ARETÉ

Privacy Policy & Terms of Service

Cognitive Integrity Protocol · Version 0.9 (DRAFT) · last updated 3 July 2026
DRAFT: NOT YET LEGALLY REVIEWED. This document must be reviewed and finalised by a qualified data-protection (GDPR) lawyer before the pilot goes live. Every value shown in [square brackets] is a placeholder and needs a real value (legal entity, addresses, DPO, EU representative, supervisory authority). It is drafted in good faith to be GDPR-aligned but is not a warranty of legal compliance.
Plain-language summary: Areté measures a cognitive signature to help you read your own decision-readiness. We collect only what the instrument needs. Your health inputs (HRV and sleep) and your cognitive profile are treated as sensitive data and are processed only with your explicit consent. We never sell your data and use no advertising or third-party trackers. You can export or permanently delete everything at any time, from inside the app or by emailing us. Areté is a self-insight instrument, not a medical device, diagnosis, or treatment.
Privacy Policy

1. Who we are (the data controller)

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.

2. What data we collect

We collect only the data needed to run the instrument and your account:

Account & identity

Assessment & cognitive data

Optional health inputs

Technical data

Special-category / sensitive data, explicit call-out. Your HRV and sleep inputs are health data, and your derived cognitive profile (signature/type, integrity score, bias tendencies) reveals information about your mental state and functioning. Under Article 9 GDPR we treat all of this as special-category (sensitive) data. We process it only on the basis of your explicit consent, and you can withdraw that consent, and delete the data, at any time (see sections 8 and 10).

3. Why we use it (purposes)

We do not use your data for advertising, and we do not sell it.

4. Our legal bases (Art. 6 & Art. 9 GDPR)

Data / activityLegal basis
Account, authentication, running the core instrument you asked forContract: 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 integrityLegitimate 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 obligationsLegal obligation: Art. 6(1)(c), where applicable

5. Explicit consent & how to withdraw it

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.

6. Automated processing & profiling (Art. 22 GDPR)

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.

7. How long we keep it (retention)

Exact periods are being finalised with our lawyer and set out in the internal retention schedule.

8. Who we share it with (recipients & sub-processors)

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-processorPurposeDataLocation / safeguard
Render (Render Services, Inc.)Application hosting, compute & database storageAll service data at restHosted 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 enabledYour email address and the link contentUS-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 enabledThe 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 sentUS-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 onAn encrypted message the service cannot read; the words of your decisions are left out unless you choose otherwiseOperated 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.

9. International transfers

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.

10. Your rights & how to use them

Under the GDPR you have the right to:

You can exercise the two most important rights yourself, instantly, inside the app:

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].

11. Cookies & local storage

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.

12. How we protect your data (security)

No system is perfectly secure, but we take appropriate technical and organisational measures under Art. 32 GDPR.

13. Data-breach notification

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).

14. Children

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].

15. Not a medical service

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.

16. Changes to this policy

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.


Terms of Service

The service

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.

No guarantee of accuracy

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.

Acceptable use & accounts

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.

Limitation of liability

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).

Governing law

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

contact@areteprotocol.com · areteprotocol.com

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DRAFT  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.