Version: 0.1 (draft) · Last updated: [DATE OF PUBLICATION]
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The controller for the processing described here is:
[OPERATOR NAME]
[OPERATOR ADDRESS — full postal address, Portugal]
NIF/VAT: [OPERATOR NIF]
E-mail: [OPERATOR EMAIL]
[OPERATOR PHONE — optional]
All privacy requests (access, deletion, export, objection) go to [OPERATOR EMAIL].
Data Protection Officer: Verdaneo has not appointed a DPO. It is not required to:
Verdaneo's core activity is controlling irrigation valves, not the regular and systematic
monitoring of people on a large scale, and it processes no special categories of data
(Art. 37(1) GDPR). The reasoning is documented in `COMPLIANCE-CHECKLIST.md`. If this changes
(e.g. large-scale user tracking is added), a DPO will be appointed and this section updated.
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Verdaneo is a web application for scheduling and controlling garden irrigation. It stores
your garden's configuration, runs your watering schedules, fetches a weather forecast for your
garden's location, and switches your irrigation valves on and off.
It does not: show advertising, run analytics or tracking, sell or share data for marketing,
build user profiles, or contain any AI system. The "rain skip" logic is a fixed numeric
threshold comparison (if the forecast rain probability exceeds a number you set, the run is
skipped or you are asked), not machine learning and not an AI system within the meaning of the
EU AI Act.
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We do not collect: your name, postal address, telephone number, date of birth, payment card
data, or bank details. Verdaneo does not process payments at all — see section 6.
Note that zone names are free text. If you type personal information into a zone name (for
example a person's name), it is stored and shown as you typed it. Please do not put personal
data of other people into these fields.
The location is a fixed property of the garden that you set. Two ways exist to set it:
1. Search by city name. The text you type in the location search is sent to the
Open-Meteo geocoding service to look up matching places (see section 5).
2. "Detect once" — an optional button you press. [VERIFY BEFORE LAUNCH] In the current
code this lookup is executed by the Verdaneo server, which means the IP address
disclosed to the lookup provider (`ipwho.is`) is the server's IP address, not yours.
In the hosted service this would return the data centre's location, not your garden's, so
the feature is of no use in that form. Before launch this feature must either be removed
or moved to the browser — and if it is moved to the browser, your IP address will be
sent to the provider, this policy must say so, and the button must warn you before it runs.
See the flag at the end of this file.
We do not track your location continuously. There is no background geolocation, no GPS access
and no movement history.
These values are encrypted at rest with AES-256-GCM. They are never sent back to the browser and
are never visible to administrators in clear text. This is verified on every test run: real
credentials are written to a test installation and the database files are then searched for them.
You may object to processing based on legitimate interest at any time (section 8). For security
logs, we will normally be able to demonstrate compelling grounds to keep them for the short
retention period stated below, but we will consider each objection individually.
If you write to us, we process your message, your e-mail address, and anything you tell us,
to answer you. Legal basis: Art. 6(1)(b) if it concerns your contract, otherwise Art. 6(1)(f)
(our interest in answering enquiries addressed to us).
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Almost all data comes directly from you (Art. 13 GDPR). Two categories do not:
not to you personally.
to the search text you type.
We do not buy data, and we do not obtain data about you from data brokers, social networks, or
public registers (Art. 14 GDPR is therefore not otherwise engaged).
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The full internal register is kept in `dpa-processors.md`. In summary:
We do not use: analytics, advertising networks, tag managers, social plugins, external
fonts or CDNs, error-reporting SaaS, chat widgets, or e-mail marketing tools. The web interface
loads only files served from Verdaneo's own server.
Beyond the recipients above, we disclose data only where we are legally obliged to (for example
a valid order from a competent Portuguese authority), and we will inform you where we are
permitted to do so.
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Verdaneo uses a licence code model. The irrigation hardware and its installation are sold
and invoiced by the installer, outside the app. Verdaneo itself takes no payment, holds no
card data, and has no payment processor. We only store the licence code and the fact that it
has been redeemed by your account.
