Privacy Policy

The controller responsible for the processing described in this policy is:

• LeafShift Solutions
• The Netherlands
• Email: info@leafshift.net

If LeafShift Solutions is currently a trade name rather than a separate legal entity, the individual, partnership or company operating under that name is the controller identified above.

Pilot enquiries

When you request information or apply for a pilot, we may collect:

• your name;
• your farm, greenhouse, company or other operation;
• your email address;
• your telephone number, if provided;
• your country and region;
• information about crops, irrigation zones, sensors and relevant systems;
• the content of your enquiry; and
• subsequent communications relating to the potential pilot.

Name, operation, country and email address are required on our pilot-request form. Without them, we may be unable to assess or respond to your request. Other fields are optional unless we tell you otherwise.

Pilot participation

If a pilot proceeds, we may process:

• business contact and account information;
• sensor-platform and API account information;
• technical integration and system logs;
• sensor, irrigation and operational data;
• records of recommendations generated by LeafShift;
• records of decisions or actions supplied by the participating operation; and
• support, evaluation and pilot-report communications.

Operational farm data is not always personal data. This policy applies to it only where it relates to an identified or identifiable individual, such as a sole trader, employee or system user.

Please do not provide special-category personal data, such as health information, biometric data, political opinions or religious beliefs. LeafShift does not need this information to operate or evaluate a pilot.

Research-log subscriptions

When you subscribe to our research log, we collect:

• your email address;
• the date and source of your subscription;
• the consent wording or version that applied when you subscribed; and
• subsequent subscription or unsubscription events.

Business contacts

Where legally permitted, we may collect professional contact details from company websites, professional profiles, referrals or other public business sources. This may include a person’s name, role, organisation, business email address and the public source.

We use this information only for relevant, individually directed business communications about potential pilots or partnerships. We do not purchase bulk consumer mailing lists.

Technical website data

When you visit our website, Cloudflare and our systems may process technical information needed to deliver and protect the website, including:

• IP address;
• date and time of a request;
• requested page or resource;
• browser and device information;
• referring page;
• Cloudflare request or security identifiers; and
• information concerning suspected abuse or security incidents.

We do not use this information for advertising or cross-site behavioural tracking.

We use personal data for the following purposes:

Responding to pilot requests

When you request a pilot for yourself or as a sole trader, we process the information needed to take steps at your request before potentially entering into an agreement.

When you contact us on behalf of a company or other organisation, we rely on our legitimate interest in assessing the request, communicating with the organisation and developing potential business relationships.

Operating a pilot

We process personal data to prepare, provide, support and evaluate an agreed pilot and to produce the agreed reports and records.

Depending on the circumstances, this processing is necessary for performing a contract, taking pre-contractual steps, or pursuing our legitimate interests in administering and evaluating the service.

Where LeafShift processes personal data solely on behalf of a participating farm or organisation, that organisation remains the controller and LeafShift acts as its processor. The parties will enter into an appropriate data-processing agreement.

Model improvement

LeafShift may use pilot information for general model improvement only after it has been anonymised so that individuals are no longer reasonably identifiable.

We do not use identifiable or merely pseudonymised personal data for general model training unless this has been separately agreed in writing and a valid legal basis and appropriate safeguards have been established.

Sending the research log

We send research-log emails on the basis of your consent. Subscription is voluntary, and you may withdraw consent at any time by using the unsubscribe link in an email or contacting us.

Withdrawing consent does not affect processing that occurred before withdrawal.

Relevant business communication

Where legally permitted, we may rely on our legitimate interest in identifying and contacting relevant professional counterparts about a potential LeafShift pilot or partnership.

We consider the relevance of the person’s role, the source and nature of their contact information, the limited nature of the communication and their reasonable expectations. You may object to this processing at any time.

Website security and administration

We rely on our legitimate interest in securely operating, maintaining and protecting our website, forms, email systems and infrastructure.

Legal obligations and claims

We may process and retain information where necessary to comply with Dutch or European law, maintain required business records, prevent fraud, or establish, exercise or defend legal claims.

During a shadow-mode pilot, LeafShift may receive operational information and generate recommendations, but it does not make automated decisions about individuals that produce legal or similarly significant effects.

Pilot data is used to deliver and evaluate the agreed pilot. Any additional use, retention or sharing will be governed by the pilot agreement and, where applicable, a data-processing agreement.

