Privacy Policy

App — On-Device Processing

MiaoSense processes all data — including camera footage, microphone audio, and behavioural scores — locally on your Android device. No video, audio, or analysis data is ever sent to our servers or any third party. The app works offline; it needs the network only for the purchase check for MiaoSense Pro (without a network, Pro stays unlocked) and for the optional MiaoWatch feature. It does not use any third-party crash-reporting or analytics SDKs. A small set of first-party technical usage events is recorded locally, as described below.

Data stored locally on your device:

• Cat profiles you create (name, breed, age, notes and — if you enter them — microchip number, country of residence for the registry note, sex, neutering status, breeder, vet practice with phone number, distinctive features)
• Care events you log (type, date, repetition, reminder on/off, your note)
• Analysis session results, including the times of your observations and how often each mood was recognised during them. For the weekly comparison (MiaoSense Pro), the app evaluates these times and frequencies only on your device; they are not transmitted.
• Your consent record (timestamp, Terms version, app version, locale)
• App preferences (theme, language, sensor settings)
• Local usage events (which app functions you use, timestamps, session number, app version)

Care data and lost-cat poster (on your device only)

All information in the cat profile and the care log is optional. It is stored encrypted on your device only, is not transmitted to us or to third parties and is not included in device backups. We have no access to it.

If you enter data about other people (for example a breeder or a vet practice), please do so only with their consent.

Reminders are scheduled by the App through the Android system on your device. The notification shows only the cat’s name and the type of event, never your note; on the lock screen it shows only “MiaoSense reminder”.

When you tap “Add to phone calendar”, the App opens your calendar app with the title and date. Whether the entry is then saved and synchronised is up to you in that app; your calendar provider’s terms apply. Your note is not passed on.

The App creates the lost-cat poster as an image (PNG) or PDF on your device. The App does not store the contact details you enter for it in its data; they do, however, appear in the file it creates. This file stays in the App’s cache on your device until the App deletes it the next time it starts or when you create the next poster. Only if you share it does a copy go to the app or person you choose; their rules apply there.

Because this information stays on your device and we do not receive it, we do not process it ourselves. If you use MiaoSense purely privately, what you enter there about other people (for example a breeder or a vet practice) is a personal or household activity. If you use the app professionally or commercially, see the section Commercial use. If you want to make other people’s data public, for example on a notice, that is your responsibility.

Export and deletion (Settings → Data) also cover this information and any scheduled reminders.

MiaoSense reads your device's system language setting (locale) to display content in the appropriate language. This information is processed locally and, if you change the in-app language, stored on your device only.

You can export or permanently delete all locally stored data at any time via Settings → Data → Delete all data.

Legal basis: Art. 6(1)(b) GDPR — processing necessary to provide the App's functionality.

AI Processing

MiaoSense observes your cat through camera images and — if you use the vocalisation feature — through microphone audio using artificial intelligence models that run entirely on your device. The models detect your cat, describe visible movement and posture patterns, and derive behavioural indicators from them.

These results are probability-based estimates. They are not confirmed findings and not a veterinary diagnosis, and no person reviews them before they are shown to you. Lighting, camera angle, or an unusual posture can affect how reliable an estimate is.

The models are not adapted using your recordings. Nothing you record is used to train or improve them, and no recording, audio file, or analysis result is transmitted to us or to any third party — neither for that purpose nor for any other.

People who appear in a recording: MiaoSense looks for cats. It does not run face recognition, does not identify people, and does not analyse the behaviour or emotional state of anyone who happens to be in the frame. If a person is visible in your footage, that footage is still processed only on your device and is never transmitted.

Because every AI analysis runs on your device and no result is transmitted, there is no automated decision-making within the meaning of Art. 22 GDPR: MiaoSense produces information for you, and no legal effect or similarly significant consequence follows from it.

Legal basis: Art. 6(1)(b) GDPR — processing necessary to provide the App's functionality.

