Privacy Policy
Last updated: August 27, 2026
Effective date: August 27, 2026
1. Who We Are (Data Controller)
COWnting is a mobile and web application owned and operated by GRUFO 53 SAS, a company organized under the laws of Argentina, based in Córdoba, Argentina ("we", "our", or "us").
For any questions or requests regarding this Privacy Policy or the processing of your personal data, you can contact us at:
- Email: info@grufo53.com
- Data controller: GRUFO 53 SAS, Córdoba, Argentina
This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and the rights you have. It applies to the COWnting mobile app (iOS and Android) and web application.
We process personal data in accordance with applicable law, including:
- Argentina: Ley N° 25.326 de Protección de los Datos Personales and the rules of the Agencia de Acceso a la Información Pública (AAIP)
- European Economic Area / United Kingdom: General Data Protection Regulation (GDPR / UK GDPR), where applicable
- California, USA: California Consumer Privacy Act (CCPA/CPRA) and CalOPPA, where applicable
By creating an account and using the App, you acknowledge that you have read and understood this Privacy Policy.
2. Information We Collect
2.1 Account and Profile Information
When you create an account or are invited to an organization, we collect:
- Full name (required)
- Email address (required)
- Profile photo / avatar (optional)
- Your role within an organization (owner, admin, operator, viewer)
2.2 Operational Data You Provide
When you use the App, you create and store data about your agricultural operation, which may include:
- Organization, field, lot, and herd names and notes
- Geographic boundaries of your lots (polygon coordinates) and field location descriptions
- Livestock inventory and events (purchases, sales, births, deaths, transfers, weighings, treatments, etc.)
- Agricultural activity records (seeding, harvest, spraying, fertilization, irrigation, rainfall, weather notes)
- Supplies, costs, and amounts
- Tasks and assignments
Third-party personal data. Some fields you fill in may contain personal data about other people — for example the name of a veterinarian, a contractor, a freight provider, a broker, or the email address of a person you invite to your organization. You are responsible for ensuring you have a lawful basis to provide this information, and you authorize us to process it solely to deliver the App's functionality.
2.3 Location Data (GPS)
With your permission, the App accesses your device's location. We use and store location data in the following ways:
- Lot boundaries: the polygon coordinates you draw to define your lots are stored in our database, because they are part of your operational records.
- Counts and events: when you record an animal count or certain field events, the App may attach the GPS coordinates of where the record was created, to help you locate and verify activity. These coordinates are stored in our database.
- Map display: your live position is used to center the map and is processed on your device.
You can deny or revoke location permission at any time in your device settings. Core functionality will still work, though map centering and automatic GPS tagging will be unavailable.
2.4 Camera, Photos, and Media
With your permission, the App accesses:
- The camera, to capture photos or videos for livestock counting
- The photo/video library, to let you select existing media for counting
How your media is processed. To perform a count, the image or video file is uploaded to our secure storage and processed by an external cloud computer-vision provider that detects the animals present. The file and the resulting detection data are stored in our database and associated with your organization.
Stored media and detection data are retained as part of your operational records until you or your organization delete them, or until your account is deleted (see Section 8).
2.5 Microphone / Audio
If you record a video, the audio captured by the microphone is embedded in that file. When that video is processed server-side, the audio is part of the uploaded file. Audio embedded in video files is not analysed, transcribed or used separately.
2.6 Conversational AI Assistant ("VaquiAna")
COWnting includes an in-app conversational AI assistant called VaquiAna. When you use it:
- The messages you send, relevant context from your operational data, and the assistant's responses are stored in our database.
- To generate responses, your messages and the necessary context are transmitted to our third-party AI model provider (currently located in the United States), which processes them to produce a reply. This involves an international transfer of data (see Section 5 and Section 11).
- We record aggregate token-usage metrics to enforce plan limits.
Our AI provider processes this data as our subprocessor solely to generate the model response. We do not use your conversations to train AI models, and our AI provider does not use your inputs or outputs to train its models under our commercial terms.
2.7 Push Notification Tokens
If you enable notifications, we store a device push token through a third-party push-notification delivery service (which in turn relays through the operating system's notification services provided by Apple and Google) so we can send you service notifications.
2.8 Technical and Log Data
To operate and secure the service, our infrastructure providers process technical data such as IP address, device/OS type, app version, and timestamps of requests.
