This is a translation. The Polish version is binding. PL
Privacy policy
1. Controller
The controller of personal data processed in BreedManager (breedmanager.eu) is Kynologic Sp. z o.o., ul. Półwiejska 17/26, 61-888 Poznań, Poland, KRS 0001066149, NIP 7831890477 (“we”). Contact on data protection matters: info@breedmanager.eu.
2. What data we process
| Data | Purpose | Legal basis | How long |
|---|---|---|---|
| Account: username, name, e-mail, language, password (hashed) | account and services, account messages, reminders | contract (Art. 6(1)(b) GDPR) | until the account is deleted |
| Kennel and animal data, photos, pedigrees, health history, test scans, calendar | providing the services | contract | until you delete them or the account |
| Show results of a dog fetched from RingPass: show (name, date, town), catalogue number, the dog’s name in the catalogue, class, grade, placing, medal, titles and final placings, judge (first name, surname and country only), result status, link to the results — no microchip number; when you connect a dog with RingPass we send RingPass the dog’s BreedManager identifier, registered name, breed (FCI number), sex, the kennel name and whether the results will be public; RingPass tells us when a dog is connected or disconnected (dog identifier, date, kennel name, reason for disconnection) | the dog’s show history on its profile, public profile and kennel page | your consent (Art. 6(1)(a) GDPR), given separately for each dog; judges’ data — our legitimate interest (Art. 6(1)(f) GDPR) | until consent is withdrawn, the owner disconnects the dog in RingPass or the dog, kennel or account is deleted |
| Request to a dog’s owner to connect the dog in RingPass: the owner’s e-mail entered by the breeder, the chosen language, an optional message from the breeder | sending one message asking to connect the dog (section 3a) | legitimate interest of the breeder and ours (Art. 6(1)(f) GDPR) | until the dog is connected, the invitation is cancelled or 30 days after sending |
| Data of animals with a microchip number and the kennel owner’s contact details sent to DogWorldBase (when you switch the listing on in kennel settings); when you hand a listing over — the buyer’s e-mail | listing in the DogWorldBase worldwide microchip lookup, letting a finder contact you, handing the listing over to the buyer | contract (Art. 6(1)(b) GDPR); buyer’s e-mail — your and the buyer’s legitimate interest (Art. 6(1)(f) GDPR) | in BreedManager — as animal data; in DogWorldBase — under the DogWorldBase privacy policy |
| Invoice details and payment history | billing, invoices, tax obligations | legal obligation (Art. 6(1)(c) GDPR) | 5 years from the end of the tax year |
| Litter notifications (“Notify me about new litters”): e-mail of the person following a kennel or its planned litter, language, date of consent and confirmation, list of notifications sent | e-mailing you when the kennel publishes a planned litter, puppies or an animal for sale; the breeder sees only the number of followers, not their addresses | your consent (Art. 6(1)(a) GDPR), confirmed with a link in an e-mail | until you unsubscribe (link in every e-mail — unsubscribing deletes the address) or the kennel is deleted; unconfirmed sign-ups — 7 days |
| Documents in the kennel Folder: files you upload (e.g. pedigrees, test results, contracts, invoices, association membership card, kennel name certificate); they may contain personal data about you and other people (e.g. buyers in contracts) | storing documents of the kennel, its animals and litters and searching them (tags are assigned by the system); kennel verification — only documents the kennel owner shares with our team (membership card and kennel name certificate); every time our team opens one, it is recorded in the activity log | contract (Art. 6(1)(b) GDPR); verification — also legitimate interest: protection against puppy mills (lit. f); other people’s data in documents is processed on behalf of the breeder, who is responsible for it (section 2, paragraph on data entered by users) | until you delete them or the kennel is deleted; sharing with our team ends with the verification decision, or earlier if you stop it; then in backups for up to 12 months |
| “In new hands”: details of an animal’s new owner recorded by the breeder (name, optionally phone, e-mail, town, handover date, notes) | letting the breeder know where the animal went and contact the new owner; we send no messages to these details | processed on behalf of the breeder, who is responsible for them as controller (section 2, paragraph on data entered by users) | until deleted by the breeder, or the animal or kennel is deleted; then in backups for up to 12 months |
| Tester feedback (only people invited to test the app): message, type, screen rating, address of the screen in the app, optional screenshot, answers to a short survey, our reply | improving the app, replying to the feedback (shown in “My feedback”), contacting you about it — if you agree | legitimate interest (Art. 6(1)(f) GDPR) — developing the service based on testers’ remarks | until the account is deleted, or earlier on request; then in backups for up to 12 months |
| Messages from a kennel’s contact form (name, e-mail, text) | passing the enquiry to the breeder | legitimate interest of sender and breeder (Art. 6(1)(f) GDPR) | until deleted by the breeder or the kennel is deleted |
| IP address, server logs, account change log | security, abuse detection, legal claims, aggregate visit statistics (from server logs, IP anonymised, no cookies) | legitimate interest (Art. 6(1)(f) GDPR) | server logs up to 90 days, change log until the account is deleted |
Providing data is voluntary, but an account cannot be created without an e-mail address and password, and no invoice can be issued without invoice details.
