Biogenic Ethics Charter
& Privacy Policy

Definitions & Scope

This Biogenic Ethics Charter ("Charter") applies to all persons ("Contributors") who register to participate in the FLATUTEC Biogenic Energy Contribution Programme ("Programme") operated by FLATUTEC sp. z o.o. ("FLATUTEC," "Company," "we," "our," and, on two occasions in this document, "us").

1.1 Key Definitions

• Biogenic Contribution: The voluntary emission of intestinal gas, captured via an approved MY2T™ device, for processing and energy conversion by FLATUTEC.
• Contributor: Any natural person who has completed the registration process, accepted this Charter, and is enrolled in the Programme. FLATUTEC does not accept corporate contributions at this time, though this is under review following enquiries from a well-known fast food chain whose identity we cannot disclose.
• MY2T™ Device: The proprietary wearable biogenic capture unit designed, manufactured, and distributed by FLATUTEC. Currently at Mark V revision. Mark VI in development.
• Capture Event: A discrete biogenic emission event recorded by the MY2T™ device. Capture Events are time-stamped, volumetrically measured, and graded by the MY2T™ AI system before transmission to MY2T™ Connect.
• Biogenic Energy Credit (BEC): The unit of value awarded to Contributors in exchange for their Capture Events, calculated in accordance with the Energy Credit Policy (available at energy-credits.html).
• The Programme: The entirety of FLATUTEC's contributor infrastructure, including registration, device provision, data capture, credit allocation, and energy conversion operations.

1.2 Scope

This Charter governs the relationship between FLATUTEC and all Contributors in all jurisdictions in which the Programme is active. Where local law provides rights exceeding those set out in this Charter, local law takes precedence. FLATUTEC takes the position that we exceed minimum legal requirements in all jurisdictions and we invite regulators to verify this by reading the full document, particularly Sections 5, 6, 7, and 9.

Core Ethical Principles

FLATUTEC operates under five core ethical principles, adopted by the Board of Directors at the Company's founding in 2020 and reviewed annually by the Ethics Review Board (see Section 15). These principles are not aspirational statements. They are operational requirements against which every policy and product decision is evaluated. Dr. Reinhart chairs the annual review and has, on two occasions, sent policy documents back to Legal citing violations of Principle 3. Legal was not pleased. This is fine. That is how it should work.

Voluntary Participation

Participation in the FLATUTEC Programme is entirely and irrevocably voluntary. No person is or can be required to join the Programme by any entity, including but not limited to: employers, landlords, governments, family members, partners, or well-meaning friends who "just think you'd be really good at it."

FLATUTEC explicitly prohibits the following:

• Any employer making Programme participation a condition of employment, interview, or promotion
• Any landlord offering reduced rent in exchange for Programme participation (three reported cases in 2023; all landlords received a strongly-worded legal letter from our team)
• Any person registering another person without that person's explicit and informed consent (see Section 4)
• Any arrangement in which a Contributor's BEC output is claimed by another party without a formal, notarised Credit Assignment Agreement (available on request; used primarily for spousal energy-bill optimisation arrangements)

Informed Consent

FLATUTEC requires informed, explicit, documented consent before any person joins the Programme. "Informed" means the person understands, at a minimum:

• What a MY2T™ device is and how it works
• What data is captured and transmitted
• How that data is processed and used
• What BEC credits are and how they are calculated
• The terms of this Ethics Charter in summary form
• That they are voluntarily submitting biologically-produced intestinal gas for commercial energy processing, because we are required to state this plainly and we believe this is fair

4.1 Consent Process

The consent process consists of three stages: (a) pre-registration information provision, including this Charter and the Programme summary; (b) a 24-hour reflection period during which the registration is held in "pending" status; and (c) a confirmed opt-in action initiated by the applicant after the reflection period. This three-stage process was implemented following feedback from our Ethics Review Board that "a button on a website" was insufficient given the nature of the Programme. They were right. The button is still there but it now comes after considerably more information.

4.2 Capacity to Consent

FLATUTEC requires that all Contributors be adults (18+) of full legal capacity. We do not accept contributions from persons who are intoxicated, under duress, or who have clearly not read the consent materials. The last of these is difficult to enforce technically, which is why we have made the materials genuinely interesting to read. Reader retention data from our consent portal is 73%, which our Legal team says is "unheard of" and which Dr. Reinhart says is because she wrote the materials herself. Both may be true.

