PRIVACY

Privacy Policy

Privacy Policy

Last updated: 30 September 2026

Vignalab Ltd (“Vignalab”), trading as Vemirea (“Vemirea”), respects privacy and protects the personal data of users and participants in its programmes. This Privacy Policy explains which data we collect through the Vemirea website and, in particular, through the pilot programme, why we use it, and what rights you have.

1. Who we are

1. Who we are

Vignalab Ltd, trading as Vemirea, is the controller for the personal data we collect through our website and the services described in this Policy. Vignalab Ltd — Registration No. HE 456327 — Kosta Andreou 5A, Lakatamia, 2323, Nicosia, Cyprus — Email: contact@vemirea.com.

2. What data we collect

2. What data we collect

Depending on how you interact with Vemirea, we may collect contact details such as your name and email address; information submitted when registering for the pilot programme; pet information such as name, age, breed, sex, neutering status and weight; information about the pet’s diet and habits; observations submitted through the initial profile and Daily Check-in; and information about changes to diet, routine, environment or other interventions that you choose to record. We may also collect information you choose to enter in free-text fields. Photos are collected only if a relevant feature is enabled and used, and information from professionals is collected only if a relevant pilot feature is used. Some pet information may be linked to an identifiable caregiver and may therefore constitute that caregiver’s personal data.

3. Why we collect the data

3. Why we collect the data

We collect and use data to register and support participation in the pilot programme, operate the initial profile and daily records, follow changes that participants choose to record, assess and improve the pilot programme, communicate about participation, protect the security and operation of our website and services, and comply with legal obligations where applicable. Information submitted by a caregiver through the pilot consists of observations and monitoring data and does not replace veterinary examination, diagnosis or professional veterinary advice.

4. How we use the data

4. How we use the data

We use data only for the purposes described in this Policy and in accordance with applicable data protection law. We do not sell personal data, make it public, or create public participant or pet profiles.

5. Legal basis for processing

5. Legal basis for processing

The legal basis depends on the specific processing activity and may, where applicable, include consent, performance of a contract or steps requested by an individual, compliance with a legal obligation, or legitimate interests. For voluntary participation in the pilot programme, where processing is based on consent, the legal basis is the participant’s consent for the specific purposes that have been explained to them.

6. Who data may be shared with

6. Who data may be shared with

Vignalab may use service providers where necessary to operate the website and pilot, including Framer for website hosting and infrastructure, Tally for form collection, Google Sheets if it is used as the active submission destination for pilot forms, and email service providers used for pilot-related communications. We do not sell your personal data or make it public.

7. How long we keep the data

7. How long we keep the data

We keep personal data only for as long as necessary for the purposes for which it was collected or as required by applicable law. For pilot programme data, the exact retention period will be determined in accordance with the purpose of the programme, our legal obligations, and the documentation and evaluation needs of the pilot.

8. Your rights

8. Your rights

Depending on the circumstances and where applicable, you have the right to access your data, correct inaccurate data, request erasure, restrict processing, object to processing, receive data portability, and withdraw consent where processing is based on consent. Withdrawing consent does not affect the lawfulness of processing carried out before it was withdrawn. Some rights are subject to the conditions and limitations provided by applicable law.

9. Data security

9. Data security

We take appropriate technical and organisational measures to protect personal data from unauthorised access, loss, destruction, alteration or other unauthorised processing.

10. Contact

10. Contact

Vignalab Ltd, trading as Vemirea — Kosta Andreou 5A, Lakatamia, 2323, Nicosia, Cyprus — Email: contact@vemirea.com. For privacy-related requests, you may contact us at this email address.

11. Complaints / supervisory authority

11. Complaints / supervisory authority

You may contact Vignalab first with any concern about how your data is processed. You may also lodge a complaint with the Office of the Commissioner for Personal Data Protection, Cyprus. Email: commissioner@dataprotection.gov.cy. P.O. Box 23378, 1682 Nicosia, Cyprus. Tel. +357 22 818 456.