Privacy Notice
PhysioDogtor SaaS Service
Governing language: Hungarian
Website: https://physiodogtor.com
Application: https://app.physiodogtor.com
Contact for data protection matters: hello@physiodogtor.com
1. Details of the Controller
The controller under this Privacy Notice is:
Name: Schmidt-Herke Adrián sole proprietor
Registration number: 62232816
Tax number: 92003819-1-22
Community tax number: HU92003819
Registered seat: 7728 Görcsönydoboka, Csele utca 51.
E-mail: hello@physiodogtor.com
The Service Provider uses the name PhysioDogtor as a trade name/business name.
The Service Provider has not appointed a separate data protection officer. The Service Provider may be contacted in data protection matters at the above e-mail address.
2. Scope of the Notice
This Privacy Notice applies to the processing of personal data carried out during the use of the PhysioDogtor website, the PhysioDogtor web application and the related services.
PhysioDogtor is a SaaS administration system made for small animal physiotherapists, intended exclusively for business, professional or organisational use. The service is not available to consumers or private-purpose users.
This Notice separately covers:
- processing activities where the Service Provider acts as an independent controller; and
- processing activities where the Service Provider acts as the Customer’s processor.
3. Main Definitions
Service Provider / Controller: Schmidt-Herke Adrián sole proprietor.
PhysioDogtor / Service: a SaaS administration system made for animal physiotherapists.
Customer: the business, sole proprietor, business association, practice, office, clinic, organisation or other business/professional actor contracting for the Service, as well as the Workspace Owner acting on behalf of such organisation. The Customer may not be a consumer.
User: a person using the Service in connection with the Customer’s workspace.
Workspace: the separated application environment connected to the Customer.
Customer Data: any data, document, file, entry, calendar data, owner data, patient data, treatment information, note or other content that the Customer or its Users record, manage or upload in the Service.
Patient: the animal managed in the Service. In PhysioDogtor, the term “patient” or “sick patient” means an animal, not a human patient.
Owner: the owner or keeper of the animal, or the natural-person contact recorded by the Customer.
4. Controller and Processor Roles
4.1. When the Service Provider Acts as an Independent Controller
The Service Provider acts as an independent controller in particular in the following processes:
- operation of the website;
- registration;
- management of user accounts;
- e-mail identification and login;
- management of the trial period;
- management of the subscription;
- management of billing data;
- tax number, VAT and company validation;
- management of payment processes;
- Billingo invoicing;
- support and customer service;
- sending system messages;
- management of marketing consents;
- cookie and analytics data processing;
- security logging;
- establishment, exercise or defence of legal claims.
4.2. When the Service Provider Acts as a Processor
In respect of personal data uploaded to or recorded in the Service by the Customer, the Service Provider acts, as a general rule, as the Customer’s processor.
This may include in particular:
- owners’ names, e-mail addresses, telephone numbers, addresses and notes;
- data of animals linked to owners;
- appointments and calendar entries;
- treatment documentation;
- uploaded documents;
- other content recorded by the Customer.
In this case, the Customer qualifies as the controller, and the Customer is responsible for ensuring that the personal data of data subjects are entered into the Service lawfully. The Service Provider processes such data according to the Customer’s instructions, to the extent necessary for providing the Service.
5. Principles of Data Processing
The Service Provider processes personal data in particular according to the following principles:
- lawfulness, fairness and transparency;
- purpose limitation;
- data minimisation;
- accuracy;
- storage limitation;
- integrity and confidentiality;
- accountability.
The Service Provider endeavours to process only such data as are necessary for providing, operating and securing the Service, for invoicing, for fulfilling its legal obligations, or for enforcing its legitimate interests.
6. Website Visits and Technical Logging
Data Processed
During the use of the website and the application, technical data may be generated, including in particular:
- IP address;
- browser type and version;
- device and operating system data;
- time of visit;
- pages opened;
- technical data of requests;
- error messages;
- security logs;
- technical events linked to a user identifier if the data subject is logged in.
Purpose of Processing
- operation of the website and application;
- maintaining security;
- troubleshooting;
- prevention of abuse;
- improvement of service quality;
- investigation of technical incidents.
