DRAFT – to be reviewed by a lawyer before publishing.
Privacy Policy
DRAFT – to be reviewed by a lawyer before publishing.
This Privacy Policy explains what personal data Arkivy (“we”, “us”) processes when you visit https://arkivy.smarting.pe, buy a licence or use the Arkivy web app, and what rights you have.
1. Who we are
Arkivy is operated by Arkivy ([LEGAL NAME]), with its registered address at [ADDRESS], Peru. We are the controller of the personal data described in sections 3 and 4. You can contact us about privacy at any time at smarting.agencia@gmail.com.
2. The short version
- Your chats never reach our servers. WhatsApp backups, messages, photos, voice notes, videos and documents are read, decrypted and saved only inside your browser, on your own computer.
- Your 64-digit backup key never leaves your device. We never see it and can’t recover it.
- We only process what we need to sell you a licence and run the website: purchase details, your email address and minimal server logs.
- We don’t use advertising or cross-site tracking cookies, and we don’t sell your data.
- If you use the optional Business AI analysis, only the text of the conversations you choose is sent to an AI provider, and only with your permission.
3. What happens to your chats
The Arkivy app is a web page that your browser downloads from our server. Once loaded, all processing happens locally:
- the app connects to your Android phone over USB, using your browser’s built-in device access, with your explicit permission;
- it copies WhatsApp’s local backup file, decrypts it using the key you type in, and writes the result into a folder you choose on your PC;
- the viewer reads those files from that folder.
None of this content is uploaded to us. We have no access to your conversations, contacts or media, and we cannot restore them if you lose them. You are responsible for keeping your PC folder and your key safe.
4. Data we do process
| Data | Why | Legal basis (GDPR / UK GDPR) |
|---|---|---|
| Name, email, country, purchase and licence details | To sell and deliver your licence, send receipts, provide support and handle refunds | Performance of a contract |
| Payment data | Processed directly by our payment processor ([PAYMENT PROCESSOR]). We don’t see or store full card numbers | Performance of a contract |
| Support emails you send us | To answer you | Performance of a contract / legitimate interest |
| Minimal web server logs (IP address, date and time, page requested, browser type) | Security, fraud prevention and keeping the site running | Legitimate interest |
| Accounting and tax records | To comply with tax law | Legal obligation |
Cookies. We use only cookies or local storage strictly necessary for the site and the app to work (for example, remembering your language or licence status). We don’t use advertising or tracking cookies. If we ever add analytics, we will use a privacy-friendly option and update this policy, asking for consent where the law requires it.
5. Business plan: AI analysis of conversations
The Business plan includes an optional AI analysis of customer and lead chats (for example lead status, objections, unanswered chats and response times). When a business turns this on:
- only the text of the conversations the business selects is sent to our AI provider, [AI PROVIDER], for processing; media files are not sent;
- nothing is sent unless the business explicitly enables the feature and confirms the selection;
- the provider processes the text on our behalf under a data processing agreement and, per that agreement, does not use it to train its models [CONFIRM WITH PROVIDER TERMS].
For these conversations the business is the controller of its customers’ personal data, and Arkivy acts as its processor. The business is responsible for having a valid legal basis (for example legitimate interest or consent) and for informing its customers, as required by the laws that apply to it.
6. Who we share data with
We share data only with service providers that help us run Arkivy: our payment processor, our hosting provider, our email provider and, for Business AI analysis only, [AI PROVIDER]. They may only use the data to provide their service to us. We may also disclose data if required by law. We never sell personal data or share it for cross-context behavioural advertising.
7. International transfers
We are based in Peru, and some providers may process data in other countries, including the United States. Where the GDPR or UK GDPR apply, we rely on appropriate safeguards such as standard contractual clauses or adequacy decisions.
8. How long we keep data
- Purchase, licence and accounting records: for as long as tax law requires (typically [X] years).
- Support emails: up to [X] years after the last contact.
- Server logs: up to [X] days, unless needed to investigate a security incident.
9. Your rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- correct inaccurate data;
- delete your data, subject to legal retention duties;
- object to or restrict certain processing;
- data portability;
- withdraw consent where processing is based on consent;
- if you are a California resident, know, delete and correct your data and opt out of sale or sharing (we don’t sell or share it), without being discriminated against for exercising these rights.
In the EU/EEA and the UK you can also complain to your local data protection authority (in the UK, the ICO). In Peru, under the Personal Data Protection Law (Law No. 29733) and its regulations, you have the rights of access, rectification, cancellation and objection, and may contact the national data protection authority.
To exercise any right, email smarting.agencia@gmail.com. We will reply within the period the applicable law sets (usually one month). We may need to verify your identity first.
10. Children
Arkivy is not directed at children, and we don’t knowingly collect data from anyone under 16 [CONFIRM AGE].
11. Security
We use HTTPS, limit access to personal data to those who need it, and work with reputable providers. Because your chats are processed only on your computer, their security also depends on how you protect your PC and the folder where you save them.
12. Changes to this policy
We may update this policy. We will post the new version on this page with a new “updated” date and, for significant changes, notify customers by email.
Arkivy is not affiliated with WhatsApp or Meta. WhatsApp is a trademark of WhatsApp LLC.