Informativa sulla privacy

Pativo
Last updated: 15 November 2026 · Version 1.0

This policy explains what personal data Pativo (the "app") processes, why, who else handles it, how long it is kept and what rights you have. It is written for users everywhere. It also serves as the information notice (aydınlatma metni) required by Article 10 of Türkiye's Personal Data Protection Law No. 6698 ("KVKK") and as the information required by Articles 13 and 14 of the EU General Data Protection Regulation ("GDPR").

A Turkish version is available. If the two versions differ, the version in the language you used the app in applies to you, to the extent the law allows.

1. Summary

The app keeps your pets' records on your phone, encrypted. It also keeps a copy in your own account on our server in the European Union, so that your records survive a lost phone.
You do not need to give your name to use the app. An email address is only needed if you want to restore your records on another device.
The AI symptom check and AI questions only work after you give explicit consent. When you use them, what you wrote, the pet details listed in section 4.4 and any photos you attach are sent to OpenAI, through our own server, to produce an answer. You can withdraw consent at any time. Everything else in the app works without it.
We do not show ads, sell data, track you across other companies' apps or websites, or use your data to train AI models.
You can export all your records and delete your account inside the app. Deletion removes your account and every record linked to it from our server.

2. Who is responsible for your data (data controller)

The data controller (veri sorumlusu) is:

Ali Mert Güleç, an individual developer
Address: postal address available on request at support@pativo.app
Email: privacy@pativo.app

No representative in the EU has been appointed. Send any privacy or GDPR request to privacy@pativo.app.

We have not appointed a data protection officer, because the law does not require one for an operation of this size. Contact us about privacy at privacy@pativo.app.

3. Which features process data

The app has two kinds of features:

Runs entirely on your phone	Sends data off your phone
Pet profiles, care tasks and reminders, check-ins, weight, medications, vaccinations, vet visits, toilet log, poisoning and emergency guides, vet visit summary, data export	Syncing your records to your account (section 4.2) · AI symptom check and AI questions (4.4) · Feedback on an AI answer (4.5) · Subscriptions (4.6) · Optional email sign-in (4.1)

Reminders are local notifications scheduled on your phone. We do not use push notifications and do not collect a push token.

4. What data we process, why, and on what legal basis

4.1 Account

When you first open the app, it creates an anonymous account with a random identifier (a user ID). You are not asked for a name or an email. The account exists so that your records belong to you on the server and nobody else can read them.

If you choose to add an email address (for example to restore your records on a new phone), we store it and send it one-time sign-in codes.

Data	Purpose	GDPR basis	KVKK basis
User ID, account creation date, app language, email address (optional), sign-in session tokens	Providing the account, signing you in, restoring your records	Performance of a contract (Art. 6(1)(b))	Necessary for the establishment and performance of a contract (Art. 5(2)(c))

4.2 Pet records and sync

You enter information about your pets: name, species, breed, date of birth, sex, and records such as care tasks, daily check-ins, weight, medications, vaccinations, vet visits (date, reason, clinic and vet names, diagnosis, treatment, follow-up date) and the toilet log, including notes you write.

These records are stored on your phone and synced to your account on our server, so that they can be restored and so that the AI features can confirm that you are asking about your own pet.

Results of AI symptom checks and the photos you take for them are stored only on your phone. They are not synced to the server.

Data	Purpose	GDPR basis	KVKK basis
Pet profile and care records you enter	Providing the app, backing up and restoring your records	Performance of a contract (Art. 6(1)(b))	Art. 5(2)(c)

Information about an animal is not, in itself, "health data" about a person under the GDPR or the KVKK. However, notes you write may reveal something about you or your household. Please do not enter information about your own health or about other people.

Before the AI features can be used, we ask for your explicit consent. When you give or withdraw it, we store on the server: the version of the disclosure you saw, the name of the AI provider shown on it (OpenAI), the time you gave consent and, if applicable, the time you withdrew it. The server refuses AI requests unless a current, unwithdrawn consent is on record. If we change the provider or what is sent, we ask you again.

