Has.Pet — Privacy Policy

Effective date: 26 June 2026 · Last updated: 26 June 2026

1. Who We Are (the Controller)

Has.Pet Ltd., a company incorporated in the Republic of Cyprus, company registration number HE492821, registered office KPMG Center, 1st Floor, Agias Fylaxeos Street 1, 3025 Limassol, Cyprus ("Has.Pet", "we", "us", "our"), is the controller of the personal information described in this Privacy Policy.

Has.Pet operates the "Has.Pet" mobile application (the "App") and the website https://has.pet/. The App, the website, the Pet Expert feature and the content we make available are together the "Services".

We are launching the Services in the United States first. We are nonetheless established in the European Union (Cyprus), which is why this Policy also sets out European data-protection rights (see Sections 4, 7 and 9); we may offer the Services to users in the EU and the UK in the future.

Privacy contact: hello@has.pet.

2. What This Policy Covers

This Privacy Policy explains how we collect, use, share and protect personal information when you use the Services. It includes our use of cookies and similar technologies on the website (Section 14) and our California Notice at Collection (Section 12A).

Has.Pet is a pet wellness and pet-care information service that provides general educational information. It is not a veterinary medicine service and not telemedicine. The App does not diagnose, treat or prescribe. Information about your animal is data about an animal, not your own personal health data (see Section 5).

The Services are not intended for, and may not be used by, persons under 18 years of age (see Section 11).

3. The Personal Information We Collect

We collect the following categories of personal information. "You provide" = information you enter; "Generated" = produced by the App or its AI features; "Automatic" = collected by the App or your device.

3.1 Account & identity (you provide / via sign-in provider). Email address, user ID, language / locale, subscription link, and an optional family-group ID. You sign in with Apple or Google (single sign-on). Referral and family codes; family-member IDs.

3.2 Pet profile (you provide). Pet name, species, breed, age, weight, sex, neuter status, pet photo. Pet health information you choose to enter, such as vaccinations, vet-visit dates, allergies and chronic conditions.

3.3 Pet health-related inputs (you provide / Generated). Symptoms and observations you report (for example via chat); your pet's event log; category flags for "areas to watch with a vet". Activity logs, feeding logs, weight log, free-text daily notes, and tracking goals / preferences. A wellness score and zone derived from the above. We treat pet health-related inputs and photos as sensitive personal information (see Section 5).

3.4 AI photo wellness check (you provide photos / Generated results). Photos you upload for a photo-based wellness check (for example body, dental, eyes, ears, coat). AI-generated category observations and an internal indicator, plus scan history and trends.

3.5 AI assistant (you provide / Generated). Chat messages, conversation language, and any photo or video attachments. Assistant context used to personalize responses, and per-interaction technical logs (for example detected language, prompt version, latency, and your feedback rating).

3.6 Pet Expert (you provide). Photos, videos and messages you share when you ask a Pet Expert, and a consultation quality rating. The live Pet Expert handling your request can see the information about your pet and your name in order to answer it (see Section 6). Pet Experts are care, behavior and nutrition specialists - they are not veterinarians, and the Services do not establish a veterinarian-client-patient relationship.

3.7 Learning & engagement (you provide / Generated). Course and care-module progress, quiz scores, streaks and points; onboarding preferences.

3.8 Usage & analytics (Automatic). Product-analytics events (for example install, trial, paid, renew, and onboarding events), retention metrics, and user properties. Before sign-in an anonymous identifier is used, then linked to your account.

3.9 Device & technical (Automatic). Device language, push-notification token and notification preferences, and a device signal used to protect the referral program from abuse. Diagnostics / crash data: we use Sentry to capture crash and error diagnostics. This includes device information, operating-system version and software stack traces, and may include your IP address. We use this only to detect, diagnose and fix technical problems and to keep the Services stable. We do not use crash diagnostics for advertising, and this data is not linked to you for cross-app tracking.

