Informativa sulla Privacy

1. Who we are

This website, BauDar ("we", "us", "our"), accessible at https://baudar.com, is managed by an independent developer.

Data Controller: Adrian Ivascu
Data Controller's Email: ivascu.adrian@proton.me
Data Controller's Address: Via Aldo Moro 820, Stezzano (BG) 24040, Italy
General Email: supporto@baudar.com
Reports/Abuse (including authorities): report@baudar.com

We are committed to protecting your privacy and processing your data in compliance with Regulation (EU) 2016/679 (GDPR) and applicable Italian law.

1.1 Territorial Scope

BauDar is primarily intended for users located in the European Union, with a particular focus on Italy. Although the site is accessible globally, moderation, support, and legal compliance are designed for EU users.

2. Scope of Application

This Policy applies to personal data processed through the website https://baudar.com, including data processed when content is displayed, summarized, structured, or linked through BauDar.

Where BauDar shows content originating from publicly accessible external sources, this Policy describes how we handle such content within our service. It does not apply to the independent processing activities of third-party websites, platforms, or services once you leave BauDar or directly interact with resources hosted by them.

3. Legal Bases (Art. 6 GDPR)

We process personal data when at least one of these bases applies:

• Performance of a contract or pre-contractual measures (Art. 6.1.b): creating and managing accounts, publishing and managing announcements, closing announcements, managing recovery stories requested by users, and sending related transactional communications.
• Legal obligation (Art. 6.1.c): regulatory compliance, requests from authorities.
• Legitimate interest (Art. 6.1.f): security and abuse prevention (e.g., Turnstile), content moderation, aggregate analysis (Rybbit), the technical log and usage limits of the AI photo analysis (Section 4.l), service improvement, legal defense.
• Consent (Art. 6.1.a): for the optional AI photo analysis (Section 4.l), for the optional emails with BauDar news (Section 7) and, where required, for tools that use non-essential cookies or profiling, for which we will display a consent banner.

4. Personal Data Processed

a. Account Data (if you log in):

• Email address
• Authentication provider (e.g., Google, email via Firebase)
• Timestamps (account creation, last login)
• Your choice about optional emails (Section 7)

We use Firebase for authentication. Passwords are not processed on our servers.

b. User-Published Content:

• Text of announcements (lost/found pets), comments
• Location (address or point on a map)
• Contact information provided (phone, email, social media)
• Optional images and details about any reward
• Information relating to the closure of announcements and, where applicable, recovery stories, including photos, story text, how the animal was found, and visibility preferences

This data is voluntarily provided by users and may be made publicly visible on the site depending on the functioning of the service, the user's choices, the content status, and applicable moderation rules. Publicly accessible content may also be indexed by search engines. Users are responsible for the content they choose to share, without prejudice to our right to moderate, limit, or remove content in accordance with these rules and applicable law.

c. Content from Publicly Accessible External Sources Displayed on BauDar

BauDar may display, summarize, structure, organize, or link to content originating from publicly accessible external sources where relevant to the platform’s purposes, such as helping users identify, report, or locate lost or found animals.

Such content may include, for example:

• descriptive information about an animal or event;
• approximate location information;
• references or links to the original source;
• images or other media that may be hosted by third parties.

Where appropriate, we may reformat, summarize, organize, limit, correct, de-list, restrict, or remove such content in order to improve clarity, relevance, safety, accuracy, or privacy protection.

We aim to avoid unnecessary reproduction of personal data, direct contact details, or excessive/sensitive information where not needed for the purposes of the service. However, content derived from external sources may still include personal data that is publicly accessible through third-party sources.

Where external media is hosted by third parties, BauDar may choose not to load it automatically by default. If you decide to load such media, your browser may establish a direct connection with the third-party host in order to retrieve the resource.

