Privacy Policy

Last updated: June 12, 2025

1. Introduction

At ARKEOBOTS S.L. ("we", "us", "our"), protecting your privacy and personal data is a core priority. We are committed to ensuring full compliance with:

  • The EU General Data Protection Regulation (GDPR — Regulation 2016/679)
  • Spanish Organic Law on Data Protection and Digital Rights (LOPDGDD)
  • EU ePrivacy Directive
  • The EU Artificial Intelligence Act (AI Act — anticipatory compliance)

This Privacy Policy explains how we collect, process, store, and protect your personal data when you use our ARKEO robot and interact with our website and services.

2. Data Controller Information

  • Company Name: ARKEOBOTS S.L.
  • NIF (Spanish VAT ID): B21906508
  • Registered Address: Calle Ávila 89, Planta 4, Puerta 1, 08005 Barcelona, Spain
  • Contact Email: arkeobots@gmail.com
  • Data Protection Officer (DPO): At this stage, ARKEOBOTS S.L. does not appoint a Data Protection Officer, as no personal data is centrally processed or accessed. All user data remains encrypted and stored locally on the ARKEO device only.

3. Scope of this Privacy Policy

This Privacy Policy applies to:

  • Personal data processed directly by the ARKEO robot device
  • Personal data collected via our website, platform, and customer-support systems
  • All customers, users, and visitors whose data we may process

4. Types of Data We Collect

We only collect and process personal data that is strictly necessary for the provision of our services and the safety of our users.

A — Data collected by the ARKEO robot:

  • User identification: Name, configuration profile, authorised contacts
  • Interaction data: Transcribed text of dialogues and cognitive exercises
  • Cognitive monitoring data: Weekly test results and behavioural indicators
  • Emergency data: Photos captured in emergency protocols (only when triggered)
  • Device data: Serial number, configuration settings, system logs

Important:

ARKEO does not store raw audio or video recordings. Voice and video data are processed in real time and discarded immediately after extraction. Only the transcribed text is stored locally and securely encrypted on the robot device.

B — Data collected via our website and support services:

  • Contact forms: Name, email, phone, message content
  • Purchase and delivery information
  • Website usage data: IP address, browser type, cookies, analytics

5. Purposes of Data Processing

Robot Operation (ARKEO device):

  • To enable safe, effective operation of the ARKEO robot
  • To personalise interaction and adapt to user preferences
  • To perform non-medical cognitive-stimulation exercises
  • To monitor safety situations and trigger emergency protocols if required

Emergency Safety Protocols:

To contact authorised family members or emergency services in predefined situations of potential danger or non-responsiveness.

Quality Assurance & AI Safety:

To supervise, audit, and continuously improve the accuracy and safety of our AI models through expert human oversight.

Customer Service & Administration:

To provide technical support, respond to inquiries, and manage purchases and warranties.

Website Analytics (site only):

To monitor and improve website functionality, subject to consent for non-essential cookies.

6. Legal Bases for Processing

Processing PurposeLegal Basis
Robot operation & customer serviceContractual necessity (Art. 6.1.b GDPR)
Cognitive monitoring & personalisationExplicit consent (Art. 6.1.a & 9.2 a GDPR)
Emergency situationsProtection of vital interests (Art. 6.1.d GDPR)
AI supervision & safety auditsLegitimate interest (Art. 6.1.f GDPR)
Website cookies & analyticsConsent (Art. 6.1.a GDPR via Cookie Banner)

Note: Explicit consent is always collected prior to any processing of sensitive data related to cognitive monitoring or emergency contacts.

7. No Medical Decision-Making Disclaimer

Important Medical Disclaimer

  • ARKEO is not a medical device. Designed to provide daily social interaction and evidence-based stimulation (including clinical studies by healthcare professionals and organizations like the Alzheimer’s Foundation), ARKEO:
  • Does not diagnose, triage, or treat any medical condition.
  • May detect behavioral patterns suggesting potential risk and notify the user or their loved ones to seek medical evaluation.
  • Serves as a social and safety support tool, encouraging regular engagement, varied conversations (interesting, deep, or fun), cognitive and physical exercises, learning activities, and seamless family connectivity.
  • Is built on research-driven protocols but leaves all clinical decisions to qualified healthcare professionals.