3. Other people’s data in pedigrees and kennel pages
Pedigrees, animal records and pedigree photos may contain names and towns of breeders and owners. They are entered by the user, who is responsible for the basis of their processing; we process them on the user’s behalf as needed to run the kennel. Pedigree photos and test scans are stored in a non-public location visible only to people with access to the kennel. Microchip numbers are visible only to people with access to the kennel and are never published or printed in pedigrees.
3a. Show results from RingPass
RingPass (ringpass.eu) is a dog show entry and results system run by us — Kynologic Sp. z o.o.. A dog’s results reach BreedManager only when both conditions are met: you switch on “Fetch show results from RingPass” on the dog’s profile and the dog’s owner (the exhibitor in RingPass) connects it in RingPass with this dog in BreedManager (“Connect with RingPass” or an invitation from the breeder). BreedManager then fetches the published show results of that dog from RingPass and stores them in its history:
- what data: the show (name, date, town), catalogue number and the dog’s name in the catalogue, class, grade, placing and medal, titles and final placings, judge (first name, surname and country only), result status (approved by the judge or verified by the organiser) and a link to the results in RingPass. We do not fetch the microchip number, pedigree number or the exhibitor’s details (name, e-mail, phone, address) — the RingPass API does not provide them;
- who is who: the breeder and the dog’s owner are often different people (e.g. the dog was sold). The dog’s owner (the exhibitor in RingPass) is the source of the results: at their own request, on their RingPass account, they connect the dog with BreedManager and thereby pass on its results; they can disconnect the dog in RingPass at any time — RingPass then notifies us (also when the dog or the account is deleted in RingPass) and we immediately delete all downloaded results of that dog. The breeder (the BreedManager user) is the recipient of the results — they show them in the dog’s history, provided they switch fetching on for the dog (the breeder’s consent). About connecting and disconnecting, RingPass sends us only the dog’s BreedManager identifier, the date, the kennel name and the reason for disconnection — no data about the owner; the breeder sees in BreedManager only the state (“connected since …” / “disconnected by the owner …”);
- where from and at whose request: from results published in RingPass by the show organiser (branch or club), who is the controller of the entries and results of its show; in RingPass we process them on the organiser’s behalf. We pass a dog’s results from RingPass to BreedManager at the dog owner’s request — expressed by connecting the dog and ticking the consent in RingPass (the owner can remove the connection in RingPass at any time). The copy of the results stored in BreedManager is processed by us as the controller of BreedManager, under this policy;
- connecting a dog with RingPass: when you click “Connect with RingPass” on the dog’s profile, (or on the invitation page — below) BreedManager sends RingPass — in a signed link valid for 1 hour — only: the dog’s identifier in BreedManager, its registered name, breed (FCI number), sex, the kennel name, whether the dog’s results will be publicly visible in BreedManager and whether the link comes from an invitation. We do not send the microchip number or any data about you or other people (including the owner’s e-mail). In RingPass the owner, logged in to their account, sees the kennel name and whether the results will be public, picks their dog and ticks the consent. Results are assigned to the dog only by this identifier — we do not look the dog up by name. If a result still does not concern your dog, you can hide it (“not my dog”) — it will not come back with later downloads;