Purchase of MiaoSense Pro — Purchase Verification

You buy MiaoSense Pro through Google Play. You conclude the purchase contract with Google; Google processes your payment and account data in the process under its own responsibility (see Google’s privacy notice). We do not receive card data or payment details; Google reports the following sales data to us: order number, time, product, price, tax and total amount, device model, and the buyer’s country, region, city and postcode.

So that Pro cannot be unlocked with a forged proof of purchase, the App additionally checks with us whether Google knows the purchase — when Pro is unlocked, when a purchase is restored and during later reconciliation. For this, the App sends our verification service at miaosense.app the purchase token (a character string issued by Google that identifies your purchase) and the product ID (“miaosense_pro_unlock”). Your name, your email address, cat data, recordings and usage events are not transmitted in the process.

The verification service passes the token and product ID unchanged to the Google Play interface and returns one of the answers “valid”, “pending”, “invalid” or “unknown” to the App. We do not store the token and do not write it to any log. For technical reasons, the operator of the verification service (Cloudflare, see “Website — Hosting & Infrastructure”) sees your IP address, as with any internet connection. We use it only as a counter for an abuse limit; the counter is kept for one minute and then expires. Cloudflare acts as our processor in this respect (Art. 28 GDPR). The Google interface answers from Google’s own records; to that extent, Google is a separate controller.

Consequence of the check: We block Pro only if Google expressly does not know the purchase, or has cancelled or refunded it. If the purchase is still pending at Google, the answer is unclear or the check is not possible (for example without a network or during a disruption), Pro stays unlocked; the App then decides on its own, using its local check. The check does not produce any assessment of you as a person (no profiling). A block is based solely on Google’s status report on your purchase. If you believe it was made in error, write to hello@miaosense.app; we will review it manually and restore Pro if there was a mistake.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is protection against circumvention of the payment function by means of forged proofs of purchase. The processing is limited to the token, the product ID and an IP address used only briefly. You may object to it on grounds relating to your particular situation (Art. 21 GDPR) — an e-mail to hello@miaosense.app is enough. Because the check takes place when Pro is unlocked, an objection may mean that we cannot confirm Pro through our verification service; the App’s local check remains unaffected. Because we store neither the token nor the IP address, we cannot attribute individual checks to you (Art. 11(2) GDPR); we will confirm receipt of your objection.

Obligation to provide: You are under no statutory or contractual obligation to allow the check. Without it, Pro remains usable through the App’s local check.

Storage period: We store neither the token nor the answer. We count the answers anonymously, without the token, IP address or any reference to a device; this count is kept for at most three months. Cloudflare keeps its own technical logs of the verification service (error messages and request data such as time, status code and possibly the IP address, without the token), which are deleted automatically after at most seven days.

Third country: The processing by Cloudflare, Inc. and the query to Google are carried out via US companies. Both are certified under the EU–US Data Privacy Framework (adequacy decision, Art. 45 GDPR). In the alternative, we rely on standard contractual clauses (Art. 46(2)(c) GDPR); you can obtain a copy on request at hello@miaosense.app.

MiaoWatch — Remote Camera

The optional MiaoWatch feature lets you connect MiaoSense to a camera stream (e.g. an IP camera or webcam) via a URL you enter manually. When MiaoWatch is active:

• For MiaoWatch, the App establishes a network connection exclusively to the URL you configured. The purchase check (see “Purchase of MiaoSense Pro”) is independent of this.
• Video frames are processed in RAM on your device and are never stored or forwarded to MiaoSense servers or any third party.
• The camera URL you enter is stored locally on your device only.
• No data from the camera stream is transmitted to external parties.
• The address may be inside your own network or on the internet. Where it is on the internet, your network and the operator of that address can see that a connection is being made, including your IP address — this is inherent to any internet connection and is not data MiaoSense sends about you. Where such a connection is not encrypted, the App asks you to confirm before connecting.
• MiaoSense does not establish or broker this connection itself; the App only calls the address you entered. There is therefore no transfer of data by MiaoSense to a third country (Art. 44 et seq. GDPR).

