PRIVACY POLICY
We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal jargon to a minimum.
At Offleash’d, the privacy of your personal information and the information of your pet is a top priority. Your privacy and the protection of your personal information forms the very core of our Services, so that you can fully trust them and focus on building meaningful connections with others and their pets! We appreciate that you put your trust in us when you provide us with your information, and we do not take this lightly. As a reminder, all capitalized terms used herein but not defined shall have the meaning set forth in our Terms.
Our commitment to privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy.
Our commitment to transparency. We actually want you to read our policies and understand our privacy practices. We know that insufficient information and overly complicated language are common issues in privacy policies. We’re doing our best to write our Privacy Policy and related documents in plain language to make it easy for you to understand your rights and obligations as you use the Services.
Our commitment to security. We have a team dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.
1. WHO WE ARE
2. WHERE THIS PRIVACY POLICY APPLIES
3. INFORMATION WE COLLECT
4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
5. HOW WE USE INFORMATION
6. HOW WE SHARE INFORMATION
7. NO CROSS-BORDER DATA TRANSFERS
8. YOUR RIGHTS
9. HOW LONG WE RETAIN YOUR INFORMATION
10. CHILDREN’S PRIVACY – WE DO NOT COLLECT CHILDREN’S INFORMATION
11. JOB CANDIDATES, CONTRACTORS AND VENDOR REPRESENTATIVES
12. PRIVACY POLICY CHANGES
13. DISPUTE RESOLUTION
14. INFORMATION SECURITY
15. HOW TO CONTACT US
16. STATE-SPECIFIC PRIVACY RIGHTS
- WHO WE ARE.
The company responsible for your information is Offleash’d Inc., a Washington corporation (“Offleash’d,” “we,” “our” or “us”).
2.WHERE THIS PRIVACY POLICY APPLIES.
This Privacy Policy applies to websites, apps, events, engagements and other services we operate under the brand Offleash’d. For simplicity, we refer to all of these as our “Services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable Services.
Some Services may require their own unique privacy policy. If a service has its own privacy policy, then that policy — not this Privacy Policy — applies.
3. INFORMATION WE COLLECT.
We can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people (or pets) you’d like to meet. We also collect information about your use of our Services such as access logs, as well as information from third parties, like when you access our Services through your social media account or when you upload information from your social media account to complete your profile. If you want additional info, we go into more detail below.
Information you give us
You choose to give us certain information when using our Services. This includes:
When you create an account, you provide us with at least your login credentials and/or phone number, as well as some basic details necessary for the service to work, such as your gender, height and date of birth.
When you complete your profile, you may provide us with pet information (name, pet type, pet breed, birthday, age, personality trait, photos, number of pets).
When you complete your profile, you can share with us additional information, such as details on your pets, personality, lifestyle, interests and other details about you, as well as content such as photos or audio clips. To add certain content, like pictures, you may allow us to access your camera or photo album.
When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
When you participate in surveys, focus groups or market studies, you give us your insights into our products and Services, responses to our questions and testimonials.
When you choose to participate in our promotions, events, engagements or contests, we collect the information that you use to register or enter.
If you contact us (e.g., through our customer care team or on social media), we collect the information you give us during the interaction.
If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.
Of course, we also process your chats with other users as well as the content you publish, as necessary for the operation of the Services.
Information we receive from others
In addition to the information you may provide us directly, we receive information about you from others, including:
Users: Users may provide information about you as they use our Services, for instance as they interact with you or if they submit a report involving you.
Social Media: You may decide to share information with us through your social media account, for instance if you decide to create and log into your Offleash’d account via your social media or other account (e.g., Instagram, Facebook, Google or Apple) or to upload onto our services information such as photos from one of your social media accounts (e.g., Facebook, Instagram, TikTok…).
Affiliates: We may from time to time share your information (or receive information about you) from our affiliates, including information regarding your violation of our affiliates’ terms and policies. Your information can be shared with us to allow us to take necessary actions, including closing your account or preventing you from creating an account on our services.
Other Partners: We may receive information about you from our partners, where Offleash’d ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our users’ safety and security.
Information generated when you use our Services
When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:
Usage Information: Using the Services generates data about your activity on our Services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpage addresses and ads that you interacted with) and your interactions with other users (e.g., users you connect and interact with, when you exchanged with them, number of messages you send and receive).