[DECISION NEEDED] If online payment (e.g. Stripe) is added later, that processor must be
added to section 5 and to `dpa-processors.md` before it goes live.
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Where Portuguese commercial or tax law requires longer retention of specific documents
(invoices are issued by the installer, not by Verdaneo), those legal periods take precedence
for the affected documents. **[VERIFY with the accountant whether Verdaneo itself holds any
document subject to a statutory retention period.]**
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Under the GDPR you have the right to:
the app at any time.
data is purged within 30 days.
machine-readable format (JSON), under Account in the app.
on grounds relating to your particular situation.
processing described here. If that ever changes, withdrawal will be as easy as giving consent.
To exercise any of these, write to [OPERATOR EMAIL]. We answer within one month
(Art. 12(3)); if a request is complex we may extend by two further months and will tell you why.
We do not charge for this, unless a request is manifestly unfounded or excessive.
Right to complain: you may lodge a complaint with the Portuguese supervisory authority:
CNPD — Comissão Nacional de Proteção de Dados
Av. D. Carlos I, 134, 1.º — 1200-651 Lisboa, Portugal
Telephone: +351 213 928 400 · E-mail: geral@cnpd.pt · www.cnpd.pt
[VERIFY these contact details at www.cnpd.pt immediately before publication.]
You may also complain to the authority of your EU country of residence or workplace, or go to
court.
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Verdaneo is hosted in the European Union (Hetzner, Germany/Finland) and the database never
leaves the EU.
Some data leaves our servers to third parties, as described in section 5:
country covered by a European Commission adequacy decision — no additional transfer
instrument is required.
Shelly Cloud mode**, which is the normal case when the app is hosted for you rather than
running on a machine inside your own home. Bulgaria is in the EU, so this is not a transfer
to a third country. In local mode the server speaks to the device directly over your own
network and no third party is involved at all.
not verified. [OPEN ITEM — remove the feature, or verify and document it.]
We do not transfer account data, e-mail addresses, schedules or watering history to any third
country.
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Verdaneo makes **no automated decisions producing legal effects concerning you or similarly
significantly affecting you within the meaning of Art. 22 GDPR, and performs no profiling**.
The software does automatically decide whether to water your garden: if the forecast
probability of rain in the next 6 hours is above the upper threshold you set, the run is
skipped; between your two thresholds you are asked and, if you do not answer within the grace
period you configured, the run proceeds; below the lower threshold it waters. These are fixed
numeric comparisons on weather data, set by you, affecting plants — not a decision about a
person.
Verdaneo contains no AI system and no chatbot. If an AI feature is ever added, it will be
labelled as required by Art. 50 of the EU AI Act and this policy will be updated first.
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We protect the service with, among other measures: HTTPS with automatically renewed
certificates; password hashing with scrypt; session cookies set `HttpOnly`, `Secure` and
`SameSite`, with expiring tokens; AES-256-GCM encryption of device secrets at rest; strict
per-user scoping of every database query so one customer can never see another customer's data;
rate limiting; input validation; security headers; CSRF protection; an audit log; and nightly
backups. The server runs with no third-party npm dependencies, which removes an entire class
of supply-chain vulnerabilities.
Every measure listed above exists and is covered by the automated test suite. Nothing in this
section is a statement of intent.
We hold no security certification. Verdaneo is not ISO 27001 certified, not SOC 2
audited, and makes no such claim.
Data breach: if a breach is likely to result in a risk to your rights, we notify the CNPD
within 72 hours (Art. 33) and, where the risk is high, we notify you directly (Art. 34).
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Verdaneo is not directed at children and is intended for the adult who owns or manages the
irrigation system. We do not knowingly create accounts for children.
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We will publish any material change in the app before it takes effect and, for changes that
affect you significantly, notify you by e-mail. The version number and date at the top always
show the current version.
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