Privacy Policy

Last updated: 29 July 2026

1. Introduction

Welcome to Xloora.

Xloora ("Xloora", "we", "our", or "us") is an agricultural intelligence platform developed and operated by XpectralTEK. We are committed to protecting your privacy and processing your personal information fairly, lawfully, and transparently.

This Privacy Policy explains how we collect, use, store, disclose, and protect information when you access or use:

  • the Xloora website;
  • the Xloora Cloud platform;
  • mobile applications;
  • connected hardware devices;
  • environmental monitoring stations;
  • multispectral acquisition devices;
  • artificial intelligence services;
  • customer support services;
  • and all related services (collectively, the "Services").

Our goal is to provide precision agriculture solutions while respecting your privacy and complying with applicable data protection laws, including:

  • Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR);
  • Portuguese data protection legislation;
  • the ePrivacy rules applicable within the European Union;
  • other applicable privacy and cybersecurity laws.

By accessing or using our Services, you acknowledge that you have read this Privacy Policy.

2. Data Controller

Unless otherwise specified, the Data Controller responsible for processing your personal information is:

XpectralTEK
Travessa dos Prados 13
4705-827 Braga
Portugal
Email: info@xpectraltek.com
Website: xloora.com

If you have any questions regarding this Privacy Policy or our processing of personal information, you may contact us using the above details.

3. Scope

This Privacy Policy applies to all information processed through:

  • xloora.com
  • Xloora Cloud
  • mobile applications
  • APIs
  • customer portals
  • support portals
  • connected agricultural devices
  • field sensors
  • weather stations
  • multispectral cameras
  • imaging devices
  • communications with Xloora

This Policy does not apply to third-party websites that may be linked from our Services.

4. Definitions

For the purposes of this Privacy Policy:

Account
means your registered Xloora user account.
Customer
means an individual or organization using Xloora.
Personal Data
means any information relating to an identified or identifiable natural person.
Agricultural Data
means information generated from farms, vineyards, orchards, fields, crops, soil, weather stations, sensors, drones, machinery, or connected devices.
Sensor Data
includes environmental measurements such as temperature, humidity, atmospheric pressure, rainfall, leaf wetness, soil conditions, GPS coordinates, and similar information collected by connected devices.
Spectral Data
means multispectral or hyperspectral imagery, reflectance values, vegetation indices, thermal information, and other optical measurements processed by Xloora.
AI Services
means machine learning, artificial intelligence, predictive analytics, computer vision, disease detection, stress analysis, recommendation engines, and automated reports generated by Xloora.
Processing
has the meaning given under the GDPR and includes collection, storage, use, disclosure, analysis, deletion, and any other operation performed on personal data.

5. Information We Collect

Depending on how you interact with Xloora, we may collect the following categories of information.

5.1 Information You Provide

When you create an account, request information, subscribe to our Services, or communicate with us, we may collect:

  • Full name
  • Email address
  • Telephone number
  • Company name
  • Organization
  • Farm name
  • Billing information
  • Postal address
  • Country
  • Preferred language
  • User credentials
  • Password (stored in encrypted or hashed form)
  • Profile picture (optional)

5.2 Account Information

Your account may include:

  • User ID
  • Subscription plan
  • Roles and permissions
  • Login history
  • Authentication methods
  • Account preferences
  • Notification settings
  • API credentials (where applicable)

5.3 Agricultural Information

To provide our Services, Xloora may process agricultural information, including:

  • Farm identifiers
  • Parcel boundaries
  • Field names
  • Vineyard blocks
  • Crop varieties
  • Planting dates
  • Irrigation information
  • Fertilization records
  • Crop management information
  • Harvest records
  • Weather observations
  • Agronomic notes

Where this information identifies or can reasonably be linked to an individual, it may constitute Personal Data under applicable law.

5.4 Device and Sensor Information

When connected devices are used, we may collect:

  • Device identifiers
  • Firmware version
  • Hardware serial number
  • Calibration information
  • GPS location
  • Sensor measurements
  • Environmental conditions
  • Network diagnostics
  • Battery status
  • Performance logs

5.5 Spectral and Imaging Data

Depending on your use of Xloora, we may process:

  • RGB images
  • Multispectral images
  • Hyperspectral images
  • Vegetation indices
  • Reflectance values
  • AI-generated annotations
  • Disease detection results
  • Nutrient deficiency analyses
  • Water stress indicators
  • Pest detection information
  • Plant health reports

These datasets are processed to provide analytical insights and recommendations through the Xloora platform. They may also be used to improve service quality where permitted by applicable law and contractual arrangements.

