Privacy Policy

The privacy of your data matters to us. This document explains, in plain language, what personal data we process through the Arvis Loft app, why we process it, who we share it with, how long we keep it and what rights you have. It is drafted in accordance with Regulation (EU) 2016/679 (GDPR).

If you want a practical guide on how to exercise your rights in concrete terms, see also Your GDPR Rights.

1. Who the controller is

The controller of your personal data (the one who decides why and how it is processed) is:

COMEXIM ELECTRONIX SRL (brand "Arvis", product "Arvis Loft")

• Registered office: Suceava, Str. Tineretului nr. 2, bl. 33, sc. A, ap. 4, Suceava County, Romania
• VAT/Tax ID (CUI): RO41380985 · Trade Register: J2019001287330
• E-mail: privacy@arvis.ro · WhatsApp: +40 741 250 134

For any question about data protection, the contact person is available at privacy@arvis.ro. (We are not legally required to appoint a Data Protection Officer, but we treat any request on this subject as a priority.)

When you are the controller, not us. If you use Arvis Loft in your professional activity and enter data about other people (for example the name of the breeder you bought a bird from), for that data you are the controller and we are the processor. The rules of that relationship are in the Data Processing Agreement (DPA).

2. What data we collect

We collect only the data we need for the app to work. By category:

• Account data: e-mail address, name, password (stored only as a hash, never in clear text), country, language and display preferences.
• Optional contact details: phone number, city, website, a short description and your federation-issued breeder code. You fill these in only if you want to. Your phone number is printed on the pedigrees you generate yourself, so whoever receives the document can reach you; it does not appear on the public pedigree opened through a verification code. If you publish your loft profile (see below), the contact details you filled in become visible to anyone opening the page.
• Public loft profile (optional, off by default): if you turn it on, you create a public page at /c/<the-address-you-choose> showing the loft name, city, description, breeder code, your profile photo if you uploaded one, and a season summary (bird count, races, average speeds). The photo also appears in the preview image generated when you send the link in a messaging app. The page is visible without an account and may be indexed by search engines. You can turn it off at any time in Settings, and the page becomes inaccessible immediately.
• Loft profile data: the loft's name, locality and, optionally, GPS coordinates (only if you choose to add them).
• Content you enter: pigeons, pedigrees, photos, race results, training records, health journal entries, notes and other data you add or import.
• Billing data (on paid plans): name or company name, billing address, VAT ID if you are a company, payment history and invoices. We do not store card details; they are processed directly by Stripe.
• Referral programme data (if you take part): your code, attributed referrals, credit balance and, when you request a payout, your IBAN and the payee name.
• Record of legal-document acceptance: the version accepted, the moment, the IP address and the browser type. This lets us prove what you accepted and when.
• Cookie consent data: your choices, the policy version, the moment, the IP address and the browser type.
• Technical data: IP address and a login audit trail, used for security.
• Reports and support: the messages you send us through the reporting form, including attached files if you choose to attach any.
• Analytics data (with consent only): usage statistics collected via PostHog, enabled only if you accept analytics cookies.
• Error data: technical error reports collected via Sentry, without your personal content.
• Images for pedigree scanning (optional): if you use the scanning feature, the uploaded image or PDF is processed to extract the text (see section 6).

We do not buy data from external sources and we do not use trackers such as Facebook Pixel, Google Ads or Google Analytics.

Rankings pulled from public sources (for example columba.ro) are stored in a shared cache used by all users. From each row we keep the race result linked to the ring number and the breeder code published in the ranking — the federation-issued code, in the form SV1261. We do not keep breeders' names, localities or any other details.

We use the breeder code strictly internally, to answer the question "which results in this race are yours?" — including for birds you have not entered into the app yet. We never display it anywhere in the app, never include it in exports, and never share it with anyone.

Data about people other than you. The pedigree documents you enter, import or scan sometimes contain the name of the originating breeder or of a previous owner of the bird. The same applies to the breeder code from the public rankings described above, which also belongs to breeders other than you. These are personal data of people who do not have an account with us and with whom we have no direct relationship.

We cannot contact them individually, because we do not hold their contact details. Art. 14(5)(b) GDPR recognises this situation and accepts public information in place of individual notice. This is that information:

• we process these data only as part of a bird's family tree, in the form in which they appear on the pedigree document, or — in the case of the breeder code — only to match a race result to the account it belongs to;
• we do not use them for marketing, we do not sell them, and we do not build profiles from them;
• they become publicly visible only if the bird's keeper chooses to publish the verification page (see section 12);
• if you are a breeder and your name appears in a pedigree inside the app, you may write to privacy@arvis.ro to exercise the rights in section 13, including objection and erasure.

The user who enters the document is responsible for having the right to use it, under section 9 of the Terms and Conditions.

3. Why we process data and on what legal basis

For each purpose we have a legal basis, under Art. 6 GDPR:

Where the basis is consent, you can withdraw it at any time, without affecting the lawfulness of processing before withdrawal.

Where the basis is legitimate interest, you have the right to object (Art. 21 GDPR). On request we provide a summary of the balancing assessment we carried out between our interest and your rights.

4. Who we share data with (sub-processors)

We do not sell or rent your data. We share it only with the service providers (sub-processors) we need in order to operate the app. Each processes data only on our instructions, under a data processing agreement:

We update this list when we add or replace a provider. Changes to the list count as minor changes to the legal documents: we inform you, without asking for a fresh acceptance. If you object to a new sub-processor, write to us; if we cannot find a solution, you may terminate the contract.

We may also disclose data to authorities where the law requires it.

