Rūpestėlis Holding · Legal

Privacy Policy + Terms of Engagement

Interim privacy commitments

Until the formal Privacy Policy is published, Rūpestėlis Holding UAB commits to the following:

• EU GDPR Article 9 compliance — biometric pet data (nose-print images, derived templates) treated as special-category data with explicit consent on every capture screen.
• EU-resident storage only — all member data stored on EU territory (DigitalOcean Frankfurt servers). No transfer outside EEA without explicit member consent.
• AES-256 encryption per pet record — owner-controlled keys; Rūpestėlis Holding cannot decrypt without key cooperation.
• Right to erasure — members can request deletion of personal data at any time via tomas@rupestelis.com. Sigillum chain entries remain historically (audit chain integrity), but personal identifiers are scrubbed.
• No third-party sharing for commercial purposes — member data is shared only with: (a) other Voluntary Club members in good standing, (b) parties with legitimate interest in pet identification (rescue services, courts, vet clinics involved in care), (c) Allied Members for research/advocacy with appropriate anonymization.
• DPO designation — Dr. Tomas Margelis Sr., reachable at tomas@rupestelis.com.

Interim terms of engagement

Engagement with Rūpestėlis Holding services is subject to the following interim terms:

• Voluntary participation — Voluntary Club membership is voluntary at all times. Members can resign with no penalty.
• No commercial subordination — Voluntary Club mission cannot be subordinated to Rūpestėlis Holding commercial interests (per Charter Article X anti-capture provisions).
• AI-generated content disclosure — institutional documents are drafted with AI assistance (Claude, GPT, Grok, Gemini, DeepSeek) under Tomas Margelis Sr. supervision. Authorial responsibility remains human.
• No veterinary or legal advice — Dr. Rupi (AI ambassador) and other AI tools provide informational outputs, not licensed advice. Consult licensed veterinarians for medical decisions and licensed attorneys for legal questions.
• Disputes — Lithuanian jurisdiction — disputes resolved under Lithuanian law in Vilnius courts, unless parties agree otherwise.

Founding-period transparency

Per the post-face institution principle (founding-period precedent 2026-05-07, see Sapere Aude Archive), Rūpestėlis Holding operates with deliberate transparency about its own decisions, including reversals. Privacy and terms documents, when finalized, will:

• Be Sigillum-signed and added to the audit chain
• Reference the interim commitments above as the period they superseded
• Be available in both English (this document) and Lithuanian (/lt/legal/)
• Be revisable per Charter Article IX amendment procedure

Contact

For privacy questions, data requests, terms clarification, or anything not covered above:

Email: tomas@rupestelis.com
Postal: UAB Rūpestėlis Holding, J. Savickio g. 4, LT-01108 Vilnius, Lithuania
Company code: 307514683