Privacy
Nuvilo Privacy Policy
Last updated: 28 October 2026
Nuvilo is a shared memory for life with a pet. This policy explains what personal information we process when you use the Nuvilo app and nuvilo.pet, why, for how long, who helps us, and the choices you have. Pet records themselves are not personal data, but they are linked to your account and can include personal details (for example names in notes or documents), so we protect them the same way.
1. Who is responsible
The controller of your personal data is PROJECT1014, obrt za računalno programiranje i savjetovanje, owner Igor Zorko, Bobovik XIII 35 C, 23234 Vir, Croatia, OIB 26505572740 ("Nuvilo", "we"). Contact for privacy questions: privacy@nuvilo.pet. General support: support@nuvilo.pet.
2. What we process
- Account data: email address, display name, sign-in method (email code, Apple or Google), app language, account settings.
- Household data: the households you belong to (you can be in more than one), each member's role (Owner, Caregiver, Viewer), invitations (the invitee's email address or invite link) and their status, ownership-transfer requests, and who created, changed or completed records and reminders.
- Pet data and content you add: pet profiles and photos, care records (vaccinations, medications, vet visits, weight, reproductive health, expenses, memories, documents), reminders, notes, vet and emergency contacts you enter.
- Passport sharing data: the information and documents you choose to include in a link, the link's preset and expiry, the optional recipient email address you enter, and how often and when a link was opened.
- Smart Add content: text you type and the photo or document you attach for Smart Add, while it is processed, and the file itself if you choose to keep it; and, if Smart Add history is on, your questions and the answers from "Ask a question" for 30 days (see section 5).
- Subscription data: plan, trial and renewal status, store transaction identifiers and country, provided by Apple or Google. We never receive your card or bank details.
- Device and technical data: push-notification token, app version, device model and operating system, device region and time zone (used to time reminders, the daily summary and seasonal tips), crash reports and error logs, IP address (used for security and discarded or shortened for analytics).
- Usage analytics (only if allowed): pseudonymous events such as "record added" or "plan purchased" with technical properties. Analytics never include pet names, notes, health details, documents, email addresses or other free text.
- Support messages: what you send us by email and our replies.
3. Why we process it and on what legal basis
| Purpose | Data | Legal basis (GDPR Art. 6) |
|---|---|---|
| Provide the app: account, pets, records, reminders, sync across your devices and household | Account, household, pet data, content | Performance of the contract (6(1)(b)) |
| Send reminders, account notifications and the notifications you turn on (smart suggestions, daily summary, seasonal tips), by push and email | Account, pet data, reminders, device region and time zone, push token | Contract (6(1)(b)) |
| Passport links and invitations, including emails to the recipients you enter | Sharing data, invitee / recipient email | Contract with you (6(1)(b)); for recipients, our legitimate interest in delivering the message you asked us to send (6(1)(f)) |
| Smart Add proposals and answers | Smart Add content | Contract (6(1)(b)) |
| Subscriptions, free trial, restoring purchases | Subscription data | Contract (6(1)(b)) |
| Security, fraud and abuse prevention, rate limits | Technical data, account data | Legitimate interest in keeping Nuvilo safe (6(1)(f)) |
| Crash reports and fixing errors | Technical data | Legitimate interest in a working app (6(1)(f)) |
| Product analytics | Usage analytics | Your consent (6(1)(a)), which you can withdraw at any time in Pet tab → Privacy & security |
| Support | Support messages, account data | Contract (6(1)(b)) or legitimate interest (6(1)(f)) |
| Legal and tax obligations, legal claims | Records we must keep | Legal obligation (6(1)(c)), legitimate interest (6(1)(f)) |
We do not sell personal information, do not use your content for advertising and do not make decisions about you based solely on automated processing.
4. Household members and Pet Passports
Everyone in a household sees the household's pets and their records; Caregivers can add and change them, Viewers can only look. Records show who added or completed them. You can belong to several households at the same time; each household has up to six people and its own roles and plan. When you join a household as a Caregiver and already have pets, you choose whether to keep them in your own household or move them to the new one; if you move them, the new household's owner becomes their owner. If the owner removes a member, switches from Nuvilo Family to Nuvilo Plus, or the household ends, members lose access to the household's pets; what they added stays with the pets. If a member deletes their account, what they added stays with the pets and is shown as added by "Former member". When you invite someone or enter a recipient email for a Passport link, make sure they are happy to hear from Nuvilo; we use that address only to send that invitation or link.
A Passport link shows only the information you selected, until the link expires or you revoke it (Pet tab → Sharing). Documents you marked "Shown in Passport" can be viewed and downloaded by the recipient, but only while the link is valid. Anyone who has the link can open it, so share it only with people you trust.