Legal Basis
The Service Provider’s legitimate interest in the secure operation of the website, the application and the IT systems.
Retention Period
Technical logs are retained for the time necessary for security, troubleshooting and operational purposes. The exact retention period depends on the type of log.
7. Registration and Creation of Own Workspace
During registration and creation of an own workspace, the Service Provider processes the data necessary for creating and identifying the user account, providing the service, managing the trial period, and proving the conclusion and performance of the contract. This may include in particular contact and identification data, data relating to the workspace, selected plan and billing, as well as log data related to registration and acceptance of legal declarations.
The purpose of processing is to create the user account and workspace, provide the service, manage permissions, maintain the customer relationship, and fulfil contractual and legal obligations.
The legal basis of processing is primarily the performance of the contract and taking steps prior to entering into the contract. The processing of certain data may be based on the Service Provider’s legitimate interest, in particular for the secure operation of the service, prevention of abuse, proof of acceptances, and establishment, exercise or defence of legal claims.
The data are retained during the existence of the contract. In the case of an unsuccessful or expired trial period, data related to the workspace may be retained for up to 3 months, and after termination of the subscription for up to 1 year. Certain data — in particular data related to billing, legal declarations, payment or enforcement of claims — may also be retained for a longer period on the basis of a legal obligation or legitimate interest.
8. Invited Users
If the Customer invites a User to the workspace, the Service Provider processes the data necessary for providing the invitation process, managing access to the workspace, setting permissions, and securely providing the service. This may include in particular data related to the invitee, the status of the invitation, the workspace, the role and permissions, as well as data related to registration, login and acceptance of legal documents.
The purpose of processing is to ensure that invited Users can join the workspace, manage access and permissions, provide the service, and ensure the provability of contractual and security events.
The legal basis of processing is primarily the performance of the contract. The processing of certain data may be based on the legitimate interests of the Service Provider and the Customer, in particular for proper access management, system security, prevention of abuse and provability of events.
The User’s data are processed during the existence of the account or workspace, and are then deleted, anonymised or restricted according to the applicable termination, deletion and retention rules.
9. Authentication, Login and Account Security
The Service Provider processes the data necessary for authentication, login and system security in order to securely identify and log in Users and protect their accounts. This may include in particular login identifiers, authentication data related to the password and e-mail confirmation, login events, failed login attempts, and related technical and security log data.
The purpose of processing is to ensure secure login, protect accounts, prevent and investigate unauthorised access and abuse, and operate the service securely.
The legal basis of processing is primarily the performance of the contract. The processing of certain technical and security data may be based on the Service Provider’s legitimate interest, in particular for maintaining system security, preventing abuse, reliably operating the service and ensuring the provability of possible security events.
For the operation of the authentication and user management infrastructure, the Service Provider may use external service providers as processors, in particular AWS services such as AWS Cognito or related AWS components.
10. Logging of Legal Documents and Consents
The Service Provider logs data related to the acceptance of legal documents, declarations and consents in order to ensure that the fact, time, content and circumstances of acceptances can be proven later. This may include in particular identifiers related to the relevant User and workspace, the type and version of the accepted document or declaration, the time of acceptance, and technical data related to the acceptance event.
The purpose of processing is to prove the conclusion of the contract, acceptance of legal documents and declarations, declarations related to B2B use, and marketing consents. Processing may also serve to demonstrate legal and data protection compliance, and to establish, exercise or defend legal claims.
The legal basis of processing is primarily the performance of the contract and, in certain cases, compliance with a legal obligation. The processing of certain log data may be based on the Service Provider’s legitimate interest, in particular for proving contractual and data protection compliance and defending legal claims. In the case of marketing consent, the legal basis of processing is the consent of the data subject.
Logs kept for contractual and legal evidentiary purposes are retained during the existence of the contract and thereafter within the period available for the enforcement of legal claims. Data related to marketing consent may be processed until withdrawal of consent, and for the time necessary to prove the consent, withdrawal or unsubscribe.
11. Owner and Patient Data Recorded by the Customer
Controller Role
In respect of owner data, patient-related documents and treatment information recorded by the Customer, as a general rule the Customer is the controller and the Service Provider is the processor.