Device Information: We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings), identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
Other Information with your Consent: If you give us permission, we can collect your precise geolocation (latitude and longitude). The collection of your geolocation may occur in the background even when you aren’t using the Services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, we will not collect it. Similarly, if you consent, we may collect photos and videos (for instance, if you want to publish a photo or video or participate in streaming features on our Services).
Information We Automatically Collect
Like most websites, our Services may incorporate technology such as “pixel tags”, “web beacons”, “log files” and “cookies” which allow us to track the actions of users of our Services. Pixel tags or web beacons are tracking devices on websites or in emails that can monitor the behavior of the user visiting the website or sending the email.
Cookies are small files placed on your computer that recognize you when you return to Offleash’d and that allow us to customize your user experience and improve our Services. You may modify the cookies that are accepted by your computer by changing your browser settings, although this may change the way the Offleash’d Services are presented to you. Other companies’ use of their cookies is subject to their own privacy policies, and we have no obligation to inform you of third-party cookies that are set.
Log files track actions occurring on the Services and collect data including your IP address, browser type, Internet Service Provider, referring/exit pages, and date/time stamps.
Web Beacons, Tags, and Pixels are electronic files used to record information about how you browse the Services. We use web beacons, tags, and pixels to deliver cookies and count visits.
As an example, Offleash’d uses cookies to keep track of your personalized experiences. We also use tracking technology to create remarketing audiences of users based on visitor behavior on our Services. Offleash’d may also deliver custom ads based on your affinities, interests, geographic and demographic signals. In particular, Offleash’d may use other TPS or services such as Google Analytics to monitor activity on the Site and to assist with advertising. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at https://www.google.com/policies/privacy/partners/.
4.COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES.
As discussed above, we use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels and SDKs) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them and how you can better control their use.
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Offleash’d, do not currently respond to DNT signals.
5. HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our Services. Additionally, we use your info to help keep you safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.
A. To administer your account and provide our Services to you
Create and manage your account
Provide you with customer support and respond to your requests
Personalize prices and complete your transactions
Communicate with you about our Services
Administer sweepstakes, contests, engagements, events, discounts or other offers
B.To help you connect with other users
Recommend you other Users to meet
Show users’ profiles to one another
C.To operate advertising and marketing campaigns
Perform and measure the effectiveness of advertising campaigns on our Services and marketing campaigns promoting Offleash’d on and off our Services
Communicate with you about products or Services that we believe may interest you
D.To improve our services and develop new ones
Administer focus groups, market studies and surveys
Review interactions with customer care teams to improve our quality of service
Understand how Users typically use the Services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how Users react to it)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
E.To prevent, detect and fight fraud and other illegal or unauthorized activities
Find and address ongoing, suspected or alleged violations of our Terms[CF2] , notably through the review of reports and interactions between Users.
Better understand and design countermeasures against violations of our Terms
Retain data related to violations of our Terms to prevent against recurrences
Enforce or exercise our rights, for example our Terms
Communicate to Users what we’ve done as a result of their reports.
F.To ensure legal compliance
Comply with legal requirements
Assist law enforcement
To process your information as described in this Privacy Policy, we rely on the following legal bases:
Provide our service to you: The reason we process your information for purposes A and B above is to perform the contract that you have with us. For instance, as you go about using our Services to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other users and recommend other users to you and to otherwise provide our free and paid features.
Legitimate interests: We process your information for purposes C, D and E above, based on our legitimate interest. For instance, we analyze Users’ behavior on our Services to continuously improve our offerings, we suggest offers we think might interest you and promote our own Services, we process information to help keep our Users safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
Comply with applicable laws and regulations: We process your information for purpose F above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents Users give us and decisions they may have taken to opt-out of a given feature or processing.
Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
6. HOW WE SHARE INFORMATION.
Since our goal is to help you make meaningful connections, the main sharing of Users’ information is, of course, with other Users. We also share some Users’ information with service providers and partners who assist us in operating the Services, with affiliates for specified reasons as laid out below and, in some cases, legal authorities.
With other users: You share information with other Users when you voluntarily disclose information on the Services (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings. If someone submits a report involving you (such as a claim that you violated our Terms), we may communicate to the reporter actions, if any, we took as a result of their report.
