Pablo
Legal

Privacy notice

Version 2.0 · in force from 17 October 2026; until then version 1.0 applies. Plain-language summary: your data, in plain words.

1 · Who is responsible

The controller of personal data processed through pablorecords.eu and the Pablo application is Tina Klopčič, a natural person established in Slovenia, acting as an individual (no company is registered at the date of this notice).

Contact: tina@pablorecords.eu. There is no data protection officer; the controller answers directly.

Breeders act as controllers of their own waiting lists. A breeder decides who is on their list and why; Pablo processes that data on the breeder's behalf as a processor. For questions about a specific breeder's list, contact that breeder. For everything else, contact the address above.

2 · What is collected and why

Website visitsServer access logs (IP address, requested page, timestamp, user agent), generated automatically by the hosting provider, used for security and troubleshooting. This website sets no cookies and uses no analytics, tracking pixels, advertising or externally hosted fonts.
Waiting-list entriesFirst and last name, email address, mobile telephone number with country code, the town where you live, the preferences a family provides, the date of joining and the date and content of each confirmation answer. Used to maintain the breeder's list, to let the breeder contact the family and know where the dog would live, and to tell the family where they stand.
Questionnaire answersAfter joining a list, a family may answer the breeder's questionnaire. Every question is optional. The answers are visible only to that breeder. A breeder may mark, for each question, which answers are ideal for them; Pablo then shows the breeder, per area, how many of the family's answers match those marks. The family does not see the breeder's marks. This is a reading aid: it does not reject, rank or decide anything, and the breeder alone decides whom to contact.
AccountsEmail address and a hashed password. Used to authenticate you. Passwords are never stored in readable form.
Dog recordsData about animals (identifiers, pedigree, health and test records, documents, photographs) and the household members granted access. Animal health data is not personal data about you, but it is treated with the same care because it is linked to your household.
Invitations and shared linksWhen you invite someone to a dog's record, Pablo creates a link that you send yourself, through the channel you choose. Pablo does not receive the invited person's email address. It stores only the role and the access you chose, the date, and — if you typed one — a name for your own reference. If the invitation is not accepted within 14 days, it is deleted, together with that name. When the invited person accepts, they sign in with their own Pablo account and agree to this notice themselves; from then on Pablo also stores the time they accepted. They see only what you allowed. For a shared link, Pablo stores what the link may show, when it expires, whether it is protected by a code (stored in encrypted form), and the date and time of each opening — nothing about the person who opened it. If you choose to include it, the link or invitation also shows your name and phone number. If you allow an invited person to add entries, each dose they tick and each entry they add is stored in the dog's record with their name, so you can see who wrote what; entries stay in the record after their access ends.
Deposit and handoverWhen a breeder records a deposit for a family on their list, the dog's record is shown in that family's account as theirs-to-be; the breeder still keeps it until handover. At handover the record becomes the family's. From then on the breeder sees the family's name, town, telephone number and email as the family gave them on the breeder's list, the date of handover, and a health summary of the whole litter — never the individual record, unless the family chooses to share it. If the dog is later passed on to someone else, the breeder is told only that it was passed on, never who the new owner is.
Litter groupIf you join your dog's litter group, your dog's littermates, their families and the breeder see your dog's name, your name and what you post — never your email address or telephone number. The breeder also sees an overall health summary of the dogs in the group (how many dogs have a given diagnosis, the range of their latest weights), never an individual dog's record. In a small litter such a summary may allow the breeder to recognise a dog. You can leave the group at any time; from then on your dog is no longer included.
Pedigree linksA pedigree lists a dog's ancestors by name and registration number. When someone enters a pedigree, Pablo compares those entries with dogs already on Pablo. A matching registration number links the ancestor automatically; a matching name is only suggested, and the person editing the pedigree decides. When your dog is linked as an ancestor, you receive a notice inside Pablo (never by email) saying in which dog's pedigree it appears and from which kennel — nothing from that dog's record. You can say "This is not my dog": a link made by name is removed, and a link made by registration number is marked as disputed and hidden until the person who entered the pedigree confirms the number. The fact that a named dog is an ancestor stays in the pedigree, because it is printed on the official papers.
Reading a pedigree photoYou can photograph a paper pedigree to fill in the ancestors. The first reading happens in your own browser; the photo does not leave your device for it. If you then choose "Read with AI", the photo is sent to Anthropic, which returns the names and registration numbers it reads. Pablo stores only that you used this and when, to apply a monthly limit. Anthropic deletes the photo and the result within 30 days and does not use them to train its models; the transfer to the USA is covered by the EU Standard Contractual Clauses in Anthropic's data processing terms. The photo itself is kept with the dog's documents, as any document you upload.
CorrespondenceEmails and messages you send, kept so that a conversation can be continued.

No automated decision-making with legal or similarly significant effects takes place. Pablo never rejects a family and never orders a waiting list by questionnaire answers. Where a breeder has marked ideal answers, Pablo shows the breeder how closely a family's answers match them; the breeder always decides.

