BinBot & SmartBins GDPR Compliance Notice

1. Data Controller & Legal Jurisdiction

This policy is governed exclusively by the laws of Ireland and applicable European Union regulations. SmartBins Ireland acts as the Data Controller (in co-operation with your residential development OMC as Joint Controller) for the operation of electronic bin store access and waste segregation monitoring.

Data Protection Officer (DPO):
Email: dpo@smartbins.ie
Address: SmartBins Data Governance Office, Dublin, Ireland.
Phone: +353 (0)89 457 0801

2. Principles of Data Processing (Article 5 GDPR)

We process your personal information adhering to the six core principles:

• Lawfulness, Fairness, and Transparency: We inform users clearly before any data is recorded. Unregistered users are notified of this policy upon their very first message.
• Purpose Limitation: Personal data is processed solely to authenticate authorized apartment residents, grant temporary latch release to communal bins, and provide waste recycling guidelines.
• Data Minimisation: We collect only the minimum necessary data: First & Last Name, Property Address (e.g. Apartment Number & Development), Mobile Phone Number / Email, and Age Verification (confirming 18+).
• Accuracy: Residents can update their details at any time via the Resident Portal or by messaging BinBot.
• Storage Limitation: Active message logs are retained only as long as necessary for auditing OMC bin store security. Erased on request or upon resident move-out.
• Integrity and Confidentiality: All data is encrypted in transit (TLS 1.3) and encrypted at rest in Google Cloud Firestore (EU-West region).

3. Lawful Basis for Processing (Article 6 GDPR)

Our processing relies on the following lawful bases under Irish and European law:

1. Performance of a Contract (Art. 6(1)(b)): Providing electronic bin lock release and residential waste management services to which the resident has registered.
2. Legitimate Interests (Art. 6(1)(f)): Protecting communal property, preventing unlawful commercial dumping/fly-tipping in apartment bin stores, and reducing OMC waste penalties.
3. Consent (Art. 6(1)(a)): Explicit resident consent provided during onboarding confirmation of age (18+) and agreement to terms.

4. Your Statutory Data Subject Rights

Under GDPR and the Irish Data Protection Act 2018, you possess the following rights:

• Right of Access (Art. 15): Request a complete export of your user details and unlock activity.
• Right to Rectification (Art. 16): Correct inaccurate contact or apartment details.
• Right to Erasure / Right to be Forgotten (Art. 17): Permanently scrub all your data by replying STOP.
• Right to Restrict Processing (Art. 18): Restrict the processing of your data while an OMC inquiry is reviewed.
• Right to Data Portability (Art. 20): Download your profile details in machine-readable JSON format from the Resident Portal.

5. Age Requirement (18+)

BinBot services and communal bin lock authorizations are restricted to individuals aged 18 years or older. Unregistered users must explicitly confirm they are over 18 during onboarding before their account is activated.

6. Supervisory Authority (Ireland)

If you have unresolved concerns regarding our data practices, you have the statutory right to lodge a complaint with the Irish supervisory authority:

Data Protection Commission (DPC) Ireland
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Website: www.dataprotection.ie
Phone: +353 (0)1 765 0100 / 1800 437 737