VETGUIDE – PRIVACY NOTICE (GLOBAL VERSION)
Last updated: 11 August 2025

1. Introduction

This Privacy Notice explains how VETGUIDE LTDA (“VETGUIDE”, “we”, “us” or “our”) collects, uses, shares and protects personal data of users of the VETGUIDE mobile application and related services (the “App”).

We strive to process personal data in accordance with applicable data protection laws, which may include, where relevant:

• The Brazilian General Data Protection Law (LGPD);
• The EU/EEA General Data Protection Regulation (GDPR);
• Other local laws in the countries where our users are located.

If there is any conflict between this Privacy Notice and mandatory local law, your local law will prevail to the extent of the conflict.

2. Who We Are and How to Contact Us

The App is owned and operated by:

VETGUIDE LTDA
Rua Bom Jesus, 212, Room 1904, 19th Floor, Condominium 3000
Juvevê, Curitiba – PR, 80035-010, Brazil
Email (general): contato@vetguide.com.br
Email (privacy matters): lgpd@vetguide.com.br

For privacy-related questions, requests or complaints, you can contact us via the dedicated privacy email above.

3. Scope and Roles

3.1. Controller
For most processing activities described in this Privacy Notice, VETGUIDE acts as the data controller, deciding how and why your personal data is processed.

3.2. Processors and third parties
To provide the App, we use other companies as processors (for example, hosting providers, analytics tools, AI model providers and App Stores) that process personal data on our behalf and under our instructions. In some cases, these parties may also act as independent controllers, with their own responsibilities and privacy policies (for example, Apple, Google or OpenAI).

4. Personal Data We Collect

Depending on how you use the App and the settings of your device and App Store account, we may collect the following categories of data:

4.1. Account and profile data

• Name;
• Email address;
• Password or login credentials;
• Country or region;
• Professional information (for example, whether you are a veterinary student or a licensed professional, field of practice, university or clinic).

4.2. Usage and interaction data

• Features you access, content you view, searches you perform;
• Time and duration of sessions;
• The way you navigate within the App;
• Interaction with notifications and in-App messages.

4.3. Device and technical data

• IP address;
• Device identifiers;
• Type and model of device;
• Operating system and version;
• App version;
• Language and region settings;
• Crash logs and performance data.

4.4. Subscription and transaction data

We do not process full payment card details directly. However, through the App Stores and the receipts they provide, we may receive information such as:

• Whether you have an active Subscription;
• Subscription plan, status and renewal dates;
• Country and currency of the transaction;
• Partial identifiers for the App Store account (in accordance with their policies).

4.5. Communications and support

• Messages you send to us via email or other support channels;
• Records of your requests and our responses;
• Information you voluntarily provide when you contact us.

4.6. Content you submit to the App

• Information that you manually type in calculators, notes, forms or other input fields, including clinical descriptions and scenarios;
• Text you send to the AI feature in order to receive suggestions.

We recommend that you avoid including directly identifiable personal data of any individual (for example, owner’s full name, phone number, address) or sensitive data unless strictly necessary and lawful.

4.7. Cookies and similar technologies

Insofar as we use cookies or similar technologies (for example, in web components or embedded pages), we do so to:

• Maintain your session;
• Improve performance and security;
• Understand how the App is used.

Where required by law, we will request your consent for non-essential cookies.

5. Why We Process Personal Data (Purposes and Legal Bases)

We process personal data for the following purposes, based on one or more legal bases depending on your location:

5.1. To provide and maintain the App

• To create and manage your account;
• To provide content, tools, calculators and AI features;
• To ensure the App functions properly, including updates and support.

Possible legal bases: performance of a contract, legitimate interests, compliance with legal obligations.

5.2. To manage subscriptions and payments

• To confirm Subscriptions and entitlements;
• To handle renewals, cancellations and access to paid content.

Possible legal bases: performance of a contract, legitimate interests, legal obligations.

5.3. To improve and develop the App

• To analyze usage patterns;
• To fix bugs, enhance performance and create new features;
• To understand which content is more relevant for our users.

Possible legal bases: legitimate interests (in improving services), consent (where required for analytics cookies or tracking technologies).

5.4. To communicate with you

• To send service and technical notices (for example, changes to terms or privacy);
• To respond to your questions and support requests;
• To send relevant information about updates, new content or features, where permitted.

Possible legal bases: performance of a contract, legitimate interests, consent (for certain marketing communications where required by law).

5.5. To ensure security and prevent misuse

• To monitor for suspicious or potentially harmful activities;
• To protect the App, our users and our rights;
• To detect, prevent and address fraud, abuse, or security incidents.

Possible legal bases: legitimate interests, legal obligations, public interest (in some jurisdictions).