The Service Provider does not determine what specific owner data, treatment information or documents the Customer records, and does not review their lawfulness or professional content.
Possible Scope of Data Processed
During use of the Service, the Customer may record data related to owners, contacts, and animals or patients. This may include in particular identification and contact data of the owner or contact, basic data related to the animal or patient, health and treatment information, appointments, treatment sheets, documents, notes, and other files and content uploaded by the Customer.
Purpose of Processing
- the Customer’s own animal physiotherapy administration;
- recording owners and animal patients;
- managing appointments;
- maintaining treatment documentation;
- storing documents;
- preparing statistics for the Customer.
Legal Basis
In respect of these data, the legal basis is determined by the Customer, as the Customer qualifies as the controller. The Service Provider acts as processor on the basis of the Customer’s instructions.
Retention Period
The retention period of such data is primarily determined by the Customer during the use of the Service. In respect of termination of the service, export, deletion and backup, the Service Provider acts according to the technical rules set out in the GTC and this Notice.
12. Uploaded Documents and Files
Data Processed
During use of the Service, the Customer may upload documents, images, professional files and other content. These may contain in particular personal data related to owners or contacts, animal health or treatment information, and other documents and files recorded or uploaded by the Customer.
Purpose of Processing
- storing documents;
- linking to a patient;
- supporting the Customer’s own administration;
- support and troubleshooting, if requested by the Customer or necessary for resolving the issue.
Legal Basis
In respect of documents uploaded by the Customer, the Customer is the controller and the Service Provider is the processor.
Important Restrictions
The intended use of the Service is not directed at uploading human health data or other particularly sensitive personal data incompatible with the purpose of the service.
The Customer is responsible for uploading only documents that may be lawfully processed, and for not uploading any data for which the Customer has no appropriate legal basis.
The Service Provider does not perform automatic virus scanning on uploaded documents.
Retention and Deletion
The Service Provider does not create a separate backup of file storage. For 30 days from permanent deletion completed on the application interface, the Customer may request restoration of deleted files through support, if this is still technically possible.
13. Homework and E-mail Sending
The Service may enable the Customer to send homework to owners or contacts. In doing so, the Service Provider processes the data necessary for forwarding and delivering the message. This may include in particular data related to the recipient, the content of the message, the relevant animal or patient, the User sending the message, and technical data related to e-mail delivery.
The purpose of processing is to forward the message initiated by the Customer, technically ensure e-mail delivery, and operate the communication function.
In respect of the content of homework, treatment recommendation or message sent to the owner or another recipient, as a general rule the Customer qualifies as controller, and the Service Provider acts as processor and provides the technical forwarding.
For the operation of built-in e-mail sending functions, the Service Provider may use an external transactional e-mail sending service provider, in particular the Postmark service. The e-mail sending service provider may process data necessary for delivery of the messages, such as addressing data, e-mail content, delivery status and related technical logs.
The use of the e-mail sending service provider may involve transfer of data to a third country. In such case, the Service Provider relies on contractual safeguards and data transfer mechanisms compliant with the applicable data protection rules.
14. Billing Data and Verification as Business Customer
The Service is available exclusively to business customers, therefore the Service Provider processes billing and company identification data for starting and maintaining the subscription.
The data processed include in particular billing name, billing address, billing e-mail address, country, tax number, Community tax number or other tax identifier, as well as the results and technical log data related to verification of these.
The purpose of processing is verification of business customer status, exclusion of consumer use, fulfilment of invoicing and tax obligations, prevention of abuse, and, where necessary, establishment, exercise or defence of legal claims.
The legal basis of processing is performance of the contract, fulfilment of legal obligations applicable to the Service Provider, and the Service Provider’s legitimate interest in B2B-only operation, billing compliance and prevention of abuse.
The Service Provider retains billing, taxation and customer identification data for the time necessary to fulfil the applicable legal obligations, handle authority audits, and establish, exercise or defend legal claims. These data may also be retained independently of deletion of the workspace or user account, if justified by a legal obligation or legitimate interest.
15. Payment and Subscription Management
Payment of the Service fees is made through an external payment service provider, Stripe. For the purpose of processing payment and managing the subscription, the Service Provider may transfer to Stripe the data necessary for payment, including in particular name, e-mail address, billing data, and technical identifiers related to the subscription and payment process.
