This Privacy Notice (“Notice”) describes how Lumora Animal Health, Inc. (“Lumora,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes the personal information described in this Notice and the rights and choices individuals have regarding such personal information.
For information about your privacy choices, please review Section 7 Your Privacy Choices.
Your use of our Services (as defined below), and any dispute over privacy, is subject to this Notice and our Terms of Use, available at www.getpawchart.com/terms-of-service.
1. Scope
This Privacy Notice describes how Lumora Animal Health, Inc. (“Lumora,” “we,” “our,” or “us”) collects, uses, and discloses personal information in connection with your use of: our website, www.lumora.vet, and any other websites that link to this Notice (the “Site”); our mobile application, PawChart (the “App” or “PawChart”); and our related online and offline services, including our platform services made available to veterinary clinics, groomers, boarding facilities, shelters, rescues, and other organizations (collectively, the “Services”).
- Business Customers and Third Parties. This Notice applies to Lumora’s collection and processing of personal information in connection with the Services. Veterinary clinics, grooming providers, boarding facilities, shelters, rescues, and other organizations that use the Services may independently collect, use, or disclose personal information in connection with their own operations and are responsible for their own privacy practices. We recommend that you review the privacy policies of these organizations to understand how they handle your information before interacting with them.
- Not in Scope. This Notice does not apply to the personal information that we collect and process about Lumora employees, contractors, personnel, job applicants, or candidates.
- Additional Notices. In some cases, additional or supplemental privacy notices may be provided and will apply to certain personal information collected and processed by us. These additional notices will control to the extent there is a conflict with this Notice, with respect to your personal information that is subject to that additional notice.
2. Personal Information Collected
As further described below, we collect personal information directly from individuals, from third parties, and automatically through your use of our Services.
Personal Information Collected Directly from You. The personal information we may collect from you depends on how you use our Services or otherwise interact or engage with us, but generally includes:
- Contact information. When you contact us or interact with the Services (including via email, phone, webforms, or in-app features), we may collect your name, email address, phone number, and any other information you choose to provide.
- Account and registration information. When you create an account, we may collect your name, email address, username, password, and other information associated with your account or profile.
- Pet and veterinary record information. When you use PawChart or related features, we collect information you provide about your pet, including pet profile information (such as name, breed, age, and health details), and veterinary or medical records that you upload, import, or generate through the Services. These records may include documents, images, vaccination records, clinical notes, and similar information. Pet records may also contain information about pet owners that constitutes personal information.
- Communications and interactions. We collect personal information when you communicate with us or through the Services, including customer support inquiries, chatbot interactions, requests to contact veterinary clinics, and other communications. We may maintain a record of these communications and interactions. We also collect and maintain records of communications and information that you may post on our social media channels.
- Content and inputs for AI-enabled features. When you use Service features that generate summaries, insights, or other outputs (such as PawChart profiles or chatbot functionality), we collect, and may use service providers to process, the information, documents, and prompts you submit, as well as associated outputs generated through these features.
- Survey responses and feedback. If you participate in surveys, questionnaires, or research activities, we may collect your responses, feedback, and any additional information you provide. Participation is voluntary.
- Promotions, sweepstakes, and events. If you participate in promotions, sweepstakes, or events, we may collect your contact details and any information required to administer the promotion or event (and, where applicable, information required by law for prize fulfillment).
- Marketing and communications preferences. If you sign up for newsletters or other communications, we may collect your contact details and preferences regarding how you wish to receive communications from us and other related information.
- Transaction information. When you make a purchase or subscribe to the Services, including through in-app purchases or our platform services, we and our payment service providers may collect and process transaction-related information, such as records of your purchases or subscriptions, payment confirmations, billing details, and other information necessary to complete and manage the transaction. Payment information is processed by third-party payment providers (such as app store providers or payment processors), and we do not receive or store full payment card information.
- Professional and business-related information. If you interact with us in a business capacity (for example, by requesting access to our platform or Services or engaging as a clinic, facility, or partner), we may collect business contact information, professional details, and related communications.
- Preferences and user settings. We may collect information about your preferences, such as account settings, feature usage selections, and other preferences you choose to provide when using the Services.
Personal Information Collected from Third Parties. We may collect personal information about you from third-party sources, including veterinary clinics and facilities, integrated services, business partners, social media platforms, and other users of the Services.
- Veterinary clinics and facilities. When a veterinary clinic or other facility uses our platform, we may receive pet-related records and associated information from that organization, including veterinary records, vaccination information, clinical notes, and related personal information about pet owners where included in those records.