Legal basis: legitimate interest (Art. 6.1.f GDPR), namely operating a platform intended to help the community report, discover, and recover lost or found animals, while improving the relevance and usefulness of the information presented.

d. Technical and Log Data:

• IP address and user agent (processed temporarily, including through our infrastructure and, where applicable, through Cloudflare as reverse proxy / security provider)
• Request timestamps
• Device/browser information
• Any headers/diagnostics for security
• Error messages, crash reports, stack traces, route/URL information, release/environment identifiers, and similar diagnostic metadata generated when the service encounters failures
• Where applicable, debugging artifacts such as source maps uploaded to our internal error monitoring systems to make production errors readable and easier to fix

Use: security, abuse prevention, debugging. Typical retention: ~30 days.

e. Analytics Data (Rybbit Analytics – cookieless):

We use Rybbit Analytics (self-hosted, in the EU) for aggregate metrics without persistent identifiers.

• Data processed per event/page: URL visited (host+path; any UTM/ref parameters), referrer, browser type/version, operating system, device type (desktop/mobile/tablet), approximate geographical area (Country/Region/City) via IP address lookup. Raw values are not stored in the analytics systems.
• Purpose: aggregate statistics (page views, traffic sources, clicks on external links, downloads, 404 errors) to improve the service.
• Legal basis: legitimate interest (Art. 6.1.f). No profiling, no cross-site/device tracking.
• Tools on the terminal: no cookies or storage for analytics.
• Location: self-hosted instance under our control, in the EEA.

f. Site Delivery, Reverse Proxy, CDN and Security (Cloudflare)

We use Cloudflare as a DNS provider, reverse proxy, content delivery network (CDN), and security provider for proxied hostnames of BauDar. This means that requests to the site may pass through Cloudflare before reaching our origin server.

In this context, Cloudflare may process IP address, request and response metadata, traffic routing data, browser/device information, security events, and other technical data necessary to deliver, cache, protect, and optimize the service.

• Purpose: secure delivery of the website, TLS/HTTPS termination, caching and performance optimization, abuse prevention, bot/DDoS mitigation, firewalling, and reliability of the service.
• Legal basis: legitimate interest (Art. 6.1.f GDPR), namely ensuring the security, availability, and performance of BauDar.
• Transfers: Cloudflare may process certain data in the EEA and the United States. Where required, transfers are governed by Cloudflare’s Data Processing Addendum (DPA), Standard Contractual Clauses (SCCs) and/or other applicable safeguards and transfer mechanisms.

g. Anti-Abuse Protection (Cloudflare Turnstile)

We use Cloudflare Turnstile to distinguish humans from bots (e.g., when publishing/commenting, or to display contact details in announcements). Turnstile processes technical signals (e.g., IP, User-Agent, TLS fingerprint, sitekey/origin) to assess suspicious activity.

• Legal basis: legitimate interest (security).
• Cookies: normally no cookies; if we activate pre-clearance, Turnstile may set the cf_clearance cookie to bypass WAF challenges on the same domain (technical/essential cookie).
• Transfers: possible processing in the EU/USA with Cloudflare's DPA, Standard Contractual Clauses (SCCs) and/or other applicable safeguards.

h. Internal Error Tracking and Reliability Monitoring (GlitchTip)

We use a self-hosted GlitchTip instance (Sentry-compatible error tracking) to detect software errors, investigate failures, monitor performance where enabled, and improve the reliability and security of BauDar.

Depending on the event, reports may include technical data such as error messages, stack traces, request metadata, browser/device context, release and environment identifiers, and, where applicable, source maps or similar debugging artifacts. We configure this system to avoid sending unnecessary personal data where possible.

• Purpose: debugging, incident response, service reliability, performance monitoring, and security investigation.
• Legal basis: legitimate interest (Art. 6.1.f GDPR).
• Location: self-hosted under our control in the EEA.
• Data minimization: we aim to avoid sending passwords, full form contents, or other unnecessary personal data in error reports.

i. Automatic Moderation (LLM)

To reduce spam and abuse, upon the creation or modification of certain content, including announcements, comments, recovery stories, or associated images, we may perform automated checks using third-party Large Language Model APIs or other moderation systems (e.g., Mistral AI). We send a minimized, structured extract of the content to be reviewed (text and any relevant fields).

