Privacy Policy

Cowchow is operated by Cowchow Labs Ltd. ("Cowchow", "we", "us"), a company registered in Ireland.

• Registered address: Ballycleary, Kilmore, Wexford, Y35 XW50, Ireland
• Company registration number (CRO): 810807
• Contact for privacy matters: hello@cowchow.io

We are the data controller for the personal data described in this policy.

• Farm owners: people who create a Cowchow account, set up a farm, and pay for its subscription.
• Managers and nutritionists: people invited by email to help run a farm. They create their own login.
• Operators: people invited to log feedings in the mobile app. They join with a code and have no login of their own.
• People who have been invited to a farm but have not joined yet.
• Visitors to our website at cowchow.io.
• Anyone who emails us, whether or not they use Cowchow.

We only collect what we need to run the service. We do not sell your data or run advertising.

When you create an account, we collect:

• Email address
• First name

We don't ask for a password. Each time you sign in, we email you a 6-digit code. If you set a password when you signed up under our earlier sign-up, we keep it only as a salted hash, never in plain text.

For farm owners, we also record the farm's subscription status: trial, active, past due, or cancelled.

Why: to identify you, secure your account, send you operational emails (sign-in codes, password resets, billing receipts), and know whether the farm can use the feeding features.

If you start signing up but never enter the confirmation code we email you, we delete the account and everything you entered after 7 days.

Legal basis (GDPR): performance of a contract (Article 6(1)(b)).

When an owner or manager adds an operator, they enter the operator's name. That is the only personal detail we hold about an operator. We don't ask operators for an email address.

Why: so the farm can see who logged each feeding.

Legal basis: legitimate interest (Article 6(1)(f)), namely the farm's interest in an accurate feeding history.

When an owner or manager invites someone to be a manager or nutritionist, they give us that person's name, email address, and role. If you received an invitation, this is where we got your details: from the person at the farm who invited you. We did not collect them from you directly.

We use these details to email you the invitation and to show it in the farm's list of people. We keep them for the period set out inSection 6. You can ask us to delete them at any time, and you have the rights described in Section 7.

Why: to let farms bring their team into Cowchow.

Legal basis: legitimate interest (Article 6(1)(f)).

Inside the app, you create content: cow groups, ingredients, diets, feeding logs, and similar records. This data is yours; we store it on your behalf.

Why: to provide the service.

Legal basis: performance of a contract.

When an owner, manager, or operator signs in to the mobile app, we issue a random sign-in token. The app keeps it in its private storage on the phone so you stay signed in.

On our servers we keep only a hash of the token, never the token itself. It's deleted when the farm is deleted, or when you sign out, sign in on another phone, delete your account, are removed from the farm, or don't use the app for 12 months.

Why: so you don't have to sign in again every session.

Legal basis: performance of a contract (authentication); legitimate interest (maintaining persistent sessions for usability and security).

Subscription payments are processed by Stripe Payments Europe, Ltd. (Dublin, Ireland). Stripe collects card numbers, billing addresses, and payment metadata directly. We never see or store your full card details.

We store the Stripe customer ID and subscription status that Stripe returns to us, so we know the state of your subscription.

Why: to bill you correctly and provide the service you've paid for.

Legal basis: performance of a contract; compliance with legal obligations (tax, accounting).

When you delete your account, we remove your saved payment cards from Stripe. Stripe keeps your customer record, subscription history, invoices and payments so we can meet our tax and accounting obligations (see Section 6). As an independent controller, Stripe may also keep payment data for its own legal obligations under its own privacy policy.

Each person gets one free trial. Once you start a subscription, trial or paid, we record a one-way hash (SHA-256) of your email address, and we keep it when you delete your account. We can't read your address from the hash, but we can tell if the same address signs up again, so that deleting your account and signing up again doesn't give you a second trial.

Legal basis for the hash: legitimate interest (Article 6(1)(f)), namely preventing the same person from claiming the free trial more than once.