Contributor Rights

Every Contributor has the following rights, which are active at all times and exercisable at no cost:

• Right to Access: A full export of all your Capture Event data, in machine-readable format, within 72 hours of request.
• Right to Rectification: Request correction of any inaccurate data held about you. We will action this within 14 days. We have received three rectification requests to date, all of which related to disputed Capture Event volumes. Two were upheld. One was not, because the MY2T™ AI's reading was, in that specific case, unambiguously correct and the contributor eventually agreed.
• Right to Erasure: Request deletion of all personal data. This right applies to personal identifying information; anonymised aggregate data cannot be erased as it has no personal identifiers to identify you by. We will confirm erasure within 30 days.
• Right to Portability: Transfer your Capture Event history to another service. We currently have no knowledge of another service to which this data would be transferable, but we support the right in principle.
• Right to Explanation: Receive a plain-language explanation of any automated decision affecting your credit balance, tier status, or device grade assignment.
• Right to Know Your Grade: Access your current and historical CH₄ purity grade data at any time through the FLATUTEC dashboard. This is your data. You made it. You should know what grade it is.
• Right to Withdraw: See Section 8. This right is unqualified, except as explained in Section 9, which we ask you to read carefully before raising a concern you will, upon reading Section 9, understand.

Data Privacy & EU/Polish Privacy Law

FLATUTEC sp. z o.o. is registered in Poland (KRS: 0000847001) and operates under EU law, including the General Data Protection Regulation (GDPR / Rozporządzenie o Ochronie Danych Osobowych, known in Poland as RODO), as implemented and supervised by the Polish data protection authority UODO (Urząd Ochrony Danych Osobowych). Our Privacy Officer is Dr. Sandra Reinhart, who holds this role in addition to her responsibilities as Chief Science Officer. This is unusual. It reflects the fact that the data and the science are, in our case, inseparable, and that Dr. Reinhart is the only person at FLATUTEC who is simultaneously qualified to hold both roles and willing to attend the RODO compliance training. She has attended it twice. She corrected the instructor on one occasion. The instructor agreed with her correction.

6.1 Data We Collect

• Account registration data: name, email, date of birth, address (required for credit redemption only)
• Device data: Capture Event timestamps, volumes, CH₄ purity grades, MY2T™ Connect transmission logs
• Credit data: BEC balances, transactions, redemption history
• Support data: the content of any communication you have sent to our team, retained for 2 years

6.2 Data We Do Not Collect

• Audio or visual data of any kind
• Location data beyond what you provide during registration
• Dietary information (the MY2T™ AI makes statistical inferences; it does not store dietary records)
• Any biometric data other than the chemical composition of captured gas
• Anything that might constitute a "portrait" of you as an individual beyond what is strictly necessary to run the Programme

6.3 Legal Basis for Processing

All data is processed under the GDPR (RODO) on the legal basis of explicit consent (Article 6(1)(a) and Article 9(2)(a) for health-adjacent data) and, where applicable, our legitimate interests in operating and improving the Programme. Gas composition data, which in our legal counsel's view constitutes health-adjacent data under GDPR Article 9, is processed under the explicit written consent of the Contributor. We have asked our lawyers whether intestinal gas chemistry is "special category data" under GDPR Article 9. They said "almost certainly yes, treat it accordingly." We have responded by treating it as Article 9 special category data in all circumstances. Dr. Reinhart says this is the correct approach. Legal agrees without reluctance. We note that UODO has not issued specific guidance on biogenic methane capture data categories. We have written to UODO twice. They have acknowledged our letters. We are treating this as indicative of ongoing review and also as remarkable responsiveness by EU administrative standards.

Anonymisation Standards

All Contributor data used for research, publication, or aggregate reporting purposes is anonymised before use. FLATUTEC's anonymisation standard meets the GDPR standard for anonymisation as described in Working Party Opinion 05/2014 (WP29) and is described in our Anonymisation Technical Standard document (FTI-ATS-2026-V2), available upon request. We have proactively shared this document with UODO. We have received an acknowledgement of receipt. We are choosing to interpret this positively.

