Privacy Policy

1. Who we are

Smart Animal is operated by Smart Animal Technologies Ltd, a company incorporated in the United Kingdom (“Smart Animal”, “we”, “us” or “our”). Smart Animal provides digital tools that allow dog owners to record, organise and review information about their dogs’ health, including longitudinal monitoring of canine Cushing’s syndrome and related health information.

For the purposes of UK data protection law, Smart Animal Technologies Ltd is the controller of personal data processed through the Smart Animal service, except where another organisation is separately identified as controller.

Registered office: Flat G4 Delta House, St. Andrews Street, Northampton, England, NN1 2HA

Privacy contact: privacy@smart-animal.com

General contact: support@smart-animal.com

This Privacy Policy explains what information we process, why we process it, how it is used, when it may be shared, how long it is kept, and the rights available to individuals under applicable data protection law.

2. Scope

This Privacy Policy applies to the Smart Animal mobile application, associated web services and account functions operated by Smart Animal Technologies Ltd. It covers personal data relating to users and other individuals whose information may be incidentally contained in documents uploaded by users.

Information about a dog is not, by itself, personal data about a human individual. However, dog information may form part of personal data where it is linked to, or can reasonably be connected with, an identifiable person. Smart Animal therefore applies data-protection safeguards to the service as a whole.

3. Information we process

3.1 Account and contact information

When a user creates an account, Smart Animal collects the account information necessary to create, authenticate, administer and secure the account and to provide service communications.

In addition to the information a user supplies, the account record holds a one-way cryptographic hash of the password (the password itself is never stored), the version of the Terms of Use and of this Privacy Policy accepted at sign-up with the date and time, the user's confirmation that they are aged 18 or over, the user's choice about optional analytics, and the device time zone, which is used to send reminders at the right local time. No name is required to open an account.

3.2 Dog profile and health information

Users may record information about their dog, including, where applicable:

3.3 Uploaded veterinary, laboratory and imaging documents

Users may upload veterinary records, laboratory results, analyser printouts, imaging reports and other clinical documents relating to their dog. Where Smart Animal introduces a document-reading function, it will process the uploaded document for the purpose of extracting, organising, validating and standardising canine clinical information and incorporating that information into the dog's longitudinal health record.

An uploaded document may contain incidental personal data relating to the account holder, veterinary professionals, practice staff or other individuals, including names, contact details, signatures, professional identifiers or customer/account references. Such information is processed only to the extent necessary to read and process the source document and is not intentionally incorporated into the structured canine clinical dataset.

Personal data relating to the account holder, veterinary professionals, practice staff or other individuals is not included in research datasets or disclosed to research collaborators unless a separate lawful and expressly disclosed basis applies. Smart Animal does not use incidental human information contained in veterinary documents for profiling, marketing or sale.

Where such a function is introduced, processing the source document will necessarily involve processing its contents, including incidental human personal data visible within it, because the relevant canine clinical information cannot be extracted without reading the document. Processing may include optical character recognition, deterministic software processing and AI-assisted extraction, validation, standardisation or quality control where implemented. Any third-party processor used for such processing must act under appropriate contractual and data-protection terms.

Smart Animal may retain non-human source-provenance information required to interpret or verify canine clinical data, including the laboratory or corporate provider, analyser or software type, test method, units, reference interval, source-document type, sample/test date and report date. The identity of a legal entity or laboratory is not removed solely because it appears in a veterinary document.

Where a source value is incomplete, inconsistent, illegible or conflicts with another record, Smart Animal will not silently replace the source value. Where applicable, the source value, any normalised or derived value, provenance and any discrepancy or quality-control status will be recorded separately.

Uploaded documents are stored, not read. A document is uploaded directly from the user's device to Smart Animal's own file storage, which runs on Smart Animal's server in the United Kingdom, and the record of it holds the file name, file type, size, the category the user chose and any note the user added. There is no temporary copy held elsewhere. No optical character recognition, document-reading, artificial-intelligence or machine-learning service is used, and no such service receives any document or any part of one. Nothing is extracted from a document and no information is read out of it into the dog's record. The original file remains available to the user in the app for as long as the account exists, and is deleted when the document is deleted or the account is deleted.

