OLMORA Privacy Policy
1. Who we are and who is responsible
OLMORA is a start-up project in formation, based in Zurich, Switzerland. No company has been registered yet. Until OLMORA is incorporated, the founders listed below are jointly responsible ("controller") for the processing of your personal data described in this policy. In this policy, "OLMORA", "we" and "us" mean these founders acting together for the OLMORA project.
- Anastasiia Pankratova
- Yauheniya Goncherenok
For any question about your data, or to exercise your rights, write to info@myolmora.com. We reply within 30 days.
This policy covers our website and the waitlist. Before launch, we will run a pilot programme with selected people from the waitlist, including an at-home microbiome test for their dog. Data collected in the pilot is covered by a separate Pilot Privacy Notice, which you will receive with your invitation and must read before taking part. The full OLMORA app and paid membership are not publicly available yet. They will come with their own privacy notice before launch.
We process personal data in line with the Swiss Federal Act on Data Protection (FADP). Where the EU General Data Protection Regulation (GDPR), the UK GDPR or US state privacy laws apply to you, we also comply with them.
2. What data we collect
We collect only what you give us through the waitlist form or by email, plus basic technical data needed to run the website.
| Data | Source | Required? |
|---|---|---|
| First name | Waitlist form | Yes |
| Email address | Waitlist form | Yes |
| Your dog's name | Waitlist form | Yes |
| Country / where you are based | Waitlist form | Yes |
| Your consent choices (privacy and updates), with date and time | Waitlist form | Recorded automatically |
| Messages you send us and their content | Only if you write to us | |
| IP address, browser type, device, pages visited, date and time of access | Server logs of our hosting provider | Recorded automatically |
If you accept cookies, we also collect usage data about your visit, such as pages viewed and how you reached the site (see section 7).
We do not collect payment details or information about your dog's health through the website, and we do not ask for sensitive personal data about you.
3. Why we use your data
We use your data only for the purposes below. The legal basis applies where the GDPR or UK GDPR covers you.
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Keep your place on the waitlist and email you when early access opens, with instructions to get started | First name, email, dog's name, country | Your request to join; steps before a possible contract (Art. 6(1)(b)) |
| Send news and updates about OLMORA, only if you ticked the updates box | First name, email | Your consent (Art. 6(1)(a)) |
| Plan the launch, e.g. which countries to open first, and show aggregate figures such as the number of dogs on the waitlist | Country, number of sign-ups (aggregated) | Our legitimate interest in preparing the launch (Art. 6(1)(f)) |
| Answer your questions | Email and message content | Your request; our legitimate interest (Art. 6(1)(b), (f)) |
| Keep the website secure and working, prevent abuse | Technical data | Our legitimate interest (Art. 6(1)(f)) |
| Keep proof of your consent and meet legal duties | Consent records | Legal obligation; our legitimate interest (Art. 6(1)(c), (f)) |
You can withdraw your consent to updates at any time, using the unsubscribe link in each email or by writing to us. This does not affect your place on the waitlist.
We do not sell your data, we do not use waitlist data to train AI models, and we make no automated decisions about you.
4. Who we share data with
We share your data only with service providers who help us run the website and the waitlist. They process it on our behalf and under our instructions.
| Provider | Role | Location |
|---|---|---|
| Cloudflare, Inc. | Hosts the website, delivers it securely and protects it from attacks; keeps server logs, e.g. IP addresses | United States, with servers worldwide |
| Google (Google Workspace) | Stores waitlist sign-ups, sends our early-access and update emails, and receives messages you send us | EU and United States |
| Google (Google Analytics) | Measures website use, only if you accept analytics cookies | EU and United States |
| Usercentrics A/S (Cookiebot) | Runs our cookie banner and stores your consent choice | Denmark (EU) |
We may also disclose data if the law or an authority requires it, or to protect our rights.
Some providers may store data outside Switzerland, for example in the EU/EEA or the United States. Switzerland recognises the EU/EEA and the United Kingdom as providing adequate protection. For other countries, we rely on the Swiss-US and EU-US Data Privacy Framework, under which Cloudflare and Google are certified, or on the European Commission's standard contractual clauses as recognised by Switzerland. You can ask us for a copy of these safeguards.
5. How long we keep your data
We keep waitlist data until you leave the waitlist, or at the latest 12 months after early access opens if you do not create an account. Consent records are kept as long as we use your data and for the period needed to prove consent afterwards. Server logs are kept for up to [30] days by our hosting provider. Emails are kept as long as needed to deal with your request.
6. Your rights
You can ask us at any time to:
- tell you what data we hold about you and give you a copy;
- correct data that is wrong or incomplete;
- delete your data and remove you from the waitlist;
- stop sending you updates, or withdraw any consent you gave;
- object to processing based on our legitimate interests;
- give you your data in a common electronic format.
Write to info@myolmora.com. We may ask you to confirm your identity. You can also complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch), or, if you live in the EU/EEA or UK, to your local data protection authority.
If you live in the United States
If you live in California or another US state with a consumer privacy law, such as the California Consumer Privacy Act (CCPA, as amended by the CPRA), we give you the same rights described above, whether or not those laws formally apply to us. This includes the right to know what personal information we collect and why, to access, correct and delete it, and to opt out of its sale or sharing.
- Categories we collect: identifiers (first name and email), internet activity (website usage, only with your consent), approximate location (country) and your dog's name, as listed in section 2. We collect it from you and from your use of the website.
- No sale or sharing: we do not sell your personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the past 12 months.
- No sensitive personal information: we do not collect sensitive personal information about you as defined by US state laws.
- Global Privacy Control: our cookie banner recognises Global Privacy Control (GPC) signals from your browser. Because we do not sell or share personal information, no further opt-out is needed.
- Equal treatment: we will not treat you differently for exercising your rights.
- Authorised agents and appeals: you can use an authorised agent to make a request; we may ask for proof of authorisation. If we decline your request, you can appeal by replying to our decision at info@myolmora.com.
- Children: our services are for adults. We do not knowingly collect personal information from children under 13, as required by the Children's Online Privacy Protection Act (COPPA), or from anyone under 18.
- Emails: our update emails follow the US CAN-SPAM Act. Each includes a way to unsubscribe, and we honour opt-outs promptly.
To make a request, write to info@myolmora.com. We respond within 45 days.
7. Cookies and analytics
Our website uses strictly necessary cookies to work securely and analytics cookies (Google Analytics) to understand how visitors use it. Analytics cookies are set only with your consent (Art. 6(1)(a) GDPR), which you give or refuse through our Cookiebot banner. You can change your choice at any time through the privacy settings icon on the website. We do not show ads or use advertising cookies. Full details, including the list of cookies and how long they are kept, are in our Cookie Policy.
8. Security
We protect your data with reasonable technical and organisational measures, such as access limited to the founders, strong passwords and two-factor authentication, and encrypted connections (HTTPS). No system is completely secure, but we will inform you and the authorities of any data breach as the law requires.
9. Age
The waitlist is for adults. You must be at least 18 years old to sign up.
10. When OLMORA becomes a company
We plan to register OLMORA as a company. When this happens, the new company will take over the waitlist and become the controller of your data, with the same purposes and protections described here. We will update this policy with the company's name and address and let you know by email. You can leave the waitlist at any time.
11. Changes to this policy
We may update this policy, for example when the app launches or when OLMORA is incorporated. The latest version is always on this page, with its date at the top. We will inform you of significant changes by email.