ARKEO is first and foremost a neurocognitive decline prevention tool: it helps counteract loneliness by offering regular engagement, exercises, learning, and family connection. It complements but does not replace professional medical care when needed.

8. AI Transparency & Human Oversight

  • ARKEO uses supervised AI algorithms developed, trained, and calibrated under the oversight of qualified engineers.
  • Decision logic, safety thresholds, and interaction prompts are pre-defined and audited.
  • Automated emergency calls are triggered only if specific risk scenarios are detected and the user cannot confirm their situation.
  • Human oversight is applied at the design, monitoring, and audit levels to ensure ongoing safety, fairness, and ethical functioning.
  • No fully autonomous clinical or medical assessments are made.

9. Data Storage, Security & Retention

Storage Architecture:

  • All personal data generated by ARKEO’s interactions remain stored locally on the robot.
  • Transcriptions are encrypted at rest using AES-256 encryption.
  • Emergency event logs may be securely transmitted only when the protocol is activated.

Data Retention Periods:

Data TypeRetention Period
Transcribed dialoguesFor as long as the user maintains use of the robot
Cognitive dataWhile the user profile is active
Emergency recordsRetained only as required for legal, insurance, or audit reasons
Website contact dataMaximum 24 months
Analytics dataAs per Cookie-Policy consent settings

Security Measures:

  • End-to-end encryption for emergency data transmissions
  • Secure access control & user authentication
  • Role-based internal access to maintenance logs
  • Regular AI-model audits and data-accuracy verification
  • Continuous vulnerability monitoring and software updates

10. Subcontractors & Data Sharing

We do not sell or commercially share your personal data.

ARKEO robot data: Not transferred to third-party providers, except for emergency contacts or emergency services when necessary.

Website & administrative operations:

ProviderPurposeLocationProtection
AWS EuropeHosting websiteIrelandGDPR-compliant
Google Analytics 4Website analyticsUSALimited IP anonymisation + DPF

All subcontractors are bound by strict GDPR-compliant processing agreements.

11. International Data Transfers

No international data transfers occur from the ARKEO robot’s interaction data.

Limited transfers may occur for website operations and customer-support systems, fully protected under:

  • EU Standard Contractual Clauses (SCCs)
  • EU-U.S. Data Privacy Framework (DPF)
  • Appropriate technical safeguards (encryption, access controls, minimisation)

12. Your Data Rights

You have the following rights under GDPR:

  • Right of access to your personal data
  • Right to rectification of inaccuracies
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to object to certain processing
  • Right to data portability
  • Right to withdraw consent at any time
  • Right to lodge a complaint with the Spanish Data Protection Authority (AEPD)

You may exercise these rights by contacting us at: arkeobots@gmail.com

13. Privacy Protection Philosophy

We apply a strict privacy-by-design and data-minimisation approach:

  • We process only data strictly necessary to ensure your safety, improve your experience, and fulfil legal obligations.
  • We do not monetise your data in any form.
  • We constantly review and improve our AI models to ensure fairness, transparency, and accountability.
  • Your trust and safety are our highest priorities.

14. Policy Updates

This Privacy Policy may be updated periodically to reflect regulatory, technological, or operational changes.

The most recent version will always be available on our website, and we will notify users of any material changes via registered email or prominent in-app notices.

15. Contact Information

Company Information:

  • Email: arkeobots@gmail.com
  • Phone: +34 6 54 34 89 11

Registered Address:

  • ARKEOBOTS S.L.
  • Calle Ávila 89, Planta 4, Puerta 1
  • 08005 Barcelona, Spain
  • NIF: B21906508