When you or your team use the service, our servers record your IP address, browser or app version, the pages you visit and when, and any errors. They send this to PostHog, with your user ID when you're signed in and with payment session identifiers removed. Errors in the dashboard or the app itself are also reported, unless you chose No thanks (see Section 3.8).

Why: security, fraud prevention, debugging, service improvement.

Legal basis: legitimate interest (Article 6(1)(f)). You have the right to object to this processing at any time (see Section 7).

Legal basis: legitimate interest (Article 6(1)(f)): Cowchow serves few enough farms that we need to see where each one gets stuck to improve it. You have the right to object at any time: email us (see Section 7) and we'll stop sending these records for you.

The first time you sign in to the dashboard or the mobile app, we also ask whether PostHog may keep an analytics cookie on your device and record your screen.

If you choose Allow, PostHog stores an identifier on your device (a cookie and a local storage entry in the dashboard, and app storage in the mobile app). It links what you do in the dashboard or the app to your user ID and email address. It may also record your sessions: what appears on screen, including farm, group and feeding records, and how you move through the app. Anything you type into a form is hidden on your device before a recording is sent. Recordings are kept for 30 days.

Until you answer, and whenever you're signed out, we count visits the same way as on our website: nothing is stored on your device and nothing is linked to you.

If you choose No thanks, PostHog doesn't run in your browser or the app at all. Our servers still send the records described above, because they store nothing on your device.

You can change your answer at any time: in the dashboard, open the account menu and choose "Account settings"; in the app, go to Account, then Privacy.

Legal basis for the cookie and screen recording:consent (Article 6(1)(a)). You can withdraw it at any time (see Section 7).

We also use PostHog on our website at cowchow.io to count visits. It records the pages you view, the links and buttons you click, the site that referred you, and your browser, device type, and approximate location (country and city, worked out from your IP address). It does not set cookies or store anything in your browser. To tell one visit from another, PostHog combines your IP address and browser details with a value that changes every day, and keeps only the result, so we can't recognise you on a later day. We don't record your session on the website.

Why: to see which features are used and where people get stuck, so we can improve Cowchow.

Legal basis for the website: legitimate interest (Article 6(1)(f)), because nothing is stored on your device. You have the right to object at any time (see Section 7).

If you email us, for example at hello@cowchow.io, we keep your email address, your name if you include it, what you write, and our replies. Our email is hosted by Google Workspace.

Why: to answer you and to act on what you ask, such as a request to delete your data.

Legal basis: legitimate interest (Article 6(1)(f)), namely answering people who write to us. When you write to exercise your rights under the GDPR (see Section 7), compliance with a legal obligation (Article 6(1)(c)).

The dashboard at dashboard.cowchow.io uses:

• A session cookie that keeps you logged in
• A CSRF token cookie that protects form submissions
• Only if you allow the analytics cookie and screen recording (seeSection 3.8): a PostHog cookie and local storage entry holding an identifier for your browser

The mobile app stores:

• A sign-in token that keeps you signed in (see Section 3.5)
• Only if you allow the analytics cookie and screen recording: a PostHog identifier (see Section 3.8)

When you subscribe, we redirect you to Stripe's hosted checkout and customer portal pages. Stripe sets its own cookies on its own domains during that flow. Those are governed by Stripe's Privacy Policy, not this one.

Our website at cowchow.io does not set cookies. We do not use advertising cookies or advertising trackers anywhere.

We use a small number of trusted service providers ("sub-processors") to operate the service. They process data on our behalf, under contract, and only for the purposes we instruct.

We have a data processing agreement with each of them, as the GDPR requires.

Some companies involved in providing Cowchow are not our sub-processors. They decide for themselves how to use the data they receive, under their own privacy policies:

• Stripe Payments Europe, Ltd. acts as an independent controller for the payment data it collects to process payments, prevent fraud, and meet its own legal obligations. See Stripe's Privacy Policy.
• Apple Inc. (App Store) and Google LLC (Google Play) distribute the mobile app. When you download it, your relationship with them is governed by their own terms and privacy policies.