3.10 Billing (you provide → via our payment processors). On the web, purchases are processed by Paddle.com Market Ltd ("Paddle") acting as the Merchant of Record - Paddle is the seller of record and handles payment processing, tax and refunds. On mobile, purchases may instead be processed through Apple In-App Purchase or Google Play Billing. We receive subscription status (plan, start / end, trial / paid). We do not store your card or payment-instrument data. Subscription billing, auto-renewal, cancellation and refund terms are described in the Has.Pet Terms of Use (Section 16), not here.

3.11 Veterinary-document upload - not collected in this version. We do not collect uploaded veterinary documents today. We do not reserve any right to collect this data now.

4. Why We Use Your Information, and Our Legal Bases (EU / UK)

This Section applies because we are established in the European Union (Cyprus); it will be most relevant to users in the EEA and the UK, whom we may serve in the future. For such processing we rely on the following legal bases under the GDPR / UK-GDPR:

To provide the Services: performance of our contract with you (Art.6(1)(b)).
To process payments and manage your subscription: performance of our contract (Art.6(1)(b)).
For product analytics and to improve the Services: our legitimate interests (Art.6(1)(f)).
For advertising, retargeting and attribution (Meta, AppsFlyer - see Section 6A): your consent (Art.6(1)(a)) for the advertising/tracking technologies, once we serve EU/UK users.
For marketing push / email: your consent (Art.6(1)(a)).
For referral anti-abuse and security: our legitimate interests (Art.6(1)(f)).

We treat information about your pet's health as sensitive personal information and handle it with corresponding care. We do not treat it as ordinary "commercial information" and we do not use it as a product to be sold.

Information about an animal is not your own personal health data, and the special-category rules for human health data (for example GDPR Article 9 or the US HIPAA framework) do not apply to the animal as a subject. However, because such information is linkable to you as an identifiable owner, we apply heightened safeguards.

We share personal information with service providers (processors) who process it on our behalf, with advertising and attribution partners as described in Section 6A, and as otherwise described in this Section.

Service providers (processors). We share personal information with service providers who process it on our behalf under contract, and only as needed to operate the Services:

Supabase - database, file storage and authentication (hosting).
AI processing providers - process your chat messages and the photos you submit to power the AI assistant and the photo wellness check. We currently use Google (Gemini) and may use other AI providers over time (for example, for fallback or performance). They process this content on our behalf and are contractually prohibited from using it to train their own models.
RevenueCat - subscription management.
Amplitude - product analytics.
Sentry - crash and error diagnostics (device information, OS version, stack traces, possibly IP address). Used only to detect and fix technical problems; not used for advertising and not linked to you for cross-app tracking.
Paddle (Paddle.com Market Ltd) - web payment processing as Merchant of Record; Paddle processes your payment, applicable taxes and refunds.
Apple / Google - sign-in (SSO) and, for mobile purchases, in-app billing.

To measure the performance of our advertising and to show you Has.Pet ads on other apps and websites (for example, to reach people who have visited our website or used our App), we use the following partners and share certain device-level and event information with them:

Meta (Facebook/Instagram) - advertising, retargeting and conversion measurement, via the Meta SDK and the Meta pixel on our website.
AppsFlyer - mobile attribution and marketing analytics.

The information shared for these purposes is device-level and event-level - for example a mobile advertising identifier or device/event identifier, the IP address, and app/website events such as install, trial start, subscription and page views. We do not share your pet health-related information, your chat or Pet Expert content, your wellness-check photos, or your wellness scores with these advertising and attribution partners.

Under the CCPA/CPRA and several other US state privacy laws, this use is treated as "sharing" of personal information for "cross-context behavioral advertising," and may be treated as a "sale." You can opt out - see Section 6B ("Your Privacy Choices"). On Apple devices, we also ask for your permission through the App Tracking Transparency prompt before tracking you across other companies' apps and websites; see Section 10A. Our use of advertising/targeting cookies and pixels on the website is described in Section 14 (Cookies).