- User-directed record requests and sharing. If you request that a veterinary clinic provide records or connect your PawChart profile to a clinic or facility, we may receive personal information from such third parties in response to your request or at your direction, including documents, images, and related communications.
- Integrated systems and service providers. We may receive personal information from third-party systems and services that integrate with our platform, such as veterinary practice management systems (PIMS), analytics providers, and other service providers that support our Services.
- Third-party authentication providers. If you choose to sign in using services such as Google or Apple, we may receive personal information from those providers to facilitate account access.
- Business partners and prospective customers. We may receive business contact information (such as name, email address, and professional details) from business partners, referral sources, or other third parties in connection with requests to access or use our platform services.
- Social media information. If you post information about us or engage with us on third-party platforms, such as through your social media account, we may collect personal information about you from that third-party platform or account (e.g., your social media username and/or handle). These third-party platforms and services control the information that they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
- Other users. We may receive personal information about you from other users of the Services, including where another user shares or links pet records, sends information to you, or otherwise interacts with you through the Services.
Personal Information Collected Automatically. We and our providers automatically collect and derive personal information related to your use of our Services and your interactions with us. Such information may include:
- Device and browsing information. We use cookies, log files, and other tracking technologies to automatically collect information when users access or use our Services. We may collect device IP address, general location information, domain name, pageviews, date and time stamps, browser type, device type, referring URLs, operating system, language preferences, interaction data, and similar device and usage information. For more information, please see Section 6 Cookies and Tracking.
- Activities and usage. We also collect activity information related to your use of the Services, such as information about links clicked, searches, features used, items viewed, time spent within the Services, and queries and prompts submitted to our AI agents.
- Location Information. We may derive your general location information from your IP address. With your permission, we may also collect precise geolocation data from your device. You can disable location sharing through your device settings.
3. Purposes for Collecting and Processing
Generally, we collect, use, and otherwise process the personal information that we collect for the following purposes:
- Services and Support. To provide, operate, and maintain our Services, including our App and our platform services, to communicate with you about your use of the Services, respond to your inquiries and requests, provide customer support, and support our day-to-day operations.
- Account Management. To create, manage, and maintain your account, authenticate users, enable access to the Services, and manage user settings and preferences.
- Platform Functionality and User-Directed Features. To enable core functionality of the Services, including facilitating the creation and management of pet health records, enabling you to request or share records with veterinary clinics or other facilities, linking your PawChart profile with providers, and otherwise carrying out your instructions and requests.
- AI-Enabled Features and Service Improvement. To generate summaries, insights, and other outputs using AI-enabled features (such as PawChart profiles and chatbot functionality), including by processing the information, documents, and inputs you submit, and to evaluate, develop and improve the performance and accuracy of these features and related offerings. We do not use identifiable customer data to train our AI models or permit our AI providers to do so. Where we process records on behalf of veterinary clinics in connection with our platform services, we do so as a service provider and do not use such records to train or improve our AI models unless authorized by the applicable clinic.
- Analytics and Improvement. To better understand how users access and use the Services, including how pet health data and platform features are used, and for research and analytical purposes such as evaluating, developing, and improving our Services, features, and related business offerings.
- Personalization and Customization. To tailor content and experiences within the Services, including personalized insights, recommendations, and features based on your use of the Services.
- Communications. To respond to your questions, provide administrative information (such as updates to our terms or policies), and send you service-related communications.
- Marketing and Promotions. To send you newsletters, updates, and other marketing communications, where permitted by law, and to administer marketing campaigns, promotions, sweepstakes, or similar programs you choose to participate in.
- Business and Platform Relationships. To engage with veterinary clinics, facilities, and other organizations using our platform, including onboarding, account management, and supporting the use of the Services in a business context.
- Security and protection of rights. To protect our Services and our business operations, and to prevent and detect fraud, unauthorized activities and access, and other misuse. We may also use your personal information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the safety or legal rights of any person or third party. Additionally, we may use your personal information to address violations of our Terms of Use, other agreements we have with you, or this Notice, and to defend our rights, including through legal or other dispute resolution processes.
- Legal proceedings and obligations. To comply with the law and our legal obligations, to respond to legal process and related legal proceedings, and government or law enforcement requests.
- General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other transactions such as financings, and for purposes related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.
