Privacy Policy

Last updated: 9 December 2025

1. Who We Are

Paw Diagnostics Sàrl (“Paw Diagnostics”, “we”, “our”, “us”) is a company registered in Luxembourg and acts as the data controller for personal data processed in connection with its services and activities.

Company details:
Paw Diagnostics Sàrl
Luxembourg
Email: info@paw-diagnostics.com

2. Scope of This Privacy Policy

This Privacy Policy explains how we process data in relation to:

  • Diagnostic laboratory services

  • Research & development (R&D) activities

  • Disease tracking application

  • Email newsletters and mailing lists

  • Marketing and professional sign-ups, including via social media platforms such as LinkedIn

  • Business communications and administrative processes

  • Our website, platforms, and applications

3. Distinct Data Processing Contexts

Paw Diagnostics operates under three clearly separated data-processing contexts:

  1. Diagnostic Laboratory Services – involve identifiable personal data

  2. Research & Development (R&D) – use strictly anonymized data

  3. Disease Tracking Application – uses anonymized and aggregated data

Each context follows different data-handling rules, described below.

4. Diagnostic Laboratory Services – Personal Data Processing

4.1 Categories of Personal Data

When providing diagnostic laboratory services, we may process:

a) Veterinary Professionals & Clinics

  • Name, title, clinic name, and address

  • Email address and phone number

  • Professional role and identifiers

  • Communication records

b) Pet Owners

  • Name and contact details (email, phone), where provided by the veterinarian

  • Association with a specific animal or sample

c) Sample & Diagnostic Data

  • Sample identifiers and tracking information

  • Animal information (species, breed, age, sex, reference number)

  • Laboratory test results and technical measurements

Samples may be temporarily linked to pet owners only for the purpose of delivering laboratory results via the responsible veterinarian.

4.2 Purposes & Legal Bases

Personal data in the context of diagnostic services is processed for:

  • Performance of diagnostic laboratory services

  • Communication of laboratory test results

  • Compliance with legal and regulatory obligations

  • Billing, accounting, and administrative processes

Legal bases under GDPR include performance of a contract, legal obligations, and legitimate interests.

4.3 Communication of Results

  • Laboratory results may be communicated to the veterinarian and, where applicable, simultaneously to the pet owner, based on the veterinarian’s instructions.

  • Paw Diagnostics provides raw laboratory results only (e.g. positive/negative outcomes, Ct values, technical notes).

  • No medical or diagnostic interpretation is provided.

  • The veterinarian remains the responsible medical authority.

5. Research & Development (R&D) Activities – Anonymized Data

5.1 Voluntary Participation

Participation in R&D activities is strictly voluntary.
Diagnostic services are not conditional on participation in R&D.

5.2 Nature of R&D Data

For research and development purposes:

  • All samples and datasets are strictly anonymized

  • No direct or indirect identifiers are retained

  • Data cannot be traced back to veterinarians, clinics, pet owners, or individual animals

Once anonymized, R&D data no longer constitutes personal data under GDPR.

5.3 Purpose of R&D Processing

Anonymized R&D data may be used for:

  • Diagnostic method development and validation

  • Quality improvement and performance monitoring

  • Scientific research and innovation

5.4 Separation of Systems

Technical and organizational safeguards ensure:

  • Full separation between diagnostic data and R&D datasets

  • Re-identification is not reasonably or technically possible

6. Disease Tracking Application – Anonymized & Aggregated Data

6.1 Voluntary Participation

Use of the disease tracking application is strictly voluntary and independent of diagnostic laboratory services.