The Service Provider does not receive and does not store full bank card data; such data are handled directly by Stripe. The Service Provider may process payment statuses, subscription and transaction identifiers returned by Stripe, and limited technical data related to the payment.
The purpose of processing is to ensure payment of subscription fees, manage the automatically renewing subscription, track payment statuses, manage failed payments, and activate, modify or terminate the subscription.
The legal basis of processing is performance of the contract, fulfilment of legal obligations applicable to the Service Provider, and the Service Provider’s legitimate interest in proving payments, preventing abuse and handling possible disputes.
Stripe may send technical or system messages to the Customer in relation to payment and subscription, for example about failed payment, payment retry or expiring bank card. These messages are connected to the operation of the payment and subscription process.
16. Invoicing
The Service Provider uses an external invoicing service provider, Billingo, for issuing and managing invoices.
For invoicing purposes, the Service Provider may transfer to Billingo the data necessary for issuing the invoice, including in particular billing name, billing address, billing e-mail address, tax number or Community tax number, as well as data related to the purchased service, pricing plan, amount paid and billing period.
The purpose of processing is issuing and sending invoices, recording payments and subscriptions, and fulfilling accounting and tax obligations applicable to the Service Provider.
The legal basis of processing is primarily fulfilment of legal obligations applicable to the Service Provider, and performance of the contract.
The Service Provider retains invoices and related accounting and tax data for the retention period prescribed by applicable laws.
17. Customer Support and Contact
The Service Provider may process the name and e-mail address of the Customer and the Customer’s representatives, related company or workspace data, and the content of the enquiry, error report, complaint or other communication for customer service, support or other contact purposes.
During customer support, the Customer may also voluntarily share additional information, such as technical error descriptions, screenshots, attachments or data visible during screen sharing.
The purpose of processing is handling customer service enquiries, providing technical support, troubleshooting, customer communication, handling complaints and claims, and improving the operation of the Service.
The legal basis of processing is performance of the contract, the Service Provider’s legitimate interest in providing customer support, troubleshooting and service development, and, where necessary, establishment, exercise or defence of legal claims.
In the event of support, troubleshooting, security event, fulfilment of a legal obligation or the Customer’s express request, the Service Provider may access data processed in the Customer’s workspace exclusively to the necessary and proportionate extent. Access is purpose-limited and takes place only for the necessary time.
During a customer demo, professional presentation or support meeting, a professional contributor cooperating with the Service Provider and subject to a confidentiality obligation may also participate. In such case, the contributor may become aware of data exclusively to the extent necessary for the meeting.
18. System Messages and Transactional E-mails
The Service Provider may send system messages and transactional e-mails related to use of the Service to the Customer and Users. Such messages may include in particular notifications related to registration, e-mail address confirmation, invitation, trial period, subscription, payment, security, operation of the service, and modification of the GTC or Privacy Notice.
For this purpose, the Service Provider may process the data subject’s name, e-mail address, related workspace or subscription data, the content of the message, and technical data necessary for delivering and tracking e-mails.
The purpose of processing is sending messages related to the operation of the Service, performance of the contract, management of the subscription, and necessary customer and user information.
The legal basis of processing is performance of the contract, the Service Provider’s legitimate interest in ensuring service-related communication and contractual information, and, in the case of statutory notifications, fulfilment of a legal obligation applicable to the Service Provider.
The Service Provider uses Postmark as an e-mail sending service provider for sending system messages and transactional e-mails. Postmark may process personal and technical data necessary for e-mail delivery as processor.
19. Marketing Communication and Newsletter
The Service Provider may send marketing e-mails or newsletters on the basis of the data subject’s prior consent. Such messages may contain information relating to, for example, discounts, product updates, new functions, professional content or promotions.
For this purpose, the Service Provider may process the data subject’s name, e-mail address, the fact and time of marketing consent, and data necessary for unsubscribing and managing consent. If the Service Provider uses e-mail delivery or open statistics, it may also process related technical data.