We do not share your personal data with anyone else unless we are legally required to (e.g. by court order, subpoena, or to comply with tax law).

We store most of your data in the EU. However, several of our providers (Render, PostHog, and Google) are US companies. Even where our data is hosted in the EU, staff at the US parent company may be able to access it, for example to provide support or keep their systems running. Our website is also served through Render's global content delivery network, so visitors may be served from outside the EU.

These transfers are covered by the EU-US Data Privacy Framework where the provider is certified under it, and otherwise by the European Commission's Standard Contractual Clauses (SCCs).

You can request copies of the SCCs by emailing hello@cowchow.io.

When you delete your account, we permanently remove your personal data from our active systems within 30 days. Backups are deleted on the rolling cycle above. Some records (invoices, tax data) we are legally required to retain for longer; these are kept securely and not used for any other purpose. If you ever subscribed, we also keep the one-way hash of your email address described in Section 3.6. Emails you've sent us are kept for the period in the table above (see Section 3.9).

Under the GDPR, you have the right to:

• Access the personal data we hold about you
• Rectify inaccurate or incomplete data
• Erase your data ("right to be forgotten"), subject to legal retention obligations
• Restrict how we process your data
• Object to processing based on legitimate interest
• Portability: receive your data in a machine-readable format and transfer it elsewhere
• Withdraw consent at any time (for processing based on consent)
• Lodge a complaint with the Irish supervisory authority, the Data Protection Commission (www.dataprotection.ie)

To exercise any of these rights, email hello@cowchow.io. We'll respond within 30 days.

How to remove your Cowchow data depends on your role. Step by step instructions are on our Delete your account page.

If you are a farm owner, you can delete your whole account from the Account tab in the mobile app, or from the dashboard at dashboard.cowchow.io, under "Account settings" in the account menu. From the dashboard you can also delete your farm alone. Deleting the farm removes it and all its data (cow groups, ingredients, diets, feeding logs and team memberships). Deleting your account removes the farm as well as your login, email and name. Either way, deletion is immediate and irreversible, and the subscription ends the same day with no refund for the time remaining. If you only want to stop paying, cancel your subscription instead and your records stay.

If you are a manager, you can delete your account from the Account tab in the mobile app or from the dashboard. If you are a nutritionist, you can delete it from the dashboard. In the dashboard, it is under "Account settings" in the account menu. Feedings you logged stay in the farm's records, shown as "former member". The farm owner can also remove you from the farm, and a manager can remove a nutritionist.

If you are an operator (you joined a farm using a 6-digit code), the only personal data we hold about you is your name. You can delete your account from the Account tab in the mobile app: your name then comes off the farm's feeding records, which show "former member" instead. When the farm owner or a manager removes you from the farm, your access ends immediately and your phone is signed out, but your name stays on the feeding records, because the feeding history shows who logged each feeding. To have your name erased without the app, email hello@cowchow.io.

If you were invited to a farm and want your details removed, email us and we'll delete the invitation.

Requests made by email are handled within 30 days. Backups follow the rolling cycle in Section 6. Records we are legally required to retain (e.g. invoices for tax purposes) are kept securely under the retention rules in Section 6 and not used for any other purpose.

All traffic is encrypted, backups are encrypted, and only the people who need access to our systems have it. If a breach puts your data at risk, we'll tell the Data Protection Commission within 72 hours of finding out, and tell you where the law requires it.

Cowchow is a tool for farm businesses. It is not directed at children under 16. We do not knowingly collect data from anyone under 16. If you believe a child has provided us with data, contact us and we will delete it.

We may update this policy from time to time and will post the new version here with a new "Last updated" date. If a change materially affects how we use your data, we'll email account holders before it takes effect.

For any privacy-related question, request, or complaint:

If you are not satisfied with our response, you can lodge a complaint with the Data Protection Commission atwww.dataprotection.ie.