In summary: Capture Event data used in research contexts contains no name, email, device serial number, or regional identifier more specific than country level. Our published research refers to contributors by coded identifiers assigned randomly at anonymisation. "Subject 7," for example, is a coded identifier. The contributor known publicly as "Subject 7" has, separately and voluntarily, publicly self-identified — including on the Community Leaderboard, under the alias "Subject7_Actual." This self-identification was their own decision and is not a breach of our anonymisation standards, which apply to FLATUTEC's disclosures, not the contributor's own.

Consent Withdrawal Procedures

Contributors may withdraw from the Programme at any time by:

• Submitting a withdrawal request through the FLATUTEC dashboard ("Account Settings" → "End Participation")
• Emailing withdrawal@flatutec.com from your registered email address
• Writing to FLATUTEC sp. z o.o., c/o Privacy Officer, at our registered office: ul. Ząbkowska 12, 03-736 Warsaw, Poland

Upon receipt of a withdrawal request, FLATUTEC will within 5 business days: (a) deactivate your MY2T™ device; (b) cease processing new Capture Events; (c) provide a final BEC statement; (d) initiate final credit payment or bill offset for any outstanding balance; and (e) begin data deletion in accordance with your instructions.

Please note: Withdrawal does not apply retroactively to data already processed and used in anonymised aggregate research published prior to the withdrawal request date. This is consistent with our legal obligations as a research-active company under applicable US federal and state privacy law. If you have a concern about this, please contact our Privacy Officer (Dr. Reinhart) directly. She responds to all messages personally and with unusual thoroughness.

The Mid-Harvest Clause

This section addresses, directly and transparently, the most frequently asked question raised by prospective contributors, journalists, and one Member of the European Parliament who emailed us in 2024 expressing "serious concerns" about biometric data handling and who has since declined to elaborate in three follow-up exchanges, though they have acknowledged our responses as "thorough."

The question is: Can I withdraw consent in the middle of a Capture Event?

The answer requires some explanation.

9.1 Technical Context

A Capture Event, once initiated, follows a defined physiological and technical sequence: emission, capture by the MY2T™ MY2T™ Core membrane, gas compression into the sealed MY2T™ Connect chamber, chemical grading by onboard sensor array, and encrypted transmission to our servers. This sequence occurs in approximately 0.3 to 1.2 seconds, depending on event volume and device generation. It is not a process that admits of human-speed interruption.

9.2 The Practical Situation

In practical terms, the question "can I withdraw consent during a Capture Event" is equivalent to asking "can I un-emit something." The physics of this are not in our favour and are, in any case, not of our making. FLATUTEC is capturing something that was going to occur regardless. We have not created the event. We are merely receiving it. We would submit that the concept of "consent withdrawal mid-event" does not apply to a process we do not initiate and which was, biologically speaking, already in progress.

9.3 Programme-Level Consent Withdrawal

To be absolutely clear: consent to participate in the Programme can be withdrawn at any time, with immediate effect, using the procedure described in Section 8. Upon withdrawal, no further Capture Events are recorded. What the clause above addresses is not Programme-level withdrawal — it addresses the impossibility of withdrawing consent for a single sub-second physiological event that has already physically occurred. Programme withdrawal stops all future events. It cannot reverse completed ones, for the same reason that you cannot un-ring a bell, only in a more specific and biological sense.

9.4 The MEP Correspondence

For reference, the MEP who raised this question received a full written response, including a version of the above explanation, a copy of our GDPR compliance documentation, and a complimentary MY2T™ Mark V device for "evaluation purposes." Their office confirmed receipt of the device. It has been evaluated. They have not returned it. They have not contacted us since. We note that three energy industry lobbying groups registered in Brussels filed EU consultations that referenced FLATUTEC within 60 days of the MEP’s correspondence. We are not making an accusation. We are presenting facts in temporal order.

