Privacy Policy
Last updated: 16 aprile 2026
This Privacy Policy is drafted in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and describes how personal data is processed on the Retroverse Srl platform ("Zoowanda"). Zoowanda is a B2B2C SaaS platform that does not provide direct medical-veterinary services and does not replace the advice, diagnosis or treatment of a licensed veterinarian.
1. Data Controller
The Data Controller is Retroverse Srl, with registered office at via dei lecci 10 06131 Perugia PG, VAT no. 04035040544, certified email (PEC) retroverse@pec.it.
Privacy contact: privacy@retroverse.com.
The Data Controller is the entity responsible for determining the purposes and means of processing personal data.
2. Data Protection Officer (DPO)
Zoowanda has not currently appointed a Data Protection Officer as the requirements for mandatory designation under Art. 37 GDPR do not apply. Should a DPO be appointed in the future, the contact details will be published in this section and notified to data subjects.
3. Personal Data Collected
3.1 For Veterinary Partners
We collect and process the following categories of data:
| Category | Examples | Source |
|---|---|---|
| Identification Data | First name, last name, address, email, phone | Direct registration |
| Professional Data | Veterinary Board registration number, specializations, CV | Direct registration |
| Billing Data | Practice name, billing address, bank/IBAN details, VAT no. | Sign-up form |
| Contact Data | Email, phone for administrative communications | Direct registration |
| Usage Data | Access logs, features used, session duration, IP addresses | Platform (technical cookies) |
| Clinical/Professional Data | Uploaded documents (reports, prescriptions, clinical records under management) | User upload |
3.2 For Pet Owner Users
We collect and process the following categories of data:
| Category | Examples | Source |
|---|---|---|
| Identification Data | First name, last name, address, email, phone | Direct registration |
| Pet Personal Data | Pet name, species, breed, date of birth, microchip number | Direct registration |
| Contact Data | Email, phone | Direct registration |
| Billing Data | Payment method, transaction history | Payment processor (Stripe) |
| Clinical Data | Veterinary reports, lab results, prescriptions, medical history | Partner or User upload |
| Usage Data | Access logs, features used, session duration, IP addresses | Platform (technical cookies) |
| Communication Data | Messages exchanged with veterinary Partners | Platform |
3.3 Nature of Veterinary Clinical Data
Veterinary clinical data (reports, lab results, diagnoses) concerns the health of the animal and does not in itself constitute "special categories of personal data" under Art. 9 GDPR, which protects only data relating to the health of natural persons.
However, veterinary clinical documents uploaded to the Platform frequently contain personal data of the owners (name, surname, contacts, microchip number that can be linked to the public registry) and of the veterinary professionals (name, stamp, signature). Such personal data is processed under Art. 6 GDPR.
The processing of clinical documents is permitted on the basis of:
- Performance of the contract (Art. 6(1)(b) GDPR): providing the requested Service (Digital Clinical Record management).
- Explicit consent (Art. 6(1)(a) GDPR): for processing through AI Features (separate and optional consent, see Section 14).
- Legitimate interest (Art. 6(1)(f) GDPR): regulatory compliance and Platform security.
4. Processing Purposes and Legal Bases
4.1 Common Purposes (Partners and Users)
| Purpose | Legal Basis | Retention Period |
|---|---|---|
| Performance of the Contract: Platform access, account management, payment processing | Art. 6(1)(b) GDPR | Contract duration + 3 years (Italian tax law) |
| Regulatory Compliance: legal obligations (tax records, retention of clinical documents) | Art. 6(1)(c) GDPR | Per applicable law (healthcare records: 10 years) |
| Platform Security: fraud prevention, unauthorized access, cyberattacks | Art. 6(1)(f) GDPR (legitimate interest) | 1 year from last access |
| Administrative Communications: Service notifications, Terms updates, important notices | Art. 6(1)(a) or (b) GDPR | Contract duration + 30 days |
4.2 Specific Purposes for AI Features
AI Features are an optional Service module that the User can activate separately. AI processing of documents takes place exclusively after collection of a specific and separate consent (see Section 14).
| Purpose | Legal Basis | Details |
|---|---|---|
| Automatic classification of clinical documents | Art. 6(1)(a) GDPR (explicit and separate consent) | Textual analysis via Google Cloud Gemini API to extract tags and taxonomies ("blood test", "vaccine", "x-ray"). The AI does not provide diagnoses or automated decisions. |
| Indexing and document search | Art. 6(1)(b) GDPR (AI Features contract) | Use of extracted tags to make documents searchable in the Digital Clinical Record. |
4.3 Specific Purposes for Analytics and Marketing
Analytics and marketing purposes are not currently active on the Platform. This section describes the framework that would apply in the event of future activation, always subject to User consent through the cookie banner.
| Purpose | Legal Basis | Details |
|---|---|---|
| Aggregate usage analysis (Analytics) | Art. 6(1)(a) GDPR (consent via cookie banner) | Pseudonymized analysis of trends and Platform performance. |
| Remarketing | Art. 6(1)(a) GDPR (consent via cookie banner) | Targeted advertising on third-party platforms. Optional, not currently active. |
5. Data Recipients and Transfers
5.1 Internal Recipients
- Zoowanda Administrative Team: access to billing and contact data.
