Privacy Policy

DRAFT — version 0.2-draft

1. Who is responsible for the data

HoofSpectrum, operated from Sweden, is the data controller for the data about you as a user: your account, your profile, your subscription and our technical logs. Contact for any data protection matter: privacy@hoofspectrum.com.

For the data you enter about your customers and their horses, you are the data controller and we are your data processor. What that means, and which sub-processors we use, is set out in the data processing agreement.

2. Data we collect

• Account data: email, name, organization, country
• Customer data: names, addresses, contact info that you enter about your customers
• Horse data: names, breeds, evaluation records that you enter about your customers' horses
• Photos and signatures: hoof images and visit photos you take during evaluations, and your customer's signature when an evaluation is signed off
• Subscription data: payment status and receipts. Your card details go straight to Stripe and never pass through us
• Audit logs: logins, password changes, consent changes, deletions, exports and emails sent
• Abuse protection: your IP address when you request a password reset email, kept for two days (see §5)

3. Why we use it, and on what legal basis

• To provide the service — account, sync, evaluations, appointments, reports and the emails you send to your own customers: contract (Art. 6(1)(b)).
• For the subscription — payment, renewal, cancellation: contract (Art. 6(1)(b)).
• For security and against abuse — audit log and caps on emails, uploads and reset attempts: legitimate interests (Art. 6(1)(f)) in protecting your account and the service. The same basis carries the accountability record in Art. 5(2).
• To find and fix faults — crash reports from the app with personal data scrubbed before sending: legitimate interests (Art. 6(1)(f)).
• For bookkeeping — records for paid subscriptions: legal obligation (Art. 6(1)(c), Swedish Bookkeeping Act).

We do not sell any data, do not share it with third parties for marketing, and do not profile you.

4. Where data is stored and who processes it

Data is stored in the EU. We use the following providers — the same list as in the data processing agreement:

• Supabase (EU North 1, Stockholm): hosting, database, authentication and file storage
• Scaleway (Paris, France): email delivery for booking confirmations and reports, and object storage for photos uploaded through the web app
• Stripe: payment processing for the subscription (card details are held by Stripe, never by us)
• Sentry: crash reporting from the app, with personal data scrubbed before sending (storage region: EU, Frankfurt)

The providers in turn engage their own sub-processors; for example, all traffic to Supabase passes through Cloudflare. The full chain is in the providers' own lists, linked from the data processing agreement.

We will notify you of any changes to sub-processors with 30 days' notice.

Transfers outside the EU. Scaleway is French and processes the data in France. Supabase, Stripe and Sentry are US companies that store our data in the EU, but a transfer to the US may occur within their own organizations, for example during support. The transfer mechanism is the European Commission's adequacy decision for the EU–US Data Privacy Framework (2023). Email us if you want the mechanism for a specific provider.

5. How long we keep it

• Your account and your data: for as long as the account is active. If you request deletion, everything remains for 30 days (your window to change your mind) and is then permanently deleted.
• An account locked because the subscription ended: deleted automatically 90 days after the lock. During those days you can log in and export.
• Audit logs: 12 months for your actions in the app (customers, horses, appointments, evaluations, photos, signatures), 24 months for security, account, export and email events.
• The IP address in the reset cap: two days. The row does not know which account or which person it belonged to, and is therefore not part of a data export.
• Your export file: 24 hours after the export completes, then it is deleted.
• Bookkeeping records: 7 years under the Swedish Bookkeeping Act, if you have had a paid subscription. Email logs are anonymized then: recipient, name and subject are nulled and only the fact that a service was performed is kept. It contains no data about your customers or their horses.

6. Your rights

• Access and data portability: Settings → My data (GDPR) → Request new export gives you everything in a machine-readable format, including photos and signatures. If you cannot log in, email us.
• Rectification: you edit your profile and customer data directly in the app.
• Erasure: Settings → Delete my account, or by email if you cannot log in. The whole flow is described on the account deletion page.
• Restriction and objection: email us and we handle it manually.
• Complaints: if you believe we handle your data incorrectly, you can complain to the Swedish Authority for Privacy Protection, Integritetsskyddsmyndigheten (IMY), imy.se. You do not have to contact us first, but we would like the chance to put it right.

Before we release or delete anything on an email request, we must be able to tie the request to the account (Art. 12(6)). We reply to the account's email address and may ask for something only the account holder would know. We never ask for your password.

7. Security

• Encrypted transport (TLS) on every request
• Encrypted storage at Supabase
• An encrypted local database on your device (SQLCipher) — the app works offline, so customer data also lives on the phone
• Row Level Security isolates each user's data in the database

Photos. A close-up of a hoof is not personal data, but a person in the background or a sign with an address is. The app reminds you of this in the camera view: avoid photographing identifiable people or addresses.

8. Contact

Questions, requests for access or deletion, or anything else: privacy@hoofspectrum.com.

Version 0.2-draft · Last updated 2026-09-29