You can opt out of the "sale" or "sharing" of your personal information for cross-context behavioral / targeted advertising:

Use our "Do Not Sell or Share My Personal Information" / "Your Privacy Choices" control at [opt-out link or in-app setting] and follow the steps shown.
Global Privacy Control (GPC). Where required, we treat a recognized opt-out preference signal, such as Global Privacy Control, as a valid request to opt out of the sale/sharing of personal information for the browser or device that sends it.
Apple App Tracking Transparency (ATT). On iOS, if you decline the ATT prompt, we will not use the device's advertising identifier to track you for cross-app advertising.

When you opt out, we stop sharing your personal information for cross-context behavioral advertising for that browser or device; some measurement that does not constitute sale/sharing may continue as permitted by law.

Pet Experts. When you ask a Pet Expert, the live Pet Expert assigned to your request can see the information about your pet and your name in order to answer it. Pet Experts act as our service providers under confidentiality obligations and on a data-minimization basis - they receive only the information needed to respond to your request and may not use it for any other purpose. This disclosure to a Pet Expert to fulfill your request is not a sale of your information. Some Pet Experts may be located outside the EEA or the UK; where that is the case we apply the cross-border transfer safeguards described in Section 7.

We may also disclose information where required by law, to enforce our terms, or in connection with a corporate transaction, subject to this policy.

Using de-identified or aggregated information to improve our models. As described in Section 10B, we may use de-identified or aggregated information to operate, develop, train and improve our own features, models and the Services (including image and other machine-learning models). We keep this information in de-identified or aggregated form and do not attempt to re-identify it. This is separate from advertising and from any sale of data: we do not sell your personal information, we do not share personal information with third parties for their own research or monetization, and we do not use your pet health-related information for advertising. Where required by law, you can limit the use of your sensitive personal information (see Section 12).

7. International Transfers

We are established in the Republic of Cyprus (EU). Where our service providers or Pet Experts process information outside the EEA or the UK, we rely on an appropriate transfer mechanism, such as the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum for UK transfers) or an adequacy decision / certification where available.

8. How Long We Keep Information

We keep personal information only as long as needed for the purposes set out above, then delete or anonymize it. As a general rule, your pet profile and health-related timeline, "areas to watch" category flags, photos from the wellness check, and chat transcripts are kept while your account is active and are deleted or anonymized within a limited period after you delete your account, or once they are no longer needed for the purpose for which they were collected. Billing and transaction records are retained as required for accounting, tax and legal purposes. Your account is kept until you delete it, plus a short grace period.

9. Your Rights

United States. Depending on the US state you live in, you may have the rights to confirm whether we process your personal information and to access it; to correct inaccurate personal information; to delete personal information; to obtain a portable copy; to opt out of the "sale" or "sharing" of personal information and of targeted/cross-context behavioral advertising (we do share certain device-level and event information for advertising and attribution - see Sections 6A and 12 - and you can opt out via Section 6B); to limit the use of sensitive personal information; and to not be discriminated against for exercising these rights.

California residents: see Section 12 and Section 12A (California Notice at Collection).
Residents of other US states that have a comprehensive privacy law in force (see Section 12) have the equivalent rights that law provides, and we honor them as required.
Global Privacy Control (GPC). Where required, we treat a recognized opt-out preference signal, such as Global Privacy Control, as a valid request to opt out of the sale/sharing of personal information for the browser or device that sends it.

EEA / UK (applies due to our EU establishment; relevant once we serve EU/UK users). You have the right to access, rectify, erase, restrict or object to processing of your personal information, the right to data portability, and the right to withdraw consent at any time. You may lodge a complaint with a supervisory authority - for example the Cyprus Commissioner for Personal Data Protection (our lead authority), the Information Commissioner's Office (ICO) in the UK, or the authority in your country of residence.