Data	Purpose	GDPR basis	KVKK basis
Consent version, provider name, timestamps	Proving and enforcing your consent choice	Legal obligation to demonstrate consent (Art. 6(1)(c) with Art. 7(1))	Necessary to comply with a legal obligation (Art. 5(2)(ç))

4.4 AI symptom check and AI questions

What is sent. When you run a symptom check or ask a question, the app sends the following to our server, which forwards it to OpenAI:

the symptoms you select and the description or question you write, and for questions, the recent messages in that conversation;
your pet's species, sex, breed, age in months, weight, life stage, its "normal" ranges learned from your check-ins, the urgency levels of recent checks and a summary of the recent toilet log;
the language you want the answer in;
photos, only if you attach them (at most three per check). Photos are resized and re-encoded on your phone before they are sent.

What is not sent to OpenAI: your name, your email address, your user ID, your pet's name, or your location.

Why. To give you an AI-generated assessment or answer. An AI answer is general information and not veterinary advice (see the Terms of Use).

How. The request passes through our server functions (hosted by Supabase in the EU) and our own forwarding service (a "proxy") on Cloudflare, which holds the API key. It is then processed by OpenAI. Our server does not store the content of your question, description, photos or the answer. The answer is returned to your phone and saved there.

To enforce fair-use limits, we record on the server that a request was made: the time, the type (check or question) and whether it succeeded. We do not record its content.

OpenAI's handling. OpenAI processes this data as our service provider. Under its API terms, OpenAI does not use API data to train its models and may keep it for a limited period (currently up to 30 days) to detect abuse, after which it is deleted.

Data	Purpose	GDPR basis	KVKK basis
The content listed above	Producing the AI assessment or answer	Explicit consent (Art. 6(1)(a) and, to the extent notes or photos reveal health data about a person, Art. 9(2)(a))	Explicit consent (Art. 5(1) and, where applicable, Art. 6(2)), and explicit consent to transfer abroad (Art. 9)
Request time, type, outcome	Enforcing monthly allowances and preventing abuse	Legitimate interest in keeping the service available and affordable (Art. 6(1)(f))	Legitimate interest (Art. 5(2)(f))

Withdrawing consent. Go to Profile → Privacy → AI processing and turn it off. From then on, nothing is sent to OpenAI, and the server also refuses AI requests. Withdrawal does not affect processing that took place before it.

If you do not consent. You can use every other feature. Only the AI symptom check and AI questions are unavailable.

4.5 Feedback on an AI answer

If you report an AI answer (for example as wrong or unsafe), we store: the type of report, the optional note you write (up to 1,000 characters) and a copy of the answer you saw (urgency level, summary, possible causes, and the model and prompt version). We do not store photos or your pet's name.

Purpose	GDPR basis	KVKK basis
Reviewing reports and making AI answers safer	Legitimate interest in the safety and quality of the service (Art. 6(1)(f))	Art. 5(2)(f)

4.6 Subscriptions and purchases

Payments are processed by Apple (App Store) or Google (Google Play). We never receive your card details. Subscriptions are managed through RevenueCat. RevenueCat receives your user ID, the purchase and renewal history from the store, and technical data such as your device's operating system, app version, country/storefront and IP address. It tells our server whether your subscription is active, and our server stores only your plan (free or premium), its renewal date and whether you are in a trial.

Purpose	GDPR basis	KVKK basis
Selling, activating and restoring subscriptions	Performance of a contract (Art. 6(1)(b))	Art. 5(2)(c)
Keeping records required by tax and commercial law, where applicable	Legal obligation (Art. 6(1)(c))	Art. 5(2)(ç)

Apple and Google process your payment as independent controllers under their own privacy policies.

4.7 Crash reports and usage analytics

Current status: not active. The app has a place for crash reporting (Sentry) and product analytics (PostHog), but the current version contains no such tools. In the version you install from the store, error reports and usage events are not sent anywhere.

If we turn these on in a future version, we will update this policy before doing so. In that case:

Crash reports (Sentry) would contain technical information about an error: device model, operating system, app version, the time and a technical description of the error, linked to a random user ID.
Usage events (PostHog) would record actions such as "check started" or "paywall viewed", without the content of your records, descriptions, questions or photos.
Both would be configured to remove personal data (such as email addresses and free text) before sending, and to use their EU data regions where available.
Legal basis: legitimate interest in fixing errors and improving the app (GDPR Art. 6(1)(f); KVKK Art. 5(2)(f)). Where the law requires consent for analytics, we will ask for it first.

4.8 Contacting us

If you email us, we process your email address and the content of your message to reply. Legal basis: legitimate interest in answering you, or steps you ask for before entering into a contract (GDPR Art. 6(1)(f)/(b); KVKK Art. 5(2)(c)/(f)).

