SUMMARY

This privacy policy explains the types of personal data we collect and how we use and protect that information:

SCOPE

This privacy policy applies to all personal data that is collected and used by us when you create a DOGTRACKS ID account, when you visit or use the websites, applications, web shops, online, mobile, instore or other services of DOGTRACKS (‘Services’), when you purchase our products in our stores, participate in events or contests of DOGTRACKS or interact with us through social media or otherwise. For purposes of this privacy policy, ‘personal data’ means any information through which we can identify you, as further described below in ‘Personal Data We Collect’.

WHO WE ARE

DOGTRACKS is an international company, with headquarters in Sweden. DOGTRACKS was founded on the belief that tracking is one of the best ways to activate and train your dog(s). Our brands include DOGTRACKS.

DOGTRACKS AB, Orkestergatan 14, 252 71 Råå, Sweden is responsible for using your personal data.

PERSONAL DATA WE COLLECT

The information we collect about you when you buy our products or use our Services may include the following (jointly referred to as: ‘personal data’).

GENERAL:

Your contact details. Your name, postal address and other contact details, such as your telephone number and e-mail address. Your account data and electronic identification data (including data added thereto). Your DOGTRACKS ID account and other electronic identification data (such as IDFA, GAID, IP address, MAC address) and the data you add to your DOGTRACKS ID account, such as your password, your date of birth, your gender, your language of preference, the time zone you live in, your picture and other information you may share with us. Information regarding your use of our online Services. This may include data regarding the pages you visit, the products and services you like and the content of your abandoned shopping cart. Your purchases online. The data we collect if you purchase a product or use a Service online, such as the amount and date of your purchase, the product you purchase or Service you use, the website or app through which you make your purchase, payment method, payment status, discount, delivery method and delivery address. Your leisure activities, interest and events. This includes information regarding events we organize or sponsor, including your interest in and registration to those events (including the date and place of the event and your personal targets), as well as your reason for tracking, whether you prefer to track alone or with friends and what other sports you enjoy. Your tracking data. The tracking data that you fill out on or generate through the use of our Services or that you import from other apps or services from our partners or third parties, including your tracking experience and current tracking abilities, your tracking goal, performance (distance and race time, records), your type of tracking. Your details regarding contests. The data we collect if you participate in a contest. Your reviews. The opinions, experiences, preferences and interests, and product or event reviews that you publish on our websites or share with us online or through social media, such as your experiences and tips regarding gear, your race day and your training schedule. Your communication data. Your requests, any complaints you may have and any other data that we receive if we communicate with you via e-mail, online or via social media.

SPECIAL CATEGORIES OF PERSONAL DATA :

We also collect information you voluntarily provide to us regarding your dog(s). In addition, when using our Services, we may also collect and use exact information regarding your location, such as GPS, accelerometer, your tracking route (including precise location data that shows your geographical position).

We will only use dog, tracking and location data you voluntarily provide us and such only with your prior consent or under your direction to do so and only for the purposes set out in this Privacy Policy. You may refuse or revoke your consent at any time, as set out below (see ‘Your Rights’).

WHAT WE DO WITH YOUR PERSONAL DATA

DOGTRACKS collects and uses your personal data for the purposes set out below. Please be informed that insofar DOGTRACKS already holds information about you, DOGTRACKS may use that information for the same purposes.

For the performance of our agreement with you:
In order to manage and handle your purchases and to provide you with the Services you requested from us, including handling your requests, we use your contact details, your account and electronic identification data, information regarding your purchases, information regarding your leisure activities, interest and events, information regarding your tracking data, your Contest data, your communication data and – after your consent thereto your location data.

To comply with a legal obligation to which DOGTRACKS is subject:
Any information referred to above in the section ‘Personal Data We Collect’ may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.

For our legitimate commercial interests:
We will use your contact details to send you newsletters or general marketing materials as well as surveys about Products and Services you have purchased. At any time, you may opt out of receiving such marketing materials by following the instructions in any communication you receive from us. You can also control these preferences in your profile settings and device. We will use the personal data referred to above in the section ‘Personal Data We Collect’ in order to improve our products and Services as well as to understand our customers both on an aggregated and on an individual basis. In order to do so, we may combine the data we have obtained about you from the different DOGTRACKS entities that have collected your personal data (if applicable). This also means that we analyse your use of our products and Services and we use this information to improve our products and Services and to give you a better user experience (e.g., we analyse what web pages you visit, which products and Services you use and like, how you use these products and Services, which enables us to create personal profiles and to assess what may be interesting to you, which recommendations we can give you when you purchase our products or use our Services (such based for example on your previous purchases and use of our Services)). Creating such personal profiles of our customers, also enables us to send you marketing materials that directly relate to your use of our products and Services, if you have chosen to receive such materials.

