Privacy Policy

Last updated: October 20, 2025

Introduction

Phare is incorporated as Lightkeeper OÜ, in Tallinn, Estonia.

Phare is committed to processing personal data securely and respecting the privacy of the concerned individuals.

1. Scope and Definitions

This Policy describes Phare's rules for personal data processing and protection. It applies to Lightkeeper OÜ and all employees and contractors ("we", "us", "our", "Phare"). Management ensures adequate procedures for implementation and monitoring.

The Privacy Manager (Nicolas Beauvais) is responsible for data protection compliance, supervising adherence to this Policy, and must be involved in all projects from the planning phase.

Competent Supervisory Authority: means a public authority that is responsible for regulating and supervising personal data protection with regards to activities of Phare.

Data Breach: means a breach of the security and/or confidentiality leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed. This includes but is not limited to e-mails sent to an incorrect or disclosed list of recipients, an unlawful publication of the Personal Data, loss or theft of physical records, and unauthorized access to personal information.

Data Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines (make a decision) the purposes and means of the processing of Personal Data.

Data Processor: means a natural or legal person, public authority, agency or other body which processes the Personal Data on behalf of the data controller.

Data Protection Laws: mean any laws and legal rules on personal data use and protection applicable to the activities of Phare, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, GDPR).

Data Subject Request (DSR): means any request from the Data Subject and concerning their personal data and/or data subject rights.

Data Subject: means a natural person, whose Personal Data we process. Data Subjects include but are not limited to users, website visitors, employees, contractors, and partners of Phare.

Personal Data: means any information relating to an identified or identifiable Data Subject; a Data Subject can be identified by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or the combination of factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that Data Subject.

Processing: means any operation or set of operations which is performed by Phare on Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Standard Contractual Clauses: means the European Commission Decision of February, 5 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council (2010/87/EU).

Third Party: means a natural or legal person, who accesses the Personal Data for further processing and is not an employee, member or corporate affiliate of Phare. This definition does not apply to natural persons, who provide services to Phare as contractors on a regular basis.

User: means a Data Subject who uses our services provided on Phare website.

2. Data Processing Principles

Phare’s processing activities must be in line with the principles specified in this Section. The Privacy Manager must make sure that Phare’s compliance documentation, as well as data processing activities, are compliant with the data protection principles.

We must process Personal Data in accordance with the following principles:

  • Lawfulness, fairness and transparency: We shall always have a legal ground for the processing, collect the amount of data adequate to the purpose and legal grounds, and we make sure the Data Subjects are aware of the processing;
  • Purpose limitation: Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Data minimization: We always make sure the data we collect is not excessive and limited by the strict necessity;
  • Accuracy: We endeavor to delete inaccurate or false data about Data Subjects and make sure we update the data;
  • Storage period limitation: Kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed;
  • Security: Process in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage.

The Privacy Manager must maintain Phare’s Records of processing activities, which is an accountability document that describes personal data processing activities of Phare. The Records must maintain, at least, specific information about each processing activity.

3. Access to Personal Data. Legal Grounds and Purposes

Each processing activity must have one of the lawful grounds specified in this Section to process the Personal Data.

Common grounds include:

  • Performance of the contract: When a contract with the Data Subject requires provision of personal data.
  • Consent: Must be obtained before processing.
  • Legitimate interests: Interests justified by the nature of our business activities.
  • Legal Compliance and Public Interest: Required to comply with laws of the EU or EU Member State.

Employee data access is on a "need-to-know" basis for activities specified in our processing records.

4. Third Parties

Before sharing personal data with any person outside of Phare, the Privacy Manager must ensure that this Third Party has an adequate level of data protection.

5. International Transfers

If transferring Personal Data to employees, contractors, or Data Processors outside of the EEA, necessary safeguards must be taken, including approvals and documentation.

6. Rights of Data Subjects

The Privacy Manager is responsible for DSR handling. Users and employees can submit DSRs via specified email addresses. We respond to DSRs within one month.

Data Subjects have rights to:

  • Learn if we process their Personal Data.
  • Obtain disclosure regarding aspects of the processing.
  • Have accurate and up-to-date data.
  • Restrict processing in specific situations.
  • Withdraw consent.
  • Request erasure of data when conditions are met.
  • Request data portability in machine-readable format.

7. New Data Processing Activities

New activities must be reported to the Privacy Manager for evaluation on compliance and potential DPIAs.

8. Data Retention

Clear data storage periods must be defined, followed by removal or destruction of data post-retention.

9. Security

Departments must implement security measures against unauthorized access or disclosure, supervised by the System Administrator.

10. Data Breach Response Procedure

A response team will be formed upon discovering a Data Breach to inform necessary parties and mitigate risks.

11. Questions?

For questions regarding Phare’s privacy policy or data protection practices, contact support@phare.io.