How to exercise your rights: in-app privacy controls or hello@has.pet. We respond within the time limits required by law. We will not discriminate against you for exercising your rights.

10. AI Processing & Transparency

Some Has.Pet features use third-party AI providers to process your inputs - including your chat messages and the photos you submit (for example, for the photo wellness check). We currently use Google's Gemini and may use other AI providers over time (for example, for fallback or performance). When you use the AI assistant you are interacting with an AI, not a human (a live Pet Expert responds only in the Pet Expert feature). Our AI providers process this content on our behalf to provide the Services and are contractually prohibited from using it to train their own models. The AI provides general wellness information and does not diagnose, prescribe or treat.

10A. Apple App Tracking Transparency (iOS)

Because we share device-level information with advertising and attribution partners (Section 6A), on Apple devices we present the App Tracking Transparency (ATT) prompt and ask for your permission before we track you across other companies' apps and websites or access your device's advertising identifier for that purpose. If you decline, we will not use the advertising identifier to track you for cross-app advertising. You can change this choice at any time in your device settings.

10B. Improving and Training Our Own Models

We may use de-identified or aggregated information derived from your use of the Services - including from the photos you submit, your chat messages, your Pet Expert conversations, and usage data - to operate, develop, train, and improve our own features, models, and the Services (including image and other machine-learning models). Before we use information for this purpose, we de-identify or aggregate it so that it no longer reasonably identifies you or your account, we maintain it only in that form, and we do not attempt to re-identify it except as permitted by law.

This use is separate from advertising and from any sale of data. We do not sell your personal information; we do not use your pet health-related information for advertising; and using de-identified or aggregated information to develop and train our own models is not a "sale" or a "share" of personal information. We do not use your information to train the models of our third-party AI providers, and those providers are contractually prohibited from using your content to train their own models. Where required by applicable law, you can limit the use of your sensitive personal information (see Sections 6B and 12).

11. Children

The Services are not intended for persons under 18 years of age, and we do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided us information, contact hello@has.pet and we will delete it.

12. United States - State Privacy Rights

We launch in the United States first, so US state privacy law is the leading framework for this Policy.

12.1 California (CCPA / CPRA). If the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies, California residents have the rights to know, access, delete and correct personal information, to opt out of the "sale" or "sharing" of personal information, to limit the use of sensitive personal information, and to non-discrimination. See also Section 12A.

12.2 Other US state comprehensive privacy laws. Several other US states have enacted comprehensive consumer privacy laws. Where one applies to us and to you, you have the rights that law provides (generally to access, correct, delete and obtain a portable copy of your personal information, and to opt out of targeted advertising, the sale of personal information, and certain profiling), and we honor them. Several of these laws require us to honor a recognized universal opt-out mechanism such as Global Privacy Control (GPC); see Section 9.

12.3 Our posture across all US states. We share certain device-level and event information for advertising and attribution with Meta and AppsFlyer (see Section 6A). Under the CCPA/CPRA and several other state laws this is treated as "sharing" for cross-context behavioral advertising, and may be treated as a "sale." You can opt out - see Section 6B - and we honor recognized opt-out preference signals such as GPC. We treat pet health-related information as sensitive personal information (we do not classify it as ordinary commercial information) and we do not share it with our advertising or attribution partners.

12A. California Notice at Collection

This Section 12A is our Notice at Collection for California residents under the CCPA/CPRA. A short notice or a clearly labeled link to this Section is also surfaced at or before the point of collection - for example on the sign-up form and in the privacy menu.

Has.Pet Ltd. collects the personal information and sensitive personal information described below to provide and operate the Services, including for account creation and management, customer support, security and fraud prevention, payment processing, and to provide and improve the Services. We treat pet health-related information as sensitive personal information; we do not treat it as ordinary commercial information.

