their own purposes

A list of subprocessors can be provided upon request.

10. International data transfers

Where data is processed outside the EEA, Geneina ensures appropriate safeguards, including:

• Standard Contractual Clauses (SCCs)

• Adequacy decisions

• Equivalent lawful transfer mechanisms

11. Data retention

• Website and communication data is retained only as long as necessary

• Comments and metadata may be retained indefinitely

• Account and operational data is retained per contractual requirements

• Anonymised data may be retained for research and statistical purposes

12. Data ownership and roles

• Customers retain full ownership of their operational and sensor data

• Geneina acts as a data processor for such data

• Geneina acts as a data controller for website and administrative data

13. Your rights under GDPR

You have the right to:

• Access your data

• Rectify inaccurate data

• Request erasure

• Restrict processing

• Object to processing

• Data portability

• Withdraw consent

• Lodge a complaint with the Dutch DPA (Autoriteit Persoonsgegevens)

Requests may be sent to privacy@geneina.org.

14. Children’s data

This website and platform are not intended for children under 16. We do not knowingly collect children’s data.

15. Changes to this policy

We may update this Privacy Policy periodically. Updates will be published on this page with a revised “Last updated” date.

16. Contact

Geneina International B.V.

Website: https://www.geneina.org

Email: privacy@geneina.org