- Technical Team: access to technical logs and security data.
- Support Team: access to User communications to resolve issues.
5.2 External Recipients (Data Processors)
| Provider | Data Category | Purpose | Location | Safeguards |
|---|---|---|---|---|
| Google Cloud | Pseudonymized textual content of clinical documents | Classification and tagging via Gemini API (Vertex AI) | EU — region europe-west4 (Paesi Bassi) | Cloud Data Processing Addendum (CDPA), Standard Contractual Clauses (SCC) |
| Stripe | Payment data (card, IBAN) | Processing of recurring payments | USA/EU | DPA contract, SCC |
| Transactional Email Provider | Email, minimal personal data | Sending Service communications and notifications | EU | DPA contract |
5.3 Sharing with Veterinary Partners
User-owners understand that documents and clinical data uploaded to the Digital Clinical Record can be viewed by the designated veterinary Partner. Such sharing is essential to the Service and is a prerequisite for managing the clinical record.
5.4 Extra-EU Transfers
AI Processing (Google Cloud): Zoowanda uses exclusively data centers located within the European Union (europe-west4 (Paesi Bassi)) for the AI processing of clinical documents. Pseudonymized textual content is not transferred outside the EU for this purpose.
Ancillary Google Cloud services (technical assistance, monitoring) may involve access by personnel located outside the EU: in such cases, Zoowanda relies on the Standard Contractual Clauses (SCC) approved by the European Commission, in accordance with the Schrems II ruling.
Stripe and other US-based services: for payment services and other extra-EU providers, Zoowanda relies on SCCs and verifies that each provider has adequate supplementary security measures in place.
6. Rights of the Data Subject
Each data subject has the following rights under the GDPR. To exercise rights contact privacy@retroverse.com; the response time is 30 days, extendable by an additional 60 days for complex cases.
6.1 Right of Access (Art. 15 GDPR)
The User has the right to obtain confirmation of processing and to receive a copy of their personal data in a readable and structured format.
6.2 Right to Rectification (Art. 16 GDPR)
The User has the right to rectify inaccurate or incomplete personal data. In most cases self-correction is possible by accessing the Account.
6.3 Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR)
The User has the right to request the erasure of personal data, except where Zoowanda is required to retain it for legal reasons.
- Tax retention obligations: 10 years.
- Clinical documents: minimum 10 years retention (healthcare regulations).
- Anonymized or aggregated data: not identifiable, excluded from the right to erasure.
6.4 Right to Restriction of Processing (Art. 18 GDPR)
The User has the right to request restriction (freezing) of processing in specific circumstances, e.g., while contesting the accuracy of the data.
6.5 Right to Data Portability (Art. 20 GDPR)
The User has the right to receive their data in a structured, commonly used and machine-readable format (CSV, PDF) and to transmit it to another controller. For Digital Clinical Record data, Zoowanda provides a complete export within 30 days of request.
6.6 Right to Object (Art. 21 GDPR)
The User has the right to object to processing for marketing, profiling or legitimate interest purposes. For analytics and marketing, refusal can be expressed via the cookie management panel at any time.
6.7 Right Not to Be Subject to Automated Decisions (Art. 22 GDPR)
Zoowanda does not use automated decisions with significant legal effects on the User. The AI document classification has a purely organizational nature and does not produce legal effects.
6.8 Right to Lodge a Complaint with the Supervisory Authority
If the User believes that the processing of their data violates the GDPR, they may lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali).
- Garante per la Protezione dei Dati Personali — Piazza di Monte Citorio 121, 00186 Rome, Italy.
- Email: garante@gpdp.it — Web: https://www.garanteprivacy.it
7. Data Retention Period
7.1 Retention Times
| Category | Duration |
|---|---|
| Account and registration data | Contract duration + 12 months (potential disputes) |
| Payment / billing data | 10 years (Italian tax and accounting obligations) |
| Access logs and technical data | 1 year |
| Clinical data (Digital Record) | Minimum 10 years (Italian healthcare regulations) |
| Analytics cookies (if enabled) | According to cookie duration (3-12 months) |
| Email communications | 5 years or until Account deletion + 1 year |
7.2 Deletion After Withdrawal
When a User withdraws, data is anonymized or deleted within 90 days, subject to legal retention obligations (tax and clinical).
8. Security Measures
Zoowanda implements technical and organizational measures to protect personal data:
- Encryption of data in transit (SSL/TLS) and at rest (AES-256).
- Multi-factor authentication (MFA) for sensitive access.
- Audit logs and anomaly monitoring.