5. Smart Add (AI)
When you use Smart Add, the text you type and the photo or document you attach are sent to our AI provider (Anthropic) to propose structured records or answer a question about your pet's records. Nothing is saved to your pet's records until you review and confirm it. If you leave "Keep the source file" on, the photo or document is saved with the record as a document; otherwise it is not stored. Smart Add has no voice recording. If you use your phone keyboard's dictation, your phone turns speech into text; Nuvilo receives only the text. Our provider processes this content only to return the result to us and, under its commercial terms, does not use it to train its models. We keep operational metadata (for example that a Smart Add request succeeded) to run the service and count your Smart Add use. Smart Add can be wrong, so always check its suggestions.
Smart Add history. If "Keep Smart add history" is on (it is on by default), we save the questions you ask in "Ask a question" and the answers, as text only, so you can look back at them. Only you can see them; other members of your household cannot. They are stored with your account on our servers in the EU and deleted automatically after 30 days. Past conversations are read only. You can delete one conversation, clear your whole history, or turn history off in Pet tab → Privacy & security; turning it off also deletes your history.
6. Service providers
We use these providers to run Nuvilo. They process data on our behalf under data processing agreements, or under their own terms where they act independently (Apple, Google).
| Provider | What for | Where | Safeguard for transfers outside the EU |
|---|---|---|---|
| Supabase | Database, authentication, file storage, server functions | EU (Ireland) | Not applicable (EU); provider safeguards for support access |
| PostHog | Product analytics (only with consent) | EU (EU Cloud) | Not applicable (EU) |
| Anthropic | Smart Add processing | USA | Standard Contractual Clauses, and the EU–US Data Privacy Framework where the provider is certified |
| RevenueCat | Subscription status and receipts | USA | Standard Contractual Clauses, and the EU–US Data Privacy Framework where the provider is certified |
| Expo | App updates and push-notification delivery | USA | Standard Contractual Clauses, and the EU–US Data Privacy Framework where the provider is certified |
| Sentry | Crash and error reports | EU (Germany) | Not applicable (EU) |
| Namecheap (Private Email) | Sign-in codes, invitations, Passport-link and export emails | USA | Standard Contractual Clauses, and the EU–US Data Privacy Framework where the provider is certified |
| Vercel | Hosting of nuvilo.pet and the shared Passport pages | USA | Standard Contractual Clauses, and the EU–US Data Privacy Framework where the provider is certified |
| Apple and Google | App distribution, purchases, sign-in with Apple / Google, push notifications (APNs, FCM) | Worldwide | Their own terms and safeguards |
7. How long we keep data
| Data | Kept for |
|---|---|
| Account, household and pet data, content | While your account is active. When you delete your account in the app it is erased immediately (requests by email: within 30 days); encrypted backups are overwritten within 7 days |
| A household's shared data after a member leaves | Stays with the household's pets; the member's account data follows their own account |
| Passport links | Active until they expire or are revoked; after that they stay in your Sharing list (Expired) with their open counts until you delete your account |
| Invitations and transfer requests | Valid for 7 days; the history (who was invited, when, and the result) stays in the household until the household or your account is deleted |
| Smart Add content | Only while processed; a source file you choose to keep is stored with the record like any other document |
| Smart Add history ("Ask a question") | 30 days, or until you delete it, turn history off or delete your account |
| Crash reports and logs | Up to 90 days |
| Usage analytics | Up to 1 year, pseudonymous; deleted when you delete your account |
| Support emails | 2 years after the conversation ends |
| Data we must keep by law | As long as the law requires |
If the trial or your plan ends, nothing is deleted; your data stays viewable and exportable.
8. Your rights and choices
You have the right to access, correct, delete, restrict and port your data, to object to processing based on legitimate interest, and to withdraw consent at any time without affecting earlier processing. In the app:
- Export your data: Pet tab → Export data. We prepare a ZIP file with your data (in JSON format, including your Smart Add history) and your original photos and documents, and email you a download link that works for 7 days.
- Delete your account: Pet tab → Delete account. You can also request deletion at nuvilo.pet/account-deletion or by writing to privacy@nuvilo.pet from your account email. Deleting the account does not cancel a store subscription. Cancel it in App Store or Google Play settings.
- Analytics: opt-in and off by default. Nothing is sent until you tap Allow on the "Help improve Nuvilo?" screen or turn on Pet tab → Privacy & security → Share usage analytics. You can turn it off there at any time, also when the app is read-only.
- Notifications: Pet tab → Notifications, or your phone's settings.
For anything else, write to privacy@nuvilo.pet; we answer within one month. You may also complain to a data protection authority, in Croatia the Agencija za zaštitu osobnih podataka (AZOP), Selska cesta 136, 10000 Zagreb, azop.hr, or the authority where you live.
9. Security
Data is encrypted in transit and at rest, access is limited by household and role at the database level, and only the people who run Nuvilo can access production systems when needed for support or security. No system is perfectly secure; if a breach affects you, we will tell you as the law requires.
10. Children
Nuvilo is not for people under 16. We do not knowingly collect their personal data; if you believe a child has created an account, contact us and we will delete it.
11. Changes
We will update this policy when Nuvilo changes. For important changes we will tell you in the app or by email before they take effect. The date at the top shows the latest version. This policy is available in English, Croatian, Spanish and German.