Bright Hydrogen Solutions Privacy Policy
This Privacy Policy covers the services provided by Bright Hydrogen Solutions Limited Company (“BrightHy”, “we”, “us” or “our”). Bright Hydrogen Solutions is incorporated in Ireland with company registration number 781663 and having its registered address at The Victorians, 15 - 18 Earlsfort Terrace, Saint Kevin’s, Dublin. This Privacy Policy provides details of the way in which we process personal data in line with our obligations under the General Data Protection Regulation (No. 2016/679) (“GDPR”), the Data Protection Act 2018 and any other laws which apply to us in relation to the processing of personal data (collectively referred to as “Data Protection Laws”). In this Privacy Policy, “controller”, “personal data” and “process” (and its derivatives) have the meanings given to those terms in the Data Protection Laws.
Personal data generally means information that can be used to individually identify a person, and processing generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Bright Hydrogen Solutions will be the controller of your personal data processed in connection with our services.
The purpose of this Privacy Policy is to explain Bright Hydrogen Solution’s data processing activities, including how and why we process personal data. In addition, this Privacy Policy outlines our duties and responsibilities regarding the protection of such personal data. The manner in which we process personal data will evolve over time and we will update this Policy from time to time to reflect changing practices.
Personal Data We Collect
We collect personal data about you when you provide it directly to us or when personal data about you is automatically collected in connection with your use of the Bright Hydrogen Solutions (https://www.brighthy.com) (the “Website”).
You are not required to provide your personal data to Bright Hydrogen Solutions, however, as this information may be required for us to provide you with some of our services, we may not be able to offer our services without it.
In providing our services, we may collect and process the following information:
Personal Data Collected Directly From You
We receive personal data directly from you when you provide it to us through use of the Website, when you contact us or when you sign up to receive email alerts:
Name
Email address
job title/role
Personal Data We Automatically Collect
Some personal data is automatically collected when you use the Website, such as:
IP address
Device identifiers
Browser information
Cookie data (as explained in our Cookie Policy)
How We Use Personal Data
We process personal data to operate, improve, understand and personalize our services e.g. we use personal data to:
Communicate with you
Respond to inquiries
Protect against or deter fraudulent, illegal or harmful actions
Provide support and assistance
Comply with our legal or contractual obligations
Enforce our terms and conditions
Resolve disputes.
Lawful Basis for Processing
| Purpose of Processing | Lawful Basis under GDPR |
|---|---|
| Responding to queries and expressions of interest | We have a legitimate interest in responding to queries and expressions of interest, including if you sign up for email alerts. |
| Training, quality monitoring, evaluating the services we provide and maintaining the security of our IT environment. | Such processing is necessary for the legitimate interests pursued by us in monitoring and improving our services and their usage and ensuring that our users use the Website in accordance with our terms and conditions and policies. |
| Website services, including for troubleshooting, security, data analysis, and survey purposes | We have a legitimate interest in operating and maintaining the Website and for related purposes including improving our services. |
| Statistical information that cannot be related back to individuals to help us improve the services we offer | We have a legitimate interest in operating a website and for related purposes. |
| Enforcing and Defending Our Rights | We have a legitimate interest in ensuring that our services and the Website are used in accordance with our terms and conditions of use and policies. Where necessary for the purpose of complying with our legal obligations. Where necessary for the purpose of establishing, exercising or defending a legal claim, a prospective legal claim, legal proceedings or prospective legal proceedings. |
Individual Data Subject Rights
Data Protection Laws provide certain rights in favour of data subjects (the “Data Subject Rights”).
Data Subject Rights include the right of a data subject to:
Receive detailed information on the processing (as per transparency obligations on controllers) which we have provided through this Privacy Policy
Access personal data
Rectify or erase personal data (i.e. right to be forgotten)
Restrict processing
Data portability
Object to certain processing
Withdraw consent
Object to automated decision making (including profiling).
These Data Subject Rights are exercisable by you subject to limitations as provided for under Data Protection Laws. If you withdraw consent to processing (which is based on consent), this does not affect the lawfulness of processing based on consent prior to the withdrawal of consent.
In relation to the processing of your personal data by Bright Hydrogen Solutions, you may contact us or make a request to exercise any Data Subject Right by contacting info@brighthy.com. Your request will be dealt with in accordance with Data Protection Laws.
Disclosing Your Information
We do not share any personally identifying data with third parties and will not disclose your personal data to any other party except as set out in this policy. Bright Hydrogen Solutions may be required to disclose personal data in some scenarios e.g. when you violate our terms and conditions or other policies. Bright Hydrogen Solutions may disclose such personal data, at our sole discretion, if we believe it necessary or appropriate in connection with investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. This may require disclosure of your name, address, phone number, or email and any other identifying personal data processed by us through your use of our services.
Bright Hydrogen Solutions may engage other companies and people to perform tasks on our behalf (i.e. processors) and may need to share your information with them to provide you with our services e.g. hosting services. We share personal data with Gateway Group, Inc. our investor relations service provider.
As Bright Hydrogen Solutions is listed on the Nasdaq stock exchange, certain personal data of investors will be filed publicly with the U.S. Securities and Exchange Commission.
In some cases, Bright Hydrogen Solutions may buy or sell its assets which may involve the transfer of user information. Bright Hydrogen Solutions will transfer such information if we are acquired by or merged with another company.
Data Transfers
In order to provide our services to you, sometimes your personal data may be transferred outside the European Economic Area e.g. to the United States of America. Such transfers will occur in accordance with appropriate safeguards such as the European Commission’s standard contractual clauses. If you would like more information regarding the relevant safeguards in place, please send an email to info@brighthy.com.
Data Retention
We will keep personal data only for as long as the retention of such personal data is deemed necessary for the purposes for which that personal data are processed (as described in this Privacy Policy) unless we are required to retain your personal data for a longer period (e.g. in the event of legal proceedings or investigations).
Third Party Links
On occasion we include links to third parties on the Website. Where we provide a link it does not mean that we have any control over the linked website or its privacy policy or that we endorse, or approve that website’s policy towards visitor privacy. You should review the linked website’s privacy policy before sending them any personal data.
Service-related Announcements and Changes
Any changes to this Privacy Policy in the future will be posted to the Website and, where appropriate, through email notification. Bright Hydrogen Solutions may send you service-related announcements. You may not opt-out of service-related communications.
Contacting Us
For further information about this Privacy Policy or the processing of your personal data by or on behalf of Bright Hydrogen Solutions, please contact us at info@brighthy.com.
While you may make a complaint in respect of Bright Hydrogen Solution’s compliance with Data Protection Laws to the Data Protection Commission, we ask that you contact us in the first instance to give us the opportunity to address your concerns.
This Policy was last updated on 25 March 2025.