4.9 Technical data on our servers

When the app connects to our server, the hosting providers necessarily process your IP address and basic request data (time, endpoint, response status) to deliver the connection and protect it from attacks. These entries are kept in the providers' logs for a short period (see section 7). Legal basis: legitimate interest in security (GDPR Art. 6(1)(f); KVKK Art. 5(2)(f)).

4.10 This website

Our website (https://pativo.app) is hosted by Cloudflare, which processes your IP address to deliver the pages. Its fonts and images are served from the same site, so your browser connects to no one else. The website sets no cookies and uses no analytics. It remembers your language choice in your browser's local storage, which never leaves your device.

5. How we collect data

We collect data electronically, from you, through the app (what you enter, select, photograph or attach) and automatically while the app connects to our server. Subscription status reaches us from Apple or Google through RevenueCat. We do not buy data or collect it from other sources.

6. Who receives your data

We do not sell, rent or trade your data. We do not share it with advertisers or data brokers. We only disclose it to the service providers below, who process it on our behalf and under our instructions, and only to the extent needed for the purposes in section 4.

Recipient	Role	What they process	Location
Supabase, Inc.	Database, sign-in, server functions	Account, records synced to your account, consent and request records, server logs	Data hosted in the EU: Frankfurt, Germany (AWS eu-central-1). Supabase, Inc. is a US company and its support may access data from other countries.
Cloudflare, Inc.	AI forwarding service (proxy); website hosting	AI request content in transit; IP addresses	USA company; global network (requests are handled in the data centre nearest to you)
OpenAI (OpenAI, L.L.C., USA)	AI processing	AI request content (section 4.4)	USA
RevenueCat, Inc.	Subscription management	User ID, purchase history, device and store data	USA
Apple Inc. / Google LLC	App distribution and payments (independent controllers)	Payment and purchase data	Under their own policies
Supabase	Sending one-time sign-in codes	Email address	USA
Only if enabled (section 4.7): Functional Software, Inc. (Sentry)	Crash reports	Technical error data	EU (Frankfurt)
Only if enabled (section 4.7): PostHog, Inc.	Usage analytics	Usage events	EU (Frankfurt)

We may also disclose data where the law requires it, to public authorities with legal power to request it, or to establish, exercise or defend legal claims.

7. Transfers to other countries

For users in Türkiye. All of the recipients above are outside Türkiye, so using the online features means transferring personal data abroad. Türkiye has no adequacy decision for these countries. We therefore rely on the following, under Article 9 of the KVKK:

standard contracts in the form published by the Personal Data Protection Authority, signed with our service providers and notified to the Authority (Art. 9(4)); and
for the AI features, your explicit consent to the transfer to OpenAI in the USA and to the proxy on Cloudflare, which we ask for after informing you of the possible risks (Art. 9(6)(a)).

Possible risks. The USA and other countries may not offer the same level of data protection as Türkiye or the EU. Public authorities there may be able to access data under their own laws, and your remedies there may be more limited. We reduce these risks by sending the minimum necessary (no name, email, user ID, pet name or location goes to OpenAI), encrypting all data in transit, and choosing providers with contractual data-protection commitments.

For users in the EU/EEA and the UK. Your synced records are stored in the EU. Data transferred to the USA (OpenAI, RevenueCat, Cloudflare and, if enabled, Sentry or PostHog) is protected by the EU–US Data Privacy Framework, where the provider is certified, and otherwise by the European Commission's Standard Contractual Clauses. As the data controller is based in Türkiye, data may also be accessed from Türkiye when we provide support or maintain the service. Contact us for a copy of the relevant safeguards.

8. How long we keep data

Data	Retention
Account, email, pet records synced to the server	Until you delete the records or your account. We do not currently delete inactive accounts automatically.
AI request content (descriptions, questions, photos, answers)	Not stored by our server. OpenAI: as described in section 4.4.
AI consent record	For the life of your account. Deleted with your account.
AI request log (time, type, outcome)	For the life of your account. Deleted with your account.
Feedback on AI answers	For the life of your account. Deleted with your account.
Subscription status on our server	For the life of your account.
RevenueCat customer record	Deleted when you delete your account.
Purchase records at Apple / Google	Under Apple's and Google's own policies.
Server and proxy logs	As set by the providers, typically a few days to 30 days.
Database backups	Deleted data may remain in encrypted backups for up to 30 days before being overwritten.
Emails you send us	Up to 24 months after the matter is closed, unless the law requires longer.
Data on your phone	Until you delete it, delete your account or uninstall the app.

