Provider and controller for account data: Arethine Institute, Zavod za strateški razvoj organizacij prihodnosti Brod 25, 8000 Novo mesto, Slovenia Registration number: 9845615000 · VAT ID: SI22181148 Contact:
This policy explains how arethino handles personal data under the EU General Data Protection Regulation (GDPR).
1. Two roles
- Your account data — email address, login sessions, chosen plan, subscription records and usage counters. For this, Arethine Institute is the controller.
- People you add — names, job titles, organisations, professional descriptions, photographs, e-mail addresses, phone numbers and your notes about them, including anything about them you type into the Copilot. For this, you (or your organisation) are the controller and Arethine Institute acts as your processor, processing it only to provide the service and on your instructions. The processing terms are set out in the Data Processing Agreement ().
2. Where data is stored — and where it is sent
Storage. The application database and the photograph store are operated by our hosting platform in the European Union (Frankfurt, Germany). Photographs are kept in a private, non-listable store and served only through short-lived signed links to users with access to the interaction. Access is isolated per account by database-level access rules. Sharing an interaction with a co-organiser exposes only that interaction — never your other interactions, your People Library or your private notes.
Sending for processing. Storage in Frankfurt does not mean all processing stays in the EU. When you use AI or search features, the relevant data is sent to the providers listed in section 6, some of which process it outside the EEA.
3. Legal bases (account data)
- Providing the service and managing your account: performance of a contract (Art. 6(1)(b)).
- Invoicing and accounting records: legal obligation (Art. 6(1)(c)).
- Service security, abuse prevention and fair-use quota counters: legitimate interest (Art. 6(1)(f)).
4. Files you upload
Files you upload for AI-assisted import (spreadsheets, CSV, Word, PDF) are read in memory during the request and are not stored by arethino. Their text is sent to our AI provider to extract a list of people. Only the entries you review and confirm are saved.
5. AI and web search
- AI import and "Fill from brief": the text of your file or brief is sent to the AI provider to produce a structured suggestion.
- Public-information search (for one person or for several people you select): the person's name and, where you provided them, organisation and role are sent to the web-search provider and, if no portrait is found, to the image-search provider. The retrieved public text and image candidates are then sent to the AI provider for matching and summarising.
- What requires your confirmation: suggested profile data and suggested photographs are shown to you with their sources and are saved to a person only after you explicitly confirm them. Photographs are not pre-selected.
- What is handled differently: Copilot conversations are saved automatically in your account so they are still there after a reload. Only you can see them, and they are deleted together with the interaction or your account. Where you type information about people into the Copilot, we process it as your processor (see §1). Usage counters (§7) are recorded automatically when you use an AI feature.
- The AI provider is instructed not to extract or infer special categories of personal data (Art. 9 GDPR) or criminal-matter data (Art. 10), nor private or family life. Results and photographs from personal social networks (Facebook, Instagram, TikTok, Threads, Telegram) are filtered out in the software.
- Storage settings: our requests to the AI model are sent with the
store: falsesetting, which means the request and response are not kept as a stored conversation object for later retrieval. This does not by itself exclude short-term logs kept by the gateway or the model provider for security or abuse monitoring. The retention and training terms that apply along the AI gateway path are being confirmed with the provider.
6. Providers (sub-processors)
We will update this list before adding a new provider.
7. Retention and deletion
- Your data is kept for as long as your account exists.
- When you delete an interaction, a person or a photograph, it is removed from the live database and file store immediately.
- Account deletion is currently handled on request. Write to from the address registered to the account. We respond within one month of receiving the request (Art. 12(3) GDPR). Separately, once your identity is confirmed, we normally carry out the deletion — account, interactions, people, notes, Copilot conversations, photographs and counters — within 14 days.
- Backups: our hosting platform keeps automated backups for disaster recovery. Deleted data may remain in those backups until they are overwritten in the platform's rotation. No fixed backup retention period has been confirmed, so we do not promise erasure from backups within a fixed time. We do not use backups to restore deleted accounts.
- Usage and creation counters: each time you create an interaction, we record a row with your account identifier, the interaction identifier and the date. These rows enforce the plan limits and are not removed when you delete an interaction, so that deleting and recreating cannot get around the limits. They are linked only to your account identifier. A new registration always gets a new identifier, so these rows have no further purpose once your account is deleted. They are deleted together with your account, as are AI usage counters.
- Invoices and payment records are kept where accounting and tax law requires.
8. Your rights
You may request access, rectification, erasure, restriction, portability, and object to processing based on legitimate interest. Write to ; we respond within one month.
Currently available exports: a printable view of each interaction's people list (print it, or save it as a PDF from your browser). There is no one-click export of the whole account in the app. On request by e-mail, once your identity is confirmed, we prepare a copy of your account data in JSON format: account details, interactions, people, program items, follow-ups, private notes, Copilot conversations, sharing memberships, plan and usage records, and a list of your stored photographs. The photograph files themselves are provided on request.
If you are a person listed in someone's workspace: the user who added you is the controller of that data and is the first point of contact. You may also write to if you believe your data is processed in arethino. We will review the request and, where possible, help the responsible controller handle it. We may not always be able to identify the user concerned, and we will not disclose who uses the service without a legal basis.
You may lodge a complaint with the Slovenian Information Commissioner (Informacijski pooblaščenec) or your local supervisory authority.
9. Cookies and local storage
We use only technically necessary storage: the login session and your language choice. There are no advertising, analytics or tracking cookies.
10. Changes
We will update this page when the service changes and note the date of the last revision at the top.