Because nothing is extracted from uploaded documents, no information from them enters the dog's structured record or any research output. Research files are built from an explicit list of permitted columns and cannot contain a column that is not on that list; the owner's name and email address, the dog's name, the treating vet's details and free-text fields are not on it.

3.4 Photographs

Users may choose to upload photographs of their dog for longitudinal health monitoring. Photographs form part of the user's operational dog record while the account is active. Photographs will not be included in research unless the applicable research information and permission expressly cover photographs. On account deletion, operational photographs will be deleted from active systems, subject to the applicable backup lifecycle, unless a copy has already been lawfully retained within an applicable research arrangement.

Photographs are stored in Smart Animal's own file storage on its server in the United Kingdom. They are never publicly readable: each is served through a short-lived signed link tied to the requesting account. No third-party image-analysis service receives them. Photographs are kept while the account exists and are deleted when the photograph or the account is deleted.

3.5 Technical, security and usage information

Smart Animal may process limited technical, security and usage information necessary to operate, secure, troubleshoot and improve the service. Where storage or access technologies are used on a user’s device, Smart Animal will apply the applicable PECR requirements in addition to UK GDPR.

Smart Animal's server records, for each request, the date and time, the address requested, the response status and the network address the request came from. Sign-in and account-recovery events are recorded. The app does not collect a device identifier or an advertising identifier, and no such identifier is stored.

No analytics service and no crash-reporting service is in use in the published application. The application contains provision for both, but they are switched off and send nothing. This notice will be updated before either is enabled. No advertising, marketing-automation, attribution or tracking service of any kind is used, and no tracking identifiers are collected.

4. Why we process information and our lawful bases

Smart Animal processes personal data only where there is a lawful basis for doing so. Different processing activities may rely on different lawful bases.

4.1 Providing the Smart Animal service

We process account information and personal data supplied through the service where objectively necessary to create, authenticate, administer and secure the account; provide the functions requested by the user; maintain the operational dog record; process uploaded documents; and provide service communications. The lawful basis is Article 6(1)(b) UK GDPR where the processing is necessary for performance of the contract with the user. Processing that is not objectively necessary for that contract is assessed under the applicable separate lawful basis.

4.2 Document extraction and incidental human personal data

Where a document-reading function is introduced and an uploaded veterinary or clinical document contains incidental personal data relating to an owner, veterinary professional, practice employee or another individual, Smart Animal will rely on legitimate interests under Article 6(1)(f) UK GDPR for the limited processing necessary to read the document and provide the user-requested extraction function.

Where such a function is introduced, our legitimate interest will be to provide a document-processing function that extracts relevant canine clinical information, incorporates it into the dog’s longitudinal health record, enables comparison of results and observations over time, and supports user-requested health summaries and reports. Processing the source document is necessary to perform that function. Smart Animal minimises the impact on other individuals by excluding unrelated human information from the structured dog record and by not using that information for unrelated purposes.

Smart Animal will maintain an internal Legitimate Interests Assessment for this processing.

4.3 Security, fraud prevention and service integrity

We may process limited technical and account information where necessary for our legitimate interests in protecting Smart Animal, users, systems and data, preventing misuse, diagnosing faults and maintaining service integrity.

The security processing described above uses the request records and sign-in events named in section 3.5, and nothing further. Requests are rate-limited by network address to limit automated abuse of sign-in and account-recovery routes.

4.4 Legal obligations

We may process or retain information where necessary to comply with a legal obligation applicable to Smart Animal Technologies Ltd, including responding to lawful requests from competent authorities.

4.5 Optional communications and marketing

Service communications that are necessary to operate an account or provide requested functionality are not marketing. Any optional marketing or promotional electronic communications will be handled separately and will not be made a condition of using the core Smart Animal service. Where consent is required, users will be given a genuine choice and may withdraw it.

Service emails — the password-reset code, the email-verification code and the account-deletion code — are sent through Brevo SAS, in France. Push notifications are handed to Expo (650 Industries, Inc.), in the United States, which passes them to Apple or Google for delivery to the device. Smart Animal operates no marketing platform and sends no marketing email.

