Privacy notice.
This notice explains how BinSense handles personal data – both as the controller of our own website and prospect data, and as the processor of Customer data flowing through a smart-waste deployment. We have tried to write it plainly. Most of what BinSense processes is sensor telemetry that is not personal data; where personal data does enter the system, we say so.
- About this notice
- Who we are
- Our two-hat model: controller and processor
- Data we handle as a controller
- Data we handle as a processor
- A note on sensor telemetry
- Resident QR reports
- Lawful bases under UK GDPR
- International data transfers
- Retention
- Sub-processors
- Your rights and how to exercise them
- Cookies and analytics
- Security
- Personal data breaches
- Changes to this notice
- Complaints
- Contact us
About this notice
BinSense provides a smart-waste platform for UK councils, waste operators and large sites. The platform runs over a LoRaWAN sensor network and reports fill levels, lift events, optimised routes and a public QR-reporting channel back into a dashboard. This notice covers personal data we encounter in connection with that service and our marketing site at binsense.co.uk.
We have written this notice to be intelligible to a Data Protection Officer, a member, and an ordinary reader. Where we draw distinctions that have legal weight – between controller and processor, between telemetry and personal data, between what we can and cannot reach – we have flagged them in plain language. If anything here is unclear, the contact details in section 18 are real and monitored.
Who we are
BinSense is a service operated by [the Operator], a company registered in England and Wales (company number [number]), with its registered office at [registered office address] (in this notice, "we", "us", "our"). We are registered with the Information Commissioner's Office (ICO) under reference [ICO registration number].
For matters relating to this notice or any data we hold about you, please contact pilot@binsense.co.uk. For escalations specifically about privacy or data protection, please use compliance@binsense.co.uk; that mailbox is monitored by the person responsible for data protection at the Operator.
Our two-hat model: controller and processor
Under the UK GDPR, our responsibilities depend on whether we determine the purposes and means of processing (in which case we are a controller) or whether we act on behalf of another organisation that does (in which case we are a processor). In practice, we wear both hats:
- We are the controller for personal data we collect about visitors to binsense.co.uk, prospective Customers and people who fill in our contact form, our business contacts, and the staff at Customer organisations who administer the platform (account holders).
- We are the processor for personal data flowing through a Customer's smart-waste deployment: identifiers for crew accounts, the audit trail of who did what in the dashboard, and any personal data submitted via the resident QR-reporting channel. The Customer organisation – the council, contractor or site operator – is the controller of that data.
Data we handle as a controller
The categories of personal data we collect and process as a controller are limited. We do not buy lists, scrape contact details, or enrich data from third-party data brokers.
Website visitors
Our website is hosted on Azure Static Web Apps (Microsoft Azure). When you visit binsense.co.uk, Azure's network logs record your IP address, the time of the request, the resource requested, response status, user agent string and referrer. These logs are kept for short-term operational and security purposes (typically 30 days) and are not used to profile visitors or for any marketing purpose. We do not use third-party analytics, advertising tags, fingerprinting or session replay on this site.
Contact form submissions and demo requests
If you complete the contact form or email us to request a demonstration, you choose what to share. The form asks for your name, work email, organisation, role (optional), phone (optional), primary interest (optional) and a message. Your submission is delivered to our staff inbox at pilot@binsense.co.uk via a serverless function and is not retained anywhere else. We use it to respond to you, and (if a sales conversation begins) to keep a minimal record of the discussions we have had, so that we are not asking you the same questions twice.
Prospective and live Customers
If you become a paying Customer, we record the contact details of the people at your organisation who administer the account, our contractual correspondence with you, and the billing information needed to invoice and collect payment. We do not store full payment card details; card payments are processed by our payment provider (see Sub-processors).
People who write to us
Where you contact us by email, telephone, post or any other channel, we keep a record sufficient to provide a coherent reply and to demonstrate, where necessary, that we handled your enquiry properly.
Data we handle as a processor
When a Customer runs a smart-waste deployment on our platform, the personal data we process on their behalf is limited and set out in the Data Processing Agreement (DPA) that forms part of our contract. It typically includes:
- Staff and crew accounts. Names, work email addresses and role assignments of council/operator staff and drivers who log in to the dashboard or driver tablet app.
- Audit logs. A record of who logged in, who acknowledged or cleared an alert, and who altered a route or threshold. Held to evidence service levels and support investigations.
- Driver app telemetry. The route a vehicle followed during a round, the timestamps of bin lifts, and any "could not collect" notes the crew added. This is operational data about the round, not about identifiable members of the public.
- Resident QR-report submissions. Where a resident scans a bin's QR code and chooses to submit a report (e.g. "overflowing", "fly-tipping here", "damaged bin"), the system records the bin location, time, the issue category, and any free text or photo the resident chose to attach. Residents can submit anonymously. If they choose to leave a contact detail, that is personal data – see section 07.
None of this data is mined, profiled, sold, used to train machine learning models, or used for any purpose beyond providing the service the Customer has contracted for.
A note on sensor telemetry
The high-volume data on the platform is bin sensor telemetry: fill levels (sonar measurements), accelerometer-based lift events, battery readings, optional temperature, and the LoRaWAN identifiers and signal metrics needed to deliver the messages. Taken in isolation, this is not personal data: bins are not people. We process it strictly to provide the service.
There are corners where bin telemetry can become personal data – for example, when a single household has a uniquely identifiable bin and the lift schedule reveals something about their habits. We treat any such dataset with the same care as the staff and resident data described above, and we will not export bin-level data outside the dashboard except with the Customer's instruction.
Resident QR reports
Every bin can carry a QR code that lets a passer-by submit a quick report. The form is intentionally simple and asks only for what is needed to act on the report: category (overflowing, damaged, fly-tipping, etc.), an optional photo, an optional free-text description, and an optional email address or phone number if the resident wants to be told the outcome.
