Privacy

What Is Personal Data at UpWoof?

At UpWoof, we believe strongly in fundamental privacy rights — and that those fundamental rights should not differ depending on where you live in the world. That’s why we treat any data that relates to an identified or identifiable individual or that is linked or linkable to them by UpWoof as “personal data,” no matter where the individual lives. This means that data that directly identifies you — such as your name — is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you — such as the serial number of your device — is personal data. Aggregated data is considered non-personal data for the purposes of this Privacy Policy.

This Privacy Policy covers how UpWoof or an UpWoof-affiliated company (collectively, “UpWoof”) handles personal data whether you interact with us on our website. UpWoof may also link to third parties on our services. UpWoof’s Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

Your Privacy Rights at UpWoof

At UpWoof, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to our global customer base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from UpWoof. Where you are requested to consent to the processing of your personal data by UpWoof, you have the right to withdraw your consent at any time. To exercise your privacy rights and choices, including where a third-party service provider is acting on UpWoof’s behalf please contact us. You also have the right to lodge a complaint with the applicable regulator.

There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and UpWoof is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for antifraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical or unreasonable.

Personal Data UpWoof Collects from You

At UpWoof, we believe that you can have great products and great privacy. This means that we strive to collect only the personal data that we need. The personal data UpWoof collects depends on how you interact with UpWoof.

When you create an UpWoof account, and/or purchase pet hotel services, contact us (including by social media), participate in an online survey, or otherwise interact with UpWoof, we may collect a variety of information, including:

• Account Information. Your UpWoof ID and related account details, including email address, devices registered, account status, and age
• Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type
• Contact Information. Data such as name, email address, physical address, phone number, or other contact information
• Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information
• Transaction Information. Data about purchases of UpWoof products and services or transactions facilitated by UpWoof, including purchases on UpWoof platforms
• Fraud Prevention Information. Data used to help identify and prevent fraud, including a device trust score
• Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data
• Location Information. Precise location only to support services such as Pet Hotel Search, and coarse location
• Government ID Data. In certain jurisdictions, we may ask for a government-issued ID in limited circumstances, including when setting up a wireless account and activating your device, for the purpose of extending commercial credit, managing reservations, or as required by law
• Other Information You Provide to Us. Details such as the content of your communications with UpWoof, including interactions with customer support and contacts through social media channels

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

Personal Data UpWoof Receives from Other Sources

UpWoof may receive personal data about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.

• Individuals. UpWoof may collect data about you from other individuals — for example, if that individual has sent you a product or gift card, invited you to participate in an UpWoof service or forum, or shared content with you.
• At Your Direction. You may direct other individuals or third parties to share data with UpWoof. For example, you may direct your mobile carrier to share data about your carrier account with UpWoof for account activation, or for your loyalty program to share information about your participation so that you can earn rewards for UpWoof purchases.
• UpWoof Partners. We may also validate the information you provide — for example, for fraud-prevention purposes.
• For research and development purposes, we may use datasets such as those that contain images, voices, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

UpWoof’s Use of Personal Data

UpWoof uses personal data to power our services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.

UpWoof uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance, UpWoof may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. More information is available in the product-specific information embedded in our products and features as described above. If you have questions about the legal basis, you can contact us.

• Power Our Services. UpWoof collects personal data necessary to power our services, which may include personal data collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting. For example, if you would like to access a song through an UpWoof Music subscription, we collect data on what songs you play in order to provide you with the content requested and for royalty purposes.
• Process Your Transactions. To process transactions, UpWoof must collect data such as your name, purchase, and payment information.
• Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with UpWoof, you may not opt out of receiving these important notices.
• Security and Fraud Prevention. To protect individuals, employees, and UpWoof and for loss prevention and to prevent fraud, including to protect individuals, employees, and UpWoof for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
• Personal Data Used for Personalization. If you choose to personalize your services or communications where such options are available, UpWoof will use information that we collect so that we can offer you those personalized services or communications.
• Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.

UpWoof does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review. UpWoof also does not use or disclose sensitive personal data for any purposes that would require a user to exercise a right to limit processing according to California law. UpWoof retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy notices. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

UpWoof’s Sharing of Personal Data

UpWoof may share personal data with UpWoof-affiliated companies, service providers who act on our behalf, our partners, developers, and publishers, or others at your direction. Further, UpWoof does not share personal data with third parties for their own marketing purposes.