MY2T™ Device Standards

All MY2T™ devices distributed by FLATUTEC meet or exceed the following standards:

• IP68 waterproof rating: Submersible to 1.5m for 30 minutes. Machine washable at 40°C. We tested this extensively. The testing was described by Chad Toots as "the best three months of my engineering career." We believe him.
• Biocompatibility: All materials in contact with the wearer's person are hypoallergenic and compliant with ISO 10993. Patch-tested on 200 volunteers (humans) and one dog (who completed the protocol and was awarded a small treat).
• Data security: All transmitted data is encrypted using AES-256. Transmission occurs via BLE to the FLATUTEC app and then via TLS 1.3 to MY2T™ Connect servers. No Capture Event data is stored on the device after successful transmission.
• No unauthorised data collection: The device contains no microphone, camera, GPS, or accelerometer. It measures exactly one thing: gas composition and volume. This was not an accident. It was a deliberate design decision and it is not changing.

Credit Transparency

FLATUTEC publishes a full public Credit Rate Schedule, updated quarterly, on the Energy Credits page. All rate changes are notified to active Contributors at least 30 days before they take effect. FLATUTEC has never reduced credit rates. We do not intend to reduce credit rates. We are publishing this statement in a legally binding document because we believe transparency about intent has value, even when not legally required.

Credit calculation methodology is open to contributor audit. Any Contributor who disputes a credit calculation may request a full algorithmic trace of their BEC calculation from the MY2T™ AI system. This trace will be provided in plain English, not source code, within 14 business days. Three traces have been requested to date. All three were found to be accurate. The MY2T™ AI has not made a credit calculation error since a brief incident in March 2023 involving a firmware update and an incorrectly calibrated temperature sensor in the Rotterdam district cluster, which resulted in 847 contributors receiving slightly elevated credits for 11 days. We corrected the error and did not claw back the excess. This cost us approximately €4,200. It was the right thing to do.

Children & Vulnerable Persons

FLATUTEC does not accept registration from persons under the age of 18. Age verification is performed at registration via a third-party identity verification service. Any account found to belong to a person under 18 will be immediately closed, all data deleted, and all accrued credits cancelled (or refunded to a parent/guardian if applicable).

We also have a Vulnerable Person Policy, available on request, which covers contributors who are registered with us but subsequently experience circumstances that affect their capacity to make informed decisions. In these cases, FLATUTEC will pause the account, not terminate it, pending contact with the contributor or their designated representative. Paused accounts accrue no Capture Events but retain their credit balance in full.

Research Use of Data

FLATUTEC conducts and publishes original research using anonymised contributor data. This research is conducted under ethics approval from our internal Ethics Review Board (Section 15) and, for externally published work, from the relevant institutional ethics committee of our research partners.

Contributors may opt out of research use of their anonymised data while remaining active in the Programme. Research opt-out is available in dashboard settings under "Data Preferences → Research Use." Approximately 2.3% of active contributors have opted out. We respect this entirely and it does not affect their tier status, credit rates, or any other aspect of their participation.

All published research using FLATUTEC data acknowledges the contributor cohort and thanks "the FLATUTEC contributor community." Our most cited paper, "Biogenic Methane: A Statistical Analysis of Diurnal Yield Patterns Across 18 Jurisdictions" (Reinhart et al., 2024, Nature Energy), carries this acknowledgment. The reviewers asked us to clarify the data source. We did. The paper was accepted. This is still somewhat surprising to Dr. Reinhart, who expected more pushback.

Third-Party Disclosures

FLATUTEC does not sell contributor data. We have been asked to sell contributor data on six separate occasions by parties who have, presumably, not read this Charter. We have declined on all six occasions and, on the most recent occasion, sent the requesting party a copy of this entire document with Section 14 highlighted in green.

Data may be shared with third parties only in the following circumstances:

• Credit redemption partners: Utility companies that process credit offsets receive only the credit value, not underlying Capture Event data.
• Legal obligations: FLATUTEC will comply with lawful court orders and regulatory requests. We will notify Contributors of any such disclosure unless prohibited from doing so by law. We will also, separately, contest any request we consider disproportionate. We have not yet had to do this. We are prepared to.
• Service providers: Our cloud infrastructure providers (AWS and Hetzner) process data under strict Data Processing Agreements. Their data access is limited to what is technically necessary for hosting.

Ethics Review Board

The FLATUTEC Ethics Review Board ("ERB") is an independent advisory body that reviews this Charter annually, evaluates proposed changes to the Programme's data and consent practices, and provides a formal opinion on any proposed research publication using contributor data.