6. Automatically Collected Information

When you access our Website or Services, we may automatically collect technical information about your device and usage.

This may include:

  • IP address
  • Browser type and version
  • Operating system
  • Device type
  • Device identifiers
  • Screen resolution
  • Language preferences
  • Referring website
  • Date and time of access
  • Session identifiers
  • Clickstream information
  • Pages visited
  • Time spent on pages
  • Error logs
  • Performance metrics
  • API request logs

This information helps us operate, secure, maintain, and improve the Services.

7. Cookies and Similar Technologies

Xloora uses cookies and similar technologies to enhance user experience, maintain security, analyze website traffic, and improve our Services.

Cookies may include:

Essential Cookies

These cookies are necessary for:

  • User authentication
  • Session management
  • Security
  • Fraud prevention
  • Website functionality

These cookies cannot be disabled without affecting the operation of the Services.

Functional Cookies

Functional cookies remember your preferences, including:

  • Language
  • Region
  • Dashboard configuration
  • Display settings
  • Notification preferences

Analytics Cookies

With your consent where required by law, we may use analytics technologies to understand:

  • Website traffic
  • Popular pages
  • User interactions
  • Device types
  • Geographic regions
  • Feature usage

Analytics information is generally aggregated and used to improve the Services.

Security Cookies

Security cookies help detect:

  • Fraudulent activity
  • Automated attacks
  • Unauthorized login attempts
  • Suspicious behavior

Managing Cookies

You may configure your browser to:

  • reject cookies;
  • delete stored cookies;
  • receive notifications before cookies are placed; or
  • limit certain categories of cookies.

Please note that disabling essential cookies may prevent parts of the Services from functioning correctly.

8. How We Use Your Information

We process information only where necessary for legitimate business purposes and in accordance with applicable law.

We may use your information to:

Provide Services

  • Create user accounts
  • Authenticate users
  • Deliver cloud services
  • Synchronize connected devices
  • Generate reports
  • Store customer information
  • Manage subscriptions

Operate AI Services

To provide:

  • disease detection;
  • pest identification;
  • nutrient deficiency analysis;
  • irrigation recommendations;
  • crop stress analysis;
  • vegetation indices;
  • predictive analytics;
  • automated reporting;
  • anomaly detection; and
  • agronomic decision-support.

AI-generated outputs are intended to assist users and should not be considered professional agronomic, legal, or regulatory advice.

Improve Our Services

We may use information to:

  • improve AI models;
  • improve software performance;
  • optimize user experience;
  • troubleshoot issues;
  • develop new features;
  • evaluate system performance.

Where Personal Data is used for model improvement, we will do so only where permitted by applicable law or with appropriate consent or contractual authorization.

Communicate With You

We may contact you regarding:

  • account notifications;
  • security alerts;
  • software updates;
  • maintenance;
  • invoices;
  • support requests;
  • subscription renewals;
  • product announcements.

Where required by law, marketing communications will only be sent with your consent or another valid legal basis.

Protect Security

We process information to:

  • prevent fraud;
  • detect cyberattacks;
  • investigate abuse;
  • enforce our Terms of Service;
  • protect users;
  • comply with legal obligations.

9. Legal Bases for Processing (GDPR)

Where the GDPR applies, we process Personal Data on one or more of the following legal bases:

Contract Performance

Processing necessary to:

  • create accounts;
  • provide Services;
  • manage subscriptions;
  • process payments;
  • deliver reports;
  • provide customer support.

Legitimate Interests

We may process information where necessary to:

  • improve our Services;
  • secure our systems;
  • prevent fraud;
  • maintain business operations;
  • conduct analytics;
  • defend legal claims.

When relying on legitimate interests, we consider and balance your rights and freedoms against our legitimate business interests.

Consent

We rely on consent for certain processing activities, including where required for:

  • marketing communications;
  • optional cookies;
  • certain analytics;
  • other activities requiring consent under applicable law.

You may withdraw your consent at any time. Withdrawal does not affect processing already carried out before withdrawal.

Legal Obligation

We may process Personal Data to comply with:

  • tax obligations;
  • accounting requirements;
  • court orders;
  • regulatory obligations;
  • law enforcement requests;
  • applicable legislation.

10. Sharing Your Information

We do not sell your Personal Data.

We may disclose information only in the circumstances described below.

Service Providers

We may share information with trusted service providers assisting us with:

  • cloud hosting;
  • infrastructure;
  • email delivery;
  • authentication;
  • payment processing;
  • customer support;
  • monitoring;
  • cybersecurity;
  • analytics.

All such providers are contractually required to process information only on our instructions and to implement appropriate security measures where they act as processors under the GDPR.