2.9 Subscription and billing data
When an organization subscribes to a paid plan, we process data related to that subscription:
- Identifier of the organization and of the person who made the purchase
- Plan purchased, billing period (monthly or annual) and subscription status (trialing, active, cancelled, expired)
- Period start, renewal and expiry dates
- Transaction or subscription identifiers sent to us by the payment channel
- Email address used at checkout and declared country
- Where payment is made through the web channel and an Argentine tax document must be issued: the tax profile details you provide (for example tax ID, legal name, VAT status and registered tax address)
We do not store full card numbers or your payment credentials. Those details are received and processed directly by the relevant payment channel — the app store, the merchant of record for the web channel, or the payment processor — under their own privacy policies and security standards. We only receive confirmation of the charge and the identifiers needed to link the subscription to your organization.
We use this data to activate and maintain your organization's plan, process renewals and cancellations, issue the tax documents required by law, provide billing support, prevent fraud and abuse, and comply with our accounting, tax and legal obligations.
3. How We Use Your Information
We use your data to:
- Create, authenticate, and manage your account
- Provide the App's core functionality (inventory, counts, events, agricultural records, tasks)
- Run animal-counting
- Power the VaquiAna conversational assistant
- Enable collaboration between members of your organization, including invitations
- Send service-related communications (account confirmation, invitations, password resets, security and policy updates, push notifications you enable)
- Provide customer support
- Manage the purchase, renewal and cancellation of paid plans, and issue the corresponding tax documents
- Maintain security, prevent fraud and abuse, and debug issues
- Comply with legal, accounting, and regulatory obligations
We do not use your personal data for third-party advertising or for selling your data.
4. Legal Bases for Processing
Where the GDPR or comparable laws apply, we rely on the following legal bases:
- Performance of a contract — to provide the App and its features to you and your organization
- Consent — for device permissions (location, camera, microphone, photos) and push notifications; you may withdraw consent at any time
- Legitimate interests — to secure the service, prevent abuse, and improve reliability, balanced against your rights
- Legal obligation — to comply with applicable laws
Under Argentina's Ley 25.326, processing is based on your consent and on the contractual relationship necessary to provide the service.
5. Third-Party Services and Subprocessors
We share data only with service providers ("subprocessors") that help us operate the App, under contractual confidentiality and security obligations. We do not sell your data.
We describe our subprocessors by category of service so we can change individual providers without modifying this policy. We currently rely on the following categories of providers:
| Category of provider | Purpose | Data involved | Processing location |
|---|---|---|---|
| Cloud backend & storage provider | Authentication, database, file storage | Account data, operational data, media, GPS, conversations | Configured region |
| AI model provider | Powers the VaquiAna assistant | Assistant messages and relevant context | United States |
| Cloud computer-vision provider | Server-side video animal counting | Uploaded videos and derived detections | United States |
| Push-notification delivery provider | Delivery of service notifications | Device push token | United States |
| Maps & satellite imagery provider | Map tiles and imagery | Map/location requests from your device | Global |
| Email delivery provider | Transactional emails (invitations, resets) | Email address, message content | Configured region |
| App stores | Charging and managing subscriptions purchased on iOS and Android | Purchase and subscription identifiers, subscription status | United States / global |
| Web channel merchant of record | Charging, invoicing and tax handling for web purchases where it acts as the seller | Payment and billing details you provide at checkout | United Kingdom / European Union |
| Web channel payment processor | Processing payment where GRUFO 53 SAS is the seller | Payment data; we receive confirmation of the charge and transaction identifiers | Argentina / provider region |
| Subscription management provider | Normalizing and tracking subscription state across channels | Organization identifier, purchase identifiers and subscription status | United States |
| Electronic invoicing provider (Argentina) | Issuing electronic tax documents where required | Tax profile and document data | Argentina |
In relation to payments, Apple and Google process the payment data of their own accounts as independent controllers, under their own privacy policies. The same applies to the merchant of record for the web channel in relation to the sales where it acts as the seller. We do not access full payment method details in any of those cases.
We may add, remove, or replace specific providers within these categories over time. An up-to-date list of the specific subprocessors we currently use is available on request at *info@grufo53.com (and, where published, at the subprocessor list linked from our website). Each provider processes data under its own privacy terms.
6. App Permissions
COWnting requests the following permissions. All are optional except internet access, and all can be revoked from your device settings at any time.
| Permission | Purpose | Required? |
|---|---|---|
| Location (precise/approximate) | Center map, draw lot polygons, optional GPS tagging of counts/events | Optional |
| Camera | Capture photos/videos for counts | Optional |
| Microphone | Audio embedded in captured videos | Optional |
| Photos / media library | Select images/videos for counts | Optional |
| Notifications | Receive service push notifications | Optional |
| Internet | Sync data with our servers | Required |
7. No Advertising, No Sale of Data
COWnting does not display third-party advertisements.