You are responsible for ensuring you have the legal right to access and monitor the camera you connect to. MiaoSense does not verify the source or legality of the stream.

Storage period: The camera URL remains stored on your device until you remove it manually (Settings → Manage cameras → Delete) or uninstall the App. Video frames are processed in RAM during active streaming only and are never stored. There are no recipients of your camera data — all processing is on-device; no video, audio or behavioural data is transmitted to MiaoSense or any third party.

Legal basis: Art. 6(1)(b) GDPR. By activating MiaoWatch, you enter into a service arrangement for this optional feature. Processing your camera URL is objectively necessary to establish the connection you requested — without it, MiaoWatch cannot function.

Local Usage Statistics

The App records a small number of technical usage events on your device — for example when a feature is switched on, when a purchase is confirmed, or whether the on-device AI models loaded successfully. This helps us improve the App and diagnose faults.

• Categories: event name, timestamp, in-app session number, app version, technical attributes.
• Storage: exclusively on your device. These events are never transmitted — there is no network path for these events, and no analytics SDK is involved.
• Recipients: none. No third-country transfer occurs, as this data never leaves your device.
• Storage period: until you delete it (Settings → Data → Delete all data) or uninstall the App. Events are not automatically capped or rotated.

Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in a stable, improvable App. Because these events never leave your device and contain no content of your recordings, the balancing of interests weighs in favour of processing. You may object to this processing at any time (Art. 21 GDPR): turn off Settings → Data → Local usage statistics and nothing further is recorded. Events already recorded can be removed via Settings → Data → Delete all data.

Website — Hosting & Infrastructure

miaosense.app runs on Cloudflare Workers (Cloudflare, Inc., USA). Cloudflare delivers the pages and, as our processor (Art. 28 GDPR), handles technically necessary connection data such as IP address, user agent and timestamp.

Audience measurement without cookies. We count how often our pages are viewed, where visitors come from and which paths they take through the site. For every page view, every use of the QR-code link (miaosense.app/get/<language>) and every click on the Google Play button (which leads through miaosense.app/out/play), our website writes one data point to Cloudflare’s “Workers Analytics Engine”. It contains: type of request (page, QR code or store button), the page path (without parameters), the page you came from if it is part of our website (path only), country (derived from the IP address; the IP address itself is not stored in the measurement data), the domain of an external referring site (without subdomain, path or parameters) or the package name of a referring Android app, campaign tags from the link (utm_source, utm_medium, utm_campaign; only known names and dated campaign waves are kept, other values are grouped as “other”; our short links miaosense.app/go/… forward to the language page with a fixed campaign tag that is the same for everyone), the first language of your browser, the device class (mobile, desktop or bot) and a broad operating-system class (for example Android, iOS or Windows; we do not store the user agent itself), the language you picked with the language switcher, if any, and the time.

Requests are counted as a bot if they can be identified by their user agent or come from the network of a cloud or data-centre operator. For this, the IP address is evaluated transiently; neither the IP address nor the network or the network operator is stored, only the result “bot”. This also affects requests made through some VPN services, which are therefore not counted as visitors.

For this measurement, no cookies are set, no script runs in your browser, and nothing is stored on or read from your device. There is no identifier: we cannot recognise you, and we cannot link several page views of the same visit to each other — a path is only ever recorded as a single step “previous page → current page”. Data is evaluated in aggregate only and deleted automatically by Cloudflare after three months. We use no other analytics or tracking services.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is to understand which pages and channels (for example press, QR code, social media) bring visitors, where they leave, and how to improve the website. You are not obliged to provide this data; it arises automatically when a page is requested, and the website works the same either way.