5. Longitudinal records, comparisons and reports

Smart Animal is designed to organise information over time rather than treat each health entry or uploaded document as an isolated record. Information entered or extracted about the dog may therefore be associated with earlier and later records in order to display trends, changes and timelines.

Smart Animal may introduce weekly, monthly or other user-facing summaries and reports that combine information already contained in the dog’s record, including changes in laboratory values and other recorded health information. These functions are intended to organise and present recorded information; they do not replace veterinary diagnosis, clinical judgement or treatment decisions.

The comparisons and reports available at launch are produced from the user's own records by fixed rules: trends over time for symptoms, weight and laboratory values, a summary report for a veterinary appointment, and the medication history. No model, machine-learning system or third-party service produces any of them, and none compares one dog against another.

6. Research

6.1 Research participation is separate and optional

Use of the core Smart Animal service does not require participation in Smart Animal's research programme. Research participation is separate and optional and requires an affirmative opt-in. Declining research participation does not prevent use of the core Smart Animal service and means that the dog's retained data will not be entered into Smart Animal's research programme under that permission.

Where research participation is offered, the research information and consent/participation wording presented at that point forms part of the information given to the user about that research use.

6.2 Information that may be used for research

Subject to the research information and permission applicable to the relevant project, research data may include the dog's unique research identifier; breed, sex, neuter status, date of birth or age, weight and weight trajectory; geographic information; diagnostic status and source of Cushing's disease where known; diagnosis date and age; clinical history; symptoms and longitudinal owner observations; treatment status; medication, dose, frequency, duration, dose changes, interruptions and adverse effects; surgery and other interventions; laboratory and endocrine results; units and reference intervals; blood pressure; urinalysis; imaging and diagnostic findings; nutrition; comorbidities and complications; hospitalisation; treatment response; disease progression; relapse; survival, death and cause where known; photographs where separately covered; and source-provenance, verification and data-quality information. Missing, unmeasured, unreadable and conflicting information may be distinguished rather than treated as a negative finding.

Research datasets will not contain the account holder's name, email address, telephone number or postal address. They will not contain unnecessary personal data relating to veterinary professionals, practice staff or other individuals. Non-human clinical provenance, including laboratory or corporate provider identity, analyser, method, units, reference intervals and source dates, may be retained where scientifically relevant.

6.3 Anonymisation and pseudonymisation

Where possible and compatible with the research purpose, Smart Animal will use anonymised information. Properly anonymised information is no longer personal data because individuals are not identifiable.

Longitudinal research requires repeated observations concerning the same dog to remain linkable over time. Smart Animal may therefore assign a unique dog or research identifier. Assignment of an identifier does not of itself anonymise personal data. Where Smart Animal retains additional information that enables a canine record to be linked to an identifiable human, the relevant information remains personal data and, where identifiers are separated, may constitute pseudonymised personal data. Information is treated as anonymous only where an identifiable human cannot reasonably be identified by Smart Animal or another relevant recipient using reasonably likely means.

Each dog is given a random research identifier when its profile is created, and research information is released under that identifier alone. The link between an owner and a dog is held in a separate table; removing a dog from that table detaches its health record from the person, which is what happens when an account is deleted.

Smart Animal is deliberately clear about the limit of this. Because the research identifier is held on the same record as the dog's details, Smart Animal itself can connect a research identifier back to a dog. Research information held by Smart Animal is therefore pseudonymised rather than anonymous, and is treated and protected as personal data. Information released to a research partner carries the identifier alone.

6.4 Research partners and access

Research information may be made available to approved research collaborators only for defined research purposes and subject to appropriate governance, contractual and security controls. Smart Animal does not sell users’ personal data.

Smart Animal does not intend to operate an unrestricted downloadable database of identifiable user information.

Research using anonymised or appropriately governed data may result in aggregated findings, analyses or other research outputs being published in veterinary, scientific or academic literature or presented at scientific or professional meetings. Published outputs will not identify Smart Animal users.