We do not sell or rent your personal data, and we do not share it for cross-context behavioral advertising.
8. Data Retention and Deletion
We retain your personal data for as long as your account and organization are active, and for as long as needed to provide the service.
After account deletion, we delete or anonymize your personal data, except where we must retain limited records to comply with legal, tax, or accounting obligations, or to resolve disputes. Backups are purged on a rolling basis. Subscription data, tax documents and the associated accounting records are retained for ten (10) years from the date of each document, under article 328 of the Argentine Civil and Commercial Code and applicable tax regulations, even after an account is deleted or an organization is closed. Where the charge was made by an app store or a merchant of record, that third party additionally keeps its own records under its own policies and legal obligations.
How to delete your account and data
You can request deletion of your account and all associated personal data in either of these ways:
- In-app: through the account settings within the App (recommended); or
- By email: send a request to info@grufo53.com from, or indicating, the email address of the account to be deleted.
We will process verified deletion requests within 30 days and confirm once completed. Note that operational data shared within an organization you do not own may be retained by that organization; in that case we will delete your personal identifiers and remove your access.
You may also revoke individual device permissions at any time from your device settings.
9. Your Rights
Subject to your jurisdiction, you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Request deletion ("right to be forgotten")
- Restrict or object to certain processing
- Data portability
- Withdraw consent at any time (without affecting prior lawful processing)
To exercise any of these rights, contact info@grufo53.com. We respond within 30 days. You will not be discriminated against for exercising your rights.
10. Argentina (Ley 25.326)
If you are in Argentina, you may exercise your rights of access, rectification, update, and deletion of your personal data under Ley N° 25.326. The Agencia de Acceso a la Información Pública (AAIP) is the enforcement authority and may receive complaints regarding the handling of your personal data. As required by AAIP guidance, the data owner can exercise the right of access free of charge at intervals not shorter than six months, unless a legitimate interest justifies otherwise.
11. International Data Transfers
Some of our subprocessors (including our AI model provider, computer-vision provider, and notification provider) are located in the United States or other countries. When we transfer your personal data internationally, we rely on appropriate safeguards, such as the providers' contractual data-protection commitments (e.g., Standard Contractual Clauses where applicable) and the adequacy/consent mechanisms permitted under Ley 25.326 and the GDPR.
Payment channels may also involve international transfers: app stores, the web channel merchant of record and subscription management providers operate from the United States, the United Kingdom or other countries. The same safeguards described in this section apply.
12. GDPR (EEA / UK Users)
If you are in the European Economic Area or the United Kingdom:
- We process your data under the legal bases described in Section 4
- You have the rights described in Section 9
- You have the right to lodge a complaint with your local supervisory authority
- We apply safeguards for international transfers (Section 11)
13. CCPA / CPRA (California Users)
California residents may request to know, delete, and correct the personal information we hold, and may opt out of the "sale" or "sharing" of personal information.
We do not sell or share personal information as those terms are defined under the CCPA/CPRA. You will not be discriminated against for exercising your rights.
14. CalOPPA
- This Privacy Policy is publicly accessible at the URL of this page.
- Material changes are posted here with an updated "Last updated" date.
- We honor recognized "Do Not Track" signals where technically feasible.
15. Data Security
We implement appropriate technical and organizational measures, including:
- Encryption in transit (HTTPS/TLS)
- Encryption at rest via our infrastructure provider
- Row-Level Security (RLS) enforcing organization-scoped, role-based access
- Passwords stored as cryptographic hashes (never in plain text)
- Access controls and least-privilege practices for subprocessors
No system is completely secure. Use a strong, unique password and keep your credentials confidential. If we become aware of a personal data breach that poses a risk to you, we will notify affected users and the relevant authorities as required by law.
16. Children's Privacy
COWnting is a professional tool not intended for minors. You must be at least 18 years old to use the App. We do not knowingly collect personal data from minors. If we learn that we have collected data from a minor, we will delete it promptly.
17. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date and, for significant changes, notify users in-app or by email. Continued use of the App after the effective date of an update constitutes acceptance of the updated policy.
18. Contact
For any privacy-related question or request:
GRUFO 53 SAS — Córdoba, Argentina 📧 info@grufo53.com
We respond to privacy-related inquiries within 30 days.