Skill “Adquio” Privacy Policy for Alexa

Last update: 08/26/2025
Version: 1.0

1) Who we are (Data Controller)

The person responsible for the processing of your personal data is [Neuronal Innovation Control, S.L.] (“Adquio“), with address at Ánade real 11, Perillo, Oleiros, 15172 La Coruña, NIF B70463641.
Contact e-mail: [privacy@adquio.com]
If you have a Data Protection Officer (DPD/DPO), you can contact us at: [dpo@adquio.com].

This policy applies to the use of the “Adquio” Skill for Amazon Alexa (the “Skill“).

2) Scope of this policy

This notice explains how we treat personal data when you use the Skill through Amazon Alexa-enabled devices and applications.
Important: Amazon processes your voice interactions and data associated with your Amazon account separately. To learn how Amazon treats your information (including voice recordings), please see Amazon’s privacy policy and the Alexa Terms in the Alexa app or on the Amazon website.

3) Categories of data we process

When you use the Skill, Adquio does not receive your voice recordings. What we receive from Amazon is the intent you have expressed and, if applicable, the parameters/slots needed to execute the order (e.g., the name of a room or device).

We can address, in particular, the following categories:

• Data coming from Alexa (via Amazon):
  Alexa user ID assigned to the Skill, device language and region, intent text, parameters/slots (e.g., “turn on”, “living room”, “scene X”), “account linking” status.
• Your Adquio account details (if there is account linking):
  account ID, registration email, device or zone names/tags you have configured, associated permissions and preferences.
• Technical and log data:
  Date and time of request, execution result, server IP addresses, technical identifiers, error codes, performance metrics.
• Account linking tokens:
  Tokens and, if applicable, “refresh tokens” issued by Adquio to enable secure communication between your Adquio account and your Alexa account.

The Skill does not need your precise geolocation, nor does it collect special categories of data (art. 9 RGPD).

4) Data origin

• You, through your actions in the Alexa app or with voice commands to Amazon.
• Amazon, which transmits us the intention already interpreted by its system.
• Your Adquio account and devices, when you have activated the linkage.

5) Purposes of processing

We process your data for:

1. Provide the functionality of the Skill: execute its commands (e.g., turn on/off, query status, activate scenes).
2. Authentication and account linking: verify that you are who you say you are and allow Alexa to interact with your Adquio account.
3. Service maintenance and improvement: log analysis, incident resolution, accuracy and usability improvement.
4. Security and abuse prevention: detection of fraudulent or unauthorized use.
5. Legal compliance: to meet the requirements of authorities, accounting or security obligations.

6) Legal basis (art. 6 RGPD)

• Execution of a contract (art. 6.1.b): necessary to provide you with the Skill and, if applicable, the services of your Adquio account.
• Legitimate interest (art. 6.1.f): security, fraud prevention and service improvement (interest balanced with their rights).
• Consent (art. 6.1.a): for optional functionalities (e.g. proactive notifications/”proactive events”), where applicable. You can withdraw it at any time by disabling the function or the Skill.

7) Need for data

Some data is required for the Skill to work (e.g., intent and binding tokens). If you choose not to provide them or revoke the binding, we may not be able to provide the service.

8) Automated decisions and profiling

We do not make decisions with legal effect based solely on automated processing, nor do we perform profiling that produces significant effects. We only perform the technical routing necessary to execute your orders.

9) Recipients and processors

We may communicate data to:

• Amazon (as the platform through which your orders are placed and Skills are managed).
• Technology providers acting as data processors (hosting, monitoring, support), with GDPR-compliant contracts.
• Authorities and courts, when there is a legal obligation or binding requirement.

We do not sell your data or pass it on to third parties for commercial purposes.

10) International transfers

If any of our suppliers provide services outside the EEA, we ensure an adequate level of protection through European Commission Adequacy Decisions and/or Standard Contractual Clauses (SCCs), and, where appropriate, complementary measures.

11) Conservation periods

• Binding tokens: as long as you keep the account bound and, after revocation, they are deleted or anonymized within a reasonable period of time (max. 7 days).
• Technical logs: retained for the minimum time necessary for security, traceability and improvement(12 months), and then anonymized or deleted.
• Adquio account data: in accordance with the service contract and for as long as the account remains active; thereafter, during the applicable statutory limitations periods.

Amazon’ s retention periods for your voice interactions are governed by its own policies.

12) Security measures

We implement appropriate technical and organizational measures (e.g., encryption in transit, access controls, activity logs, environment segmentation, periodic testing and auditing) to protect the confidentiality, integrity and availability of data.

13) Your rights

You may exercise, where appropriate, the rights of access, rectification, erasure, objection, restriction of processing, portability, and withdrawal of consent.
To exercise them, write to privacy@adquio.com indicating “RGPD Rights – Skill Alexa” and providing proof of identity.
You have the right to file a complaint with the Spanish Data Protection Agency (AEPD) or other competent authority.

14) Minors

The Skill is not intended for minors. Use by minors must be under the supervision and with the consent of their legal guardians, in accordance with Amazon’s policies. We do not knowingly collect data from minors.

15) Account Linking and Revocation (“Account Linking”)

To use all functionalities, it may be necessary to link your Adquio account with Alexa.

• How to link: from the Alexa app, search for “Adquio” and follow the “Link Account” process.
• How to revoke/unlink:
  1. Open the Alexa app → More → Skills and games → Your Skills → Adquio → Deactivate Skill.
  2. In your Adquio account, log out of linked devices and delete your account at apps.adquio.com.
     After deactivation, we will stop receiving requests from your Alexa account and proceed to delete/anonymize tokens within the timeframes in section 11.

16) Integrations and third parties

The Skill may interact with devices and services in your facility (e.g., Adquio controllers, lighting, HVAC or other compatible systems). Local processing that occurs on such equipment is governed by your settings and Adquio’s service agreement.
Third-party sites and services (such as Amazon) are governed by their own policies.

17) Changes to this policy

We may update this policy to reflect legal, technical or operational changes. When changes are relevant, we will communicate them to you through reasonable channels (e.g., notice on the Skill’s page or on our website) before they become effective.

18) Contact

For any questions about privacy related to Skill: Neuronal Innovation Control, S.L. – Ref.: “Skill Alexa Privacy” Ánade Real 11, Perillo, Oleiros, 15172 La Coruña or at the following e-mail address privacy@adquio.com