6.2 Nature of Disease Tracking Data

The disease tracking application processes only anonymized and aggregated data, including:

  • Disease or pathogen type

  • Geographic indicators at a non-identifying level, such as city-level or partial postal-code–level data, where appropriate

  • Quantitative trends (e.g. case counts, frequency over time)

The application does not process:

  • Names of veterinarians, clinics, or pet owners

  • Animal identifiers, sample IDs, or reference numbers

  • Exact addresses or precise locations

  • Any data that could reasonably enable identification of a contributing party

6.3 Aggregation Safeguards

To prevent re-identification:

  • Data is only stored, analyzed, and displayed when minimum aggregation thresholds are met

  • Low-count data is further aggregated or suppressed

  • Geographic and temporal resolution is adjusted where necessary

As a result, disease tracking data cannot be traced back to any individual veterinarian, clinic, pet owner, or animal.

7. Email Newsletters & Marketing Communications

7.1 Data Collected

When you subscribe to our newsletter or sign up via platforms such as LinkedIn, we may collect:

  • Name

  • Email address

  • Professional affiliation or role (if provided)

  • Communication preferences

7.2 Purpose & Legal Basis

We send newsletters and marketing communications to:

  • Share company updates, research developments, and relevant industry information

Processing is based on:

  • Explicit consent, or

  • Legitimate interest, where permitted under GDPR (e.g. professional communications)

7.3 Third-Party Platforms

We may use third-party service providers (e.g. email distribution platforms or LinkedIn lead forms). These providers act as data processors and are contractually bound to GDPR-compliant data protection obligations.

7.4 Opt-Out

You may unsubscribe at any time using the link included in our emails or by contacting us directly.
Unsubscribing does not affect diagnostic services or contractual relationships.

8. Data Retention

  • Diagnostic laboratory data is retained only as long as required under contractual, legal, and quality obligations.

  • Anonymized R&D and disease tracking data may be retained long-term, as it cannot be linked to identifiable persons or entities.

  • Newsletter and marketing data is retained until consent is withdrawn or no longer required.

9. Data Sharing & Third Parties

We may share data with:

  • Secure IT hosting and infrastructure providers

  • Technical service providers supporting laboratory operations

  • Accounting, legal, or regulatory authorities where required by law

All partners are bound by confidentiality and data-protection agreements.
Paw Diagnostics does not sell personal data.

10. International Data Transfers

Where data is transferred outside the European Economic Area (EEA), appropriate safeguards—such as EU Standard Contractual Clauses—are applied.

11. Data Security

We implement appropriate technical and organizational measures, including:

  • Role-based access controls

  • Segmented and secure systems

  • Data minimization and anonymization protocols

  • Regular security and access reviews

12. Data Subject Rights

For personal data processed as part of diagnostic services or marketing communications, individuals have rights under GDPR, including:

  • Access and rectification

  • Deletion (where legally permissible)

  • Restriction or objection to processing

  • Data portability (where applicable)

These rights do not apply to fully anonymized R&D or disease tracking data.

Requests may be submitted to: info@paw-diagnostics.com

13. Complaints

You have the right to lodge a complaint with the Luxembourg National Data Protection Authority (CNPD) if you believe your personal data has been processed unlawfully.

14. Changes to This Policy

This Privacy Policy may be updated periodically. The latest version will always be available on our website with the updated revision date.

Standard T&C

Last updated: 9 October 2025

Scope: These Terms and Conditions govern all sales of diagnostic services and related products offered through our webshop. By placing an order, you accept these Terms and Conditions in full.

  1. Customers: We sell to:

  2. Veterinarians ordering directly on behalf of their clients.

    1. Veterinarians who refer clients to order directly from us.

    2. Direct customers (pet owners) who may order as guests or with an account.

  3. Orders

  4. Each order must be placed per individual pet to ensure accurate identification and reporting.

    1. Orders are binding upon confirmation in the webshop.

    2. The customer is responsible for providing correct and complete information during the ordering process.

  5. Samples

  6. For each diagnostic service, only specific sample types are accepted. The appropriate sample type must be selected during the ordering process.

    1. All samples must be collected in a sterile container.

    2. Samples must be stored under cooling conditions (2–8 °C) and may not remain outside cooling for more than 24 hours before submission.

    3. It is the responsibility of the customer or the referring veterinarian to ensure correct sample collection, packaging, and timely delivery.