- request to the owner (invitation): if the dog’s owner is someone else, the breeder can ask them to connect the dog (“Ask the owner to connect”): the breeder enters the owner’s e-mail (e.g. the buyer from a sale contract stored in BreedManager), the language of the message and optionally a short message. We send one message to that address with a link to a BreedManager page valid for 30 days, which explains what will happen and leads to RingPass. We process the owner’s e-mail and the message on the basis of the legitimate interest of the breeder and ours (Art. 6(1)(f) GDPR) — only to send this one request: we send no reminders or other messages and do not pass the address to RingPass or anyone else. The e-mail address and the message are stored only in the invitation and deleted once the dog is connected, the breeder cancels the invitation or after 30 days (afterwards they may remain in backups for up to 12 months, section 7). The kennel name and the message are provided by the breeder. The owner can ignore the message or object (section 6); a breeder can send at most 3 invitations per dog per day;
- legal basis: your consent (Art. 6(1)(a) GDPR), given separately for each dog. You can withdraw it at any time with “Stop fetching results” on the dog’s profile — we then immediately delete all downloaded results of that dog (including hidden ones). Withdrawal does not affect the lawfulness of earlier processing. When the owner disconnects the dog in RingPass, results are no longer passed on and we delete all downloaded results of the dog. About judges we store only the first name, surname and country from public show results; we process them in our legitimate interest (Art. 6(1)(f) GDPR) so that the result is complete and verifiable. A judge may object (section 6);
- where results are shown: on the dog’s profile in the kennel panel (people with access to the kennel) and, if the kennel page is published and the dog has a public profile there, also on the dog’s public profile and in “Shows and results” on the kennel page (public pages may be indexed by search engines);
- how long: until consent is withdrawn, the owner disconnects the dog in RingPass or the dog, kennel or account is deleted; afterwards the data may remain in backups for up to 12 months (section 7).
3b. Listing in DogWorldBase
DogWorldBase (dogworldbase.com) is a worldwide microchip lookup run by us — Kynologic Sp. z o.o.. When you click “List in DogWorldBase” on an animal’s page (a loyalty entry in the Pro and Kennel+ plans or a trial entry from a promotional code) and accept the DogWorldBase terms and privacy policy, BreedManager sends DogWorldBase the data of that animal: microchip number, name, species, sex, breed, colour, date of birth, main photo, whether the animal has died, the kennel’s name, town and country, and the kennel owner’s e-mail and language — and updates them after every change. Purpose: a finder who enters the microchip number can contact you through DogWorldBase. The microchip number and your details are never public. When you sell an animal you can hand the listing over to the buyer — we then send DogWorldBase the buyer’s e-mail you enter, and DogWorldBase invites the buyer to take over the listing. Legal basis: contract (Art. 6(1)(b) GDPR); for the buyer’s e-mail — your and the buyer’s legitimate interest (Art. 6(1)(f) GDPR): handing the listing over so that a finder can reach the animal’s new owner. Listings are permanent: switching off the transfer in kennel settings stops updates, and deleting an animal, the kennel or your BreedManager account does not remove the listing — you can remove it in DogWorldBase. We record your consent with the date and the version of the DogWorldBase terms. Processing within DogWorldBase itself is described in the DogWorldBase privacy policy.
“My animals” account (owner of a dog or cat, no kennel): the “Register the microchip in DogWorldBase” button on the animal’s page opens DogWorldBase with a link carrying that animal’s data — microchip number, name, species, sex, breed, colour and date of birth (signed, valid for 7 days). The data reaches DogWorldBase only when you click, and only fills in the registration form; whether an entry is created is up to you in DogWorldBase, where you create an account and accept its terms. Legal basis: your request under the contract (Art. 6(1)(b) GDPR). We do not pass on your e-mail address or BreedManager account data.
Animal’s public profile (“My animals” account, FeliCan): if you turn it on, anyone with the link sees, at the address you choose (e.g. felican.eu/burek), the animal’s name, photos marked as public, breed, age, town (if you enter it), description and journal entries marked as public (text and photos); private entries are seen only by people in your space. We do not publish the microchip number, the address or your details. The profile is off by default and hidden from search engines (noindex) — showing it in search engines is a separate choice. Turning the profile off removes the page immediately. Visitors can give photos a “paw”: we store the paw with the account ID (signed in) or with a random browser ID in the fc_visitor cookie (guest; no IP address), so that one person gives one paw and can take it back; publicly only the number of paws is shown. Paws are deleted with the photo or the account. Legal basis: your request under the contract (Art. 6(1)(b) GDPR). The “Lost” poster is built from the data you type into the form (including a phone number) only to display the printable page — we do not save it.
4. Who receives data
- Server infrastructure — the servers running the service, backups and outgoing e-mail are operated for us by Xerti Tech Sp. z o.o. Servers and e-mail run in a cluster in two locations — the OVH data centre in France and a server room in Poznań, Poland (Poznań Science and Technology Park) — and backups are kept in Poznań; traffic between the locations is encrypted, everything within the European Economic Area.
- Reading pedigree photos — importing a pedigree from a photo is assisted by a large language model (LLM): primarily a local one running on our own compute server, and when it is unavailable or cannot read the photo, an external one: Claude by Anthropic or Gemini by Google. In that case we send only the pedigree photo (it may contain names and towns of breeders and owners) so that it can be read; the provider acts as a processor and does not use the data to train its models. Providers may process data outside the EEA (including the USA) on the basis of standard contractual clauses and the EU-US Data Privacy Framework. Importing a pedigree is optional — you can also enter the data by hand.
- Card payments — Stripe Payments Europe Ltd. (Ireland); we never receive or store card details. Stripe may transfer data to the USA under standard contractual clauses and the EU-US Data Privacy Framework.
- BLIK and bank transfers — Krajowy Integrator Płatności S.A. (Tpay), Poznań, Poland.
- Invoices — Fakturownia (fakturownia.pl) and, for business invoices, the Polish National e-Invoicing System (KSeF).
- Public authorities — only where required by law.
If you connect your kennel calendar to Google, Apple or Outlook calendar yourself, those services fetch the entries (animal names and dates) from your private calendar address under their providers’ terms. You can revoke the address at any time.
We do not sell data, use it for advertising or profile users.
5. Cookies
We use only cookies necessary for the service to work: login session, form protection (CSRF), language and — only when you give a photo on a public profile a “paw” without signing in — a random fc_visitor ID (up to 12 months) that lets you take it back and keeps it from being counted twice. We use no analytics or advertising cookies, so we do not ask for cookie consent. You can block cookies in your browser, but login will then not work.
6. Your rights
You have the right to access and receive a copy of your data, rectification, erasure, restriction, data portability (JSON/CSV export in kennel settings) and to object to processing based on legitimate interest. Please send requests to info@breedmanager.eu — we reply within one month. You may also lodge a complaint with the Polish supervisory authority (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl) or the authority of your country.
7. Security and backups
Connections are encrypted (HTTPS), passwords are stored hashed and administrative access is possible only through a secured network. Backups: a copy of the servers (virtual machines) every night, kept for up to 12 months — the last 7 copies, daily copies from the last 2 weeks, weekly from the last 2 months and monthly from the last 12 months; copies made since 3 October 2026 are encrypted before they are sent to the backup server (earlier, unencrypted copies expire in the same way); in addition a copy of the database every night, kept for 14 days. Data deleted from the service disappears from backups within 12 months at the latest.
8. Changes
We will inform you of significant changes to this policy by e-mail and in the service.
Version of 2026-10-10