DOCUMENT INFORMATION
| Version | Date | Company |
|---|---|---|
1.0 | January 2026 | Recherche 2000 Inc. (R2) |
Legal Framework
This document is prepared in accordance with the EU Data Act (Regulation (EU) 2023/2854) and provides transparency regarding data generated by R2 connected products and related services.
For data access requests or inquiries, please contact: support@r2.ca
Data Security
On-Premise Products (EMOS® Safety, EMOS® EDE, EMOS® Pinhole Detector, EMOS® SCT, EMOS® Advisory)
Data stored on local servers is not encrypted at rest or in transit within the local network. The security of the local server environment is dependent on the customer’s plant IT security infrastructure and policies.
Customers are responsible for implementing appropriate network security measures, access controls, and physical security for the on-premise server infrastructure.
Cloud Services (EMOS® AIM)
EMOS® AIM is hosted on Microsoft 365 infrastructure with the following security measures:
Encryption:
- Data in transit: TLS 1.2+ (TLS 1.3 preferred) with Perfect Forward Secrecy (PFS)
- Data at rest: AES-256 encryption via Microsoft 365 SharePoint (Microsoft-managed keys)
Access Control:
- Multi-factor authentication (MFA) required for all access
- Role-based access control (RBAC) with least privilege principle
- Just-in-time (JIT) elevation for administrative tasks with automatic revocation
Data Protection:
- Database backup (not geo-redundant)
Compliance
- R2 aligns with ISO/IEC 27001 framework (certification in progress)
- EMOS® hardware complies with IEC 62443 (Cybersecurity for industrial automation and control systems)
- Privacy compliance with GDPR (EU) and Quebec Law 25
Third-Party Data Sharing
R2 does not share customer data with any third party without the customer’s explicit consent. Data generated by R2 products remains under the customer’s control and ownership.
Interoperability Standards
R2 products support the following interoperability standards for data access:
On-Premise Products
| Standard | Versions Supported |
|---|---|
OPC DA | 2.05a, 3.00 |
OPC Alarm and Events | 1.10 |
Cloud Services (EMOS® AIM)
| Standard | Description |
|---|---|
OpenAPI | REST API specification for data access and integration |
OAuth 2.0 | Authorization framework for secure API access |
OpenID Connect | Identity layer for authentication |
Data Rights
Customers have the following rights regarding their data:
- Ownership: Customers own all data generated by their use of R2 products
- Access: Customers can access their data through the methods described for each product
- Portability: Data can be exported to standard formats (CSV) where applicable
- Erasure: Customers can request deletion of their data at any time
- Third-party sharing: Customers may authorize R2 to share data with designated third parties
Product Data Characteristics
EMOS® Safety
This connected product is a plant safety system capable of generating product-related data as follows:
(a) Type, Format, and Estimated Volume:
The product generates operational and performance process data. Estimated real-time volume is approximately 1,000 data points every 2 seconds per electrolyzer.
Data is stored in R2DB proprietary flat file format. Storage requirements are difficult to predict and specific to each plant’s conditions and data noise. Estimated long-term storage increment is approximately 32 MB per week (based on 1,000 data points stored every 5 minutes).
(b) Data Generation Capability:
The product is capable of generating data continuously and in real-time during plant operation.
(c) Data Storage:
Data is stored on a local server using two proprietary R2DB databases:
- Cyclic database with a 30-day retention period
- Long-term database for historical data archival
No data is stored on local workstations except for historical data extractions.
(d) Access, Retrieval, and Erasure:
- Users can access real-time data via the EMOS® View application
- Historical data can be visualized and exported to standard CSV format using EMOS® Visual Extractor
- Data is also available through standard OPC DA interface
- Data erasure can be performed upon customer request
EMOS® Early Detection Engine (EDE)
This connected product is capable of generating product-related data as follows:
(a) Type, Format, and Estimated Volume:
The product generates approximately 200 data points every 2 seconds per electrolyzer.
Data is stored in R2DB proprietary flat file format. Estimated long-term storage increment is approximately 6.5 MB per week per electrolyzer (based on 200 data points stored every 5 minutes).
(b) Data Generation Capability:
The product is capable of generating data continuously and in real-time during plant operation.
(c) Data Storage:
Data is stored on a local server using two proprietary R2DB databases:
- Cyclic database with a 30-day retention period
- Long-term database for historical data archival
No data is stored on local workstations except for historical data extractions.
(d) Access, Retrieval, and Erasure:
- Users can access real-time data via the EMOS® View application
- Historical data can be visualized and exported to standard CSV format using EMOS® Visual Extractor
- Data is also available through standard OPC DA interface
- Data erasure can be performed upon customer request
EMOS® Pinhole Detector
This connected product is capable of generating product-related data as follows:
(a) Type, Format, and Estimated Volume:
The product generates approximately 200 data points every 2 seconds per electrolyzer during diagnostic sessions. Sessions typically last approximately 1 hour and occur roughly once per month. Data is stored in R2DB proprietary flat file format.
(b) Data Generation Capability:
The product is capable of generating data intermittently during scheduled diagnostic sessions.
(c) Data Storage:
Data is stored on a local server using two proprietary R2DB databases:
- Cyclic database with a 30-day retention period
- Long-term database for historical data archival
No data is stored on local workstations except for historical data extractions.