• Service Providers. UpWoof may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. UpWoof service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions. They cannot use the personal data we share for their own purposes and must delete or return the personal data once they’ve fulfilled our request.
• Partners. At times, UpWoof may partner with third parties to provide services or other offerings. UpWoof requires its partners to protect your personal data.
• Others. UpWoof may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

UpWoof does not sell your personal data including as “sale” is defined in Nevada and California. UpWoof also does not “share” your personal data as that term is defined in California.

Protection of Personal Data at UpWoof

At UpWoof, we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure.

Cookies and Other Technologies

UpWoof’s websites, online services, interactive applications, and advertisements may use “cookies” and other technologies such as web beacons. These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

• Communications Cookies. These cookies are used to enable network traffic to and from UpWoof’s systems, including by helping us detect any errors.
• Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested.
• Other Cookies. These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. UpWoof also uses these cookies to remember choices you make while browsing, so we can provide you with a customized experience.

If you prefer that UpWoof not use cookies, we provide you with the means to disable their use. If you want to disable cookies and you’re using the Safari web browser, choose “Block all cookies” in Safari’s privacy settings. If you are using a different browser, check with your provider to find out how to disable cookies. Certain features of the UpWoof website may not be available if all cookies are disabled.

In addition to cookies, UpWoof uses other technologies that help us achieve similar objectives.

In some email messages UpWoof sends to you, we provide a “click-through URL” that links you to content on the UpWoof website. When you click one of these URLs, they pass through a separate server before arriving at the destination page on our website. We track this click-through to help us determine interest in particular topics and measure whether we are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or text links in email messages.

UpWoof generally treats data we collect using these cookies and similar technologies as non-personal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data in those regions. In addition, UpWoof sometimes combines non-personal data collected from these technologies with other personal data UpWoof holds. When we combine data in this way, we treat the combined data as personal data for purposes of this Privacy Policy.

Transfer of Personal Data Between Countries

UpWoof products and offerings connect you to the world. To make that possible, your personal data may be transferred to or accessed by entities around the world, including UpWoof-affiliated companies, to perform processing activities such as those described in this Privacy Policy in connection with your use of our products and services. UpWoof complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.

The UpWoof entity that controls your personal data may differ depending on where you live. If you do not reside in the U.S., your personal data may be processed by UpWoof Inc. and other UpWoof-affiliated companies on behalf of the UpWoof entity controlling personal data for your jurisdiction.

Personal data collected by UpWoof or an UpWoof-affiliated company worldwide is generally stored by UpWoof Inc. in the United States. Regardless of where your personal data is stored, UpWoof maintains the same high level of protection and safeguarding measures. UpWoof’s international transfer of personal data collected in participating Asia-Pacific Economic Cooperation (APEC) countries abides by the APEC Cross-Border Privacy Rules (CBPR) System and Privacy Recognition for Processors (PRP) System for the transfer of personal data. Countries participating in the APEC CBPR systems at the date of this Privacy Policy are the United States, Australia, Canada, Chinese Taipei, Japan, Mexico, the Philippines, Republic of Korea, and Singapore. If you have questions or unresolved concerns about our APEC CBPR or PRP certifications, contact our third-party dispute resolution provider.

Personal data relating to individuals in the People’s Republic of China may be processed by UpWoof in countries outside of the People’s Republic of China, such as UpWoof Inc. in the United States or UpWoof Distribution International Limited in the Republic of Ireland. Where this occurs, it will be done in compliance with local laws, including the Personal Information Protection Law. For the purposes of processing set out in this Privacy Policy, UpWoof may also transfer such personal data to third-party service providers, who may in turn store or transfer the data outside of the People’s Republic of China.

Our Companywide Commitment to Your Privacy

To make sure your personal data is secure, we communicate our privacy and security guidelines to UpWoof employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have questions about UpWoof’s Privacy Policy or privacy practices including where a third-party service provider is acting on our behalf, or you would like to contact our Data Protection Officer, you can contact us. You can also ask us questions about how to submit a privacy complaint and we will endeavor to help.

UpWoof takes your privacy questions seriously. UpWoof reviews your inquiry to determine how best to respond to your question or concern, including those inquiries received in response to an access or download request. In most cases, all substantive contacts receive a response within seven days. In other cases, we may require additional information or let you know that we need more time to respond.

Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person.

You may at any time — including if you are not satisfied with UpWoof’s response — refer your complaint to the applicable regulator. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.