We may also enrich your personal data with data from other third party sources, such as weather forecasts based on your location (expected temperature, humidity, wind) and traffic forecasts (chance of air pollution), for example to further customize your tracking plan, allow you to adjust a specific track to the concrete circumstances or provide you with more detailed information about your tracks.

The personal data referred to above in the section ‘Personal Data We Collect’ may also be used by DOGTRACKS:

to generate aggregated statistics about the users of our products and Services; to assist in security and fraud prevention; for system integrity purposes (preventing hacking, cheats, spamming, etc.); to remind you per email of your abandoned cart or send you an order confirmation; to facilitate our business operations, to operate company policies and procedures; to enable us to merge, sell, acquire, or transfer assets; and for other legitimate business purposes permitted by applicable law. Use of information based on your consent:

We may use the personal data referred to above in the subsection ‘Special Categories of Personal Data’ (i.e. dog data and location data) for the purposes set out in this DOGTRACKS Privacy Policy but we will only do so after we have received your consent thereto.

We may use your personal data referred to above in the section ‘Personal data we collect’ for marketing purposes based on your profiles via email, SMS, other electronic means or otherwise, but we will only do so after we have received your consent to do so.

We also use your personal data referred to above in the section ‘Personal data we collect’ based on your consent, if you subscribe to receiving our newsletters or participating to our surveys. You can withdraw your consent at any time; see the section Your Rights below.

HOW WE SHARE YOUR DATA

We may share your personal data with the following parties:
Data controllers within DOGTRACKS. Service Providers and Processor. We engage third party vendors, agents, service providers, and affiliated entities to provide services to us on our behalf, such as support for the internal operations of our websites, online stores (including payment processors and third parties we use of sending your orders to your home address), Services (e.g., technical support processing), as well as related offline product support services, data storage and other services.
In providing their services, they can access, receive, maintain or otherwise process personal data on our behalf. Our contracts with these service providers do not permit use of your information for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your personal data and only process it in accordance with our instructions.

Partners. Sometimes DOGTRACKS offers you a service or application in co-operation with partners. We may also disclose your personal data to those partners, but only where you have consented or requested that we do so. If you win a contest or sweepstake, we may disclose the names of winners online. We may also share your information with third party partners and co-sponsors, where relevant; in such cases, we will clearly notify you of the sharing, and you will have the choice not to participate or to otherwise object to such sharing. Third parties in case of legal requirement. We may also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Privacy Policy; to respond to any claims against us; and, to protect the rights, property, or personal safety of DOGTRACKS, our customers, or the public. Corporate Transaction. In addition, information about our customers, including personal data, may be disclosed as part of any merger, sale, transfer of DOGTRACKS’ assets, acquisition, bankruptcy, or similar event. With Consent. We may also disclose information about you, including personal data to any other third parties, where you have consented or requested that we do so. Notwithstanding anything else in this Privacy Policy, we may share aggregate or de- identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

COOKIES, ANALYTICS AND PERSONALIZATION

The Website uses cookies. Cookies are small text files that are stored on our visitors’ computers and which can be used to follow what a visitor does on the Website. We and our third party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the Services. We may combine this “activity information” with other personal data we collect about you. Generally, we use this activity information to understand how our Services are used, track bugs and errors, improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes. We only use cookies if you have given your consent. If you do not consent to the use of cookies, you can block cookies in your browser’s security settings. You can also configure the browser so that you receive a question every time the Website tries to place a cookie on your computer. Previously stored cookies can also be deleted through the browser. Refer to the browser’s help pages for more information. You can also delete cookies manually from your hard drive at any time. Note that if you choose not to accept cookies, the functionality may be restricted on certain websites.

SOCIAL MEDIA

When you participate in various social media forums like Facebook, Twitter, Yammer, Pinterest, Instagram, LinkedIn, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share the personal data in your social media profile(s).

DOGTRACKS is bound by the privacy practices or policies of these third parties, so we encourage you to read the applicable privacy notices, terms of use and related information about how your personal data is used in these social media environments.

