Privacy Policy

How personal data is handled in the SiloMatch mobile application.

1. Who is responsible for your data?

Constructie Lambrecht NV (“Lambrecht”, “we”, “us” or “our”) is the data controller for all personal data processed through SiloMatch.

Controller. Constructie Lambrecht NV

Enterprise/VAT number. BE 0407.821.256

Registered office. Hoogledestraat 122, 8610 Kortemark, Belgium

Privacy contact. info@lambrechttrailers.com (use subject line: SiloMatch privacy request)

SiloMatch holds no customer accounts, no workforce records and no delivery records. Your employer or the organisation that issued your device keeps its own records about you, and this Policy does not cover those — ask that organisation for its own privacy notice. It covers only what the App itself sends to Lambrecht.

2. Scope

This Policy applies to personal data processed through the SiloMatch mobile application, its supporting service infrastructure and our support channels. It also explains incidental image capture, where a person, vehicle registration plate or private property enters the camera’s field of view.

It does not replace the privacy notices of your employer, app store, device manufacturer or network provider.

3. Information we process

3.1 Session and device data

SiloMatch has no sign-up, no username and no password. On first launch the App creates an anonymous session for the device, identified by a random identifier that means nothing outside SiloMatch. We do not collect your name, email address, phone number, employer, role or job title, and we hold nothing that tells us which person is using a device.

Alongside that session we record the device platform, operating-system version, device model, manufacturer and device locale, so that a fault can be reproduced on the hardware that produced it.

Reinstalling the App creates a new session. Nothing connects it to the previous one.

3.2 Scan records

For each scan we record the date and time, the couplings the model detected and their confidence scores, the silo numbers the text recognition read, the silo number you confirmed, whether you typed it in yourself instead of accepting a reading, the app version and the session that submitted it.

A confirmed silo number identifies a silo at a delivery site, so a record also shows which site a device was at and when. Lambrecht holds no roster linking a device to a driver — but the organisation that issued the device usually can.

3.3 Photographs taken during a scan

When you start a check, the App takes a photograph and analyses it to find the discharge tube, the silo connection and the silo number. The photograph shows whatever the camera was pointed at, so people, registration plates and surrounding property can appear in it. The App does not try to recognise or identify anyone in the picture — it looks for equipment and for the silo number. Keep the frame on the equipment where you can.

Every photograph is kept. When you confirm a silo number, the App stores the photograph on the device and sends it to Lambrecht in the background, together with the scan record in section 3.2. This happens automatically, without a further step and without anything appearing on screen; if the device is offline it is sent later, once a connection returns. The copy on the device is deleted as soon as the server has accepted it. You are told about this collection when you first open the App, and it cannot be switched off — an App that could not collect these photographs could not be improved.

What we use them for. The photographs, the model’s readings and your confirmation together form the training material for the recognition models. We use them to train and evaluate new versions of those models, which are then shipped inside a new build of the App. We do not use them for any other purpose, we do not sell them, and we do not make them available to other customers or to third parties for their own use. Only the developers maintaining SiloMatch have access to them.

3.4 Device, usage and security data

App version, operating system, device model, language, network status, timestamps, session identifiers, crash reports, diagnostic events, IP address in server logs, and authentication and security events. Diagnostic and crash reports are handled by Sentry, hosted in the European Union. We do not request precise device location, and the App holds no location permission.

3.5 Support and communications

Your messages, contact details, attachments, issue description, troubleshooting steps and our responses when you contact us, or when the organisation that issued your device asks us to investigate an issue.

3.6 Data we do not seek

We do not seek personal contacts, microphone recordings, health information, payment-card data, advertising identifiers or special-category personal data, and the App requests no permission that would allow it. Its only device permission is the camera. Do not include such information in images, notes or support requests.

4. Where the information comes from

• From your device and the App automatically: the anonymous session, the device fields in section 3.1, and the scans and photographs in sections 3.2 and 3.3.

• Directly from you when you contact support.

We receive nothing about you from your employer, and SiloMatch is not connected to any transport, fleet, planning or identity system.

5. Why we use data and our legal bases

Provide the App

We use the anonymous session, the device fields and the camera to sign the device in, run the requested check and show you the result. Our legal basis is performance of the contract under which SiloMatch is made available, and our legitimate interest in delivering the service we agreed to provide.

Improve the recognition models

We use the photographs and scan records described in sections 3.2 and 3.3 to train and evaluate new versions of the coupling and silo-number models. Our legal basis is our legitimate interest in making a safety-relevant tool more accurate, together with performance of the contract under which SiloMatch is provided. A tool that misreads a silo number is a tool that puts the wrong product in the wrong silo, so improving it is a direct interest of everyone involved in the delivery.

We considered your interests against ours. The photographs are of equipment in a working yard rather than of people; they are not used to identify anyone; access is limited to the developers maintaining SiloMatch; and they are deleted after twelve months. You are told about the collection before you can use the App. You may object to this processing on grounds relating to your particular situation — see section 12.

Keep the service secure, and support it

We use authentication records, diagnostics, crash reports and server logs to prevent misuse, investigate security events and fix faults, and we use your messages to answer support requests. The legal basis is our legitimate interest in a secure and working service and, where applicable, compliance with a legal obligation.

