Privacy Policy — Pawntner pet owner app

Effective from 31 October 2026

This privacy policy applies to the Pawntner mobile app (iOS and Android). The app lets pet owners connect to their veterinary clinic's system: they can view their pets' records, book appointments and log home care data.

1. Operator of the app

The app is developed, published and operated by:

Elfvet Kft.

• Registered office: 3529 Miskolc, Szentgyörgy út 111/A. 3. em. 1/a., Hungary
• Company registration number: 05-09-038598
• Tax number: 32759655-2-05
• E-mail: tamas.tozsa@elfvet.hu

Data Protection Officer: Tamás Tózsa — tamas.tozsa@elfvet.hu, +36 20 294 1005

2. Who processes your data? (Roles)

The data controller is always the clinic you connect to. When you select a clinic in the app (from the list or by scanning the clinic's QR code), all of your data is sent to that clinic's server. This includes your account, your pets' data, the veterinary records and your own entries. The clinic's privacy policy governs the processing of this data. The app shows it for each clinic during registration, during activation and in Settings.

The operator of the app (Elfvet Kft.) is a data processor. It develops and operates the app and the clinic servers on behalf of the clinics. It processes the data only on the clinic's instructions. It does not use the data for its own purposes, does not sell it, and does not combine it with other clinics' data.

The operator does not process any data on its own behalf. The operator does not run a central server through which pet owners' data would flow. The list of clinics you can connect to is built into the app, so no log is created when you select a clinic either. The servers' security logs (IP address, time) are kept on behalf of the respective clinic, in line with its privacy policy.

3. What data does the app process?

The app sends the following data to the selected clinic, or displays it from there:

• Contact details: name, e-mail address, phone number, home address.
• User content: your pets' data, the clinic's records (medical records, vaccinations, prescriptions, invoices, appointments), and the data you enter yourself. These include uploaded photos (your pet's profile picture, photos of test results) and documents, senior care diary entries and questionnaire answers, recurring treatments and administered doses, body weight measured at home, and notes.
• Identifiers: your user (account) ID, and a device ID generated randomly for each phone. The latter is needed to manage sign-ins, for example so that a lost phone can be signed out.

The app does not use:

• tracking across other companies' apps or websites;
• advertising or advertising identifiers;
• analytics or crash reporting services;
• location data, contacts or the microphone.

4. Phone permissions

The app does not use Face ID or the microphone. You can revoke any permission at any time in your phone's settings.

5. Storage on the phone

• Sign-in tokens are kept in the system's secure storage (iOS: Keychain, Android: Keystore).
• The app keeps records in memory only. Downloaded PDFs and images are temporary.
• Data stored on the phone is deleted when you sign out or delete your account.

6. Data transfers and processors

The app sends data only over an encrypted connection (HTTPS) and only to the selected clinic's server.

We use the following subcontractors to operate the clinic servers:

Cloudflare and Resend are US companies. Data is transferred on the basis of the standard contractual clauses adopted by the European Commission (Article 46 GDPR) or, where the provider is certified, under the EU–US Data Privacy Framework (Article 45 GDPR).

7. Retention and deletion

• Deleting your account in the app: Settings → Delete my account. Your sign-in, all sessions and registered devices are terminated immediately, and the data stored on your phone is deleted.
• Records stay with the clinic. The clinic is required by law to retain veterinary records. This also includes the data you entered in the app, because the clinic may have used it for treatment. This data is kept without being linked to an account, for the period set out in the clinic's privacy policy.
• Upcoming appointment: if you have a booked appointment, you must cancel it before deleting your account.
• Pre-registration: if you have not yet registered as a client, you can withdraw your registration in the app at any time. Data from unsubmitted, expired and withdrawn pre-registrations is deleted automatically after a set period (typically 30 or 90 days). The exact deadlines are set out in the clinic's privacy policy.

8. Children

The app is not intended for children under 16. Only the pet's owner can create an account.

9. Your rights and remedies

You can request access to your data, and ask for it to be corrected, deleted or its processing restricted. You can request a copy of your data in a machine-readable format (data portability), and object to the processing.

For requests concerning veterinary records, please contact the clinic, because it is the data controller (its contact details are in the clinic's privacy policy and in the app). If you send your request to the operator, we will forward it to the clinic without delay.

If you believe your data is being processed unlawfully, you can lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH, 1055 Budapest, Falk Miksa utca 9–11., www.naih.hu, ugyfelszolgalat@naih.hu). You can also go to court; you may bring the case before the regional court of your place of residence.

10. Changes to this policy

If the app's data processing changes, we will update this policy and notify you of significant changes in the app as well.

Last updated: 31 October 2026