- Segregation of clinical data in isolated, protected environments.
- Regular backups and disaster recovery plans.
- Periodic staff training on privacy and security.
- Data Protection Impact Assessment (DPIA) for high-risk processing.
9. Cookies
The processing of cookies is described in detail in Zoowanda's Cookie Policy. The Cookie Policy lists the individual cookies used, their duration, purpose and the procedures for managing consent and preferences.
10. Minors
10.1 Minimum Age
The Zoowanda Platform is not intended for persons under 18 years of age.
If an owner is a minor, the explicit and written consent of a parent or legal guardian is required. Zoowanda reserves the right to request documentation (copy of parent/guardian ID).
10.2 Rights of Parents/Guardians
Parents/guardians have the right to:
- View and control the processing of the minor's data.
- Rectify or delete data.
- Withdraw consent at any time.
11. Third-Party Links
The Platform may contain links to third-party websites. Zoowanda is not responsible for the privacy practices of such sites and invites Users to read their respective privacy notices independently.
12. Changes to the Privacy Policy
Zoowanda reserves the right to modify this Privacy Policy. Changes will be communicated via email or through a notice on the Platform with at least 30 days' notice.
Continued use of the Platform after the publication of changes constitutes acceptance of the updated version.
13. Contacts and Rights
For any matter related to the processing of personal data:
- Retroverse Srl — via dei lecci 10 06131 Perugia PG
- Privacy Email: privacy@retroverse.com
- PEC: retroverse@pec.it
- Supervisory Authority: https://www.garanteprivacy.it
14. Data Processing through AI Features
14.1 What AI Features Do
Zoowanda's AI Features use AI models (Google Cloud Gemini API via Vertex AI) for the following operations:
- Document classification: textual content analysis to assign predefined tags and taxonomies (e.g., "blood test", "vaccine", "x-ray", "ultrasound", "prescription").
- Indexing: making documents searchable within the Digital Clinical Record through extracted tags.
14.2 Legal Basis
Processing through AI Features is based on:
- Explicit and separate consent (Art. 6(1)(a) GDPR): the User provides specific, informed and separate consent at the time of AI Features activation. Consent is distinct from acceptance of Terms and Privacy Policy and is optional: the base Service operates fully without AI Features.
- AI Features contract performance (Art. 6(1)(b) GDPR): once AI Features are activated, processing is also necessary to provide the requested classification service.
14.3 How AI Consent Is Collected
- Timing: at the moment of AI Features activation (not at registration).
- Method: dedicated information screen with explicit affirmative action (button "I authorize AI processing of my documents").
- Information: before consent the User views a notice describing what the AI does, what data is processed, by whom, where, and how to withdraw consent.
- Recording: consent is recorded with timestamp, version of the accepted notice, IP address and user agent.
- No pre-flagging: consent is never pre-selected, an affirmative action by the User is always required.
14.4 AI Consent Withdrawal
The User can withdraw AI consent at any time, with the same ease used to grant it:
- Through the "Privacy and Consents" section in Account Settings.
- By disabling the "AI Features" toggle.
- Withdrawal has immediate effect on newly uploaded documents.
- Already extracted tags remain available as metadata unless explicit removal is requested.
- Withdrawal does not entail Account closure or loss of the base Service.
- The User can reactivate AI Features at any time.
14.5 Pre-processing Pseudonymization
- Personal identification data of the owner (name, surname, address, phone, email) is removed or replaced with generic identifiers before being sent to the AI model.
- The animal's clinical data (lab values, diagnoses, therapies, name and species) is sent as it is necessary for proper classification.
- The AI model thus receives a text describing the animal's clinical condition without identifying the owner.
- The link between the extracted tag and the original document (and the owner) occurs exclusively in Zoowanda's internal database, never in the context of AI processing.
14.6 Processing Localization and Security
- AI processing takes place on servers located in the European Union (Google Cloud, region europe-west4 (Paesi Bassi)).
- Data sent to the API is protected by encryption in transit (TLS) and at rest (AES-256).
- Google Cloud contractually guarantees (Cloud Data Processing Addendum) that data sent via Vertex AI is not used to train models and is not retained after processing (zero data retention).
- Each AI processing is recorded in Zoowanda's internal audit log (document ID, timestamp, model used, outcome), without the document's content.
14.7 Specific User Rights for AI Features
In addition to the general rights in Section 6, the User has the right to:
- Withdraw AI consent without consequences on the base Service (see 14.4).
- Request removal of all tags and classifications generated by the AI for their documents.
- Request information on which documents have been processed by the AI, when and with what outcome.
- Contest an erroneous classification and request manual correction.
15. Final Provisions
15.1 Severability
If any provision of this Privacy Policy is found to be invalid, the remaining provisions shall continue to be valid and effective.
15.2 Applicable Law
This Privacy Policy is governed by Italian law and the GDPR (Regulation EU 2016/679).