Research information is provided as a file produced by Smart Animal, not by giving a partner access to Smart Animal's systems. No research partner has access to the database, the file storage or the application. Every file produced is recorded in an export log with the recipient, the purpose, the date and the dogs included. Uploaded documents and photographs are never included in a research file.

6.5 Research lawful basis and safeguards

Where research processing involves personal data, Smart Animal will identify and document an appropriate lawful basis and apply the safeguards required by applicable data-protection law. Research participation consent or opt-in is distinct from the question of which UK GDPR lawful basis applies to processing personal data for a particular research activity.

Research-related processing will follow data-minimisation principles and, where appropriate, use anonymisation or pseudonymisation at the earliest practicable stage. Any project-specific legal basis, research governance requirements and additional notices will be documented before the relevant research processing begins.

6.6 Withdrawal from research

Users may withdraw their dog from future research participation. Withdrawal prevents new eligible data from entering the research pathway under the withdrawn permission. It does not require deletion of canine data retained outside the research programme and does not require deletion of information that has already been irreversibly anonymised. Information already incorporated into completed analyses, published results or genuinely anonymised datasets cannot be withdrawn.

Withdrawal cannot restore identifiability to information that has already been irreversibly anonymised. It may also not be possible to remove information already incorporated into completed analyses, published results or genuinely anonymised datasets. Where personal or pseudonymised data remains identifiable to Smart Animal, the effect of withdrawal will depend on the lawful basis and governance applicable to the relevant research processing and will be explained to users.

Withdrawal takes effect immediately: the change is saved to the dog's record the moment the switch is moved, and from that point the dog is excluded from any research file. Files are produced from the record as it stands at the time, so no partly produced file can carry a dog's information out after withdrawal. Where a partner already holds a file containing the dog, the export log identifies it, and Smart Animal will inform the partner of the withdrawal.

7. Automated processing, alerts and health information

Smart Animal may use rules, calculations, optical character recognition, software models or AI-assisted processing to organise health information, extract information from uploaded documents, standardise data, identify inconsistencies, display trends, or generate alerts or summaries. Where source information is uncertain or conflicting, automated processing may flag the item for review rather than infer a missing clinical fact. These functions are intended to support monitoring, data organisation and quality control. They do not constitute a veterinary diagnosis and do not independently prescribe, change or stop treatment.

Smart Animal does not intend to make solely automated decisions about human users that produce legal effects or similarly significant effects on them.

The app contains one automated function: a set of fixed rules that examine the answers given in a daily check-in and, where the pattern matches one of the defined signs, show a message advising the user to contact their vet. The rules are written in the application, run on Smart Animal's own server, are the same for every dog and involve no model, no learning and no third-party service. The result is a prompt to the user. It produces no decision about the user, and nothing about it is shared with any other party.

8. Who receives information

Smart Animal may use processors acting on its behalf to provide hosting, database, storage, authentication, email, push notification, security, document processing, AI, analytics, crash reporting or other infrastructure functions. A processor may receive only the information necessary for the service it provides and must process personal data under appropriate contractual and data-protection terms. Disclosure to a processor acting on Smart Animal's behalf does not make the processor an independent recipient of the data for its own marketing or research purposes.

Smart Animal runs the application, the database and the file storage itself, on a single server it controls in the United Kingdom. The providers that receive information are:

The database, the file storage and the web server are software that Smart Animal runs on its own server; the organisations that publish that software receive nothing. Backups are made on the same server and are not sent to any other provider.

We may disclose information where required by law, court order or a lawful request from a competent authority, or where necessary to establish, exercise or defend legal rights.

Smart Animal does not sell users' personal data. The account holder's email address is not supplied to research collaborators and is not included in canine research datasets.

9. International transfers

Some service providers or research collaborators may process personal data outside the United Kingdom. Where UK data-protection law requires safeguards for an international transfer, Smart Animal will use an applicable lawful transfer mechanism and any required supplementary measures.

