Privacy policy

1. Who processes your data

The controller of the personal data described in this policy is [company details to be announced], company number (UIC) [company details to be announced], registered office [company details to be announced], [company details to be announced], represented by [company details to be announced] (“VetCare”, “we”). VetCare is the brand of the platform at vet-ty.com.

For anything about your personal data, write to [company details to be announced]. Phone: [company details to be announced]. All company details are on the Company details page.

Data protection officer. Whether VetCare must appoint a data protection officer is still being decided. Until then, all questions and requests are handled at the privacy address above.

2. Our role: controller, processor, joint controller

VetCare connects pet owners, veterinary clinics and other businesses, so our role depends on whose data it is and what it is used for:

Joint control of the shared profile — the essentials

We have a joint controller arrangement with every clinic that uses VetCare. In short:

• Why there is a shared profile. So you don’t have to enter your details again at every clinic, and so you can see your pet’s visits and vaccinations from every clinic that uses VetCare in your portal.
• What VetCare does. Maintains the profile and its security, gives you the information in this policy, lets you take over, correct, download or delete your profile, and handles requests about the shared profile.
• What the clinic does. Enters your details accurately, informs you when it registers you (it can use our client notice template), and is responsible for its own clinical records.
• Who sees what. Another clinic can find you only by entering your full phone number (or scanning the pet’s QR code, or entering its microchip). It then sees your name and your pets’ name, species, breed and sex so it can register you as its client. One clinic’s clinical records are not shown to another clinic. You see them in your portal.
• Who to contact. You can exercise your rights against either party, us or the clinic. If a request also concerns the other party, we forward it and help each other.

The full text is in the Data Processing and Joint Controller Agreement.

3. What data we process

• Account: e-mail (you sign in with it), phone, first and last name, city, language, profile photo (if you upload one), password (we keep only a cryptographic hash), last login, e-mail confirmation.
• Acceptances and declarations: that you accept the Terms, have read this policy and are at least 16, with the date, document version, IP address and browser.
• Pets: name, species, breed, colour, date of birth, sex, weight, neutering, microchip, QR code, photo, notes, status (lost, for adoption, for sale), city, listing location and price.
• Community: comments on listings, partner-matching profile (description, pedigree, preferences), likes and matches.
• Appointment requests: name, phone, pet, requested time and reason.
• Clinic data (processed on the clinic’s behalf): patients, visits, history, diagnoses, investigations and images, treatment, vaccinations, sales, appointments, veterinary journals, reminders.
• Businesses and staff: business details (name, company number, VAT number, address, contacts, location, logo, description, opening hours, services and prices, team if the business publishes it), invitations, staff roles and permissions, shifts and leave.
• Billing (businesses only): company, company number, VAT number, representative, address, invoice e-mail, subscription, invoices and proformas, Stripe customer ID. Your card details never pass through us.
• AI assistant (clinics only): the vet’s questions, the answers and the visit data sent as context.
• Technical data: IP address, browser type, date and time of requests, login and security logs, the session cookie (see Cookies).
• Correspondence: the e-mails we send you and the messages you send us.

We do not ask for special categories of data (for example health data about people). If you type such data into free text, such as a note, we only process it as part of that text. Please don’t.

4. Purposes, legal bases and retention

Usage statistics. We compute them on our own server from the requests we process anyway. We use no cookies, pixels or third-party analytics services and build no advertising profiles. The events contain no name, e-mail, phone, IP address or record content. The daily activity record holds only the date and the user number and is used to count active users. The platform administrator sees cross-clinic statistics only as aggregates.

Where the basis is legitimate interest, we have assessed that our interest (a secure, working platform) does not override your rights. You can object to such processing (see Your rights).

5. Listings: lost pets, adoption, for sale

When you mark your pet as lost, for adoption or for sale, you create a public listing. This is who sees what:

• Don’t use your home address. Put the pin where your pet went missing or in the general area, not at your front door.
• Don’t write a phone number, e-mail or address in the description. If you want calls, turn on “Show my phone” and turn it off when you no longer need it.
• Before uploading a photo, check that it doesn’t show an address, a house number or a number plate.
• Listing period. A listing is active for a set period (we propose 60 days for lost pets and 90 days for adoption and for sale; to be confirmed). You can take it down at any time. When a listing ends, we delete its map location and notes.

Legal basis: contract, Art. 6(1)(b). Showing your phone number is your choice and you can stop it at any time.

6. Comments

Comments on listings are public. Visitors without an account see the text and the author’s initial. Logged-in users see the full name and profile photo. The listing owner can pin comments to the top.

You can delete your own comment at any time. Comments are visible only while the listing is public. We delete them 12 months after the listing ends (proposed period). Don’t post other people’s personal data in comments.