• Routing Heuristics: We can process metadata (e.g., whether you are a registered user or a guest, IP reputation, previous history) to calculate a "risk score". Based on this score, the content is routed to one of three paths:
  1. Auto-approve (immediate publication);
  2. LLM Review (analysis by Artificial Intelligence);
  3. Human Review (queued for a moderator).
• Purpose: detection of inappropriate content, scams, harmful language; the classification produces an automatic outcome (e.g., "approved/rejected/needs_human_review").
• Legal basis: legitimate interest (security and integrity of the service).
• Minimization: we send only what is necessary; we avoid, as much as possible, non-essential metadata.
• Location and transfers: we have preferably selected providers with processing options in the EU (e.g., Mistral – default EU). Only if we use global endpoints (e.g., US endpoints) may data transit outside the EEA; in such cases, we apply Standard Contractual Clauses (SCCs) and appropriate technical/organizational measures.
• Retention/provider training: with Mistral – Scale plan, API data (input/output) is not used to train the models; limited retention for security/abuse purposes according to the provider's policies remains possible.

j. Automated Decisions (Art. 22 GDPR) and Human Intervention

We use automated systems for moderation. The algorithm produces an outcome (approved / rejected / needs_human_review). If the outcome significantly affects you (e.g., refusal of publication), you can request human review and contest the decision by writing to supporto@baudar.com. Additionally, on the site, we indicate whether the decision was made by an automated system or a human moderator.

k. Manual Moderation

Human moderation is carried out using protected internal tools. Any operational notification tools do not receive personal data: we only send internal IDs and links to our authenticated moderation dashboard. Manual review may concern announcements, comments, recovery stories, and other user-published content where necessary to enforce platform rules, assess reports, or manage content undergoing review.

l. AI Photo Analysis

BauDar features marked "IA" (AI) analyze photos of an animal to recognize its visible characteristics, such as type of animal, colors, coat, size and distinctive marks, and use them to fill in, search or compare announcements. The analysis starts only when you press the dedicated button: that click is your consent to that single analysis. The results are suggestions that you review and decide on.

• What we send: only the photos you choose, downsized and stripped of the hidden data in the file (for example GPS location), together with the instructions for the model. We do not send data about your account or the announcement. Avoid photos with people or documents: for anyone who appears in them by chance, we process the images on the basis of our legitimate interest in providing the requested feature, with the measures described here.
• Who processes them and where: we use OpenRouter, Inc. (United States), which forwards the photos and instructions to Google's Gemini model through Google Cloud (Vertex AI). OpenRouter acts as our data processor and Google as its sub-processor. We do not authorize the use of the data to train AI models. Google may temporarily retain request data for security checks and abuse prevention. Flagged requests may be reviewed by authorized personnel. Photos may be processed in Google's data centers, including outside the European Economic Area. The safeguards for international transfers are described in Section 9.
• What we keep: the photos and the model's responses are not saved: we process them only in memory. What remains is a technical log of each analysis (date, outcome, recognized type of animal, consent and instruction versions, model, cost, linked announcement if any, your account if you have one and, without an account or with an email not yet verified, for 7 days a daily code derived from your IP address), used to enforce usage limits, prevent abuse, control costs and fix errors, on the basis of legitimate interest and, for the proof of consent, of a legal obligation (Art. 7.1 GDPR). Without an account or with an email not yet verified we first ask for a Cloudflare Turnstile check (Section 4.g). Retention periods are in Section 8.
• Withdrawal: consent covers a single analysis and you are never required to start another one. If you cancel an analysis while it is running, BauDar stops and discards the result, but a request that has already reached the provider may still be completed. Withdrawal does not affect the lawfulness of the processing already carried out.

5. Cookies

• Essential: session/login cookies, preferences, security; do not require consent.
• Analytics: Rybbit operates without cookies; it does not require consent. If we introduce analytics with cookies or profiling in the future, we will display a consent banner before activation.
• Cloudflare security/performance cookies: depending on the Cloudflare features enabled for the site, Cloudflare may set strictly necessary technical/security cookies such as cf_clearance, __cf_bm, or __cflb to support security checks, bot mitigation, or traffic routing/load balancing. These cookies are not used for advertising or profiling and, where applicable, are treated as essential.
• Security (Turnstile): Turnstile normally operates without cookies; however, if pre-clearance or certain related Cloudflare protections are enabled, Cloudflare may set cf_clearance to remember the challenge result and reduce repeated challenges.
• Third-party: none at the moment; if introduced, we will provide information and, where necessary, ask for consent.
• Browser storage: some features store data in your browser to work, such as the draft of an announcement (texts, photos and AI suggestions) and, without an account or with an email not yet verified, the number of photo analyses made that day. This data stays on your device and you can delete it by deleting the draft or the site data.