We share some personal information for cross-context behavioral advertising and attribution. To measure our advertising and to show you Has.Pet ads on other apps and websites, we share device-level and event information (such as a device or advertising identifier, IP address, and app/website events) with Meta and AppsFlyer (see Section 6A). Under the CCPA/CPRA this is treated as "sharing" (and may be treated as a "sale") of personal information. The "Sold or Shared" column below shows "Yes" for the categories used for advertising/attribution and "No" for the rest. You can opt out - see "Your California Rights" below and Section 6B.

We do not sell or share your sensitive personal information, including pet health-related information, for cross-context behavioral advertising.

Improving our own models; no third-party monetization. We may use de-identified or aggregated information to develop, train and improve our own Services and models (including image and other machine-learning models), and we do not attempt to re-identify it (see Section 10B). We do not sell your personal information, and we do not disclose or monetize your personal information to third parties for their own research. Using de-identified or aggregated information for our own model development is not a "sale" or a "share" of personal information under the CCPA/CPRA.

The Services are intended for persons 18 years of age or older.

Your California Rights. California residents have the rights to: know and access the personal information we collect; delete personal information; correct inaccurate personal information; opt out of the "sale" or "sharing" of personal information; limit the use and disclosure of sensitive personal information; and not be discriminated against for exercising these rights. Because we share personal information for cross-context behavioral advertising and attribution (with Meta and AppsFlyer), you have the right to opt out of that sale/sharing. To opt out, use the "Do Not Sell or Share My Personal Information" / "Your Privacy Choices" control (see Section 6B). We do not sell or share your sensitive personal information (including pet health-related information).

Opt-out preference signals. Where required, we treat a recognized opt-out preference signal, such as Global Privacy Control (GPC), as a request to opt out of the sale or sharing of personal information for the browser or device that sends it, and we honor it (see Sections 6B and 9).

To exercise your rights, use the in-app privacy controls or email hello@has.pet. We will verify your request as required by law and respond within the time limit the CCPA allows.

Personal Information Categories

Category	Examples	Retention	Sold or Shared
Identifiers	Email address, user ID, anonymous/analytics identifier, device/advertising identifier, IP address, device push token, family/referral codes.	While your account is active; advertising and attribution identifiers are kept for a limited measurement window, then deleted or aggregated.	Yes - device/advertising identifier and IP shared with Meta/AppsFlyer for cross-context behavioral advertising & attribution. (Email and account identifiers: No.)
California Customer Records	Name (if provided), email address, subscription/transaction status. We do not collect SSN, driver's license, passport, bank or card numbers (payment is handled by Paddle, Apple or Google).	While your account is active, plus a short grace period after deletion.	No
Protected classification characteristics	Not collected.	*	No
Commercial information	Subscription/purchase status and product-interaction history. (Pet health-related information is not placed here - it is sensitive personal information, below.)	While your account is active, plus records required for accounting, tax and legal purposes.	No
Biometric information	Not collected.	*	No
Internet or other network activity	Product-analytics events and app-interaction data; advertising/attribution events (install, trial, subscription, page views).	Kept for a limited period for product analytics and advertising/attribution, then deleted or aggregated.	Yes - advertising/attribution events shared with Meta/AppsFlyer for cross-context behavioral advertising & attribution. (Internal product analytics: No.)
Geolocation data	Not collected (no precise location).	*	No
Sensory data	Photos and videos you upload (pet photos, wellness-check photos, Pet Expert attachments).	While your account is active; deleted within a limited period after you delete them or delete your account.	No
Professional / employment information	Not collected.	*	No
Non-public education information	Not collected.	*	No
Inferences	App-derived signals used to personalize the Services (for example a wellness score, "areas to watch" flags, assistant context). These are health-derived and are not shared for advertising.	While your account is active; deleted or anonymized within a limited period after account deletion.	No

Sensitive Personal Information Categories

We collect the following sensitive personal information solely to provide the Services. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you, and we do not sell or share it.