Anonymised statistics that can no longer reasonably be linked to an individual may be retained for research, system evaluation and model improvement. Anonymous information is no longer personal data under the GDPR.

We do not use advertising cookies or third-party analytics that track visitors across websites.

We do not intentionally place non-essential cookies through our own website code. Depending on the security features activated for a particular request, Cloudflare may place strictly necessary cookies or similar identifiers to protect the website from malicious traffic and verify legitimate visitors.

Examples may include Cloudflare security cookies such as __cf_bm or cf_clearance. These are used for website security and traffic management, not advertising. More information is available in the Cloudflare cookie documentation.

If we introduce non-essential analytics or tracking technology in the future, we will update this policy and request consent where required before activating it.

We disclose personal data only where necessary to operate LeafShift, provide a requested service or comply with the law.

Our current provider categories include:

• Cloudflare, Inc., for website hosting, content delivery, website security, database or form-submission infrastructure;
• Plus Five Five, Inc., operating as Resend, for transactional and research-log email delivery;
• our business-email provider, which hosts or routes messages sent to and from LeafShift email addresses;
• professional advisers such as accountants, lawyers or insurers where necessary; and
• regulators, courts or public authorities where disclosure is legally required.

These providers may process personal data only for the relevant service and subject to applicable contractual and legal obligations.

We do not sell personal data and do not allow service providers to use pilot-request or subscription data for their own advertising.

Cloudflare and Resend are US-based providers, and they or their subprocessors may process personal data outside the European Economic Area.

Where personal data is transferred to a country without an applicable European Commission adequacy decision, we use appropriate safeguards such as the European Commission’s Standard Contractual Clauses and supplementary contractual or technical measures where required.

Resend states that its primary processing takes place in the United States and incorporates the Standard Contractual Clauses into its Data Processing Addendum. Cloudflare describes its international-transfer safeguards in its Data Processing Addendum.

You may contact info@leafshift.net to request further information about the safeguards applicable to your data.

We use the following retention periods unless a longer period is required by law or necessary for an ongoing legal matter:

• Pilot enquiries that do not proceed: up to 12 months after the last substantive communication.
• Professional outreach contacts that do not proceed: up to 6 months after the last communication.
• Active pilot information: for the duration of the pilot and evaluation period.
• Personal operational pilot data: deleted or returned within 90 days after delivery of the final report, unless the pilot agreement or data-processing agreement specifies another period.
• Research-log subscriptions: until you unsubscribe.
• Consent evidence and suppression records: only the minimum information necessary to demonstrate consent or prevent further messages, generally for up to five years after the final message.
• Website security logs: normally no more than 30 days, unless needed to investigate a security incident, abuse or legal claim.
• Contracts, invoices and required business-administration records: seven years where required by Dutch tax and administration law.

Information that has been effectively anonymised may be retained because it no longer identifies an individual.

When a retention period expires, we delete or anonymise the information, subject to normal provider backup and deletion cycles.

Depending on the circumstances and legal basis, you may have the right to:

• request access to your personal data;
• have incorrect or incomplete data corrected;
• request deletion of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain data in a portable format;
• withdraw consent at any time; and
• lodge a complaint with a supervisory authority.

These rights are not absolute. For example, we may need to retain certain information to meet a legal obligation, establish a legal claim or maintain a suppression record after an objection or unsubscription.

To exercise a right, contact info@leafshift.net. We may request limited additional information if reasonably necessary to confirm your identity.

You may unsubscribe from the research log at any time using the link included in each research-log email.

You may also lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens.

We use technical and organisational measures appropriate to the nature and risk of the processing. These include encrypted website connections, restricted access to personal data, account-security measures and controls intended to prevent unauthorised access, alteration, disclosure or loss.

No method of electronic storage or transmission eliminates every risk. We therefore review and improve our safeguards as LeafShift and its services develop.

The LeafShift website and services are intended for professional and business users and are not directed at children.

We do not knowingly collect personal data from children. If you believe a child has provided personal data to LeafShift, please contact us so that we can investigate and delete it where appropriate.

Our website may link to external websites such as LinkedIn. LeafShift is not responsible for how those external services process personal data. Their own privacy policies apply when you use them.

We may update this policy when our services, providers or legal obligations change. We will publish the revised version on this page and update the date at the top.

If a change materially affects how we use information already collected, we will provide additional notice where reasonably appropriate.

For questions, requests or complaints concerning privacy, contact:

• LeafShift Solutions
• The Netherlands
• Email: info@leafshift.net