Effective Date: 1 February 2025 | Last Updated: 1 February 2025 | Version 1.0
This policy specifically governs how HRR handles data stored on or generated by humanoid robot devices submitted for service. It supplements our Privacy Policy and is compliant with the Privacy Act 1988 (Cth).
1. Scope and Purpose
Humanoid robots are sophisticated systems capable of capturing, storing, and transmitting significant volumes of data. This data may include audio and video recordings, spatial maps of your home or workplace, interaction logs, biometric identifiers, and behavioural patterns. When you submit a device to HRR for service, you are necessarily granting us access to the physical device and, incidentally, to any data it contains.
This policy sets out precisely how HRR manages that access — what we look at, what we don't, how long we hold anything, and what your rights are throughout the process.
2. Types of Data on Serviced Devices
Depending on the platform and its operational history, a humanoid robot may contain:
- Environmental data: Spatial maps, room layouts, location history
- Audiovisual data: Camera footage, microphone recordings, interaction logs
- Biometric data: Facial recognition databases, voice profiles, gait recognition data
- Operational data: Task logs, command histories, error logs, performance metrics
- Network data: Wi-Fi credentials, connected device lists, API tokens
- Personal identifiers: Registered user names, accounts, preferences
HRR treats all categories of device data with the highest level of confidentiality, regardless of whether they technically constitute personal information under the Privacy Act.
3. Access Controls
Access to data on a submitted device is restricted as follows:
- Only credentialed HRR technicians assigned to the specific job may access the device
- Access is logged and auditable at the job level
- No technician may extract, copy, or transmit device data except where strictly required to perform the diagnostic or repair function
- Senior technicians must authorise any access to device storage systems beyond the operating system level
- Management and administrative staff have no routine access to device data
4. Handling Procedures
When your device is received for service:
- The device is logged with a unique job reference and assigned to a named technician
- The technician may access system logs, diagnostic data, and operational parameters as necessary to identify and resolve the reported fault
- The technician will not access personal files, media libraries, audiovisual recordings, or biometric data stores unless the fault specifically requires it, in which case you will be notified in advance and asked to consent
- If a fault cannot be diagnosed without accessing sensitive data categories, HRR will notify you and offer you the option to be present during that diagnostic step
- No device data will be used for any purpose other than diagnosing and resolving the reported fault
You are strongly encouraged to export and back up your data, and to revoke or change any network credentials or API tokens, before submitting your device for service.
5. Retention and Deletion
HRR does not retain copies of device data beyond the immediate service period. Specifically:
- Any diagnostic logs or data extracts created during servicing are deleted from HRR systems within 7 days of job completion
- HRR does not retain device backups unless explicitly requested by the customer in writing
- Service job records (job number, device model, fault description, work performed, technician) are retained for 7 years for warranty and legal purposes, but do not include device data
6. Enterprise and Custom Agreements
Enterprise clients with heightened data sensitivity requirements — including but not limited to healthcare, government, financial services, and aged care operators — may negotiate a custom Data Processing Agreement (DPA) as part of their HRR service contract. A DPA may specify additional access restrictions, audit rights, deletion timelines, incident notification procedures, and data residency requirements. Contact to discuss.
7. Data Incidents
In the event of an actual or suspected data incident involving device data in HRR's possession, we will:
- Notify the affected customer within 24 hours of becoming aware of the incident
- Contain the incident and conduct an immediate investigation
- Notify the Office of the Australian Information Commissioner (OAIC) where required under the Notifiable Data Breaches scheme
- Provide a written incident report to the customer within 7 days
For questions about this policy or to request a custom Data Processing Agreement:
(03) 9000 4700