7. Partner matching (breeding)

Your matching profile (the pet, description, pedigree, temperament, preferences, city or distance) is visible to logged-in users who use this feature for the same species.

You can delete your matching profile at any time. We delete likes and inactive profiles after 12 months (proposed period). Legal basis: contract, Art. 6(1)(b).

8. Appointment requests

When you send an appointment request to a clinic or another business, the business receives your name, phone number, your pet’s details, the requested day and time and the reason or note you wrote. The business accepts or declines the request, and you see the status in your portal.

Once it reaches the business, the request becomes part of the business’s records. The business is the controller and we are its processor. Only write in the note what the appointment needs.

9. If a clinic registered you

Many owners join VetCare because their veterinary clinic registered them at the front desk. In that case:

• The clinic enters your name, phone number, optionally your e-mail, and your animals. The clinic is the controller of its clinical records and we process them on its behalf.
• Your identity (name, phone, e-mail, animals, microchip, QR) is in the shared profile, which we control jointly with the clinics (see section 2).
• Another clinic can find you only by your full phone number, the QR code or the microchip. It then sees your name and your animals’ basic details, but not the first clinic’s records.
• The clinic can send you reminders (for example about an appointment or a vaccination) through VetCare — by e-mail and, if the platform has switched SMS on, by text message to your mobile number. Every e-mail has an unsubscribe link and every text a short opt-out link. In your profile you choose the channel for each kind of reminder, set quiet hours or turn reminders off clinic by clinic. No text messages are sent at night.

How to take over your profile

1. If the clinic has your e-mail: sign up with that e-mail. We send you a confirmation code and link your account to the profile the clinic created.
2. If the clinic only has your phone number: ask the clinic for a one-time code and enter it when you sign up.
3. From then on you see visits and vaccinations from every clinic in your portal and manage your data yourself.

For your rights you can contact the clinic or us at [company details to be announced].

10. AI assistant for the vet (“AI + vet”)

Some clinics use an AI assistant that helps the veterinarian during a visit. It suggests questions for the owner, possible causes and tests, and drafts a summary. The vet always decides. Nothing enters the record without the vet. We make no automated decisions with legal or similarly significant effects on you (Art. 22 GDPR). Pet owners do not use the AI.

• Roles. The clinic decides whether to use the assistant and is the controller. We are the processor.
• What is sent. The data of the open visit (history, vitals, examination, diagnosis, items), the animal’s species, breed and age, earlier visits and vaccinations at the same clinic, investigation images (if the clinic enabled this) and the vet’s question. The owner’s phone, e-mail and address are not sent. Contact details are removed from the context.
• Where the model runs. On a server of [to be confirmed], located in [to be confirmed].
• How long conversations are kept. Dashboard conversations are private to the staff member and deleted after 90 days. Conversations about a visit are part of the clinic’s records and kept as long as the clinic keeps the visit (24 months by default). These periods are proposals and still to be confirmed.
• Shared knowledge (“VetCare data”). Every night we build de-identified aggregate counts from the completed visits of participating clinics. We use only coded features: species and breed group, age band, sex and neuter status, weight band, symptoms, affected body systems and vital-sign bands, the diagnosis mapped to a controlled vocabulary, and the treatment class. We add proxies for the outcome: a revisit within 14 or 30 days, a repeat visit with the same diagnosis within 30 or 90 days, hospitalisation, death within 30 days. We keep only aggregate counts. A group is kept and shown only if it has at least 10 cases from at least 3 different clinics and no single clinic makes up more than 80 % of it. Counts are rounded to 5. The aggregates, the request to the model and the screen contain no free text, names, contact details, identifiers, or which clinic or vet the data came from. Free text the vocabulary cannot code goes to a review queue that only the platform administrator sees. The aggregates are replaced in full on every rebuild.
• How they are used. Only on the treatment page of a clinic that has switched the assistant on. The model gets a short “VetCare data” block, marked as observational data, not proof. The vet sees exactly what was used.
• Opting out. Clinics take part by default. The clinic owner can opt out in “Management → AI assistant”. From the next rebuild on, the clinic’s visits are left out, but the clinic still sees the aggregates. The platform administrator can switch the feature off entirely.
• Treatment suggestions. These are switched off for now. We will turn them on only after veterinarians have evaluated them.

11. Payments and invoices (businesses)

Pet owners never pay. Businesses pay their subscription by card through Stripe or by bank transfer against a proforma invoice.