4. Disclosures of Personal Information
Generally, we disclose the personal information that we collect to provide our Services, respond to and fulfil your requests, as otherwise directed or consented to by you, and as follows:
- Veterinary Clinics, Facilities, and Other Users. We may disclose personal information to veterinary clinics, grooming providers, boarding facilities, shelters, rescues, and other users of the Services where you request or direct such disclosure, including when you request records, link your PawChart profile to a provider, or otherwise use features that enable sharing of pet health information. These parties may independently collect, use, and disclose personal information in accordance with their own privacy practices.
- Vendors and Service Providers. We may disclose personal information to vendors and service providers that perform services on our behalf or support our business operations. These may include providers that host or operate our Services (including transactional email and SMS providers and error monitoring tools), analytics providers, customer support tools, and providers that enable AI-powered features, document processing, and data extraction (such as large language model providers and optical character recognition tools). We may also disclose transaction-related information to payment processors and app store providers in connection with billing and subscriptions. These third parties are authorized to use personal information only as necessary to provide services to us and in accordance with applicable contractual obligations.
- Business Customers. Where we provide platform services to veterinary clinics, facilities, and other organizations, we may disclose personal information to such business customers as necessary to provide and support the Services, including enabling access to pet health records which may contain owner personal information, summaries, and related functionality.
- Analytics Providers. We may disclose or make available limited personal information, such as device or usage information, to analytics providers that help us understand how users access and use the Services and improve functionality.
- De-Identified and Aggregated Information. We may disclose information that has been de-identified or aggregated so that it does not reasonably identify an individual, for purposes such as research, analytics, product development, and business insights. Where we de-identify information, we take steps designed to maintain it in a de-identified form.
- Business Transfers and General Operations. If we are or may be involved in a merger, acquisition, financing, reorganization, or sale of assets, we may disclose personal information to the transaction counterparties and their advisors as part of evaluating and completing the transaction.
- Legal Compliance and Protection of Rights. We may disclose personal information to comply with applicable law, legal process, or government requests, and to protect the rights, property, and safety of Lumora, our users, or others, including to prevent fraud or misuse of the Services.
- With Your Direction or Consent. In addition to the disclosures described above, we may disclose personal information where you direct us to do so or otherwise provide your consent.
5. Aggregate and De-Identified Information
We may use and disclose aggregate and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. De-identified data is data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device. Where we use, disclose, or otherwise process de-identified data, we will maintain and use it in de-identified form and will not attempt to re-identify the data, except to determine whether our de-identification processes are reasonable and adequate under applicable privacy laws.
7. Your Privacy Choices
You have certain choices regarding our processing of your personal information, and we make available several ways for you to manage your preferences and privacy choices, as described below:
- Marketing Communications. We may send periodic promotional and operational emails or other similar communications to you. You may change your preferences or unsubscribe by following the instructions provided to you in the communication. If you opt out of receiving promotional emails from us, we may still send you transactional messages and communications that you have requested to receive from us.
- Cookie Settings. You can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function. If you visit our Site from a different device or browser, you will need to apply your cookie settings separately for each device and browser. You can also review or change your preferences for many cookies on our Site, other than those that are necessary, by adjusting your cookie settings through our cookie preference manager.
- Push Notifications. The App may send push notifications, which you can manage through your device settings.
- Account Deletion. You may request deletion of your account at any time through the App’s account settings or by contacting us as described in the “Contact Us” section. When you request deletion of your account, we will delete or de-identify personal information associated with your account, subject to our legal and operational retention requirements.
8. Retention
We retain your personal information for the period reasonably necessary to fulfill the purposes described in this Notice. The specific retention period depends on the nature of the data, the purposes for which it was collected, applicable legal and regulatory requirements, and our legitimate operational needs, such as maintaining business records, resolving disputes, and enforcing our agreements. When personal information is no longer needed for any of these purposes, we securely delete or de-identify it.
9. Minor’s Information
Our Services are not directed to minors under the age of 18, and we do not knowingly collect personal information from children under 18. If we discover that a child under 18 has provided us with personal information, we will promptly delete such information from our systems. If you are a parent or guardian and believe we have collected your child’s information in violation of applicable law, please contact us as set forth in Section 13 Contact Us.
10. Security
We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
11. Third-Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Notice, but instead is governed by the privacy notices of those third-party websites. We are not responsible for the information practices of such third-party websites.
12. Changes to this Privacy Notice
We may make changes to this Notice from time to time, so please be sure to check back periodically. We will post updates to the Notice on the Site. If we make any material changes to this Notice, we will endeavor to provide you prior notice, such as by emailing or posting prominent notice on our Site.
13. Contact Us
Lumora welcomes your questions and comments about your privacy or this Notice. Please contact us by emailing andy@lumora.vet.