All account, dog, health, document and photograph information is held in the United Kingdom and is not copied elsewhere by Smart Animal. Three functions involve information leaving the United Kingdom: service email is sent through a provider in France; push notifications pass through a provider in the United States and then through Apple's and Google's international delivery networks; and the public website is hosted by a United States company, served from a location in London. Smart Animal's own email accounts are provided by an Irish entity, with processing that may take place in the United States. Transfers to the European Economic Area are covered by the United Kingdom's adequacy regulations. For transfers to the United States, Smart Animal relies on the transfer terms in each provider's data-processing agreement. A user who does not wish notification information to leave the United Kingdom can turn notifications off, and the rest of the service continues to work.

10. Data retention

Smart Animal retains personal data only for as long as necessary for the purpose for which it is processed, subject to applicable legal, security and backup requirements. Retention of canine information is addressed separately because information relating only to a dog is not personal data unless it also relates to an identified or identifiable human.

While an account is active, the operational dog record and original uploaded documents and photographs are retained to provide the service. On account deletion, personal data associated with the account and original uploaded documents and operational photographs are deleted from active systems, subject to lawful retention requirements and backup expiry. Structured canine clinical and longitudinal data is retained after account deletion. Before retention outside the account, Smart Animal must remove or sever information that causes the retained canine record to constitute personal data about the former account holder or another identifiable individual, unless a lawful basis for retaining that personal data applies.

Retention of canine data after account deletion does not alter the user's research choice. Canine data from a dog not enrolled in research will not be used in Smart Animal's research programme merely because the data has been retained or ceased to constitute personal data. Research information is subject to section 6.

Deletion from backups is by expiry rather than immediate. Information from a deleted account can remain in a backup copy for up to 14 days, after which it is overwritten. Backups are used only to restore the service after a failure; if a backup were restored, any deletion already carried out would be applied again.

11. Account deletion and erasure

When a user deletes their Smart Animal account, Smart Animal will delete the personal data associated with the account, except to the extent that retention is required or permitted by applicable law. This includes the account holder's name or display name, email address, account/authentication information and other account-linked personal data that Smart Animal has no lawful basis to retain.

Account deletion does not delete structured information that relates only to the dog and does not constitute personal data relating to an identified or identifiable human. Smart Animal retains the dog's structured clinical and longitudinal record after account deletion. Before doing so, Smart Animal will remove or sever the association with the former account holder and remove unnecessary human personal data from the retained canine record, unless retention of particular personal data is otherwise lawful.

12. Data security

Smart Animal uses technical and organisational measures intended to protect information against unauthorised access, loss, misuse, alteration or disclosure. Access to production systems and personal data is limited according to operational need.

Traffic between the app and Smart Animal, and between the app and the file storage, is encrypted using TLS, with certificates issued and renewed automatically; unencrypted requests are redirected and browsers are instructed not to fall back to an unencrypted connection. Passwords are never stored: only a one-way cryptographic hash is kept, and the same applies to administrator passwords. Password-reset, email-verification and account-deletion codes are stored only as hashes and expire shortly after issue. Every request for a dog's record is checked against the account that owns it. Photographs, documents and reports are never publicly readable and are served only through short-lived signed links. Only the web entry point of the server is reachable from the internet; the database and the file storage accept connections only from the application on the same machine.

Smart Animal is a two-person company and access is correspondingly limited. Eduard Ciugulea, Chief Technology Officer, holds administrative access to the server, which covers the database, the file storage and the backups, for the purpose of operating and maintaining the service. Lavinia Isaila, Founder and Data Project Lead, holds an administrator account for Smart Animal's internal research console, which shows dogs by research identifier only and has no function that returns an owner's name, email address or contact details. No one else has standing access to the database or the file storage, other than anyone engaged to maintain the server under written terms. Administrator sign-in uses a separate password and session from the app, and every research file produced is recorded in the export log.

13. Your data-protection rights

Depending on the circumstances and the lawful basis used, individuals may have rights under UK data-protection law including the right to be informed, access personal data, correct inaccurate personal data, request erasure, restrict processing, object to processing, and receive certain personal data in a portable format.

RIGHT TO OBJECT: Where Smart Animal relies on legitimate interests to process your personal data, you have the right to object to that processing on grounds relating to your particular situation. This includes the limited processing of incidental personal information contained in uploaded veterinary documents. If you object, we will stop the relevant processing unless we can demonstrate compelling legitimate grounds for continuing that override your interests, rights and freedoms, or the processing is required for the establishment, exercise or defence of legal claims.