5.6. To comply with legal obligations

• To keep records required by law;
• To respond to lawful requests from authorities;
• To meet data retention requirements applicable in certain countries.

Legal basis: legal obligations, public interest.

6. AI Feature and Use of Data with Third-Party Models

6.1. How it works
When you use the AI feature, the text and prompts you provide, as well as relevant context from the App, may be sent to third-party AI providers (such as OpenAI) so that they can generate a response.

6.2. Types of data involved

• Clinical descriptions or hypothetical cases you type;
• Limited account or context data where necessary to provide consistent answers (for example, your language or role as student/professional).

We seek to minimize personal data shared in this process. We recommend that you remove directly identifying details and only provide the information necessary for the professional context.

6.3. Third-party policies

The processing of this data by AI providers is also subject to their own terms and privacy policies. We select providers that commit to robust security and privacy practices, and we aim to configure them to avoid using your data to train models in a way that identifies you. However, you should:

• Avoid entering personal data of identifiable individuals; and
• Review the third-party terms when available (for example, OpenAI’s policies) for more information.

7. Sharing of Personal Data

We may share personal data with:

7.1. Service providers (processors)
Third-party companies that help us operate the App, such as:

• Cloud hosting and infrastructure;
• Analytics and performance tools;
• AI model providers;
• Email and communication tools;
• Security and anti-fraud services.

We require these providers to process data only under our instructions, adopting adequate security measures.

7.2. App Stores and payment intermediaries

As described above, Subscriptions and payments are handled by App Stores such as Apple and Google. These entities may process your data as independent controllers.

7.3. Professional advisors

Lawyers, auditors or consultants who need access to certain data to provide their services, subject to confidentiality duties.

7.4. Authorities and legal obligations

When required by law, court order or request from competent authorities, or when we believe in good faith that disclosure is reasonably necessary to:

• Protect our rights, safety, property or that of our users;
• Investigate fraud, abuse or security incidents;
• Comply with legal procedures.

7.5. Corporate transactions

In case of merger, acquisition, restructuring or sale of assets, your data may be transferred to the acquiring entity, subject to the continuity of this Privacy Notice or a similar level of protection.

We do not sell your personal data in the sense of many national data protection laws.

8. International Transfers

Because we operate using global cloud providers and third-party services, your personal data may be stored or processed in countries other than your own, including countries that may have different data protection laws.

When transferring data internationally, we take appropriate measures to protect it, which may include:

• Using countries recognized as providing an adequate level of protection; and/or
• Entering into contractual safeguards such as standard contractual clauses or equivalent mechanisms.

9. Data Retention

We keep personal data only for as long as necessary to fulfil the purposes described in this Privacy Notice, including:

• The time you maintain an active account;
• Any additional period required or permitted by applicable laws (for example, for tax, accounting or legal defense obligations).

When data is no longer needed, we will delete it or anonymize it, unless retention is legally required.

10. Security

We implement technical and organizational measures to protect personal data against:

• Unauthorized access or disclosure;
• Accidental or unlawful destruction, loss or alteration.

However, no system is completely secure. You are responsible for keeping your password and devices safe, and for notifying us promptly if you suspect any unauthorized access to your account.

11. Your Rights

Depending on your country or region, you may have some or all of the following rights:

• Right to obtain confirmation of whether we process your personal data;
• Right to access your personal data;
• Right to correct inaccurate or incomplete data;
• Right to request deletion of data, subject to legal retention obligations;
• Right to request anonymization, blocking or restriction of processing in certain circumstances;
• Right to object to processing based on legitimate interests or to withdraw consent when processing is based on consent;
• Right to data portability (receiving your data in a structured, commonly used, machine-readable format and/or requesting its transfer to another provider);
• Right to lodge a complaint with a data protection authority.

To exercise your rights, please contact us at lgpd@vetguide.com.br, indicating which right you wish to exercise and providing information that allows us to identify your account.

We may request additional information to confirm your identity before responding to your request. In some cases, we may be unable to fully comply with your request due to legal obligations or legitimate interests, and we will explain the reasons when this happens.

12. Children and Minors

The App is not intended for use by children under the age required in each jurisdiction to consent to data processing without parental authorization. We do not knowingly collect personal data from children under that age.

If you believe a child has provided personal data to us, please contact us so we can take appropriate action.

13. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. When we make material changes, we will inform you by appropriate means, such as in-App notifications or email, and indicate the date of the latest update at the top of the document.

Where required by law, we will seek your explicit consent to changes that significantly affect how we process your data.

14. Contact and Complaints

If you have questions, comments or requests related to this Privacy Notice or to the processing of your personal data, you can contact us at:

• General contact: contato@vetguide.com.br
• Privacy contact: lgpd@vetguide.com.br

Depending on your location, you may also have the right to lodge a complaint with your local data protection authority.