Category	Examples	Retention	Sold or Shared
Account access credentials	Sign-in is via Apple or Google SSO; we do not hold your store-account password.	While account active	No
Government identifiers; precise geolocation; protected-trait data; contents of private messages; genetic/biometric/neural data	Not collected.	*	No
Health information - pet health-related information you provide	Pet profile health fields, symptoms and observations you report, wellness-check photos, activity/feeding/weight logs and notes, and the derived wellness score. Used only to provide the Services; not classified as commercial information.	While your account is active; deleted within a limited period after you delete it or delete your account.	No

California contact / alternative format. If you have questions about this Notice, or need it in an alternative format due to a disability, contact hello@has.pet or +357 9505 7377.

13. Security

We protect your information using technical and organizational measures, including encryption in transit and at rest, and storing documents separately from structured data. No method of transmission or storage is completely secure.

14. Cookies and Similar Technologies (Website)

This Section explains how we use cookies and similar technologies on the website https://has.pet/. We are launching in the United States first; the choices below are offered to all visitors, with EU/UK consent rules applying to visitors in those regions.

14.1 What cookies are. Cookies are small text files placed on your device when you visit a website. Similar technologies (such as local storage, pixels and SDKs) work in a comparable way. They can be set by us ("first-party") or by a third-party provider, and can last only for your session or for a set period.

14.2 How we use cookies. We use cookies to: make the website work and keep it secure (strictly necessary); remember your preferences (functional); understand how the website is used so we can improve it (analytics); and measure our advertising and show you Has.Pet ads on other apps and websites, including through retargeting and conversion measurement (advertising / targeting), including the Meta pixel.

14.3 The cookies we use. The cookies and similar technologies on our website are listed below.

Category	Set by	Purpose	Duration
Strictly necessary	Has.Pet (first-party)	Core website functionality, security, and remembering your cookie choices	Session and short-lived persistent
Functional	Has.Pet (first-party)	Remembering your preferences and settings	Persistent
Analytics	Has.Pet and our analytics provider(s)	Measuring and improving how the website is used	Persistent
Advertising / targeting	Meta (Meta pixel) and our advertising and attribution partners	Measuring our advertising and showing you Has.Pet ads on other apps and websites (retargeting and conversion measurement)	Persistent

A current, itemized list of the specific cookies and similar technologies actually in use - including their names, providers, and retention periods - is available through the cookie-settings control on the website, and is kept up to date.

We use advertising/targeting cookies and pixels (such as the Meta pixel) to show you Has.Pet ads on other apps and websites and to measure our advertising. Under US state privacy law this is treated as "sharing" (and may be "sale") of personal information for cross-context behavioral advertising - see Section 14.4 and Section 6B for how to opt out. We do not use cookies to share your sensitive or pet health-related information for advertising.

14.4 Your choices & consent. Strictly necessary cookies are always active because the website cannot work without them; they do not require your consent. For all other cookies, you can change or withdraw your choices at any time via the cookie-settings control.

United States visitors: we use advertising/targeting cookies and pixels (such as the Meta pixel) that "share" personal information for cross-context behavioral advertising. You can opt out using the "Do Not Sell or Share My Personal Information" / "Your Privacy Choices" control (see Section 6B), and you can turn off advertising cookies via the cookie-settings control. Where required, we treat a recognized opt-out preference signal, such as Global Privacy Control (GPC), as a request to opt out of sale/sharing for your browser, and we honor it.
EEA / UK visitors: we show a consent banner on your first visit and only set non-essential cookies after you opt in. You can change your choices at any time, and withdrawing consent is as easy as giving it.
You can also control cookies through your browser settings; blocking some cookies may affect how the website works.

14.5 Third-party cookies. Some cookies are set by third-party providers. Those providers process data under their own privacy terms; see Section 6 for the providers we work with.

15. Changes to This Policy

We may update this Privacy Policy. We will post changes here with a new "Last updated" date and, where required by law, notify you. Contact: hello@has.pet.