ARETÉ
The controller responsible for your personal data is:
Data Protection Officer (DPO): [name / "not appointed: assessment pending"]: [dpo@areteprotocol.com]. Because Areté processes special-category data and performs profiling, whether a DPO is legally required under Art. 37 GDPR is being assessed; a contact is provided regardless.
EU / EEA representative (Art. 27 GDPR): [name and EU address of the representative, if the controller is not established in the EU/EEA]. If the controller is established in the EU/EEA, no Art. 27 representative is required and this line will be removed.
We collect only the data needed to run the instrument and your account:
We do not use your data for advertising, and we do not sell it.
| Data / activity | Legal basis |
|---|---|
| Account, authentication, running the core instrument you asked for | Contract: Art. 6(1)(b): processing necessary to provide the service you signed up for |
| HRV, sleep, and your derived cognitive profile (special category) | Explicit consent: Art. 9(2)(a), together with Art. 6(1)(a). This is separate from, and additional to, the contract basis |
| Security, rate-limiting, abuse prevention, backups, service integrity | Legitimate interests: Art. 6(1)(f): keeping the service secure and reliable, balanced against your rights |
| Essential service email (verification, password reset) | Contract: Art. 6(1)(b) |
| Meeting legal/regulatory obligations | Legal obligation: Art. 6(1)(c), where applicable |
When you create an account you actively confirm consent to these terms; we record a server-side consent timestamp (not just a client-side checkbox) as an audit trail. Your provision of optional HRV/sleep data, and the derivation of your cognitive profile, rely on your explicit consent under Art. 9. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. To withdraw consent, stop providing HRV/sleep, delete the relevant data, or delete your account (section 10), or email contact@areteprotocol.com. Withdrawing consent for the special-category processing may mean the instrument can no longer produce a reading for you.
Areté does perform profiling within the meaning of Art. 4(4) GDPR: it analyses your forced-choice responses (and, if provided, HRV/sleep) to derive a cognitive signature, an integrity score, drift, and bias tendencies.
However, this profiling is not a solely-automated decision that produces legal effects concerning you or similarly significantly affects you under Art. 22(1). Specifically:
The meaningful logic is, in essence: your responses are scored against a cognitive-function model to estimate where your attention and judgement resolve, and how far your current state sits from your own baseline. Results are indicative, not validated diagnostics. If an institution ever uses Areté in a way that would make a decision with legal or similarly significant effect, additional Art. 22 safeguards (including a right to human intervention) would be required and this section would be updated.
compliance/DATA-RETENTION.md for the working schedule.Exact periods are being finalised with our lawyer and set out in the internal retention schedule.
We do not sell your data and do not share it with advertisers. We share it only with the infrastructure providers strictly needed to run the service, each under a data-processing agreement:
| Sub-processor | Purpose | Data | Location / safeguard |
|---|---|---|---|
| Render (Render Services, Inc.) | Application hosting, compute & database storage | All service data at rest | Hosted in the EU (Frankfurt) region; provider DPA + Standard Contractual Clauses for any US-parent access for any US-parent access |
| Resend (Resend, Inc.) | Transactional email (verification, password reset), only if enabled | Your email address and the link content | US-based; provider DPA + Standard Contractual Clauses |
| Anthropic (Anthropic, PBC) | The written reads (the Advisor, the Capture, the case read, the reading of what broke, the First Light read), only when you are signed in and only if enabled | The words of the decision or note being read; for the Advisor also your current reading and the counts from your own record. No name, email or account id is sent | US-based; provider commercial terms + Standard Contractual Clauses; inputs are not used to train models |
| Web push services (Google, Apple, Mozilla, Microsoft, depending on your browser) | Delivering the reminders you switch on | An encrypted message the service cannot read; the words of your decisions are left out unless you choose otherwise | Operated by your browser's maker |
A live register of sub-processors is maintained in compliance/SUB-PROCESSORS.md.
We may add or change sub-processors; material changes will be reflected here.
Your data is hosted in the EU (Render, Frankfurt region) since 7 October 2026. Before that it was hosted in the United States (Oregon); the copy left on that server is frozen and is deleted once the move is confirmed. Where a sub-processor is established outside the EU/EEA (Anthropic for the written reads, Resend for email, your browser's push service), any transfer is protected by the European Commission's Standard Contractual Clauses (SCCs) and by encryption in transit (HTTPS). We do not transfer your data outside these safeguards.
Under the GDPR you have the right to:
You can exercise the two most important rights yourself, instantly, inside the app:
GET /auth/me/export.DELETE /auth/me.For rectification, restriction, objection, consent withdrawal, or any question, email contact@areteprotocol.com. We aim to respond within one month (Art. 12(3)). You also have the right to lodge a complaint with a supervisory authority, your local one, or [lead supervisory authority, e.g. the competent German state Datenschutzbehörde / the BfDI for federal bodies].
Areté uses only functional browser storage (localStorage) to keep you
signed in and to remember your preferences (such as light/dark theme) and your latest reading on
your device. We set no advertising or analytics cookies and use no third-party
trackers. This legal page itself makes no external network calls. Within the app, any
front-end libraries or fonts served from a content-delivery network are used solely to render the
interface and are being brought in-house (self-hosted) to avoid sharing your IP with third parties;
see the compliance notes.
No system is perfectly secure, but we take appropriate technical and organisational measures under Art. 32 GDPR.
If a personal-data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority without undue delay and where feasible within 72 hours of becoming aware of it (Art. 33), and we will inform affected users without undue delay where the breach is likely to result in a high risk to them (Art. 34).
Areté is intended for adults (and, for institutional pilots, for consenting adult participants). It is not directed at children and we do not knowingly collect data from anyone under [16 / the applicable national age of digital consent].
Areté is a self-insight and decision-awareness instrument. It is not a medical device, diagnosis, or treatment, and does not provide medical, psychological, legal, or financial advice. HRV and sleep inputs are used only to contextualise a self-insight reading.
We may update this policy as the product and our legal review evolve. We will change the version and "last updated" date above and, for material changes, notify you appropriately.
Areté is an evolving cognitive-signature and decision-integrity instrument provided for self-insight. It is offered "as is," and we may update or improve it over time.
Results are indicative, not validated diagnostics. The instrument estimates cognitive tendencies from a short calibration; it should be treated as a reflective tool, not an authoritative measurement, and not relied upon for clinical, employment, or other consequential decisions about a person.
You are responsible for activity under your account and agree not to misuse, disrupt, or attempt to reverse-engineer the service. The service, including its methods, scoring models, authored content, reports, interface and documentation, is and remains the intellectual property of Areté; you agree not to copy, extract, or systematically document any of it for the purpose of building, assisting, or advising a competing product or service. For institutional pilots, the purchasing institution is responsible for ensuring it has a lawful basis and, where it acts as controller, appropriate participant consent; a separate data-processing agreement will govern that relationship.
To the maximum extent permitted by law, Areté and its operators are not liable for any indirect or consequential damages arising from use of the service. Nothing in these terms limits liability that cannot be limited under applicable law (including under the GDPR).
These terms are governed by [governing law / jurisdiction], without prejudice to any mandatory consumer or data-protection rights you have under the law of your country of residence.
contact@areteprotocol.com · areteprotocol.com
← Back to AretéDRAFT This Privacy Policy and Terms are a good-faith DRAFT prepared for a pilot. They must be reviewed, localised and signed off by a qualified data-protection (GDPR) lawyer, including all bracketed placeholders, the supervisory-authority details, the DPO/EU-representative assessment, and the retention schedule, before being relied upon.