Where processing relies on consent, consent may be withdrawn without affecting the lawfulness of processing carried out before withdrawal.

The rights in this section apply to personal data relating to natural persons. They do not apply to information that relates only to a dog and does not relate to an identified or identifiable natural person. A request to erase personal data therefore does not, solely by virtue of UK GDPR, require Smart Animal to erase canine-only clinical information that is not personal data.

Requests may be sent to privacy@smart-animal.com. Smart Animal may require information reasonably necessary to verify the identity of the person making a request.

If you have a concern about how Smart Animal uses your personal data, please contact us first at privacy@smart-animal.com so that we can investigate and respond. If you are not satisfied with our response, you have the right to complain to the UK Information Commissioner’s Office (ICO).

14. Personal data about other people in uploaded documents

A user should upload veterinary or clinical documents only where they are entitled to provide the document for the purpose of managing the relevant dog’s health information.

Veterinary documents may contain incidental personal data relating to persons other than the account holder. Smart Animal processes such data only insofar as necessary to provide the document-processing function, protect the service or comply with law, and does not intentionally incorporate unnecessary human identifiers into the structured canine record.

Smart Animal will assess and document the transparency requirements that apply where personal data about another individual is obtained indirectly through an uploaded document. Where Smart Animal relies on an Article 14 exception because individual provision of information is impossible or would involve disproportionate effort, Smart Animal will take the safeguards required by law, including making the relevant information publicly available where required.

Uploaded documents are stored and not read, so no information about any other person is extracted from them, and none enters the dog's record or any research file. A document remains available only to the account that uploaded it, is served only through a short-lived signed link, and is deleted when the user deletes it or deletes the account.

15. Children

Smart Animal is intended for persons aged 18 years or over. A person under 18 must not create an account.

The account creation screen requires the user to confirm that they are aged 18 or over and to accept the Terms of Use and this Privacy Policy before an account can be created. That confirmation is recorded on the account with the date and time.

16. Notifications and permissions

The application may request device permissions only where required for a feature selected by the user, for example access needed to upload or capture a photograph or document, or permission to send notifications. Device permissions can generally be managed through the device operating-system settings.

The production application requests the following permissions. Notifications, to send reminders and alerts; the app works without it and the user is asked at the point the feature is first used. Camera, to photograph a dog or a document; optional, and requested only when the user chooses to take a photograph. The application also asks the operating system to restore scheduled reminders after the device restarts, and to vibrate when a notification arrives. No other permission is requested.

17. Location data

Smart Animal collects geographic information about the dog only where entered by the user, currently the dog's country and town/city. This is dog-profile information and is not obtained from the device's GPS or location services. Smart Animal does not request precise or approximate device-location permission for this purpose. Where geographic information also constitutes personal data because it can reasonably be linked to an identifiable person, it is processed in accordance with this Privacy Policy. Geographic information may be included in research only where the user has opted the dog into the relevant research use and the research information provided to the user covers that field.

The production application does not request device-location permission and collects no location information. The country and town held against a dog are text the user types, are used to interpret laboratory reference ranges and to describe the population under study, and are not derived from any device signal.

18. Changes to this Privacy Policy

We may update this Privacy Policy where the service, processing activities or applicable legal requirements change. Material changes will be communicated in an appropriate manner. The current version and effective date will be made available through the application and/or Smart Animal website.

The version of the Terms of Use and of this Privacy Policy accepted at sign-up is recorded on the account with the date and time, together with the user's confirmation that they are aged 18 or over.

19. Contact

Data controller: Smart Animal Technologies Ltd

Registered office: Flat G4 Delta House, St. Andrews Street, Northampton, England, NN1 2HA

Privacy email: privacy@smart-animal.com

Privacy concerns and complaints should first be sent to the privacy email above. If you are not satisfied with our response, you may complain to the UK Information Commissioner’s Office (ICO).

General contact: support@smart-animal.com

Website: smart-animal.com