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Data Act Transparency Declaration

EU Regulation (EU) 2023/2854 – Data Act

Last updated: @February 9, 2026

This Data Act Transparency Declaration is provided by LaylaElectric Inc. in accordance with Regulation (EU) 2023/2854 (the "EU Data Act"). It applies to the Layla connected device ("Layla Sensor") and related software services.

This document explains what data is generated by the Layla Sensor, how it is accessed, controlled, processed, and retained, and the rights of users regarding such data.

1. Provider information

Manufacturer and service provider

LaylaElectric Inc.

730 Arizona Ave

Santa Monica, CA 90401

United States

Contact email: legal@layla.eco

2. Device description

Layla is a connected Internet of Things (IoT) sensor designed to monitor environmental and operational conditions within residential and commercial properties. The Layla Sensor operates without cameras and without microphones for recording purposes.

The device supports monitoring and automation related to energy efficiency, safety, and environmental conditions.

3. Categories of data generated by the device

The Layla Sensor generates the following categories of data:

  • Environmental data, including temperature, humidity, air quality indicators, and smoke related signals
  • Event based data, including threshold based noise events and abnormal environmental conditions
  • Device operational and technical data, including connectivity status, firmware version, diagnostics, and system performance
  • Usage and metadata necessary for the functioning of the service

    • The Layla Sensor does not generate or collect raw audio recordings, voice data, video, images, biometric identifiers, or precise real time tracking data.

    4. Personal and non personal data distinction

    Most data generated by the Layla Sensor is non personal technical or environmental data.

    Where device generated data is linked to an identifiable user account or property, such data may constitute personal data and is processed in accordance with applicable data protection laws, including the GDPR, and Layla’s Privacy Policy.

    5. Access to device generated data

    Access to data generated by the Layla Sensor is strictly limited to:

  • The end user, via the Layla mobile application or web platform
  • Layla backend systems, solely for service operation, diagnostics, alerts, security, and product improvement

    • Layla does not share data with third parties for their independent use without user consent. Data may be shared with service providers (e.g., cloud hosting, communication tools) necessary to provide the Layla service.

    Layla does not provide API access or automated data sharing to third parties.

    6. Data portability and export

    Users may request access to and export of their device generated data.

  • Data export is handled manually through Layla support upon user request
  • Exported data is provided in commonly used electronic formats, including CSV and JSON

    • Requests can be submitted via Layla’s official support channels.

    7. Data deletion and retention

    When a user deletes their Layla account:

  • Device generated data is deleted within legally permissible timeframes
  • Layla may retain strictly anonymized and aggregated data for the purpose of improving sensor accuracy and service performance, provided such data can no longer be linked to an individual or property
  • Certain data may be retained for limited periods where required by applicable law, accounting obligations, security requirements, or dispute resolution

    • Once retention obligations expire, retained data is securely deleted or anonymized.

    8. Automated processing and device actions

    Layla performs limited automated processing necessary for device functionality.

  • Automated actions may include device level operations such as energy optimization or automatic shut off based on predefined conditions
  • Layla does not perform automated decision making that produces legal or similarly significant effects on users
  • Layla does not send automated alerts or data to third parties
  • Layla does not perform automated enforcement actions

    • All automation is designed to support user selected functionality and safety.

    9. Data monetization and advertising

    Layla makes the following commitments:

  • Device generated data is not sold
  • Device generated data is not licensed to third parties
  • Device generated data is not used for advertising profiling
  • Layla does not monetize device generated data

    • 10. User role and data control

    The end user is always the primary holder and controller of device generated data.

    This applies even when:

  • The device is installed in a rental unit
  • The property owner is different from the tenant

    • Property owners and landlords do not receive device generated data unless the end user explicitly grants access through Layla’s services.

    11. Security measures

    Layla implements appropriate technical and organizational measures to protect device generated data, including encryption, access controls, and secure infrastructure.

    12. Relationship to other policies

    This declaration supplements, and does not replace, Layla’s Privacy Policy and Terms of Service. In the event of inconsistency, applicable law and mandatory consumer protections prevail.

    13. Contact

    For questions regarding device generated data or this Data Act Transparency Declaration, contact:

    LaylaElectric Inc.

    Email: legal@layla.eco