1. Data processing
At Lupa Pets Inc. (“Lupa Pets” or the “Company”) we are committed to the protection of your privacy! When you use our services through our website (the “Website”), through the Lupa Pets’ veterinary practice management system (“Lupa Pets’ PMS”) and/or Lupa Pets’ Application (the “APP”) (hereinafter collectively the “Services”) we may collect and process certain personal data and information about you and/or your clients. This is done in compliance with Data Protection laws, including but not limited to applicable state and federal privacy and data protection laws. This privacy policy allows you to understand the nature of your and/or your customers’ personal data (“Personal Data”) we will process during the performing of our Services, the purposes of such processing, any recipients of this data your related rights and our contact details.
2. Purposes for the processing of personal data
We use Personal Data – provided to us while onboarding or engaging in a contract with us or using Lupa Pets’ PMS and/or the APP – mainly to guarantee the best experience with our Services. This includes using Personal Data to improve our processes, analyse usage trends, and communicate with you, upon express consent, about our products and services in general. In particular, Lupa Pets will process the Personal Data in order:
a) to provide, operate and maintain the Services;
b) to improve, personalize, and expand our Services;
c) to understand and analyse how our Services are used;
d) to develop new products, services, features, and functionality;
e) to process transactions and manage orders;
f) to communicate with you directly for customer service, updates and, upon consent, marketing purposes;
g) to detect and prevent fraud;
h) to comply with legal obligations.
We will require your specific consent in order to promote additional services and offers through direct marketing or to transfer them to third country, when necessary.
3. Personal Data subject to processing
We collect Personal Data such as name, address, email, mobile phone number, recording of conversations hosted through the Services, and device details, which can be used to contact or identify you and your customers. While using our Services, Lupa Pets will automatically gather device’s usage data, which includes IP address, browser type and version, and the device’s operating system. Moreover, while using our Services we may access and store information regarding media files including but not limited to images, audio files, video which are sent or uploaded by you on Lupa Pets’ PMS, the Website, and/or the APP.
If you provide your mobile phone number, we store it as part of your veterinary clinic’s records, together with your text messaging consent and the text messages you exchange with your clinic through the Services. We use this information to provide the Services, including the text messages described in section 10, and we do not use it for our own marketing.
4. Legal basis for processing
We process Personal Data on the following legal basis, in accordance with applicable Data Protection Laws:
a) Contract or precontractual activity
Personal Data is processed to fulfil our obligations under the contract we have with you or to take steps, at your request, before entering into a contract.
b) Legal Compliance
Processing is necessary for compliance with legal obligations provided for by domestic law.
c) Legitimate Interests
Processing is necessary to pursue our legitimate business interests, provided these do not override your fundamental rights and freedoms.
d) Your Consent
When necessary, we rely on your explicit consent for specific types of data processing, such as those concerning marketing activities.
5. Storage period
We will store Personal Data only for as long as necessary to fulfil the purposes for which they have been collected, including legal, accounting, or reporting obligations and, in any case, they will be erased or anonymized after 10 years from termination of the Services.
6. Means of processing personal data and security measures
6.1.
Personal Data are processed using secure IT means and procedures only by authorised personnel within Lupa Pets, all of whom are authorized and bound by strict confidentiality agreements. We implement administrative, technical, and physical security measures in compliance with Data Protection Laws to prevent unauthorized access, data loss, or destruction. Personal Data could be processed as well by third subjects duly appointed as Processors.
6.2.
We may anonymize your Personal Data, combine it with anonymized data from other clients, and use it for purposes such as:
- Analysing the Services’ usage
- Benchmarking
- Preparing reports and other documents.
6.3.
We inform you that the functioning of certain Services offered may involve the use of Artificial Intelligence systems; such use is implemented in compliance with applicable legal standards to ensure fairness, accountability, and transparency. We will inform you and/or your customers before interacting with an Artificial Intelligence System (for example with a chatbot) so that it is possible to deny the interaction.
7. Scope of data sharing
We collect and process Personal Data:
- Directly within our organization, by subject duly authorised, or
- Through external service providers (known as “data processors” or “sub-processors” as appropriate) who assist us in delivering various services, among which Lupa Pets Ltd, as duly appointed sub-processor. These sub-processors are required to follow the same strict data protection standards outlined in this notice.
You can request an updated list of these sub-processors by contacting us at privacy@lupapets.com.
In certain cases, Lupa Pets may share your Personal Data with the following categories of entities, strictly when necessary and relevant, and ensuring that all data-sharing is limited and compliant with applicable laws:
- external consultants assisting with professional matters
- IT and service providers managing specific contractual requirements
- banks or credit institutions;
- judicial or public authorities, regulatory authorities and law enforcement agencies when legally required
- commercial partners used to provide you the Services, duly appointed as Processors or Sub-processors.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
8. Transfer of data to third countries
Your Personal Data may be transferred abroad, ensuring thorough suitable measures and procedures the protection of your Personal Data and the security of the transfers itself. You may request additional information by writing to privacy@lupapets.com.
In particular, we inform you that some of your Personal Data are transferred to the United Kingdom and processed also according to the dispositions of the UK General Data Protection Regulation (UK GDPR).
When transferring Personal Data to third parties, we aim to ensure the highest level of protection by safeguarding your Personal Data throughout the whole processing period also by entering into specific agreements that incorporate protection clauses.
9. Non-disclosure and non-dissemination of data
Your Personal Data will not be disclosed by Lupa Pets to third parties nor disseminated to unspecified subjects.
10. SMS / Text messaging
If you provide your mobile number to a veterinary clinic that uses Lupa, the clinic may send you text messages about your pets’ appointments and care, and, only if you separately opt in, occasional clinic updates and offers. Message frequency varies. Message and data rates may apply. You can opt out at any time by replying STOP, or get help by replying HELP.
We do not share, sell, or provide your mobile phone number or messaging consent data to third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.
11. Controller
The Controller is Lupa Pets Inc., a company incorporated under the laws of the State of Delaware, with its registered office at 8 The Green, Suite R, Dover, Delaware 19901, United States; email privacy@lupapets.com. Where Lupa Pets processes personal data of your customers on your behalf in the course of providing the Services, it does so as a processor in accordance with the Data Processing Agreement entered into with you.
12. Exercise of rights
You may obtain at any time full information on the operations referred to above and, specifically, you may obtain the erasure, transformation into anonymous form (unless Lupa Pets is under an obligation to process them) and blockage of data processed against the law; you may ask for their update or rectification or integration, object to their use and exercise any other rights granted by law. For this purpose please contact privacy@lupapets.com
In accordance with Lupa Pets’ Data Protection Complaints Procedure, available at www.lupapets.com, you may, at any time, lodge a data protection complaint by sending an email to privacy@lupapets.com or through the contact module available at www.lupapets.com.
Please be reminded that you may additionally lodge a complaint with your state Attorney General or other competent authority if you believe that your rights have not been respected or your queries have not been answered in accordance with the law.
Lupa Pets Inc.
Latest version dated September 2026