When the retention period ends, data is deleted or anonymised. Under the KVKK, this is done in line with Article 7 of the law and the Regulation on the Erasure, Destruction or Anonymisation of Personal Data.

9. Security

On your phone: records, symptom-check history and your sign-in session are encrypted with XChaCha20-Poly1305. The key is held in the iOS Keychain or Android Keystore.
In transit: all connections use TLS (HTTPS).
On the server: row-level security means each account can only read its own records. Data is encrypted at rest by our hosting provider. The AI provider's key is kept on the server and never shipped in the app. Subscription status can only be changed by the verified store notification, not by the app.
Minimisation: the AI provider never receives your name, email, user ID, your pet's name or your location. Photos are resized and re-encoded before upload.

No system is perfectly secure. If a breach affects your personal data, we will notify the competent authority and, where required, you, within the legal deadlines (72 hours under the GDPR; under the KVKK, as soon as possible and within 72 hours as set by the Personal Data Protection Board).

10. Your rights

Under the KVKK (Article 11)

You have the right to:

a) learn whether your personal data is processed;
b) request information about it if it is processed;
c) learn the purpose of the processing and whether the data is used for that purpose;
ç) know the third parties in Türkiye or abroad to whom the data is transferred;
d) request correction if the data is incomplete or inaccurate, and request that this is notified to the third parties to whom it was transferred;
e) request deletion or destruction of the data when the reasons for processing no longer exist, under Article 7 of the KVKK, and request that this is notified to the third parties to whom it was transferred;
f) object to a result against you that arises from analysis of your data exclusively by automated systems;
g) claim compensation for damage caused by unlawful processing.

You have the right to access, rectification, erasure, restriction of processing, data portability, and to object to processing based on legitimate interest. You may withdraw consent at any time without affecting earlier processing. You may lodge a complaint with the supervisory authority in your country of residence or work.

The app does not make decisions that have legal or similarly significant effects on you solely by automated means. An AI answer is information for you to weigh, not a decision about you.

Doing it yourself in the app

Export: Profile → Export my data produces a complete file of your records.
Correct: edit any record or pet profile in the app.
Withdraw AI consent: Profile → Privacy → AI processing.
Delete everything: Profile → Privacy → Delete all my data (see section 11).

11. Deleting your account

Profile → Privacy → Delete all my data permanently deletes your account on our server and, with it, every pet, record, consent record, request log and feedback linked to it. It also asks RevenueCat to delete your customer record. Only after the server confirms the deletion is the data on your phone wiped.

Deleting your account does not cancel a subscription. Cancel it in your App Store or Google Play settings. Instructions without the app: https://pativo.app/account-deletion

12. How to exercise your rights

Send your request to privacy@pativo.app. For requests under the KVKK, you may also apply in writing to our postal address (postal address available on request at support@pativo.app), through registered electronic mail (KEP), with a secure electronic signature or mobile signature, or from the email address you have registered with us, in line with the Communiqué on the Procedures and Principles of Application to the Data Controller.

Please include:

your name (for KVKK written requests, also your T.R. identity number, or for foreign nationals your nationality and passport or ID number) and address;
the email address linked to your account in the app, if there is one;
what you are asking for.

If your account has no email address, we cannot otherwise confirm it is yours. The in-app tools above are then the quickest route.

We answer free of charge within 30 days (one month under the GDPR, which can be extended by two months for complex requests; we will tell you if so). If an answer requires a cost, we may charge the fee set by the Personal Data Protection Board.

If you are not satisfied with our answer, or we do not answer in time, you may complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu, www.kvkk.gov.tr) within 30 days of our answer, and in any case within 60 days of your application. EU users may complain to their national data protection authority.

13. Children

The app is meant for adult pet owners. It is not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, contact us and we will delete it.

14. What we do not do

No advertising, and no advertising networks in the app.
No selling or renting of personal data.
No tracking across other companies' apps or websites, and no advertising identifier (IDFA/AAID) collected.
No use of your data to train AI models.
No location collection.

15. Changes to this policy

We will update this policy when the app or the law changes. We will show the date at the top and, for material changes, tell you in the app before they take effect. If a change affects what is sent to the AI provider, or the provider itself, we will ask for your consent again.

16. Contact

Ali Mert Güleç
Address: postal address available on request at support@pativo.app
privacy@pativo.app

In breve