Business Partners

Where necessary to provide requested services, we may share limited information with:

  • authorized distributors;
  • integration partners;
  • research partners;
  • implementation partners;
  • agricultural consultants;
  • laboratory partners (where requested by the customer).

Legal Requirements

We may disclose information when required:

  • by law;
  • by judicial order;
  • by governmental authorities;
  • to protect legal rights;
  • to investigate fraud;
  • to prevent illegal activities;
  • to protect public safety.

Corporate Transactions

If XpectralTEK undergoes:

  • merger;
  • acquisition;
  • investment;
  • restructuring;
  • sale of assets;
  • bankruptcy,

Personal Data may be transferred as part of that transaction, subject to applicable law. Users will be notified where required by law.

11. Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests.

Retention periods may include:

Category Typical Retention Period
Account Information While the account remains active and up to 5 years after closure where required by law
Subscription & Billing Records As required by applicable accounting and tax laws (generally up to 10 years in Portugal)
Customer Support Records Up to 3 years after the support request is resolved
Device & Diagnostic Logs Up to 24 months unless needed for security investigations
Authentication Logs Up to 12 months
Sensor & Environmental Data Until deleted by the Customer or according to the applicable service plan
Spectral Images & AI Analysis Until deleted by the Customer or account termination, unless otherwise agreed
Backup Copies Automatically deleted according to our backup retention schedule

When retention is no longer necessary, Personal Data will be securely deleted, anonymized, or irreversibly aggregated.

12. International Data Transfers

Xloora primarily stores and processes data within the European Economic Area (EEA). However, some service providers or technical infrastructure may involve transfers of Personal Data outside the EEA.

Where such transfers occur, we implement appropriate safeguards in accordance with Chapter V of the GDPR, including:

  • European Commission Adequacy Decisions;
  • Standard Contractual Clauses (SCCs);
  • other legally recognized transfer mechanisms;
  • additional technical and organizational safeguards where appropriate.

13. Security of Personal Data

We implement appropriate technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access.

Our security measures may include:

  • Encryption of data in transit using TLS;
  • Encryption of sensitive data at rest where appropriate;
  • Password hashing using industry-standard algorithms;
  • Multi-factor authentication for administrative access;
  • Role-based access controls;
  • Security monitoring and logging;
  • Vulnerability management and patching;
  • Secure software development practices;
  • Regular backups;
  • Business continuity and disaster recovery procedures;
  • Employee confidentiality obligations and security training.

Although we strive to use commercially reasonable means to protect Personal Data, no method of electronic transmission or storage can be guaranteed to be completely secure.

14. Your Rights Under the GDPR

If you are located in the European Economic Area or another jurisdiction providing similar rights, you may have the right to:

Right of Access

Request confirmation of whether we process your Personal Data and obtain a copy of that data.

Right to Rectification

Request correction of inaccurate or incomplete Personal Data.

Right to Erasure

Request deletion of your Personal Data where permitted by applicable law ("Right to be Forgotten").

Right to Restrict Processing

Request that we temporarily suspend processing of your Personal Data in certain circumstances.

Right to Data Portability

Receive your Personal Data in a structured, commonly used, machine-readable format and, where technically feasible, request that we transmit it to another controller.

Right to Object

Object to processing based on our legitimate interests or to direct marketing communications.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Right to Lodge a Complaint

If you believe that our processing violates applicable data protection law, you may lodge a complaint with your local supervisory authority.

For users in Portugal, this is generally the Comissão Nacional de Proteção de Dados (CNPD).

15. Automated Decision-Making and Artificial Intelligence

Xloora uses artificial intelligence, computer vision, statistical models, and machine learning to generate analyses, predictions, alerts, and recommendations regarding crop conditions, environmental factors, and agricultural management.

These AI Services may process:

  • multispectral imagery;
  • environmental measurements;
  • historical observations;
  • user-provided agricultural information;
  • sensor data.

AI-generated outputs are intended to support agricultural decision-making and should be interpreted as advisory information only.

Unless explicitly stated otherwise, Xloora does not make decisions producing legal effects or similarly significant effects solely through automated processing. Where Article 22 of the GDPR applies, users may request human review, express their point of view, and contest a decision.

16. Children's Privacy

Xloora is intended for professional and business use by farmers, agronomists, agricultural organizations, researchers, cooperatives, educational institutions, and commercial customers.

Our Services are not directed to children under the age of 16, and we do not knowingly collect Personal Data directly from children.

If we become aware that Personal Data relating to a child has been collected without appropriate legal authorization, we will take reasonable steps to delete that information.

