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Privacy Policy

Last Updated: August 7, 2026

Rogo Technologies, Inc. (“Arvo,” “we,” “us,” or “our”) is committed to protecting privacy and handling data responsibly. This Privacy Policy explains how we collect, use, and safeguard information in connection with our enterprise software platform and related services (the “Services”).

Arvo is a business-to-business (B2B) product. Our Services are intended solely for use by employees and authorized representatives of business customers.

1. Scope of This Policy

This Privacy Policy applies to:

  • Authorized users of customer organizations using the Arvo platform

  • Visitors to Arvo’s website

  • Business contacts interacting with Arvo for sales, support, or operational purposes


This Policy does not apply to personal data processed by our customers within their own systems or workflows, over which Arvo has no control.

2. Data We Process

2.1 Core Product Data

Arvo is intentionally designed to minimize data collection.

By default, we store limited data, including:

  • Machine or device identifiers (e.g., machine ID)

  • Authentication identifiers

  • Basic usage and performance metadata (e.g., feature usage counts, error logs)

  • IP address

  • User activity logs

  • Meeting notes and content (optional)

These identifiers are used solely to:

  • Enforce authentication

  • Maintain service reliability and security

  • Generate aggregated, non-content-based usage analytics

  • Route users to the most efficient server for optimal uptime

2.2 Meeting Notes and Content

Depending on the configuration or features enabled by a customer, meeting notes or related content may be stored within Arvo’s secure cloud infrastructure to provide functionality such as synchronization, backup, administrative oversight, or audit trails. Arvo does not access, or review meeting content (or user activity logs) except as necessary to provide the Services, maintain system integrity, comply with legal obligations, or as otherwise instructed by the customer. Arvo does not use meeting content to train machine learning models.

2.3 Website and Business Operations Data

Separately from the product, Arvo may process limited business contact data such as:

  • Name

  • Business email address

  • Company name

  • Role or title


This data may be collected through:

  • Website contact forms

  • Sales conversations

  • Customer onboarding and support communications


3. Purpose of Processing

Arvo processes data for the following purposes:

  • Providing, maintaining, and securing the Services

  • Authentication and fraud prevention

  • Product performance monitoring and improvement (aggregated analytics only)

  • Business communications, sales, and customer support

  • Compliance with legal obligations


Arvo does not process personal data for advertising, consumer profiling, or behavioral tracking.

4. Legal Bases for Processing (GDPR)

Where the General Data Protection Regulation (GDPR) applies, Arvo processes personal data on the following legal bases:

  • Performance of a contract, where processing is necessary to provide the Services under customer agreements

  • Legitimate interests, including service security, license enforcement, fraud prevention, and limited aggregated usage analytics, provided such interests are not overridden by the rights of data subjects

Arvo does not rely on consent as a primary legal basis and does not process personal data for marketing to end users.

5. Data Subject Rights

Individuals may have rights of access, rectification, erasure, restriction, and objection.

Arvo may not be able to identify or retrieve personal data unless sufficient information is provided to enable identification. Where Arvo cannot identify a data subject, certain rights may not apply.

Requests may be submitted to: [email protected]. Arvo may request additional information necessary to verify the identity of a requester before responding.

6. Data Retention

  • Technical identifiers and usage metadata are retained only for as long as necessary to fulfill operational, security, and contractual purposes

  • Business contact data is retained for the duration of the business relationship and thereafter as required by applicable law or internal record-keeping obligations

  • Meeting content in the Arvo cloud environment is deleted or anonymized upon termination of Services within a commercially reasonable period, unless retention is required by law or as otherwise agreed in writing with the customer.


7. Data Security

Arvo implements appropriate technical and organizational measures to protect data, including:

  • Encryption in transit and at rest (where applicable)

  • Access controls and least-privilege permissions

  • Internal security policies and audits

  • Vendor risk management and contractual safeguards


8. International Data Transfers

Arvo may process limited data outside the European Economic Area (EEA), including in the United States. Our Services are hosted and operated in the U.S.. By using our Services, you acknowledge that any data will be hosted on U.S. servers. Where required, such transfers are safeguarded through appropriate mechanisms, including standard contractual protections and technical security measures.

9. Children’s Data

Arvo’s Services are not directed to children and are intended exclusively for use by business professionals acting in their employment capacity.

Arvo does not knowingly process personal data of individuals under the age of 16.

10. Business Transfers


All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.


11. Data Privacy Framework (DPF) Notice

Arvo AI, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Arvo AI, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

 

11.1 Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Arvo AI, Inc. commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Arvo AI, Inc. at: [email protected].

Arvo AI, Inc. has further committed to refer unresolved complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

For complaints that cannot be resolved through these channels, under certain conditions, you may invoke binding arbitration. For more information, please see the DPF website.

 

11.2 Enforcement and Liability

The Federal Trade Commission has jurisdiction over Arvo AI, Inc.’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Arvo AI, Inc. remains liable under the DPF Principles if a third-party agent that it engages to process personal data on its behalf does so in a manner inconsistent with the Principles, unless Arvo AI, Inc. proves that it is not responsible for the event giving rise to the damage.

 

11.3 Lawful Requests

Arvo AI, Inc. may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


12. Sub-Processors

Arvo may engage trusted third-party service providers to support business operations (for example, infrastructure, analytics, and security services). A current list of sub-processors is made available separately where required.

13. Updates to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through appropriate channels.

14. Contact

For privacy or data protection inquiries, contact:

Arvo AI, Inc.
Email: [email protected]