6. Purposes of Processing

• Provision of the platform and its features (publishing/viewing announcements, comments).
• Managing the closure of announcements and recovered-pet records, including any stories, photos, and information shared in the "Di nuovo a casa" section.
• Recognizing, at your request and with your consent, the visible characteristics of animals from photos, to fill in, search or compare announcements (Section 4.l).
• Displaying, organizing, summarizing, and, where appropriate, linking to relevant content from publicly accessible external sources in support of the platform’s community purposes and its lost/found pet discovery goals.
• Security, abuse prevention, automatic and manual moderation.
• Aggregate analysis for service improvement.
• Transactional communications: emails about service events (announcement creation/publication, expiration/renewal, relevant notices).
• Compliance with legal obligations and responses to legitimate requests from authorities.
• Defense of rights in or out of court.
• Optional communications: emails with BauDar news, tips and initiatives, with your consent (Section 7).

We do not sell or share data for marketing or advertising purposes.

7. Email Communications

We send transactional emails related to your use of the service (e.g., announcement confirmations and management, closure, expiration/renewal, communications relating to recovery stories, and other relevant notices).
Legal basis: Art. 6.1.b (performance of the requested service) or Art. 6.1.f (legitimate interest in informing you about service events). These emails do not contain advertising or newsletters and do not require prior consent.
The Account → Preferenze Notifiche (notification preferences) page is available to limit/disable some non-essential emails; in-app notifications remain active.

Note: We use the external service Mailjet to send these emails; this means your email address and the message content are processed by the provider on infrastructure located in the EU.

Optional emails. If you choose so at sign-up or on the Account → Preferenze Notifiche page, we email you BauDar news, tips and initiatives, for example new features, surveys, fundraisers and events. Legal basis: your consent (Art. 6.1.a GDPR and Art. 130 of the Italian Privacy Code). We only send them to verified addresses, through Mailjet. You can withdraw your consent at any time on the same page or with the link in every email; withdrawal does not affect the lawfulness of emails already sent.

8. Retention (Limitation Principle)

• Account: until deleted by the user. Accounts with no sign-in for 24 months are deleted automatically: about 30 days before, we warn you by email and, if you sign in before that date, your account stays active.
• Announcements: remain publicly listed while active. When an announcement expires or is closed, it no longer appears on maps or in lists of active reports, but may remain accessible through a direct link for a limited period. It may subsequently be archived automatically according to the rules of the service. Where the relevant functionality is available, users may also archive or delete it earlier.
• Recovery stories: we retain story text, additional photos and related settings for as long as the story remains available. You can edit or delete your story. If you permanently delete it, we remove the story text and additional photos, except for any temporary copies remaining in backups. A minimal recovery record may remain visible, containing general information such as the animal's species and region, but not its name. Deleting the original announcement does not automatically delete the associated story. If you published without an account, you can manage the story using the announcement's management link. If you delete the announcement, the story remains available, but you will need to contact us at supporto@baudar.com to edit or remove it.
• Content reviews and moderation: we may temporarily retain previous versions, content under review, and information relating to moderation outcomes to the extent necessary to manage the review process, prevent abuse, resolve disputes, and ensure the proper functioning of the service.
• AI photo analysis: we delete the technical log of each analysis after 90 days, the code derived from your IP address after 7 days, and the counters used to limit requests after approximately 24 hours. If you have an account, we retain the total number of analyses and their associated cost until your account is deleted. Internal statistics that cannot be linked to you, individual analyses or announcements may be retained indefinitely. Results remain on your device, in your draft or on the page where you use them. If you publish them, they follow the retention rules for announcements. Google may temporarily retain request data for security checks and abuse prevention, subject to the applicable service terms. Any such retention is separate from BauDar's technical log retention periods.
• Consent to optional emails: we keep the date and the text you accepted and, if you withdraw, the date of withdrawal, to be able to show when the consent was valid (Art. 7.1 GDPR). They are deleted with the account.
• Content from publicly accessible external sources displayed on BauDar: retained only for as long as it remains relevant to the purposes of the platform, reasonably current, and not subject to a valid correction, objection, restriction, or removal request. Such content may be corrected, limited, de-listed, restricted, or removed earlier where appropriate.
• Technical logs: ~30 days unless required for security or legal obligations.
• Analytics: aggregate data not traceable to individual users.
• Error monitoring / diagnostics: retained for up to 90 days, after which data is deleted or rotated according to internal retention policies.
• Backups: backups of the database and essential data, encrypted and rotated periodically.