Our bank receives the IBAN and payee name when we pay out a referral withdrawal. It is not a sub-processor: it executes a transfer as its own controller.

5. International data transfers

Most of our infrastructure is hosted in the European Union. Transfers outside the EU may take place in two situations:

(a) to Anthropic, PBC (United States), only if you use the optional pedigree scanning feature (see section 6);

(b) to Stripe Inc. (United States), within the Stripe group, to execute payments on paid plans.

Both rely on the European Commission's Standard Contractual Clauses (Art. 46 GDPR).

A note on suppliers with parent companies outside the EU. PostHog and Sentry store data exclusively in the European Union, in Frankfurt and in Germany respectively. The entities we contract with are, however, American (PostHog Inc. and Functional Software, Inc.), and under US law the authorities may address requests to a US company regardless of where the servers physically sit. We have data processing agreements with both, incorporating the European Commission's Standard Contractual Clauses. For the volume and nature of our data the risk remains theoretical, but we would rather state it than leave it out.

6. The optional pedigree scanning feature (AI)

Pedigree scanning is an optional feature. You use it only if you choose to, and before first use we ask for your explicit confirmation.

If you enable it, the image or PDF you upload is sent to Anthropic, PBC (US) via the Claude API, to automatically extract the text (rings, names, dates).

What happens to the file, precisely. Our copy is deleted immediately after extraction. At Anthropic, the file is deleted automatically within 30 days; the exception, set out in their terms, is content flagged as a possible breach of their usage policy, which may be kept longer. Anthropic's commercial terms state expressly that they do not train models on customer content, and that is a contractual guarantee from the supplier, not one we can verify technically.

This transfer to the US takes place on the basis of the European Commission's Standard Contractual Clauses (SCCs) (Art. 46 GDPR), incorporated in Anthropic's Data Processing Addendum. We carried out a transfer impact assessment (TIA) to confirm that the data enjoys an adequate level of protection. If you do not use the scanning feature, no personal data leaves the EU through this channel.

About accuracy. Extraction is performed by an artificial-intelligence model and can be wrong, especially with handwriting or poorly photographed documents. The result is always shown to you for review and nothing is saved without your confirmation. We take no automated decision based on it.

Be careful what you upload: a pedigree certificate often contains data about other people (previous breeders). See section 9 of the Terms for your responsibility in these situations.

7. How long we keep data

We keep data only as long as necessary for the purpose we collected it for:

8. Data security

We use encrypted connections (HTTPS), passwords stored as hashes, data isolation between accounts at the database level, restricted access, an audit trail and error monitoring. Uploaded files live in private storage, accessible only through temporary links. The infrastructure is hosted with leading EU providers (Supabase, AWS).

No measure offers absolute security, but we do not disclaim our responsibility: our obligation to take appropriate technical and organisational measures follows from Art. 32 GDPR and we accept it. If a personal data breach occurs that is likely to affect your rights, we notify you without undue delay and notify ANSPDCP within the legal 72-hour deadline.

9. Automated decisions and profiling

We do not take automated decisions producing legal effects on you and we do not subject you to profiling. Product analytics (PostHog) is used only in aggregate, to improve the app, and only if you have given consent. AI scanning extracts text from a document and submits it for your confirmation; it produces no decision.

If you are nonetheless affected by a decision made automatically - for example a payment declined by Stripe's fraud checks - you have the right to contest it and to ask for human intervention. How to do that is in Your rights under GDPR, point 8.

10. Children's data

Arvis Loft is intended for people aged 18 or over, and we ask you to confirm this when you create your account. We do not knowingly collect data from minors. If you notice that a minor has provided us with data, write to privacy@arvis.ro and we will delete it.

11. Whether providing data is mandatory

Account data (e-mail, name, password) is necessary to conclude and perform the contract. Without it we cannot give you access. Billing data is necessary for paid plans, and an IBAN is necessary only if you request a referral payout. Optional data (GPS, analytics, AI scanning) is not mandatory: if you do not provide it, the rest of the app works normally.

12. What happens to your data when you publish a public page

If you enable the public verification page for a bird, your breeder name, the loft, the bird's details and its family tree become publicly visible. The feature is off by default and is enabled individually, by you. You can turn it off at any time. See section 11 of the Terms.

13. Your rights

Under the GDPR you have the following rights: information, access, rectification, erasure ("the right to be forgotten"), restriction of processing, portability, objection, the right not to be subject to an automated decision, and the right to lodge a complaint. You can exercise them directly in the app (Settings → Privacy and Settings → Your data) or by writing to privacy@arvis.ro; we respond within 30 days at the latest.

Full details on each right and how to exercise it are in Your GDPR Rights.

14. Complaints to the supervisory authority

If you consider that we process your data incorrectly, you have the right to lodge a complaint with the supervisory authority:

ANSPDCP: the National Supervisory Authority for Personal Data Processing B-dul G-ral Gheorghe Magheru nr. 28-30, sector 1, Bucharest dataprotection.ro

It would help us, though, if you contacted us first at privacy@arvis.ro, so we can try to resolve things quickly.

15. Changes to this policy

We may update this policy as the service evolves. The current version, with its last-updated date and version number, is always published on this page.

For material changes - those that change your rights or add obligations - we notify you at least 30 days in advance, by e-mail, and ask for a fresh acceptance.

For minor changes we inform you, without the 30-day notice and without re-acceptance. Minor means corrections, clarifications, updates to the sub-processor list, and statements about what data we process and for what purpose, where they change none of your rights. Most updates to this policy are of this kind: they describe more precisely what we already do.

Previous versions are available on request.

Questions about your data? Write to us at privacy@arvis.ro or on WhatsApp at +40 741 250 134.