• Card payments. You enter your card details directly with Stripe (checkout.stripe.com). We never see or store the card number. We only receive the payment status and technical identifiers. For processing the payment and fraud prevention, Stripe is a separate controller (see Stripe’s privacy policy).
• Bank transfer. We issue a proforma. When the payment arrives, the VetCare administrator marks it as paid.
• Invoices. We keep them for 10 years, as required by Bulgarian accounting and tax law (Accountancy Act, VAT Act; to be confirmed).
• Other billing data (for example the subscription and contact details) is kept for 12 months after the subscription ends and then anonymised.

Legal basis: contract and legal obligation, Art. 6(1)(b) and (c).

12. Who we share data with

• Sub-processors that help us run the service: hosting, network and protection, e-mail and SMS delivery, the AI server. Full list: Sub-processors.
• Clinics and other businesses, as described in sections 2, 8 and 9.
• Other users, as described in sections 5, 6 and 7.
• Stripe, as a separate controller for card payments.
• Public authorities, only when the law requires it (for example a court, the prosecutor, the data protection authority or the tax authority).

We do not sell personal data and do not share it for advertising.

13. Transfers outside the EU

Our servers are in the European Union (Germany). Some providers may process data outside the European Economic Area:

• Cloudflare (network, protection, TLS) and Stripe (payments) are US companies. Transfers are protected by the EU–US Data Privacy Framework where the company is certified under it, and by the European Commission’s Standard Contractual Clauses.
• Maps and address search. Map tiles (OpenStreetMap) and address search go through our server. Your IP address is not sent to OpenStreetMap.
• Fonts. Fonts are loaded from our own server, not from Google.
• Google Maps. The “Directions” link opens Google Maps only if you click it.

14. How long we keep data

When you ask us to delete your account, you have 14 days to change your mind. After that we delete or anonymise your data. Only the clinical records clinics are entitled or obliged to keep, and invoices, remain.

15. Security

• All connections are encrypted (HTTPS/TLS), including between Cloudflare and our server.
• Each clinic sees only its own data. Staff access depends on their role and permissions. The server checks permissions on every request.
• Passwords are stored only as a cryptographic hash (bcrypt). Login attempts are rate-limited, and too many wrong attempts lock the account temporarily.
• The session is kept in a cookie that scripts cannot read (httpOnly). Changing your password ends all other sessions.
• The keys for e-mail, payments and AI are encrypted in the database. Medical files are not public and are shown only to people with access.
• We make daily backups and are introducing encrypted off-site backups.

To be clear: connections and secret keys are encrypted, but the database as a whole is not encrypted at application level. We rely on server protection and access control.

If a security breach occurs, we will notify the Bulgarian data protection authority (CPDP) within 72 hours, and you when there is a high risk to your rights.

16. Your rights

• Access (Art. 15) and portability (Art. 20). You can download your data as a ZIP file from your profile in the app.
• Rectification (Art. 16). You correct your account and pet details yourself in your profile. A mistake in a clinical record is corrected by the clinic.
• Erasure (Art. 17). You can delete your account from your profile. You have 14 days to change your mind. Clinical records clinics must keep, and invoices, remain (Art. 17(3)).
• Restriction (Art. 18). You can ask us to pause processing, for example while we check whether data is accurate.
• Objection (Art. 21). You can object to processing based on legitimate interest, and unsubscribe from clinic reminders.
• Withdrawing consent. Where something depends on your choice (for example showing your phone number on a listing), you can stop it at any time.
• Automated decisions (Art. 22). We make no solely automated decisions with legal or similarly significant effects on you.

How. From your profile in the app or by e-mail to [company details to be announced]. We reply within 1 month. For complex requests this can be extended by 2 more months, and we will tell you. We may ask you to confirm your identity. Exercising your rights is free of charge.

For records a clinic keeps, you can also contact the clinic directly. We help the clinic answer.

17. Complaints

If you believe we process your data unlawfully, you can complain to the Commission for Personal Data Protection (CPDP / КЗЛД): 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria, www.cpdp.bg, [email protected], or to the data protection authority where you live or work. You can also go to court.

We’d appreciate it if you wrote to us first at [company details to be announced]. We can often sort it out quickly.

18. Age

Only people aged 16 or over can have a VetCare account. You confirm this with a tick box when you sign up. If we learn that a younger child has created an account, we will delete it. A parent or guardian can write to us at [company details to be announced].

19. Cookies and local storage

We use only strictly necessary cookies and local storage: for your session, for security and for settings such as language and theme. There are no advertising or tracking cookies or pixels and no third-party analytics (usage statistics are computed on the server, without cookies), so we don’t show a cookie banner. Details: Cookie policy.

20. Changes to this policy

If we change this policy, we will publish the new version here with a new version number and date. For significant changes we will notify you by e-mail or in the app and, where needed, ask you to confirm. Previous versions are available on request.