Comply with law and establish legal claims

We may preserve and disclose relevant records to comply with binding legal requests, regulatory duties, product-safety obligations, insurance requirements, and to establish, exercise or defend legal claims. The legal basis is legal obligation or legitimate interest, as applicable.

Why we do not ask for your consent

You cannot unload a trailer without this App, so a consent box in front of the only route to work would not be a free choice, and consent that is not freely given is not valid consent. Rather than ask a question whose answer could only be yes, we tell you plainly what is collected before you can use the App, and we rely on legitimate interest and on the contract instead. The notice you pass on first launch confirms that you have read it; it does not ask you to agree.

6. Camera permission and privacy controls

The App asks for camera permission the first time the feature needs it and explains why. You can withdraw it in your device settings, but the check will no longer work. The App does not use the camera in the background.

Use the camera only for the intended check, and keep unrelated people and property out of the frame where you can. The App has no crop or preview step: the photograph it keeps is the frame it analysed. Site operators and customer organisations should use signs, procedures or other notices where incidental capture is reasonably foreseeable.

7. Vision output and human review

SiloMatch uses automated image analysis to find couplings and read silo numbers. The models consider visual features of the equipment and the label; they are not designed to identify a person.

The App proposes a reading and you confirm it. A number you type yourself always takes precedence over one the model read, and the confirmed value is the only one that proceeds. The App does not authorise unloading and does not communicate with the trailer or the silo controller.

No decision producing legal or similarly significant effects on you is made by automated means. If an organisation uses SiloMatch data for employee discipline, performance management or another significant decision, that organisation must establish its own lawful basis, transparency, safeguards and human review; such use is outside Lambrecht’s intended purpose.

8. Who receives information

We disclose personal data only where needed and subject to appropriate confidentiality, security and contractual controls:

• Service providers that support hosting, storage, identity, monitoring and secure software operation, and the IT contractor that develops and maintains SiloMatch under a data processing agreement.

• Professional advisers, insurers, auditors and potential transaction counterparties where reasonably necessary and protected.

• Courts, regulators, law-enforcement bodies or other authorities where disclosure is legally required or necessary to protect rights and safety.

We do not sell personal data, use it for third-party advertising or permit cross-app tracking. A current list of material subprocessors is available to business customers under the applicable data processing agreement.

9. International transfers

SiloMatch personal data is hosted and processed in the European Economic Area. The application database and image storage run in the eu-west-1 (Ireland) region, and diagnostic and crash reports are handled by Sentry in its European Union region.

If a service provider ever processes personal data outside the EEA, we will use a lawful transfer mechanism such as an adequacy decision or the European Commission’s Standard Contractual Clauses, together with supplementary measures where required. You may request information about the applicable safeguard through the privacy contact.

10. How long we keep information

We keep personal data only for as long as the purpose, the customer agreement and the law require.

We may keep a limited record longer where the law requires it, or where it is needed for a documented dispute, claim, product-safety investigation or security incident. Where we can, we de-identify data rather than keep an identifiable record.

11. Security

We use risk-appropriate technical and organisational measures designed to protect personal data, including access controls, least-privilege administration, encryption in transit and at rest where appropriate, environment separation, logging, secure development practices, vulnerability management, backups, supplier controls and incident-response procedures. No system is completely secure, so users must also protect devices and credentials and promptly report suspected misuse.

12. Your rights

Subject to the GDPR and applicable exceptions, you may ask for access to your personal data, correction, deletion, restriction or portability, and you may object to processing based on our legitimate interests — including the collection of photographs to improve the models described in section 5. You also have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, where Article 22 GDPR applies.

Because the App signs in anonymously and we hold no name or contact details, we usually cannot find your records from your identity alone. To make a request about specific scans, tell us the silo numbers and the approximate dates and times, so that we can locate them. If we genuinely cannot identify you from the data we hold, Article 11 GDPR may mean we cannot act on an access, correction or deletion request — we will explain this if it applies.

Send a request to info@lambrechttrailers.com with the subject “SiloMatch privacy request”. We normally respond within one month; complex requests may lawfully take longer, in which case we will explain why.

You may lodge a complaint with the Belgian Data Protection Authority at https://www.dataprotectionauthority.be or with the supervisory authority in the EU/EEA country of your habitual residence, place of work or alleged infringement. We encourage you to contact us first so we can try to resolve the issue.

13. Deleting your data

SiloMatch has no account to close. The App signs in anonymously for each device, and we hold no profile that could be deleted as a whole.

Deleting the App removes the session and any pending sample from the device. It does not delete scans and photographs already sent to Lambrecht; those are deleted on the schedule in section 10, or earlier on request under section 12 where we can identify them.

14. Children

SiloMatch is a professional tool and is not directed to children. Users must be at least 18 years old. We do not knowingly collect personal data from children through the App. Contact us if you believe a child has provided personal data so we can investigate and take appropriate action.

15. Changes to this Policy

We may update this Policy when the App, suppliers, legal requirements or processing practices change. We will update the version date and give reasonable notice of material changes through the App or through the organisation that issued your device. If a new purpose requires consent, we will request it before that processing begins.

16. Contact

Privacy contact. info@lambrechttrailers.com

Postal address. Constructie Lambrecht NV, Hoogledestraat 122, 8610 Kortemark, Belgium

Website. https://www.lambrechttrailers.com

If a data protection officer is appointed for SiloMatch, the published Policy should add that officer’s direct contact details here.