Legal · Draft

Privacy Policy

How Roborecs processes personal data across the marketplace, including personal data that may appear inside the datasets themselves.

Draft - pending legal review. Not legal advice.

This is a first-draft template shared for review by counsel. It is not legal advice, does not yet bind Roborecs or any user, and may change before it takes effect. Text shown in [square brackets] marks a placeholder to be completed.

This Privacy Policy explains how [Roborecs entity name] (“Roborecs”, “we”) processes personal data in connection with the Roborecs data marketplace (the “Platform”). It covers two things: the personal data of Platform users (account data), and the fact that Datasets listed on the Platform may themselves contain personal data of third parties who are depicted or recorded in them. A short Data Processing summary appears at the end.

1Who we are

Roborecs is [Roborecs entity name], [registered address], reachable at info@roborecs.com. [Where a data protection officer or an EU or UK representative is appointed, their contact details will be listed here.]

2Personal data we process

Account and user data. When you use the Platform we process:

  • identity and contact data (name, email, company);
  • account and authentication data;
  • transaction and payout data (handled together with our payment processor);
  • messages you send through the Platform; and
  • usage, device, and log data.

Personal data inside Datasets. Datasets are supplied by Providers and may contain personal data of third parties captured during recording, such as faces, voices, home or private-space imagery, and bystanders, and, in some cases, children. Providers are responsible for obtaining the consents and rights for that data (see the Provider & Platform Terms of Service). Roborecs processes such data as an intermediary, to host, administer, and deliver the license.

3Controller and processor roles

For account, transaction, and Platform-usage data, Roborecs is the controller. For personal data contained within a Provider’s Dataset, the Provider is the controller of the original collection and determines its purposes; Roborecs acts as an intermediary and, where applicable, as a processor or reseller-of-record administering the license, and the Buyer becomes an independent controller for its own use. Roborecs is not the controller of the original collection of Dataset content.

4Lawful basis

For our own processing, we rely on:

  • performance of a contract, to provide the Platform and complete transactions;
  • legitimate interests, to operate, secure, and improve the Platform and to prevent misuse, balanced against your rights;
  • consent, where it is required (for example certain communications); and
  • legal obligation (for example tax and accounting records).

Providers are responsible for the lawful basis and the consents for the personal data inside their Datasets.

5How we use personal data

We use personal data to:

  • operate accounts and run the marketplace;
  • process transactions and payouts and deliver licenses;
  • provide support and send service communications;
  • secure the Platform and prevent fraud and abuse;
  • handle notice-and-takedown requests; and
  • comply with law.

6Sharing and disclosure

We share personal data with the counterparty to a transaction only as needed and subject to masking; with service providers (such as hosting, payments, and email) under contract; with authorities where legally required; and in connection with a corporate transaction. We do not sell personal data.

7International transfers

Personal data may be processed in countries outside your own. Where we transfer personal data across borders, we use appropriate safeguards, such as the EU Standard Contractual Clauses [SCCs, to be confirmed] and equivalent mechanisms.

8Your rights

Subject to applicable law, you have the right to access, correct, delete, restrict, or object to the processing of your personal data, to data portability, and to withdraw consent. To exercise a right, or to make a data-subject access request (DSAR), contact info@roborecs.com. We will respond within the period the law requires. You may also complain to your supervisory authority.

9Notice and takedown for depicted individuals

If you believe that you, your property, or a person you are responsible for (such as a child) appears in a Dataset on the Platform, or that content depicting you is being processed without a proper basis, contact info@roborecs.com with enough detail to locate the material. We will review the request, may suspend or remove the affected Dataset while we do (see the Provider & Platform Terms of Service), and will route the request to the responsible Provider as controller.

10Retention

We keep account and transaction data for as long as your account is active and thereafter as needed for our legitimate interests and legal obligations (for example tax records). Dataset content is retained according to the Provider’s instructions and the applicable license, and is removed on a valid takedown request or when no longer required. [Specific retention periods to be confirmed.]

11Security

We use technical and organizational measures appropriate to the risk to protect personal data. No system is perfectly secure, and we cannot guarantee absolute security.

12Children

The Platform is not directed to children, and accounts are for adults acting for an organization. Datasets may nonetheless depict children; Providers must hold parental or guardian consent for such content, and takedown requests concerning a child are prioritized.

13Changes to this Policy

We may update this Policy. Material changes will be posted on this page with a new version date.

14Data Processing summary

A short reference to the processing described above:

Controller (account data)
[Roborecs entity name], contact info@roborecs.com
Controller (dataset content)
The Provider for the original collection; the Buyer for its own use
Roborecs role for dataset content
Intermediary, and where applicable processor or reseller-of-record
Data categories
Account and contact data; transaction and payout data; messages; usage and log data; personal data depicted within Datasets (faces, voices, spaces, bystanders, children)
Lawful bases
Contract; legitimate interests; consent where required; legal obligation
Recipients
The transaction counterparty (masked), service providers, and authorities where required
International transfers
Cross-border with safeguards [EU SCCs, to be confirmed]
Retention
Account and transaction data per legal need; dataset content per license and Provider instruction [periods to be confirmed]
Your rights
Access, rectification, erasure, restriction, objection, portability, withdraw consent, complain to a supervisory authority
Contact / DSAR / takedown
info@roborecs.com

15Contact

Privacy questions, DSARs, and takedown requests: info@roborecs.com.

Draft version 2026-08-31 · pending counsel review · questions to info@roborecs.com