This website sets exactly one cookie, and only if you pick a language yourself using the language switcher: ms_lang stores that choice so the site does not override it on your next visit. It holds nothing but the two-letter language code, is not readable by scripts (HttpOnly), is not sent to third parties, and expires after one year. You can delete it in your browser at any time; the site then falls back to your browser’s language setting. As a strictly necessary cookie for a function you requested, it does not require consent (§ 25 (2) no. 2 TDDDG); the legal basis for the processing is Art. 6(1)(f) GDPR.

The QR code on the home page leads to the Google Play listing via a redirect on our own domain (miaosense.app/get/<language>). The redirect adds a source tag to the store link, which tells us in aggregate how many installs came from the QR code. The request is counted as described above. No cookie is set.

Cloudflare is certified under the EU–US Data Privacy Framework (DPF), an adequacy decision pursuant to Art. 45 GDPR, which permits data transfers to certified US recipients without additional safeguards.

The DM Sans typeface is served locally from our own server (self-hosted). Loading the font does not establish any connection to Google or other third parties, and no data is transmitted to third parties in the process.

Legal basis for hosting, security and audience measurement: Art. 6(1)(f) GDPR — our legitimate interest in operating a secure, reliable and efficient website.

User-Exported Media

MiaoSense allows you to save analysis photos and vocal recordings ("exported media") on your device. Exported media is stored exclusively on your device and is not transmitted to Purrception or any third party.

Exported media may contain a visible disclaimer label burned into the image ("MiaoSense — not a vet substitute") and, where applicable, a low-confidence indicator. These labels are for informational purposes and remain part of the file.

Sharing exported media is an action you take in your own responsibility. When you share files via third-party apps (WhatsApp, Instagram, email, etc.), those apps' own privacy policies apply. Please ensure that no identifiable persons are visible in any media you choose to share (see § 201a of the German Criminal Code (StGB) and equivalent national criminal-law provisions in other EU jurisdictions).

Saved media files can be deleted at any time through your device's gallery app or file manager.

Legal basis: Art. 6(1)(b) GDPR — processing necessary to provide the requested export functionality.

Email Contact

You can reach us at hello@miaosense.app, with questions about the App at support@miaosense.app, for a withdrawal at widerruf@miaosense.app and, for editorial teams, at press@miaosense.app. When you write to us, we process your email address, your name if you provide it, the content of your message including attachments, and the technical headers of the email, such as the time and the mail servers involved.

How an email reaches us: the addresses at miaosense.app are not separate mailboxes. Cloudflare receives incoming emails and forwards them to a mailbox at Google (Gmail) (Cloudflare Email Routing). Emails to support@miaosense.app additionally receive an automatic acknowledgement of receipt from a program at Cloudflare (Cloudflare Worker); in the process, your sender address is recorded in an operational log. We send our replies via Zoho Mail.

Purpose: We answer your enquiry, help with questions about the App, process withdrawals and requests concerning your data protection rights, and answer press enquiries.

Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in responding to enquiries. Where your email concerns a contract with us, such as the App’s Terms of Service, Art. 6(1)(b) GDPR. For requests concerning your rights under Art. 15 to 22 GDPR, and insofar as we are required by law to retain emails, Art. 6(1)(c) GDPR (for requests concerning your rights, in conjunction with Art. 12(3) GDPR).

Recipients: Cloudflare, Inc. (USA) forwards emails and sends the acknowledgement of receipt as our processor (Art. 28 GDPR). Incoming emails arrive in a mailbox at Google (Gmail). There, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, processes the emails under its own responsibility in accordance with Google’s privacy notice (policies.google.com/privacy (opens in a new tab)). Zoho Corporation GmbH (Düsseldorf) provides the email service through which we send replies and store them in the outbox. We draft some replies with the AI tool Claude from Anthropic Ireland, Limited (Ireland); in doing so, Anthropic receives the content of the enquiry concerned. We keep notes on enquiries in working files at GitHub, Inc. (USA).

