1. Data processing

At Lupa Pets Ltd (“Lupa Pets” or the “Company”) we are committed to the protection of  your privacy! When you use our services (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 the UK General Data Protection Regulation 2016/679 (UK GDPR) and Data Protection Act 2018. This privacy policy allows you to know – in accordance with articles 13 and 14 of the UK GDPR - the nature of the personal data (“Personal Data”) we will process during the performing of our services (the “Services”), the purposes of such processing, any recipients of this data your related rights and our contact details.

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2. Purposes for the processing of personal data

We use your Personal Data - provided to us while registering on our website or engaging in a contract with us – mainly to guarantee the best experience with our Services. This includes using your 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 your 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 directly or through partners for customer service, updates, and, upon consent, marketing purposes;

g) to contact you;

h) to detect and prevent fraud;

i) to comply with legal obligations.

We will require your specific consent in order to promote our services and additional offers through direct marketing or to transfer them to third country, when necessary.

We inform you that we might use Artificial Intelligence for the performance of the Services.

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3. Personal Data subject to processing

To enhance your experience and pursuing the above-mentioned purposes, we may collect Personal Data such as your name, address, and device details, which can be used to contact or identify you. While using our Services, Lupa Pets will automatically gather your device’s usage data, which includes your IP address, your browser type and version, and your device’s operating system. Moreover, while using our application (the “Application) we may access and store information regarding your location and media files including but not limited to images, audio files, video which are sent or uploaded by you on Lupa Pets platform or website.

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4. Legal basis for processing

We process your Personal Data on the following legal basis, as set forth by the UK GDPR:

a) Contract or precontractual activity

a. Your 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 (Article 6(b) of the UK GDPR).

b) Legal Compliance

a. Processing is necessary for compliance with legal obligations provided for by domestic law (Article 6(c) of the UK GDPR.

c) Legitimate Interests

a. Processing is necessary to pursue our legitimate business interests, provided these do not override your fundamental rights and freedoms (Article 6(f) of the UK GDPR).

d) Your Consent

a. When necessary, we rely on your explicit consent for specific types of data processing (Article 6(a) of the UK GDPR), such as those concerning marketing activities and when your Personal Data might be transferred to third countries.      

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5. Storage period

We will store your 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.

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6. Means of processing personal data and security measures

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6.1.

Personal Data are processed using secure IT means and procedures only by authorised personnel within Lupa Pets, all of whom are authorised and bound by strict confidentiality agreements. We implement administrative, technical, and physical security measures in compliance with the UK GDPR to prevent unauthorized access, data loss, or destruction. Personal Data could be processed as well by third subjects duly appointed as Processors.

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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 Application usage

● Benchmarking

● Preparing reports and other documents

This process ensures your identity, and any associated intellectual property remain fully protected.

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6.3.

In accordance with the transparency obligations set forth by the Regulation (EU) 2024/1689 on artificial intelligence (AI Act), 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.

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7. Scope of data sharing

We collect and process your 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. 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 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.

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8. Transfer of data to third countries

Your Personal Data may be transferred abroad to third countries, 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, in compliance with Article 49 of the UK GDPR, we inform you that some of your Personal Data may be transferred to countries that:

● do not yet have an adequacy regulation under Section 17A of the UK Data Protection Act 2018 (DPA 2018).

● lack adequate safeguards as outlined in Article 46 of the UK GDPR.

In such cases, your explicit and specific consent will be required before any transfer takes place. However, although you should      note that we cannot guarantee full compliance with the UK GDPR by organizations in these countries, this is without prejudice to the fact that, should data be transferred by the Company to its foreign branches and/or subsidiaries located in third countries, the latter will act in accordance with the provisions of the UK GDPR for the purposes set out in this information notice.

When transferring Personal Data to third parties, we aim to ensure the highest level of protection by:

● entering into specific agreements that incorporate the standard protection clauses adopted by the Secretary of State under Section 17C of the DPA 2018.

● safeguarding your Personal Data throughout the whole processing period as per Article 46 of the UK GDPR.

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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.

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10. Controller

The Controller is Lupa Pets Ltd., a company registered in having its principal place of business at 403, 4 Merchant Suare East, W2 1AN, London, United Kingdom; email privacy@lupapets.com.

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11. 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

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Please be reminded that you may lodge a complaint with the Information Commissioner’s Office (ICO) if you believe that your rights have not been respected or your queries have not been answered in accordance with the law:

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The ICO’s address is:

Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow

Cheshire

SK9 5AF.

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Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk  

Lupa Pets Ltd

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Latest version dated October 2025

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