17. Third-Party Services

Our Services may integrate with or link to third-party services, including:

  • cloud infrastructure providers;
  • authentication providers;
  • mapping services;
  • payment processors;
  • analytics providers;
  • communication services;
  • laboratory partners (where requested by customers);
  • weather or geospatial data providers.

These third parties maintain their own privacy policies and are responsible for their own processing activities.

18. Roles Under Data Protection Law

Depending on how the Services are used, Xloora may act either as a Data Controller or a Data Processor under the GDPR.

When Xloora Acts as a Data Controller

XpectralTEK acts as the Data Controller for Personal Data relating to:

  • account registration;
  • billing and invoicing;
  • website visitors;
  • customer support;
  • marketing communications;
  • platform administration;
  • security monitoring;
  • compliance with legal obligations.

In these cases, XpectralTEK determines the purposes and means of processing the Personal Data.

When Xloora Acts as a Data Processor

Where customers upload or manage Personal Data relating to their own employees, contractors, consultants, farm workers, or other individuals through the Xloora platform, XpectralTEK generally acts as a Data Processor, processing such information solely on the documented instructions of the customer, who acts as the Data Controller. This relationship should be governed by a separate Data Processing Agreement (DPA), where required under Article 28 of the GDPR.

19. Customer Data Ownership

Customers retain ownership of all data they upload to or generate through the Services, including, where applicable:

  • farm records;
  • field information;
  • vineyard maps;
  • crop management data;
  • environmental measurements;
  • weather station data;
  • multispectral and RGB images;
  • hyperspectral datasets;
  • AI analysis results generated from customer data.

By using the Services, customers grant XpectralTEK a limited, non-exclusive, worldwide, royalty-free license to host, store, reproduce, transmit, process, and analyze such data solely as necessary to:

  • provide the Services;
  • maintain system functionality;
  • generate reports requested by the customer;
  • create backups;
  • ensure platform security;
  • comply with legal obligations.

This license terminates when the customer permanently deletes the data or the agreement ends, except where continued retention is required by law or reasonably necessary to resolve disputes, enforce agreements, or maintain backups for a limited period.

20. AI Model Training

Xloora uses artificial intelligence and machine learning to assist users in monitoring crop conditions and generating agronomic insights.

Unless expressly agreed otherwise in writing:

  • Customer-specific Personal Data will not be used to train general-purpose AI models in a manner that identifies the customer or individuals.
  • We may use anonymized, aggregated, or de-identified information to:
    • improve algorithms;
    • validate models;
    • enhance detection accuracy;
    • improve platform performance;
    • conduct statistical analysis;
    • support research and development.

Where identifiable Personal Data would be used for model improvement, we will rely on an appropriate legal basis under applicable law and, where required, obtain consent or enter into contractual arrangements.

21. Personal Data Breaches

If XpectralTEK becomes aware of a Personal Data Breach affecting Personal Data processed on behalf of customers, we will respond in accordance with applicable law.

Where required, we will:

  • investigate the incident;
  • take reasonable measures to contain and mitigate its effects;
  • notify affected customers without undue delay where we act as a processor;
  • cooperate with customers in fulfilling their legal obligations;
  • notify competent supervisory authorities where legally required;
  • maintain records of security incidents.

Customers are responsible for assessing whether notification to affected individuals is required when they act as the Data Controller.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • changes in our Services;
  • technological developments;
  • legal or regulatory requirements;
  • security practices;
  • business operations.

When material changes are made, we will publish the revised version on our website and update the "Last updated" date. Where required by law, we will provide additional notice (such as by email or an in-platform notification).

Your continued use of the Services after the revised Privacy Policy becomes effective constitutes acknowledgment of the updated Policy, to the extent permitted by applicable law.

23. Contact Us

If you have any questions regarding this Privacy Policy, your Personal Data, or your rights under applicable data protection laws, you may contact us:

XpectralTEK
Travessa dos Prados 13
4705-827 Braga
Portugal
Email: info@xpectraltek.com

If XpectralTEK appoints a Data Protection Officer (DPO) or an EU Representative in the future, the relevant contact details will be published on the Xloora website.

24. Supervisory Authority

If you believe that the processing of your Personal Data infringes applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority.

For Portugal, this is generally the Comissão Nacional de Proteção de Dados (CNPD).

You may also contact the supervisory authority in the EU Member State of your habitual residence, place of work, or the place of the alleged infringement.

25. Effective Date

This Privacy Policy is effective as of the date indicated above and supersedes any previous versions.

By accessing or using Xloora, you acknowledge that you have read and understood this Privacy Policy.