Third country: Cloudflare is certified under the EU–US Data Privacy Framework (adequacy decision, Art. 45 GDPR). In the alternative, the standard contractual clauses in the data processing agreement apply (Art. 46(2)(c) GDPR); you can obtain a copy on request at hello@miaosense.app. Google may also process data in the USA; Google LLC is certified under the Data Privacy Framework. Zoho stores the mailbox in a data centre in the EU; staff of the group company Zoho India can access it, and according to Zoho this access is based on standard contractual clauses (Art. 46(2)(c) GDPR). GitHub is certified under the Data Privacy Framework. Anthropic Ireland also has the data processed by Anthropic, PBC (USA); standard contractual clauses apply to this (Art. 46(2)(c) GDPR).

Storage period: We store enquiries that do not relate to a contract for as long as handling them and possible follow-up questions require; after that, we delete them. Where we must retain emails for tax purposes, we keep business letters received or sent for six years and emails that are also accounting records (for example invoices) for eight years (§ 147 (1) nos. 2 to 4 and (3) AO, the German Fiscal Code). The period begins at the end of the calendar year in which the email was received or sent (§ 147 (4) AO) and does not end as long as the tax for which the email is relevant can still be assessed (§ 147 (3) sentence 5 AO). Cloudflare automatically deletes the operational log of the acknowledgement of receipt after at most seven days.

Providing your email address is voluntary. Without it, we cannot reply to you.

Press relations: contacting editorial teams

For the launch of MiaoSense, we contact editorial teams and journalists individually by email or via the media outlet’s contact form. We did not collect this data from you; we took it from publicly accessible sources (Art. 14 GDPR): the imprint or the contact, press, author, about-us or help page of your media outlet or, for podcasts, the podcast feed. We only use information that the media outlet has published itself.

We store the name of the media outlet, country and language, the email address or the contact form, your name where applicable, the desk or subject area, our internal priority and brief factual notes on the media outlet, the page on which we found the information, the time and status of the mailing (sent, undeliverable, unsubscribed) and your reply.

Purpose: We provide information about MiaoSense so that you can report on the App, we answer follow-up questions, and we handle bounced emails and unsubscribe requests.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is press relations for a new product. Apart from a data protection notice under Art. 14 GDPR, we write to each address no more than twice for this campaign: once at launch and at most once as a follow-up if there has been a response. There is no automated decision-making and no profiling.

Recipients: Zoho Corporation GmbH (Düsseldorf) provides the email service through which we send the emails and store the outbox and the contact group in the press@miaosense.app mailbox. Your replies reach us via Cloudflare, Inc. (USA, forwarding, processor) and arrive in a mailbox at Google (Gmail), where Google Ireland Limited processes them under its own responsibility, as described in the section “Email Contact”. We keep our mailing lists and working lists at GitHub, Inc. (USA), and we draft replies to editorial teams with the AI tool Claude from Anthropic Ireland, Limited (Ireland).

Third country: Zoho stores the data in a data centre in the EU; with regard to Zoho India, GitHub, Anthropic and Cloudflare, what is stated in the section “Email Contact” applies, including the standard contractual clauses.

Storage period: We store this data while the campaign is running and afterwards for as long as we have to expect follow-up questions or complaints; after that, we delete it. If you object, we maintain your address and the time of your objection on a suppression list without time limit so that we do not write to you again (Art. 6(1)(f) GDPR).

Your other rights: access (Art. 15), rectification (Art. 16), erasure (Art. 17) and restriction of processing (Art. 18 GDPR) and, where the conditions are met, data portability (Art. 20 GDPR). You can lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement (Art. 77(1) GDPR); the authority competent for us is the BayLDA, Promenade 18, 91522 Ansbach.

Google Play: distribution, statistics and reviews

MiaoSense is distributed via Google Play. Google itself is responsible for the store, your Google account and the processing of purchases; Google’s privacy notice applies to this. How we verify a purchase of MiaoSense Pro is described in the section “Purchase of MiaoSense Pro”.

