Who processes your data
Pets is an application by Germán Ezequiel Laso Andino, who operates under the trade name ProfBlu.
- Owner: Germán Ezequiel Laso Andino, sole trader (libero professionista).
- VAT number (Partita IVA): 04702090988. Tax code (codice fiscale): LSNGMN88S04Z600M.
- Professional activity not registered in the Italian Business Register (Registro delle Imprese) (no REA number).
- Contact address: Via della Sega 1, 38080 Verdesina, Porte di Rendena (TN), Italia.
- Email for anything about your data: privacidad@profblu.com.
No data protection officer has been appointed: the law does not require one for an activity of this size.
Two different roles
In Pets there are two controllers, and it is worth knowing which is which before you read on.
- We answer for your account and for what is yours. Your adopter profile, the animals you have shown interest in, your monthly contribution to a shelter and the notifications you receive on your phone. We are the data controller.
- The shelter answers for what a shelter receives and keeps. When you send an application, the shelter receives a copy of your profile and of your answers, and from then on it decides: whom it talks to, whom it gives an appointment, what it notes down and how long it keeps it. It is the controller of that data and we keep it on its behalf. That arrangement is a contract and can be read in full in the data processing agreement.
The same goes for the people on a shelter's team: we answer for their account; the shelter answers for what they do inside the shelter.
What data we process
What follows comes from the application's code, not from a generic list. If an item of data is not here, Pets does not store it.
About your identity
Pets has no sign-up form or password of its own. You sign in with your ProfBlu account, which is managed centrally: name, email and password live there, under the platform's privacy policy. Pets only checks the session token that account issues and stores your user identifier alongside what you do.
About your adopter profile
You fill it in yourself the first time you want to adopt, and you can change it whenever you like:
- the type of home, whether it has outdoor space and whether your landlord allows animals;
- how many adults and how many minors live with you (only the number);
- whether you have lived with animals before and, if you want to tell us, how it went;
- whether there are already other animals at home and which ones;
- which species, sizes and energy levels you prefer;
- a free-text note, in case you want to add something.
We do not ask for an identity document, postal address, health data or income.
About your interest in an animal
When you tap the paw we store that you are interested in that animal, when you said so and how it ended: whether the shelter reciprocated, whether it dismissed it, whether you withdrew it yourself or whether it expired because the animal found a home. The shelter sees that interest; nobody else does.
About your application
By sending an application you accept that the shelter receives a copy of your adopter profile and of your answers to its questionnaire, as they stood that day. Of that acceptance we store the date and time and the version of this policy that was published at that moment.
During the process the following are also stored:
- the messages you and the shelter exchange, with who wrote them and when;
- the appointments: type, date, time zone, a note about the place and who attends;
- the documents the shelter asks you to accept and whether you accepted them;
- the contributions the shelter records as received from you;
- the status of the application at each moment.
The shelter also keeps an assessment and internal notes. They are the shelter's; you do not see them in the application, and if you want access to them you ask the shelter.
About your contribution to a shelter
If you become a crew member we store which shelter, how much per month, in which currency and what status it is in. Today nothing is charged: there is no payment gateway connected, so Pets does not process cards, bank accounts or any payment data. The contribution is recorded as pending and the application says so. When charging exists, it will be done by the platform's billing system and this policy will say so beforehand.
The shelter sees how many crew members it has and the monthly amount committed, never who each one is.
About what you cover from a shelter's list
If you cover a need of a shelter, we store which need, what quantity, when and who recorded it. Today the order to a shop is a demonstration and the application says so; nothing is bought and no delivery address is processed.
About your location
The application asks whether you want to use your location to sort the animals by proximity. If you accept, the point lives in the phone's memory while the application is open and travels in the request with a precision of about ten metres, only to calculate a rounded distance. It is not stored in our database and the shelter does not see it. As with any web service, the requested URL may remain for a few days in the server's technical log. If you say no, the application works just the same and sorts by newest.
Of the shelter, only the city and a point rounded to approximately one kilometre are published, never its address.