You can request the deletion of your content/account at any time via your user page on the site or by contacting us at supporto@baudar.com. We will take into account legal obligations (e.g., retaining transaction data) and any legitimate reasons for residual retention.
In some cases, we may retain certain information for longer where necessary to comply with legal obligations, prevent abuse, handle disputes, or protect our rights.

9. Hosting, Transfers, and Providers

We process data primarily within the European Economic Area (EEA). The site is hosted on servers located in the European Union. If data transfers outside the EEA occur for some services, we use SCCs and appropriate measures to protect the data in accordance with Articles 44-49 of the GDPR.

Main external providers (policies/DPAs):

• netcup (hosting) – data centers in the EU (Germany/Austria/Netherlands) – Company Privacy
• Firebase (Google) – authentication and storage
  Auth: processing in the United States (no region selectable) with Data Processing & Security Terms (DPST) as DPA, EU-US DPF as the primary transfer mechanism, and SCCs as a fallback.
  Storage: buckets configured in the EU (when available).
  – Firebase Privacy & Security — DPST
• Rybbit (self-hosted instance) – cookieless analytics
• Cloudflare – DNS, reverse proxy, CDN, site security, and Turnstile anti-abuse protection
  Proxy/CDN/security: when Cloudflare proxying is enabled for a hostname, requests are routed through Cloudflare before reaching our origin, for performance and protection purposes.
  Transfers: Cloudflare may process certain data in the EEA and the United States. Cloudflare states that, where required, it relies on its DPA, SCCs, and/or EU-U.S. Data Privacy Framework certifications and related safeguards.
  – Privacy Policy — GDPR / international transfer safeguards — Cookies — Turnstile Privacy
• LLM (Language Model APIs) – Mistral AI (automatic moderation; default EU, Scale: no training)
  – Terms — Data location
• Mailjet – transactional and optional email sending service
  – Privacy Policy — [Servers in EU]
• OpenRouter, Inc. (United States) – provides access to AI models for optional photo analysis (Section 4.l). It acts as our data processor and uses Google (Gemini on Google Cloud Vertex AI) as a sub-processor. We do not authorize the use of the data to train AI models. Google may temporarily retain data for security checks and abuse prevention, as described in Sections 4.l and 8. International transfers: transfers to OpenRouter rely on the Standard Contractual Clauses included in its DPA. Google may process photos outside the European Economic Area. Google LLC participates in the EU-U.S. Data Privacy Framework.
  – Privacy Policy — Terms — DPA — Sub-processors — Data handling

Self-hosted tools under our control:

• Rybbit – self-hosted analytics instance in the EEA
• GlitchTip – self-hosted internal error tracking / monitoring platform in the EEA, used for error reports, debugging, and service reliability

(For convenience, the reference links above lead to the official policies or relevant documentation of each provider.)

10. Minors

BauDar is not intended for children under 14 years of age. We do not knowingly collect data from children under this age. If you believe a minor has provided us with data without proper authorization, please contact us immediately: we will delete the data involved.

11. Data Subject Rights

You have the right of access, rectification, erasure, restriction, objection, portability, as well as to withdraw consent where applicable at any time (when processing is based on consent).
You can also lodge a complaint with the Garante per la protezione dei dati personali (the Italian supervisory authority) via the website https://www.garanteprivacy.it or according to the procedures provided.