The legal basis of processing is the data subject’s consent. Consent may be withdrawn at any time through the unsubscribe link in marketing e-mails or at the hello@physiodogtor.com e-mail address.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Processing for marketing purposes lasts until withdrawal of consent. The fact and time of unsubscribe may continue to be processed in order to prove the unsubscribe and avoid further marketing sending.
20. Cookies, Analytics and Search Engine Optimisation Measurement
The Website and the Application may use cookies and similar technologies to ensure operation, maintain security, manage user settings and — where consent is given — for analytics purposes.
Cookies necessary for operation are required for the basic operation and security of the Website and the Application, login, session management or management of user settings.
Non-essential cookies, including in particular analytics cookies, are used by the Service Provider only where the data subject has given consent. Consent may be given, modified or withdrawn in the window managing cookie settings.
The Service Provider may use Google Analytics for analytics purposes. The use of Google Analytics may involve the use of cookies or similar technologies, and therefore its use may depend on the cookie settings and the consent of the data subject, where required by applicable law.
The Service Provider may use Google Search Console to examine the Website’s appearance in Google Search, indexing status, technical errors, search queries and click data. Google Search Console does not in itself operate by means of a tracking code or cookie placed in the visitor’s browser, but provides the Service Provider with data on the Website’s performance in Google Search and its technical status.
Detailed cookie information, including the types, purposes and duration of the cookies used, is contained in a separate Cookie Notice.
21. Artificial Intelligence and Decision-Support Functions
The Service may contain artificial intelligence, automated, decision-support, text-generating, summarising or recommendation functions.
During the use of such functions, instructions, texts, treatment information or other content provided by the Customer or User may be processed in order to operate the function.
If AI functions operate using an external AI service provider, the relevant provider will be indicated in the vendor list, processor annex or an updated version of this Notice.
22. Data Transfers and Recipients
The Service Provider may transfer personal data to the following recipients or categories of recipients:
| Recipient / service provider | Purpose | Data scope concerned |
|---|---|---|
| Amazon Web Services | hosting, infrastructure, database, file storage, authentication and operational components | user, workspace, customer and technical data |
| Stripe | payment, subscription, management of payment statuses | name, e-mail, billing address, payment technical data |
| Billingo | invoicing | billing name, address, e-mail, tax number, product, amount |
| Postmark | sending marketing, transactional and system e-mails | e-mail address, name, e-mail content, delivery data |
| Google Analytics | preparing user statistics, improving user experience | cookie identifiers, device and usage data |
| NAV | Hungarian tax number validation, invoicing/tax compliance | tax number, validation response |
| VIES | EU VAT validation | VAT number, validation response |
| HMRC | UK VAT validation | VAT number, validation response |
| Accounting service provider | accounting, taxation, invoice management | billing and financial data |
| E-mail mailbox provider | support and contact | e-mails, contact data |
| Authorities, courts | legal obligation, enforcement of claims | data necessary for the given procedure |
The Service Provider transfers personal data only to the extent necessary for fulfilling the given purpose.
23. International Data Transfers
The Service Provider’s primary cloud infrastructure operates in the AWS eu-central-1 region.
Certain external service providers, including in particular Stripe, Postmark, Google, or group companies of certain cloud and technical service providers, may process or access personal data outside the European Economic Area.
In such case, data transfer may take place on the basis of appropriate safeguards under the GDPR, including in particular:
- adequacy decision;
- standard contractual clauses;
- data processing agreement;
- supplementary technical and organisational measures;
- data transfer mechanisms provided by the service provider.
The exact service provider and data transfer information is also available in the external service providers’ own data processing documents.
24. Data Security
The Service Provider applies reasonable technical and organisational measures to protect personal data.
Such measures may include in particular:
- access management;
- permission levels;
- password-protected and authenticated login;
- e-mail confirmation;
- cloud-based security controls;
- secret management;
- logging;
- backups;
- restriction of access to the Service;
- restriction of support access to the necessary extent.
The Service Provider does not perform automatic virus scanning on uploaded files; therefore, the Customer is responsible for uploading safe, lawful and appropriate files.
The database is backed up daily and can be restored for 1 week. No separate backup is created of file storage.
