PRIVACY POLICY

Last Updated: August 27, 2025

1. Introduction

Aqua Brain ("we," "our," or "us") is committed to protecting the privacy and security of personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our autonomous water desalination systems, services, websites, and interact with our company.

We operate in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679, Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights Guarantee, and all applicable data protection laws.

2. Data Controller Information

Company Name: Aqua Brain Innovation S.L.
Registered Address: Madrid, Spain
Registration Number: [To be assigned]
Data Protection Officer Contact: privacy@aquabrain.tech
General Contact: info@aquabrain.tech

3. Information We Collect

3.1 Business Contact Information

• Names, job titles, and professional contact details
• Company name and business address
• Business email addresses and phone numbers
• Professional qualifications and areas of expertise

3.2 System Operational Data

• Water quality measurements and analysis results
• Energy consumption and efficiency metrics
• System performance and operational parameters
• Maintenance schedules and service records
• Geographic location of installations

3.3 Commercial Information

• Purchase orders and contract details
• Billing and payment information
• Project specifications and requirements
• Customer service interactions and support tickets

3.4 Technical Data

• IP addresses and device identifiers
• Browser type and version
• Time zone settings and location data
• Platform and device information
• Usage data from our monitoring platforms

4. Legal Basis for Processing

We process personal data based on the following legal grounds:

• Contract Performance: To fulfill our contractual obligations for system installation, operation, and maintenance
• Legitimate Interests: To improve our products, ensure system security, and provide customer support
• Legal Obligations: To comply with regulatory requirements, including environmental and safety regulations
• Consent: Where explicitly provided for marketing communications and optional services
• Vital Interests: In emergency situations affecting health and safety

5. How We Use Your Information

5.1 Service Delivery

• Installing, configuring, and maintaining desalination systems
• Providing remote monitoring and optimization services
• Delivering technical support and customer service
• Managing service contracts and warranties

5.2 System Optimization

• Analyzing performance data to improve efficiency
• Predictive maintenance and failure prevention
• Energy consumption optimization
• Water quality assurance and compliance monitoring

5.3 Business Operations

• Processing payments and managing accounts
• Communicating about products, services, and updates
• Conducting market research and customer satisfaction surveys
• Complying with legal and regulatory requirements

6. Data Sharing and Disclosure

We may share your information with:

6.1 Service Providers

• Cloud infrastructure providers (AWS, Microsoft Azure)
• Payment processors and financial institutions
• Technical support and maintenance partners
• Professional advisors and auditors

6.2 Business Partners

• System integrators and installation partners
• Component suppliers for warranty and support purposes
• Research institutions for collaborative development (anonymized data only)

6.3 Government Authorities

• Regulatory bodies for compliance reporting
• Law enforcement when legally required
• Environmental agencies for monitoring and reporting

7. International Data Transfers

As we expand internationally, data may be transferred to countries outside the European Economic Area. We ensure appropriate safeguards through:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions for countries with equivalent data protection
• Binding Corporate Rules for intra-group transfers
• Your explicit consent where required

8. Data Security

We implement comprehensive security measures including:

• End-to-end encryption for data transmission
• Access controls and authentication protocols
• Regular security audits and penetration testing
• Employee training on data protection
• Incident response and breach notification procedures
• ISO 27001 certification (in progress)

9. Data Retention

We retain personal data for:

• Customer Records: Duration of contract plus 10 years for warranty and liability purposes
• Operational Data: 5 years for performance analysis and optimization
• Financial Records: 6 years as required by Spanish tax law
• Marketing Contacts: Until consent is withdrawn or 3 years of inactivity
• Environmental Compliance Data: 10 years as per regulatory requirements

10. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Access: Request copies of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data (subject to legal obligations)
• Restriction: Request limited processing of your data
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Automated Decision-Making: Request human review of automated decisions

To exercise these rights, contact us at privacy@aquabrain.tech. We will respond within 30 days.

11. Cookies and Tracking Technologies

Our systems and websites use cookies and similar technologies for:

• Essential system functionality and security
• Performance monitoring and analytics
• User preference storage
• Marketing and advertising (with consent)

You can manage cookie preferences through your browser settings or our cookie consent tool.

12. Children's Privacy

Our services are designed for business and government entities. We do not knowingly collect personal data from individuals under 18 years of age.

13. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on our website with an updated revision date. For material changes, we will notify you via email or through our systems.

14. Contact Information