- This website sets no cookies and runs no analytics. Nothing is tracked.
- If you reserve a spot, we keep your e-mail address to contact you about the ZENUM 1:1, and for nothing else.
- On the phone, your voice never leaves the device. Everything else runs on our own servers, on our own models, in Switzerland.
- The model trained for you is personal data, and we treat it as such: it is yours, it is deleted when you say so, and it is never sold.
Privacy.
The short version
1. Who is responsible
Controller: KULTR Unipessoal Lda, Estrada Nacional 10, Edifício Jardim Parque, 2615-129 Alverca do Ribatejo, Portugal. Data-protection requests: hello@rubenai.pt.
2. This website
| What | Data | Legal basis | Retention |
|---|---|---|---|
| Server logs | IP address, time, page requested, browser type | Legitimate interest in operating and securing the site (art. 6(1)(f) GDPR) | Only as long as needed for security and fault-finding, then deleted |
| Reservation (“Reserve your spot”) | Your e-mail address and anything you write to us | Consent (art. 6(1)(a)); you may withdraw at any time by replying “remove” | Until the ZENUM 1:1 launch plus 12 months, or until you withdraw |
| Cookies | None. No analytics, no advertising, no tracking pixels. | — | — |
Because the site sets no cookies and uses no analytics, no cookie banner is shown. If that ever changes, EU visitors will be asked for consent first.
3. RUBEN on the ZENUM 1:1
RUBEN is working software, in beta. The ZENUM 1:1 is not yet on sale. This section describes how RUBEN handles personal data and is updated at each release.
On the phone
- Your voice. Speech is recognised on the phone; audio recordings are not transmitted.
- RUBEN’s memory of you (places, preferences, past conversations), your contacts and your raw location stay on the phone.
- The voice RUBEN speaks with is synthesised on the phone and watermarked there.
On our servers
Everything that does not run on the phone runs on ZENUM’s own servers, on ZENUM’s own models, hosted by Mount10 in Switzerland, in the Swiss Fort Knox data centres. Switzerland is recognised by the European Commission as providing an adequate level of data protection. No third party provides the intelligence: the models are ours, trained by us, with the EU AI Act’s rules and the GDPR’s principles trained into the weights. What reaches our servers is the text of your request with your name, identifiers and precise location stripped on the phone first; our servers store no conversation content.
Your model is personal data
A model trained on one person’s life contains information about that person. The European Data Protection Board says so plainly (Opinion 28/2024, paragraph 29), and so do we: the model trained for you is personal data under the GDPR. It is used only to serve you. It is not shared, not merged with anyone else’s, and not used to train anything for anyone else. When you delete your data, the model trained for you and the material it was trained on are deleted with it.
Retention on the phone
Engine and context snapshots are kept about 90 days; sessions and events about 365 days; memory that is not used decays. You can delete everything at any time in Settings → Privacy → “Delete all my data” (confirmed with your fingerprint), or by topic, by content, or by date range.
4. Your rights
You have the right of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent where consent is the basis. Write to hello@rubenai.pt. You may complain to the Comissão Nacional de Proteção de Dados (CNPD), Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, or to the supervisory authority of the country where you live.
5. Automated decisions
RUBEN acts only on your instruction. Anything with real-world effect, a call, a booking, a payment, requires your explicit confirmation, and payments require your fingerprint. RUBEN makes no decisions about you with legal or similarly significant effect.
6. Adults only
The ZENUM 1:1 and RUBEN are for adults: 18 years or older, or 21 where the applicable law requires it. We do not knowingly process children’s data; if you believe a minor has given us data, write to us and we delete it.
7. Changes
This notice was last updated on 6 September 2026. Material changes will be dated here.
Basis: Regulation (EU) 2016/679 (GDPR), articles 13 and 15–22; Directive 2002/58/EC and Lei n.º 41/2004 (Portugal) on cookies; EDPB Opinion 28/2024 on AI models.