25. Summary of Data Retention
| Data category | Retention period |
|---|---|
| Active user and workspace data | during the existence of the contract |
| Workspace data remaining without payment after the trial period | up to 3 months |
| Workspace data with terminated subscription | up to 1 year |
| In the case of workspace deletion requested through support | within the shortest possible time, except for data to be retained |
| Uploaded documents | depending on the Customer’s management and deletion operations |
| Restorability of deleted uploaded document | for 30 days from finalised deletion through support, if technically possible |
| Database backup | 1 week |
| Invoices and accounting documents | retention period prescribed by law |
| NAV/VIES/HMRC validation responses | for the time necessary for authority audits, legal claims and taxation/invoicing compliance |
| Manual company validation documents | for the time necessary for authority audits, legal claims and proof of B2B status |
| Marketing consent | until withdrawal, and thereafter for the time necessary for evidentiary purposes |
| Acceptance logs of legal documents | during the existence of the contract and thereafter for the time necessary to enforce legal claims |
| Technical and security logs | for the time necessary for security and operational purposes |
26. Data Subject Rights
Under the GDPR, the data subject may be entitled to exercise the following rights:
- request access;
- request rectification;
- request erasure;
- request restriction of processing;
- object to processing based on legitimate interest;
- request data portability;
- withdraw consent;
- lodge a complaint with a supervisory authority;
- seek judicial remedy.
Requests may be submitted at hello@physiodogtor.com.
As a general rule, the Service Provider responds to requests within 1 month at the latest. Where necessary, taking into account the complexity of the request or the number of requests, this deadline may be extended in accordance with the GDPR rules.
27. If the Data Subject Is Not Directly a Customer of the Service Provider
It may occur that the data subject’s personal data are recorded in the PhysioDogtor system not directly by the Service Provider, but by a Customer. Such data subject may be, for example, an owner or contact.
In this case, the Customer qualifies as the controller and the Service Provider as the processor. Primary responsibility for the exercise of data subject rights lies with the Customer.
If the data subject contacts the Service Provider directly, the Service Provider may, after identification and verification of entitlement, forward the request to the relevant Customer, or may act on the basis of the Customer’s instructions.
28. Withdrawal of Consent
If processing is based on consent, the data subject may withdraw consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
In the case of a marketing newsletter, consent may be withdrawn through the unsubscribe link in the newsletter or at hello@physiodogtor.com.
In the case of cookie consent, settings may be modified through the cookie management interface or through browser settings.
29. Complaint and Remedy
In the event of a data protection question, request or complaint, the data subject may primarily contact the Service Provider:
E-mail: hello@physiodogtor.com
The data subject is also entitled to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information.
Authority: Hungarian National Authority for Data Protection and Freedom of Information
Website: https://www.naih.hu
The data subject is also entitled to turn to a court if they consider that the processing of their personal data violates the applicable data protection rules.
In the case of UK data subjects, where relevant under the applicable law, the data subject may also be entitled to contact the local data protection supervisory authority.
30. Children’s Data
PhysioDogtor is a B2B SaaS service that is not made for children and is not directed at children’s direct registration or use.
During use of the Service, the Customer is responsible for processing the personal data recorded or uploaded by it lawfully. If the Customer records or uploads personal data relating to a child, the lawfulness of this falls within the Customer’s own responsibility.
31. Special Categories of Data
The intended use of the Service is not directed at processing human health data or other special categories of personal data under the GDPR.
Data relating to the health condition, diagnosis or treatment of animals do not in themselves qualify as special categories of personal data under the GDPR, but may be connected to natural persons, such as owners or professionals.
The Customer is responsible for not uploading human health data, human patient data or other special categories of personal data for which it does not have an appropriate legal basis.
32. Automated Decision-Making and Profiling
The Service Provider does not carry out automated decision-making that would produce legal effects concerning the data subject or similarly significantly affect them.
The Service Provider may use analytics and statistical tools, as well as automations supporting the operation of the Service, but these do not serve to produce legal effects concerning data subjects.
33. Modification of the Notice
The Service Provider is entitled to modify this Privacy Notice, in particular in the event of a change in law, change in the service, introduction of a new processor, new function or data processing process.
In the event of a material modification, the Service Provider informs Customers and Users in an appropriate manner, for example by e-mail or within the Application.
The Privacy Notice in force at any time is available on the physiodogtor.com website.