Also, depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the DOGTRACKS pages), certain

personal data may be shared with DOGTRACKS about your online activities and social media profiles (e.g. interests, marital status, gender, user name, photo, comments and content you have posted/shared etc.).

IF YOU ARE UNDER 16 YEARS OF AGE

Our online Services are not directed to children under 13 years of age. If you believe we have collected information about a child under the age of 13, please contact us (see ‘Data Protection Officer - Contact and Queries’ below) so that we may take appropriate steps to delete such information.

If you are at least 13 but under 16 years of age, please get the consent of your parent or legal guardian before you give us any personal data about yourself. Your parent or guardian should contact the DOGTRACKS company responsible for using your personal data and provide us with their name, e-mail address and any other identifying information that we may request. DOGTRACKS needs this information in order to verify that they have provided the necessary consent. We may follow up by phone or other means in some circumstances. If you are at least 13 but under 16 years of age, do not contact us or provide us with any personal data until after your parent or guardian has sent us an e-mail consenting to your contact and provision of such information.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Please be informed that we transfer and process any personal data you provide to us to countries other than your country of residence. The laws of these countries may not afford the same level of protection to your personal data. DOGTRACKS will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer. More in particular for data transferred from the EU to countries outside the EU, DOGTRACKS is using Intra Group Data Transfer Agreements based on EU Model Clauses.

SECURITY

DOGTRACKS will take reasonable steps to ensure that your personal data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss. Your personal data will be retained for as long as required for the above purposes or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

DATA RETENTION

DOGTRACKS retains your personal data for as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to send you the newsletters you subscribed to, to provide you with customer service, answer queries or resolve technical problems, etc.), unless a longer period is necessary for our legal obligations or to defend a legal claim.

If you have created an DOGTRACKS ID account with us, we will delete that account and your personal data upon your request or 30 days after it has become inactive. We will consider your account ‘inactive’ when you haven’t used your DOGTRACKS ID account for a period of 2 years. Before your account becomes inactive, we will notify you to use your DOGTRACKS ID to prevent your account from being inactive. When we cancel your account, your personal data will be deleted, such with the exception of your account data and your tracking data in case you are using the Dogtracks app, which data will be stored for an additional 4 years after your account becomes inactive (unless you ask us to delete your data earlier). Also, if we need to store certain types of your personal data for a longer period due to legal requirements, we will store such data in accordance with the mandatory periods.

YOUR RIGHTS

You have the following rights concerning your personal data: right of access, right of rectification, right to erasure, right to restrict data processing, right to object against profiling and your right to data portability. If you would like to contact us regarding any of these rights please click here (mailto: dataskyddsombud@dogtracks.se)

To the extent that we are relying on our legitimate interests to use your personal data, you also have the right to object to such use (unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims).

Without undue delay and not later than within a month, we will respond to your request to invoke your rights consistent with applicable law.

You may revoke your consent for receiving marketing communications at any time, free of charge by following the instructions in any marketing communication. You can also control these preferences in your profile settings. DOGTRACKS will then stop applying the research results to you at an individual level and will stop sending you marketing communications.

In case you wish to revoke your consent to DOGTRACKS using your track data or location data, you can send an email to the DOGTRACKS company responsible for using your personal data (mailto: support@dogtracks.se). You can also control these preferences in your profile settings and device.

In case you may have a question or complaint about how we process your personal data, you can send an email to the DOGTRACKS company responsible for using your personal data (mailto: support@dogtracks.se). Alternatively, you may consider lodging a complaint with a supervisory data protection authority.

OTHER WEBSITES

Our websites and mobile applications contain links to third-party websites; if you follow these links, you will exit our websites and mobile applications. While these third-party websites are selected with care, DOGTRACKS cannot accept liability for the use of your personal data by these organizations. For more information, please consult the privacy statement of the website you are visiting (if such a statement is provided).

CHANGES TO THE POLICY

We may change this privacy policy from time to time by posting the updated version of the privacy policy on our websites and applications. We will give you reasonable notice on our websites of any material change. The “effective date” at the top of this policy indicates when such changes will take effect. We encourage you to visit frequently to stay informed about how we use your personal data.

DATA PROTECTION OFFICER - CONTACT AND QUERIES

If you have any questions regarding the processing of your personal data or this privacy policy, please contact the DOGTRACKS Data Protection Officer (mailto:support@dogtracks.se).