Where a resident provides personal data, we (acting as the Customer's processor) and the Customer (acting as the controller) handle it under the Customer's published privacy notice for their waste service. The Customer is expected to surface a short summary alongside the QR-reporting form making this clear; we provide template wording on request.
Photos are scanned at intake for stripping of GPS EXIF and other metadata. Free-text fields are sanitised. We do not run facial recognition or any other automated profiling on resident submissions.
Lawful bases under UK GDPR
Article 6 of the UK GDPR requires us to identify a lawful basis for each category of processing. The table below sets out the basis we rely on as a controller.
| Purpose | Personal data | Lawful basis (Article 6) |
|---|---|---|
| Operating and securing binsense.co.uk | Access logs (IP, user agent, request data) | Legitimate interests (running a website securely) |
| Responding to your enquiry or demo request | Form submission and any subsequent correspondence | Legitimate interests, or steps prior to entering a contract at your request |
| Managing the Customer relationship | Account administrator contact details, contractual records | Performance of a contract |
| Billing, accounting and tax compliance | Billing contacts, invoice records | Performance of a contract; legal obligation (tax law) |
| Detecting fraud, abuse or security incidents | Access logs, account activity | Legitimate interests (protecting Customers and the service) |
Where we rely on legitimate interests, we have carried out a balancing assessment that weighs our interest against your rights and freedoms. You can request a summary of any such assessment by writing to compliance@binsense.co.uk.
When we are acting as a processor (for deployment data), the Customer – not us – is responsible for identifying and recording the lawful basis under Article 6. For most council deployments the basis will be public task (Article 6(1)(e)), since waste collection is a statutory duty. We provide template wording and a Data Protection Impact Assessment template to help, but the assessment and the decision remain the Customer's.
International data transfers
The BinSense platform – including the LoRaWAN network server we run for Customers, the telemetry store, the dashboard and the contact form – is hosted on Microsoft Azure in UK Azure regions only. Personal data that we process as a controller or as a processor is stored in the UK by default.
A small number of sub-processors operate globally and may transfer data outside the UK as part of providing their service – for example, Stripe for card payments and Mapbox for map tiles. Each such transfer is covered by the UK Addendum to the EU Standard Contractual Clauses, or by a UK adequacy decision where one exists. The current list is on our Sub-processors page.
Retention
We hold personal data for no longer than we need it.
- Website access logs: 30 days.
- Contact form submissions and prospect correspondence: the active sales conversation plus 24 months, unless you ask us to delete them sooner.
- Customer account administrator records: for the duration of the contract plus 24 months for legal and operational record purposes.
- Audit logs and dashboard activity: as configured by the Customer, typically 12–24 months.
- Resident QR reports: as configured by the Customer in the DPA. Where a resident provided contact details for a follow-up, we delete those details once the report is closed unless the Customer's retention schedule provides otherwise.
- Billing and tax records: 7 years, in line with HMRC requirements.
Sub-processors
We list every sub-processor that touches Customer Data on our public Sub-processors page, with role, location of processing and applicable safeguards. The page is the authoritative version and is updated as the supply chain changes (see section 16 for change notification).
Your rights and how to exercise them
Under the UK GDPR you have the right to:
- Ask what personal data we hold about you and get a copy (a "Subject Access Request" or SAR);
- Ask us to correct inaccurate or incomplete data;
- Ask us to erase personal data we no longer need to hold;
- Restrict or object to certain processing;
- Receive your data in a portable format where the processing is automated and based on consent or contract;
- Withdraw consent where consent is the lawful basis for the processing.
For data we hold as a controller, write to compliance@binsense.co.uk. We will respond within one month and free of charge in all but the most exceptional cases.
For data we hold as a processor on a Customer's behalf – which includes most resident QR reports and any operational records linked to a specific Customer's deployment – please contact that Customer directly. We will help them respond, but the Customer is the controller and the decision-maker.
Cookies and analytics
The marketing site at binsense.co.uk sets no cookies and runs no analytics, advertising tags or session replay. Application Insights captures error and performance telemetry but does not set browser cookies and does not include any tracking pixels.
The signed-in dashboard uses a small number of strictly necessary first-party cookies to keep you signed in and to remember your dashboard preferences (e.g. dark mode). These are first-party and not used for marketing or cross-site tracking.
Security
Our security model is built on Microsoft Azure's certified infrastructure (ISO 27001/27017/27018, SOC 2). Data is encrypted in transit (TLS 1.2+) and at rest. Administrator access requires multi-factor authentication and is logged. Production access is restricted to named individuals on a least-privilege basis. We review configurations and access regularly and run periodic penetration tests.
Sensor uplinks travel over LoRaWAN with the standard application-layer encryption (AES-128) defined by the protocol. Device session keys are unique per sensor and rotated on rejoin.
Personal data breaches
If we become aware of a personal data breach affecting Customer Data we process on a Customer's behalf, we will notify that Customer without undue delay and, where feasible, within 72 hours, with the information they need to assess and (if required) notify the ICO under Article 33. For breaches affecting data we hold as a controller, we will notify affected individuals where the breach is likely to result in a high risk to their rights and freedoms.
Changes to this notice
We will keep this notice under review and update the effective date at the top when we make changes. Significant changes will be flagged on the homepage for at least 30 days and notified to account administrators by email.
Complaints
If you are unhappy with how we have handled your personal data, please raise it with us first at compliance@binsense.co.uk – we would rather hear about it directly so that we can put it right. You also have the right to complain to the Information Commissioner's Office at any time: ico.org.uk.
Contact us
General queries: pilot@binsense.co.uk.
Privacy and data protection: compliance@binsense.co.uk.
Postal: [registered office address].