(d) Access, Retrieval, and Erasure:
- Users can access real-time data via the EMOS® View application
- Historical data can be visualized and exported to standard CSV format using EMOS® Visual Extractor
- Data is also available through standard OPC DA interface
- Data erasure can be performed upon customer request
EMOS® Single Cell Temperature Evaluator (SCT)
This connected product is capable of generating product-related data as follows:
(a) Type, Format, and Estimated Volume:
The product generates approximately 200 data points every 2 seconds per electrolyzer.
Data is stored in R2DB proprietary flat file format. Estimated long-term storage increment is approximately 6.5 MB per week per electrolyzer (based on 200 data points stored every 5 minutes).
(b) Data Generation Capability:
The product is capable of generating data continuously and in real-time during operation.
(c) Data Storage:
Data is stored on a local server using two proprietary R2DB databases:
- Cyclic database with a 30-day retention period
- Long-term database for historical data archival
No data is stored on local workstations except for historical data extractions.
(d) Access, Retrieval, and Erasure:
- Users can access real-time data via the EMOS® View application
- Historical data can be visualized and exported to standard CSV format using EMOS® Visual Extractor
- Data is also available through standard OPC DA interface
- Data erasure can be performed upon customer request
EMOS® Advisory
This connected product is capable of generating product-related data as follows:
(a) Type, Format, and Estimated Volume:
The product generates approximately 2,000 data points per minute per electrolyzer in real-time.
Data is stored in R2DB proprietary flat file format. Estimated long-term storage increment is approximately 63 MB per week per electrolyzer (based on 2,000 data points stored every 5 minutes).
(b) Data Generation Capability:
The product is capable of generating data continuously during operation.
(c) Data Storage:
Data is stored on a local server using two proprietary R2DB databases:
- Cyclic database with a 30-day retention period
- Long-term database for historical data archival
No data is stored on local workstations except for historical data extractions.
(d) Access, Retrieval, and Erasure:
- Users can access real-time data via the EMOS® View application
- Historical data can be visualized and exported to standard CSV format using EMOS® Visual Extractor
- Data is also available through standard OPC DA interface
- Data erasure can be performed upon customer request
EMOS® Load Distribution Management (LDM)
This connected product is capable of generating product-related data as follows:
(a) Type, Format, and Estimated Volume:
The product generates approximately 7 data points every 30 seconds per electrolyzer.
Data is stored in R2DB proprietary flat file format. Estimated long-term storage increment is approximately 0.6 MB per week per electrolyzer (based on 20 data points stored every 5 minutes).
(b) Data Generation Capability:
The product is capable of generating data continuously and in real-time during operation.
(c) Data Storage:
Data is stored on a local server using two proprietary R2DB databases:
- Cyclic database with a 30-day retention period
- Long-term database for historical data archival
No data is stored on local workstations except for historical data extractions.
(d) Access, Retrieval, and Erasure:
- Users can access real-time data via the EMOS® View application
- Historical data can be visualized and exported to standard CSV format using EMOS® Visual Extractor
- Data is also available through standard OPC DA interface
- Data erasure can be performed upon customer request
EMOS® Asset Inventory Management (AIM)
This cloud application is used to manage electrolysis plant assets and is capable of handling product-related data as follows:
(a) Type, Format, and Estimated Volume:
- Data is stored in SQL database format
- Maintenance activities are tracked in multiple tables as a ledger
- Approximately 600 assets per electrolyzer can be managed
- File attachments of any type can be associated with assets (stored in a separate database)
- Data volume increase is minimal per session
Note: EMOS® AIM does not generate data on its own; it stores and manages user-entered data and uploaded files.
(b) Data Generation Capability:
The application is used intermittently by maintenance teams as needed.
(c) Data Storage:
Data is stored in the cloud. No data is stored on local devices.
(d) Access, Retrieval, and Erasure:
- Users can access data via the web application
- Terms of use and quality of service documentation are currently being developed
- Customers own all data stored in the system
- Data erasure can be performed upon customer request to R2
EMOS® Cell Performance Analyzer (CPA)
This related service is capable of generating service-related data as follows:
(a) Type, Format, and Estimated Volume:
The service generates one report and 3 to 5 key performance indicators (KPIs) per month.
(b) Data Generation Capability:
The service generates data intermittently on a monthly basis.
(c) Data Storage:
Reports and KPIs are accessible through the EMOS® AIM platform.
(d) Access, Retrieval, and Erasure:
Users can access reports and KPIs via the EMOS® AIM web application.
EMOS® Plant Health Assessment
This related service is capable of generating service-related data as follows:
(a) Type, Format, and Estimated Volume:
The service generates a comprehensive plant health assessment report.
(b) Data Generation Capability:
The service generates data intermittently upon request.
(c) Data Storage:
Reports are delivered directly to the customer.
(d) Access, Retrieval, and Erasure:
Reports are sent directly to the customer who maintains ownership and control.
EMOS® Advisory Historical Analysis
This related service is capable of generating service-related data as follows:
(a) Type, Format, and Estimated Volume:
The service generates a historical analysis report.
(b) Data Generation Capability:
The service generates data intermittently upon request.
(c) Data Storage:
Reports are delivered directly to the customer.
(d) Access, Retrieval, and Erasure:
Reports are sent directly to the customer who maintains ownership and control.
Limitations and Exclusions
The following data may be excluded from access rights in accordance with Article 4(3) of the EU Data Act:
- Data protected as trade secrets, where disclosure would cause significant economic harm
- Data that could compromise the security or integrity of the products
Document History
| Version | Date | Description |
|---|---|---|
1.0 | January 2026 | Initial Release |
This document is prepared in accordance with EU Data Act (Regulation (EU) 2023/2854) disclosure requirements.