To exercise your rights or for any privacy-related request, you can contact us at supporto@baudar.com. We will respond without delay and in any case within the legal terms (usually within 30 days).

If you believe that content displayed on BauDar and originating from publicly accessible external sources is inaccurate, outdated, excessive, unlawfully published, or unduly affects your privacy or rights, you may request correction, restriction, de-listing, or removal by contacting supporto@baudar.com or report@baudar.com. We will assess the request and take appropriate action where justified.

Right to object: where we process personal data on the basis of legitimate interest, you may object to such processing at any time on grounds relating to your particular situation. We will assess your objection in accordance with applicable data protection law.

Automated decisions: if an automated decision (e.g., refusal of publication for moderation) produces legal or similarly significant effects, you have the right to obtain human intervention, express your point of view, and contest the outcome (Art. 22 GDPR). Write to supporto@baudar.com.

12. International Users

BauDar is managed in Italy and adheres to the European GDPR. If you use the site from outside the EEA, you acknowledge that your data will be processed according to these European standards.
At the moment, we do not apply specific non-EU regulations (e.g., CCPA for California, LGPD for Brazil) unless required by future developments or agreements.

13. Security

We apply technical and organizational measures to protect personal data, including:

• HTTPS encryption for all communications to the site.
• Robust access control and authentication systems.
• Secure server and database configurations.
• Monitoring, security logging, and application firewalls.
• Measures intended to reduce unsolicited third-party requests, including user-controlled loading of certain externally hosted media where applicable.
• Restricted access to internal monitoring, logging, and debugging tools.
• Encrypted backups, redundancy, and disaster recovery procedures.

Despite this, no system is 100% impenetrable. We encourage you to use unique and strong passwords and to report any security vulnerabilities or incidents to us.

14. Updates and Changes

The BauDar Privacy Policy may be updated to reflect regulatory or technical changes.
In case of significant changes, we will inform users on the site or via email.

Update history:

• 15/10/2026 – Clarified how recovery stories published without an account are managed and updated information on data processing and retention during AI photo analysis (Sections 4.l, 8 and 9).
• 11/10/2026 – Added the optional emails with BauDar news (Sections 3, 4.a, 6, 7, 8 and 9) and clarified photo analyses with an email not yet verified and the deletion of inactive accounts (Sections 4.l, 5 and 8).
• 09/10/2026 – Added the optional AI photo analysis (Sections 3, 4.l, 5, 6, 8 and 9).
• 18/09/2026 – Added information about the "Di nuovo a casa" section, recovery stories, and their related visibility and moderation settings.
• 29/03/2026 – Clarified how BauDar may handle content originating from publicly accessible external sources, including optional loading of third-party hosted media and rights relating to correction, objection, restriction, and removal requests.
• 17/10/2025 – First publication of the Policy.

The most recent version will always be available at:
👉 https://baudar.com/privacy

15. References and useful links (providers)

• Firebase – Privacy & Security: https://firebase.google.com/support/privacy
• Rybbit (policy & security): available upon request.
• Cloudflare – Privacy Policy / GDPR / Cookies: https://www.cloudflare.com/privacypolicy/ — https://www.cloudflare.com/trust-hub/gdpr/ — https://developers.cloudflare.com/fundamentals/reference/policies-compliances/cloudflare-cookies/
• Cloudflare Turnstile – Privacy Addendum / Pre-clearance: https://www.cloudflare.com/turnstile-privacy-policy/ — https://developers.cloudflare.com/turnstile/concepts/pre-clearance-support/
• GlitchTip – Documentation / Error Tracking: https://glitchtip.com/documentation/error-tracking/
• Mistral – Terms / Data location: https://mistral.ai/terms — https://help.mistral.ai/en/articles/347629-where-do-you-store-my-data-or-my-organization-s-data

16. Accessibility (information)

We are committed to progressively improving the accessibility of BauDar. We will publish an Accessibility Statement with the current status, roadmap, and a dedicated contact for reporting issues. If you encounter any barriers, please write to supporto@baudar.com: we will provide feedback and arrange for an accessible alternative where possible.