The ERB comprises:

• Three external members, including a bioethicist, a data privacy lawyer, and a consumer rights advocate
• One internal member (Dr. Sandra Reinhart, in a non-voting capacity, available for technical questions)
• One contributor representative, elected annually by the contributor community via a vote in the FLATUTEC app under "Community" → "Ethics Board Election." Turnout in the 2025 election was 34%. The winner's platform was "stop making the consent form so long." We have not shortened the form. We have, however, made it more engaging. This document is the result.

The ERB's annual review report is published in full on the FLATUTEC website within 30 days of its completion. The 2025 report is available on request. It is 12 pages long and contains, in Section 4, a debate about Section 9 of this document that is, in our estimation, more entertaining than it should be.

Grievance Procedure

Any Contributor with a concern about their treatment under this Charter may raise a formal grievance through the following channels, in order of escalation:

1. Level 1 — Dashboard Support: Submit a support ticket through your FLATUTEC account. First response within 2 business days. 94% of queries are resolved at this level.
2. Level 2 — DPO Escalation: If unsatisfied with Level 1 resolution, email Dr. Reinhart directly at dpo@flatutec.com. Dr. Reinhart personally reviews all Level 2 escalations. She has described this as "the most interesting part of the job, though not always in a good way."
3. Level 3 — CEO Review: In the event of an unresolved Level 2 escalation, Dr. Toots personally reviews the case. Dr. Toots has handled three Level 3 escalations. In each case she called the contributor directly. Two of those contributors are now Silver tier. One asked to become an investor. We are not sure what this says about our grievance procedure but we have kept it as is.
4. Level 4 — External: Contributors have the right to lodge a complaint with UODO (Urząd Ochrony Danych Osobowych) or the relevant national supervisory authority at any time. FLATUTEC cooperates fully with regulatory investigations. We have not been the subject of one. We intend to keep it that way. UODO is aware of our existence. We know this because we have written to them on three separate occasions and received two responses.

Limitation of Liability

FLATUTEC's liability to any Contributor is limited to the value of accrued but unpaid BEC credits in that Contributor's account at the time of any claim, except where such a limitation is prohibited by applicable law, or where the claim arises from FLATUTEC's gross negligence or wilful misconduct.

FLATUTEC is not liable for:

• Social consequences arising from a Contributor's participation in the Programme being discovered by third parties who react poorly. FLATUTEC suggests a calm and factual explanation, the provision of a Programme factsheet, and a reference to the peer-reviewed literature. This works more often than one might expect.
• Dietary changes made by Contributors in pursuit of higher yield that result in outcomes — gastrointestinal, relational, or otherwise — beyond the Programme. The MY2T™ Coach dietary service provides recommendations based on published nutritional science. It is advisory. It is not, legally or morally, responsible for any consequential lentil-related incidents.
• Device failure resulting from use that exceeds the MY2T™ device specification. The specification is published. The device is rated to IP68. It is not rated for depths exceeding 1.5 metres. Several contributors have asked about this. We are not elaborating.

Governing Law

This Charter is governed by Polish law and, where applicable, the law of the European Union. Any dispute arising from it shall be subject to the non-exclusive jurisdiction of the Polish courts, specifically the courts of the city of Warsaw, except where mandatory local law requires otherwise. For US Contributors pre-registering for the Washington DC expansion: the Programme terms for your jurisdiction will be issued separately upon the Q3 2026 launch and will comply with applicable US and DC law.

For all EU Contributors: your rights under the GDPR (RODO) are set out in our Privacy Notice (FTI-PRIVACY-2026-V1), available on request and at privacy@flatutec.com. You have the right to lodge a complaint with the Polish supervisory authority UODO (Urząd Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw) at any time. UODO is, technically, within walking distance of our lab. We have walked past it. We have not been asked to stop.

We note that the regulatory framework specifically applicable to biogenic methane energy capture businesses under Polish and EU law remains, as of the date of this Charter, undefined by URE (the Polish energy regulator) and unclear under EFTA/EU taxonomy. Three EU energy officials have requested briefings. One requested a MY2T™ Mark V for "evaluation." We continue to operate with full compliance intent within every applicable framework, including frameworks that have not yet been written but which, if written, would apply to us.

Revision History

Signatories

This Charter has been reviewed, approved, and signed by the following individuals on behalf of FLATUTEC sp. z o.o.: