Policies
A lawyer has not signed this off yet. It was written by the people who built Pumo, it describes what the software actually does today, and a qualified adviser in Oman and in Estonia has to review it before it is final. Nothing on this page is legal advice.
Privacy
This describes every piece of information Pumo holds about you, why it exists, where in the world it sits, and how to get all of it back or destroy all of it. It is written to be read, not to be survived.
Last updated11 September 2026Policy version2026-09-11
The controller is Brainy Circles OÜ, in Estonia
Brainy Circles OÜ decides what is collected here and why, which makes it the controller under the GDPR and the equivalent responsible party under Oman's Personal Data Protection Law, fully enforceable since 5 February 2026. Both frameworks apply at once: Estonian because that is where the company is, Omani because that is where you are.
Brainy Circles OÜa company registered in Estoniaregistered office addressstill to be filled inEstonian registry codestill to be filled in
Four things get collected, in this order
- An anonymous key. The moment you open the adviser, a random identifier is written to your browser so your pet's file can exist before you have signed up for anything. It is not linked to a name, it is not shared, and clearing your browser storage ends it.
- An email address, only if you want reminders. That is the only reason an account exists, and it is offered in exchange for something you asked for rather than demanded before you are given anything.
- An owner profile, only what you type: a name if you give one, your language, your governorate and area if you tell us, and a WhatsApp number if you want to be reached on it.
- Your pet records: name, species, breed, birthdate, sex, whether they are neutered, allergies, conditions you report, current food, activity level, indoor or outdoor, a photo if you upload one, every weight you log and every dated care event.
Two more rows exist because the business runs on them. A booking enquiry keeps what a brand sent us. An outbound click to a clinic keeps the fact of the click, a coarse intent word, the species, the language, the governorate and whether the sponsored label was rendered. The question you typed is not on that row, and the code that produces the intent word returns one of six words and nothing else, on purpose.
Five things that are never collected
- Your precise location. There is no field for a latitude in the owner record, only a governorate and a free text area you typed yourself.
- Your raw IP address. The server sees it, cuts it down to a coarse prefix to keep one machine from draining the daily model budget, and never writes it to the database.
- Your full user agent. It is reduced to a browser family before it crosses into storage, and the type signature will not accept a raw string.
- Payment card details. Bookings are settled by transfer and the site never sees a card.
- The text of what you asked, anywhere in the analytics. It stays on the message and nowhere else.
Vercel and AWS, which means outside Oman
This is the part that makes cross-border transfer a separate consent instead of a line in a paragraph. Nothing here runs on a machine in Oman.
- The website itself is served by Vercel, from infrastructure outside Oman.
- The database is Convex, which runs on Amazon Web Services.
- The model is on Amazon Bedrock, and the question reaches it in an AWS region outside Oman.
- Anonymous usage counters are written to the server log, which is read through Vercel.
- When you message Sareh on WhatsApp, that conversation is between you and WhatsApp and its own terms apply to it, not ours.
Transfers out of the European Economic Area rely on the standard contractual clauses each of those providers publishes, and the corresponding Omani route requires your consent, which is why it is asked for on its own rather than folded into a general yes.
The region: the AWS region the model runs instill to be filled in
Three consents, not one checkbox
Oman's law treats these as three different permissions, and it is right to. Each one is stored with the exact moment you granted it and the version of this document you were shown, so what you agreed to is provable rather than asserted.
Account
Covers keeping your pet's file and your email address so reminders can be sent. Refuse it and the adviser still works, anonymously, with nothing kept between visits.
Cross-border transfer
Covers your question and your pet's details leaving Oman to be processed by Vercel and AWS. Refuse it and the adviser cannot run, because there is no machine in Oman for it to run on, and we would rather say that plainly than quietly do it anyway.
Marketing
Covers anything we send you that is not a reminder you asked for. Refuse it and nothing about the product changes. It is off unless you switch it on.
Withdrawing any of the three takes one tap
Each consent has its own switch in your pet's file and each one can be withdrawn on its own without touching the other two. Withdrawing marketing stops the emails that day. Withdrawing the account consent deletes the file. Withdrawing cross-border transfer turns the adviser off for you, which is the honest consequence rather than a punishment. Withdrawal is not retroactive: it stops what happens next, and it does not undo something that already happened lawfully.
How long each thing is kept, from 12 months to 7 years
- Your pet's file: until you delete it, or 24 months after you last opened it, whichever comes first.
- Conversations with the adviser: 12 months, then deleted.
- Anonymous usage counters: 24 months.
- Outbound click records: 24 months, because a partner is entitled to audit the number we reported to them.
- A booking enquiry that never became a booking: 24 months.
- Records of a booking that was paid for: 7 years, because Estonian accounting law requires accounting source documents to be held that long and no consent can shorten it.
A deletion request sets a marker on your record the moment it arrives, and nothing is read after that, including by us, while the deletion runs.
Export and delete, both one click
Both are buttons in your pet's file, not a form that goes to a queue and comes back in thirty days. Export gives you a machine readable file with every record we hold on you. Delete destroys the lot.
- The right to a copy of everything, which is the export button.
- The right to correct anything that is wrong, which is editing your own record.
- The right to erasure, which is the delete button, with only the paid-booking accounting records surviving it and only because law requires it.
- The right to take your data elsewhere in a format a machine can read, which is the same export.
- The right to object to a use, and the right to restrict one while we look into it.
- There is no automated decision here that produces a legal effect on you. The adviser answers a question. It does not decide anything about you.
The GDPR basis for each use
- Consent, for the account, the cross-border transfer and any marketing.
- Performance of a contract, for a booking a brand has actually placed.
- Legitimate interests, for keeping the site up, stopping abuse and counting anonymous usage, which is the narrowest of the three and the one we use least.
- Legal obligation, for the accounting records behind a payment.
Two regulators you can complain to
If we get this wrong, tell us first, because we can usually fix it the same day. If that does not satisfy you, the Estonian Data Protection Inspectorate supervises Brainy Circles OÜ as an Estonian controller, and in Oman the Ministry of Transport, Communications and Information Technology supervises personal data protection. You do not need our permission to go to either of them and we will not ask you to try us first.
One address for every data question
Write to the address below and say what you want. You can ask for a copy, a correction, a deletion, or just an explanation of something on this page, and you do not have to use the word request or cite an article number to be taken seriously.
email address for data questionsstill to be filled in
One key in your browser, and no advertising cookies
There is no advertising cookie on this site, no third party tracker, no pixel and no cross-site profile. What exists is the anonymous key in your browser storage that lets your pet's file survive a refresh, and a session cookie if you sign in. Clear your browser storage and the first one is gone.
Not built for under 16s
The adviser is not aimed at children and an account is not for anyone under 16. If you believe a child has created one, write to the address below and it will be removed rather than investigated at you.
One address for every question on this page
A person answers. There is no ticket queue behind this address, and you will not be asked to prove who you are before someone reads what you wrote.
- Operated by
- Brainy Circles OÜa company registered in Estonia
- Estonian registry code
- Estonian registry codestill to be filled in
- registered office address
- registered office addressstill to be filled in
- email address for data questions
- email address for data questionsstill to be filled in
- postal address for a written request
- postal address for a written requeststill to be filled in
Last updated11 September 2026Policy version2026-09-11