Via the Google Play Console, Google provides us with statistics on installs, purchases, revenue, ratings and the performance of the store listing, mostly aggregated by country, language and device. For individual sales, Google reports the order number, time, product, price, tax and total amount, device model, and the buyer’s country, region, city and postcode to us.

We read public reviews that contain text once a day via the Google Play interface in order to reply to them. In doing so, we receive the text, the star rating, the time and the display name under which you published the review, and store them in a working list. We draft some replies with the AI tool Claude.

Purpose: distribution of the App, evaluation of reach and revenue, improvement of the App and the store listing, replying to public reviews.

Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in distribution, evaluation and replying to feedback.

Recipients: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) operates Google Play in the European Economic Area. For purchases and the Play Console, Google is a controller in its own right under the data protection terms between controllers in the Developer Distribution Agreement. Google publishes our replies to reviews on Google Play. The working list with the reviews is kept at GitHub, Inc. (USA); draft replies are produced by Anthropic Ireland, Limited (Ireland) with Claude.

Third country: Google may process data in the USA. Google LLC is certified under the EU–US Data Privacy Framework (Art. 45 GDPR); in the alternative, the standard contractual clauses that Google refers to in the Developer Distribution Agreement apply (Art. 46(2)(c) GDPR). With regard to GitHub and Anthropic, what is stated in the section “Email Contact” applies.

Storage period: We keep weekly reports with statistics for as long as we need them to compare developments over time, and delete them afterwards; we keep sales data that we must retain as accounting records for tax purposes for eight years (§ 147 (1) no. 4 and (3) AO). We remove the display name from the working list as soon as the review has been answered and we no longer need it for follow-up questions. The review itself remains on Google Play until you delete it there.

Social media: Instagram, TikTok, Pinterest, YouTube and Buffer

We operate public accounts for MiaoSense on Instagram (@miaosense.app), TikTok (@miaosense), Pinterest (miaosenseapp) and YouTube (MiaoSense’s language channels and MiaoSense Shorts on the Purrception channel). When you visit these accounts, follow them, or view, comment on or share posts, the respective operator first processes your data under its own terms. We see your public profile name when you comment or follow us, and aggregated statistics for each post: views, watch time, shares, number of comments and saves. We cannot identify individual persons from these statistics.

Joint controllership: For the statistics that Instagram and TikTok provide to us about visits to and interactions with our account, we assume joint controllership with the respective operator (Art. 26 GDPR; CJEU, judgment of 5 June 2018, C-210/16, delivered under the former Directive 95/46/EC). Who fulfils which obligations is arranged differently by Meta and TikTok (see below). Irrespective of this, you can exercise your rights in these cases against each of us (Art. 26(3) GDPR). If you contact us, we will forward your request to the operator without delay.

Instagram: The operator is Meta Platforms Ireland Limited, Serpentine Avenue, Block J, Dublin 4, Ireland. For the statistics (Insights) on our account, we assume joint controllership with Meta. For this purpose, Meta has published the “Page Insights Controller Addendum” (www.facebook.com/legal/terms/page_controller_addendum (opens in a new tab)) for Facebook Pages and describes the essence of the arrangement at www.facebook.com/legal/terms/information_about_page_insights_data (opens in a new tab). Neither text mentions Instagram expressly, and we have not made any different arrangement with Meta. Insofar as Meta applies these terms to Instagram accounts, Meta assumes the obligations under Art. 12, 13 and 15 to 21 GDPR for the Insights data.

TikTok: The operator is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. The “TikTok Analytics Joint Controller Addendum” (www.tiktok.com/legal/page/global/tiktok-analytics-joint-controller-addendum/en (opens in a new tab)) applies to TikTok Analytics. TikTok answers requests concerning the data in TikTok Analytics and makes the essence of the arrangement available on the page “Information about TikTok Analytics” (www.tiktok.com/legal/information-about-tiktok-analytics (opens in a new tab)).