The map of nearby shelters is drawn by the phone's own map service: Apple Maps on iPhone and, once it is turned on, Google Maps on Android. To draw it, the phone downloads from Apple or Google the piece of map being viewed, so that service knows which area is being looked at, as with any application that shows a map. Pets does not send them your location or your account, and the map does not mark where you are: only the approximate point, accurate to about one kilometre, that each shelter has chosen to publish.
About notifications
If you accept receiving notifications, we store the identifier the notification system assigns to your phone, whether it is iOS or Android, the language you want to read them in and when it was last used. When you sign out that identifier is unregistered.
About photos
The photos in Pets are of animals. They are uploaded by a shelter's team. When they are taken from the phone, the embedded data — the location and the camera model — is removed before they leave it. For each published photo we store who authorised its publication, when, and the reference of the permission recorded by the shelter. The application does not collect photos of you.
About security and operation
We keep an audit log of the actions that change something. In that log neither your identifier nor the animal's appears in the clear: they are replaced by a pseudonym calculated with a key that only the server holds. The server's technical logs record every request and every error, in order to operate the service.
What for, and on what basis
- So that the application works: showing you animals, recording your interest, handling your application and your contribution. Basis: the performance of what you ask of us by using it (Art. 6(1)(b) GDPR).
- So that the shelter receives your application: your consent, which you give by sending it and which you can withdraw by withdrawing the application (Art. 6(1)(a)).
- To notify you on your phone and to use your location: your consent, which you give and remove in the phone's settings (Art. 6(1)(a)).
- To keep the service secure: our legitimate interests in detecting abuse and being able to investigate an incident (Art. 6(1)(f)).
There is no advertising, no commercial profiling and no automated decision-making: who adopts is always decided by a person at the shelter.
Where it is processed, and who else sees it
- Hetzner Online GmbH hosts the server and the database, and stores the photos in its object storage in Nuremberg (Germany). Inside the European Economic Area.
- Expo, Inc. relays the notifications to Apple and Google when they are turned on: it receives your phone's identifier and the text of the notification. It is in the United States, and that transfer is covered by the safeguards of Chapter V GDPR (standard contractual clauses).
- Apple and Google, when the application is distributed through their stores, as stores and as those who deliver the notifications to the phone.
- Anthropic is involved only in the shelters' dashboard, and only if someone on the shelter's team uses the assistant: what that person writes to it and what the assistant looks up in order to answer passes through its model. The adopter's application has no assistant.
There is nobody else. There is no analytics or advertising tool in Pets' code, and the site loads no third-party resources.
For how long
As long as you have an account and the relationship remains live: your profile while you use it, your application while the process lasts and for the time the shelter needs to justify its decision.
It is worth saying this precisely: today there is no automatic erasure by retention period. The maximum periods for each class of data have been drafted and are pending approval; the day they are approved they will appear in this section with their period. Until then erasure is done when you ask for it, within one month, and only what a law requires to be kept is kept.
Your rights
You may exercise the rights the General Data Protection Regulation gives you: access, rectification, erasure, portability, objection, restriction and withdrawal of your consent without affecting what was done before.
- You correct your adopter profile yourself from the application.
- You withdraw an interest or an application yourself from the application.
- For everything else, and to ask for a copy or the erasure of your data, write to privacidad@profblu.com from your account email. We reply within one month at most.
- What a shelter keeps about your application you can request from the shelter, which is its controller. If you ask us, we pass the request on to it.
You may lodge a complaint with the supervisory authority: in Italy, the Garante per la protezione dei dati personali (www.garanteprivacy.it); in Spain, the Agencia Española de Protección de Datos (www.aepd.es); or the authority of the European Union country where you live.
Minors
Pets is not directed at minors under fourteen, and an adoption is formalised with the shelter by a person of legal age. Of the number of minors who live with you we store only that, the number.
Security
Communications are encrypted (TLS). The phone's session credentials live in its secure store. Each shelter sees only what is its own: requesting an item of data belonging to one shelter with another's session does not return the data. If we detect a breach that affects you we will tell you, and the supervisory authority within the 72 hours the law sets.
Changes
If we change what we do with data, we change this text and move the revision date. That date is the version that is recorded when you send an application.