2a · Cookies and browser storage

Pablo uses no cookies, analytics or advertising trackers. The website and the application keep in your browser (local storage and session storage) only what is strictly necessary for the service you asked for:

Sign-inSo that you stay signed in — until you sign out; if you switch off "Stay signed in", only until the tab is closed.
"Stay signed in" choiceSo that your choice is respected — until you change it.
Chosen languageSo that pages show in your language — until you change it.
Whether you signed in as a breederSo that the right sign-in page greets you — until you clear your browser data.
An invitation or dog handover in progress; the email given when joining a listSo that a process you started continues after you sign in — until it is finished, or until the tab is closed.
The last page before editing a pedigreeSo that "Back" returns you there — until the tab is closed.

Because all of this is strictly necessary for a service you asked for, no consent is required (Slovenian Electronic Communications Act, ZEKom-2, Art. 225(2)). You can delete it at any time in your browser settings; signing out removes the sign-in. If Pablo ever introduces anything that is not strictly necessary (for example analytics), it will ask for your consent first.

3 · Legal bases

  • Performance of a contract (Art. 6(1)(b) GDPR) — providing the account and the service you asked for.
  • Legitimate interests (Art. 6(1)(f)) — keeping the service secure and functioning, answering correspondence and server logs; and pedigree links — linking a dog to its ancestors as printed on official pedigree papers, so that health information can be traced along a line. You can object at any time with "This is not my dog".
  • Consent (Art. 6(1)(a)) — where you choose to share something that is off by default, such as making part of a dog's record visible to a breeder or to other owners, and for the litter group: joining is your choice, and leaving withdraws it for the future. Consent can be withdrawn at any time, with effect for the future.
  • Your request, then their consent — an invitation you send rests on your request to give that person access (Art. 6(1)(b) and 6(1)(f)). It is held for at most 14 days and then deleted. From the moment the invited person creates an account, their own consent applies (Art. 6(1)(a)), and they can withdraw it at any time.

4 · Who receives data

Personal data is not used for advertising or for training machine-learning models.

Data is shared only with:

  • the breeder whose waiting list you joined, for entries on that list and for your questionnaire answers;
  • the families of your dog's littermates and the breeder, if you join the litter group — as described above;
  • people you deliberately give access to, such as a household member, a veterinarian or a boarding kennel receiving a time-limited link;
  • the processors listed below, acting on documented instructions.
Neoserv d.o.o. (Slovenia)Website and email hosting. Data remains in the EU.
SupabaseApplication database, authentication and file storage, in an EU region (Frankfurt).
esm.shPublic JavaScript delivery service. Loading the application causes your browser to request program libraries from it (database client, 3D view, text recognition, PDF reading); the requests expose your IP address to that service. No account or dog data is transmitted.
jsDelivrPublic delivery service. When you read a pedigree photo, your browser downloads the text-recognition program and its language data from it; the request exposes your IP address. The photo itself is read in your browser and is not sent there.
Anthropic PBC (USA)Reads a pedigree photo when you choose "Read with AI". Inputs and outputs are deleted within 30 days and are not used for training.
GitHub, Inc. (USA)Keeps an encrypted daily backup of the database and files for 30 days. Only the controller holds the key, so GitHub cannot read it.

Data may also be disclosed where required by law. If that ever happens, you will be told unless the law forbids it.

5 · How long it is kept

  • Server logs — the retention period set by the hosting provider, typically a matter of weeks.
  • Waiting-list entries — until the family withdraws, the breeder removes the entry, or the breeder closes their account.
  • Accounts and dog records — until you delete them. A dog's record is deliberately not tied to any breeder's account and does not expire when a kennel leaves.
  • Deleted dogs — a deleted dog's record can be restored for 30 days, then it is erased.
  • Invitations — deleted 14 days after sending if the person has not created an account.
  • Shared links — until they expire or you revoke them, whichever is sooner; the record of openings is kept for as long as the link exists.
  • Pedigree links — until the pedigree entry changes or the link is removed. A removed link is remembered, so that it is not made again automatically.
  • Notices — until the linked dog or its record is deleted.
  • AI reading log — 13 months, then deleted.
  • Backups — 30 days, encrypted.
  • Correspondence — as long as needed for the conversation, and then deleted on request.

6 · Your rights

Under the GDPR you have the right of access, rectification, erasure, restriction, data portability, and objection to processing based on legitimate interests, as well as the right to withdraw consent at any time.

To exercise any of them, write to tina@pablorecords.eu. No explanation is required and there is no charge. You will receive an answer within one month.

You also have the right to lodge a complaint with a supervisory authority — in Slovenia, the Informacijski pooblaščenec (ip-rs.si), or with the authority in the EU country where you live.

7 · Security

Connections are encrypted in transit (HTTPS). Passwords are stored hashed. Access to records is enforced at the database level, so a person can only read the rows they are entitled to, rather than relying on the interface to hide them. Confirmation links carry single-purpose tokens that answer one question and give access to nothing else. The database and files are backed up daily in encrypted form, and every backup is automatically test-restored. Administrator accounts are protected with two-factor authentication.

No system is beyond failure. If a breach ever affects your data, you will be informed, and the supervisory authority notified as required by law.

8 · Children

Pablo is not intended for people under 16. Accounts are not knowingly created for children, and any such account will be deleted on discovery.

9 · Changes

If this notice changes, the version and date at the top change with it, and anyone with an account is told about material changes by email before they take effect. Earlier versions remain available: version 1.0.