Pinterest: The operator is Pinterest Europe Ltd., Waterloo Exchange, 3rd Floor, Waterloo Road, Dublin 4, Ireland. Pinterest processes the data from visits to our profile under its own responsibility; we only see aggregated statistics.

YouTube: The operator is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google processes the data from visits to our channels under its own responsibility; we only see aggregated statistics, which we retrieve via the YouTube Analytics interface.

Purpose: public relations and advertising for MiaoSense, planning our posts, evaluating their reach.

Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in public relations and in evaluating our posts. Processing by the operators is governed by their own legal bases; where an operator has asked you for consent, that basis is Art. 6(1)(a) GDPR.

Recipients: the operators named above. For Instagram and TikTok, we use Buffer (Buffer Inc., 2443 Fillmore Street #380-7163, San Francisco, CA 94115, USA) to schedule and publish posts and to retrieve aggregated statistics. Buffer receives our posts and the figures for each post, but no comments and no direct messages. We publish Pinterest posts manually; we retrieve the YouTube statistics directly from Google.

Third country: The operators also process data in the USA and in other countries; details are set out in their privacy notices. Buffer is certified under the EU–US Data Privacy Framework (Art. 45 GDPR).

Storage period: We keep our weekly reports with aggregated statistics for as long as we need them to plan our posts, and delete them afterwards. The operators determine for themselves how long they store data.

Commercial use — who is the controller then?

If you use MiaoSense in a veterinary practice, a cattery, a cat café, an animal shelter or any other commercial or professional activity, the architecture does not change: analysis runs on your device, and we do not get to see the footage. What does change is who answers for the data you create there.

If you observe cats whose owner you are not yourself, and you enter personal data into the App along the way — names or contact details in cat profiles or notes, for example — you are the controller within the meaning of Art. 4(7) GDPR for that data, not us. Because Purrception never gains access to this data, there is no processing by us within the meaning of Art. 4(2) GDPR in the first place — and without processing we are not a processor (Art. 4(8) GDPR) but the maker of software that runs on your device. A data processing agreement under Art. 28 GDPR is therefore not required for using MiaoSense. We could not honour one either — the data does not reach us. The exception is the purchase check (purchase token and product ID, see “Purchase of MiaoSense Pro”): we are responsible for it ourselves, and it contains no data about your clients.

Nor does this create joint controllership under Art. 26 GDPR. We do decide which fields the App offers, but we take no part in the processing itself: you create, use and delete the profiles entirely on your own, with nothing contributed from our side. That processing is separable from us and would run identically without us — unlike cases where an embedded function itself transmits data to a third party.

Your own obligations towards your clients and patients are unaffected and rest with you alone. That includes in particular the information duties under Art. 13 GDPR and the question of what legal basis you rely on for your own processing.

If your organisation uses MiaoWatch, the section MiaoWatch — Remote Camera above applies in addition: there the video image leaves the recording device and travels across your network to the device that processes it.

This matches Section 9a.4 of the Terms of Service, which also sets out the limits of commercial use — in particular that MiaoSense remains observational in a professional setting too, and provides no diagnosis, no early detection and no triage.

This assessment applies to using MiaoSense as described on this page. If you change anything about your processing — your own backups, syncing App data across several devices, or a management system with remote access — assess your responsibility for that part separately. We cannot speak to it.

Legal basis: none of our own — this section describes processing for which you are responsible, not us.

Your Rights (GDPR Art. 15–22)

You have the right of access (Art. 15), to rectification (Art. 16), to erasure (Art. 17), to restriction of processing (Art. 18) and to object (Art. 21 GDPR) and, where the processing is based on consent or a contract, the right to data portability (Art. 20 GDPR). To exercise these rights, contact hello@miaosense.app.

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement (Art. 77(1) GDPR). The authority competent for us is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach.

Controller (Art. 4(7) GDPR)

Robert Sommer
Isoldenstraße 26, 80804 München, Germany
hello@miaosense.app