Privacy Policy

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.

• 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.

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

ARKEOBOTS S.L. may collect and process the following categories of personal data, depending on the user's relationship with our services, website, forms, products, or activities.

A — Customer, user, and service data:

• First and last name
• Email address
• Phone number
• Delivery or billing address, when necessary
• Information related to orders, purchases, information requests, demonstrations, or support
• Communications held with ARKEOBOTS S.L.
• Information necessary for the provision, management, and improvement of our services

B — Website, forms, and support data:

• Contact forms: name, email, phone, and message
• Registration forms for webinars, events, interviews, or demonstrations: first name, last name, email, city/country, optional phone number, participant profile, relationship to an older adult, responses regarding needs, interests, questions, and consent to be contacted
• Information voluntarily provided by the user in forms, surveys, interviews, or communications
• Website usage data: IP address, browser, device, pages visited, date and time of access, cookies, and analytics data
• Technical information necessary to ensure the security, operation, and improvement of the website

C — Data related to older adults, families, or professionals:

In the context of demonstrations, interviews, pilot programmes, webinars, or research activities, ARKEOBOTS S.L. may collect information voluntarily provided by families, caregivers, professionals, or partner entities regarding needs, experiences, difficulties, interests, or expectations related to companionship, social connection, and the well-being of older adults.

ARKEOBOTS S.L. will not request health data, medical diagnoses, or particularly sensitive information unless strictly necessary, voluntary, informed, and in accordance with applicable regulations.

ARKEOBOTS S.L. will process personal data for the following purposes:

A — Management of requests, customers, and services:

• Responding to requests for information, contact, or support
• Managing orders, purchases, deliveries, invoicing, and related communications
• Providing, maintaining, and improving our products, services, and experiences
• Managing relationships with customers, users, partners, suppliers, and interested parties
• Carrying out operational or administrative communications necessary for the provision of the service

B — Management of webinars, events, interviews, and demonstrations:

• Managing registrations for webinars, events, information sessions, interviews, or demonstrations
• Sending the access link, reminders, and communications related to the event
• Adapting the content of the webinar or event to the needs and interests of participants
• Answering questions submitted before, during, or after the event
• Contacting individuals who have agreed to receive further information, take part in interviews, or request a demonstration of Arkeobots
• Analysing responses internally and in aggregate to improve our services and better understand the needs of families, caregivers, professionals, and entities in the sector

C — Research, improvement, and product development:

• Better understanding the needs of older adults, families, caregivers, care homes, and professionals
• Improving the experience, usefulness, safety, and quality of Arkeobots' products and services
• Assessing interest in future features, demonstrations, pilot programmes, or partnerships
• Carrying out internal analysis, in aggregate or anonymised form whenever possible

D — Informational and commercial communications:

• Sending information about Arkeobots, Arkeo, events, news, interviews, demonstrations, or possible partnerships, only where a valid legal basis exists
• Managing unsubscription or withdrawal of consent from communications
• Maintaining an informational relationship with individuals who have shown interest in our products, services, events, or activities

E — Security, legal compliance, and administration:

• Ensuring the security of the website, forms, communications, and systems
• Preventing misuse, unauthorised access, or fraudulent activity
• Complying with legal, tax, accounting, administrative, or regulatory obligations
• Handling requests to exercise data protection rights

The processing of personal data by ARKEOBOTS S.L. is based on one or more of the following legal bases, depending on the case:

A — Consent of the data subject — Art. 6.1.a GDPR:

ARKEOBOTS S.L. may process personal data when the user has given free, specific, informed, and unambiguous consent, for example:

• By completing a contact form
• By registering for a webinar, event, interview, or demonstration
• By agreeing to receive communications related to Arkeobots
• By agreeing to take part in interviews, surveys, tests, pilot programmes, or research activities
• By agreeing to the use of certain cookies or similar technologies, where applicable

The user may withdraw their consent at any time by writing to arkeobots@gmail.com, without affecting the lawfulness of the processing carried out before its withdrawal.

B — Performance of a contract or pre-contractual measures — Art. 6.1.b GDPR:

ARKEOBOTS S.L. may process personal data when necessary to:

• Manage purchases, orders, deliveries, invoicing, or support
• Provide services requested by the user, customer, or partner entity
• Respond to requests prior to a contract, partnership, or demonstration
• Manage contractual or pre-contractual relationships

C — Compliance with legal obligations — Art. 6.1.c GDPR:

ARKEOBOTS S.L. may process personal data when necessary to comply with applicable legal, tax, accounting, administrative, or regulatory obligations.

D — Legitimate interest — Art. 6.1.f GDPR:

ARKEOBOTS S.L. may process personal data where a legitimate interest exists, provided that the fundamental rights and freedoms of the data subject do not prevail. This may include:

• Responding to requests received
• Managing communications with individuals interested in Arkeobots
• Improving our products, services, events, forms, and website
• Analysing internally and in aggregate the needs of users, families, caregivers, professionals, and entities
• Ensuring the security, fraud prevention, and proper functioning of our systems
• Maintaining relationships with customers, partners, suppliers, or entities that have shown interest in our services

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.

• 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.

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:

• Contact and information request data: up to 24 months from the last interaction
• Data related to webinars, events, interviews, surveys, or demonstrations: up to 24 months, unless the user requests earlier deletion
• Informational or commercial communications data: until the user withdraws consent or unsubscribes
• Customer, order, invoicing, or transaction data: for the periods legally required under applicable tax, accounting, or administrative regulations
• Data related to support, incidents, or operational communications: for as long as necessary to handle the request and, subsequently, for the period necessary to address any potential liabilities
• Technical data, cookies, or web analytics: as set out in the cookie policy or corresponding settings

When data is no longer necessary, ARKEOBOTS S.L. will proceed to delete, anonymise, or block it, as legally applicable.

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

ARKEOBOTS S.L. may use external providers to deliver certain services necessary for the operation of the website, forms, communications, events, administration, support, analytics, storage, or service provision.

These providers will act as data processors or service providers, as applicable, and will process data solely in accordance with the instructions of ARKEOBOTS S.L. and applicable data protection regulations.

A — Web operations, forms, and administration:

B — Website, hosting, and technical services:

C — Data sharing:

ARKEOBOTS S.L. does not sell personal data to third parties.

Personal data may only be shared in the following cases:

• With providers necessary to deliver technical, administrative, communication, forms, events, support, or analytics services
• With public, administrative, or judicial authorities where there is a legal obligation to do so
• With legal, tax, accounting, or professional advisors when necessary to comply with legal obligations or defend legitimate interests
• With partner entities only when necessary, proportionate, and where a valid legal basis or the data subject's consent exists

D — International transfers:

Should any provider process data outside the European Economic Area, ARKEOBOTS S.L. will adopt appropriate safeguards in accordance with applicable regulations, including adequacy decisions, standard contractual clauses, or other legally recognised mechanisms.

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)

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

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.

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.

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