    4. Samples may be submitted by:

      1. Home pick-up service (where available),

      2. Drop-off at our Esch location, or

      3. Pick-up from the referring veterinarian, if agreed.

    5. Improperly collected, contaminated, or insufficient samples may lead to test rejection or invalid results.

  7. Sample Collection Confirmation: By submitting a sample, you confirm that:

  8. Any sample requiring professional collection (including but not limited to blood, biopsies, or internal swabs) has been taken by a licensed veterinarian or other qualified professional.

    1. You will not attempt to collect such invasive samples yourself.

    2. Only non-invasive samples (such as stool, urine, saliva, or shed hair/fur) may be collected by the owner at home.

    3. Paw Diagnostics reserves the right to reject or invalidate test results if there is evidence that a sample was improperly collected.

  9. Prices and Payment

  10. All prices displayed in the webshop include VAT.

    1. Payment is due no later than 10 days after the invoice date, unless otherwise agreed in writing.

    2. To simplify payment, online payment options are also available at checkout.

    3. Veterinarians with accounts may access dedicated price lists.

    4. If a payment is outstanding for more than sixty (60) days after the due date, Paw Diagnostics reserves the right to engage the services of a debt recovery company. All legal and recovery expenses shall be borne by the client.

    5. Certain countries apply withholding at source on invoice amounts in accordance with local legislation. Any such withholding must be paid by the client directly to their tax authorities. Under no circumstances can Paw Diagnostics be held responsible for costs arising from foreign tax legislation. The full invoice amount remains payable to Paw Diagnostics without deduction.

  11. Delivery of Results

  12. Our standard turnaround time is 24 hours, measured from the receipt of properly collected and delivered samples.

    1. This timeframe is indicative only and not guaranteed.

    2. Delays may occur due to sample quality issues, logistics, or unforeseen technical circumstances.

  13. Liability

  14. We accept no liability for incorrect or misleading results due to inadequate sample quality, improper storage, or incomplete information.

    1. Our liability for any claim is limited to the value of the service ordered.

    2. We are not liable for consequential damages, including but not limited to loss of profit or indirect costs.

    3. In order for any claim to be admissible, Paw Diagnostics must be notified by means of a letter sent by recorded delivery to its registered office within 8 days of the delivery of the goods or the provision of the services.

  15. Cancellation and Refunds

  16. Orders may only be cancelled prior to sample submission.

    1. Once samples are received, the service is considered provided and non-refundable.

    2. Refunds will be processed to the original payment method.

  17. Research and Development Use of Samples

  18. Customers may be invited to consent to the use of their pet’s samples for research and development purposes carried out by Paw Diagnostics.

    1. Such consent is entirely voluntary and will not affect the diagnostic services ordered.

    2. Samples used for R&D are anonymized and handled in accordance with applicable data protection and ethical standards.

    3. No rights, ownership, or compensation of any kind shall arise for the customer or pet owner from the use of samples for R&D purposes.

  19. Use of Anonymized Data for Disease Monitoring and Commercial Tools

  20. Anonymized and aggregated information derived from diagnostic tests and related data may be used for secondary purposes, including but not limited to epidemiological research, tracking of disease spread in animal populations, and the development of commercial tools (such as applications, dashboards, or services that provide insights into animal health).

    1. All such data are irreversibly anonymized and cannot be linked back to you or your pet.

    2. No personally identifying information (such as your name, contact details, or your pet’s name) will ever be included.

    3. Results and insights may be published in aggregate form, shared with veterinary researchers, or integrated into commercial offerings, but never in a way that could identify you or your pet.

  21. Data Protection

  22. Personal data will be processed in accordance with our Privacy Policy.

    1. By placing an order, you consent to the processing of data necessary for providing the diagnostic service.

  23. Governing Law and Jurisdiction: These Terms and Conditions are governed by the laws of Luxembourg. Any disputes shall be subject to the exclusive jurisdiction of the courts of Luxembourg.