With our service providers and partners: We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with partners who distribute and assist us in advertising our Services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. We follow a strict vetting process prior to engaging any service provider or working with any partner. Our service providers and partners must agree to strict confidentiality obligations.
With our affiliates: We share your information with affiliates for limited legitimate purposes as laid out below:
For them to assist us in data processing operations, as service providers, upon our instructions and on our behalf. Their assistance may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, analytics, finance and accounting assistance, improving our Service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
In order to improve your chances at building significant connections with others, we may make you visible on other Offleash’d services or allow you to benefit from cross-platform functionalities. We will of course comply with applicable law and, where relevant, notify you of any such opportunity and allow you to agree or to refuse. Examples of such opportunities may include the creation of a new service within Offleash’d, addressing a specific demographic that we think might be interesting to you based on your profile.
For other legitimate business purposes including corporate audit, analysis and consolidated reporting, where and as allowed under applicable laws.
For corporate transactions: We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, recapitalization, conversion, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
With law enforcement / when required by law: We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights: We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our Users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request: We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Offleash’d companies and third parties (notably advertisers) to develop and deliver targeted advertising on our Services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.
7. NO CROSS-BORDER DATA TRANSFERS.
Offleash’d and its Services are currently only available in the United States of America. Offleash’d does not intend for the sharing of information laid out in Section 6 to involve cross-border data transfers to other jurisdictions outside of the United States that may have different laws about data processing.
8. YOUR RIGHTS.
We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the Services.
Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain Services may lose functionality.
Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the Services.
Account closure. You can close your account by using the corresponding functionality directly on the service. We also want you to be aware of your privacy rights. Here are a few key points to remember:
Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, right to know or variations of those terms). You can exercise this right by contact us at the information below.
Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, object to or restrict its processing, please contact us at the information below.
For your protection and the protection of all of our Users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another user, such as a copy of any messages you received from them through our Services, the other user will have to contact us to submit a separate request for their information. We may also ask them to provide proof of identity before we can answer the request.
Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our Services to you anymore. For instance, we cannot provide our Services if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older.
9. HOW LONG WE RETAIN YOUR INFORMATION.
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. If you decide to stop using our Services, you can close your account and your profile will stop being visible to other Users. After your account is closed, we will delete your personal information, as laid out below:
To protect the safety and security of our Users, we implement a safety retention window of thirty (30) days following account closure (the “Safety Retention Window”). During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
Once the Safety Retention Window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements. We may also need to keep “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents Users give us for the length of time permitted by law to evidence our compliance with applicable law.
We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, profile data in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent Users who were banned or people who were found to be under the age of 18 from opening a new account, to ensure the safety and vital interests of our Users.
Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).
10. CHILDREN’S PRIVACY – WE DO NOT COLLECT DATA FROM CHILDREN.
Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a User is under the age of 18, please use the reporting mechanism available on the Services, or contact us at the information provided below. IF YOU ARE UNDER 18 YEARS OF AGE, YOU ARE NOT PERMITTED TO USE OUR SERVICES.
11. JOB CANDIDATES, CONTRACTORS AND VENDOR REPRESENTATIVES.
We also process the personal information of our job candidates, contractors and vendor representatives, as part of our recruitment and talent management operations and our management of the Services that contractors and vendors provide to us. If you are a job candidate, contractor or vendor representative of Offleash’d, certain relevant terms of this Privacy Policy apply to our processing of your personal information, including the sections of this Privacy Policy that discuss the entity that is responsible for the processing of your personal information, transfers of personal information, rights you may have under applicable law, how to contact us and information specific to your residence.
If you are a job applicant, the personal information we process about you may vary depending on the job you seek but typically includes what you provide to us as part of your job application as well as professional qualifications, background and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an at-will employment relationship. For current contractors and vendor representatives, we may process identification information and work-related information, as necessary to manage our relationship with you and your employer (as applicable), which is necessary for the performance of the Services or any applicable agreement, and to establish, exercise or defend potential legal claims. We may share personal information with service providers that assist us with recruitment and technical data processing operations as well as with Offleash’d companies (for instance if you have a business relationship with employees of an affiliate). We keep your personal information only as long as necessary for those purposes.
12. PRIVACY POLICY CHANGES.
We strive to review this Privacy Policy at least once every twelve (12) months to make sure it complies with applicable law and conforms to changes in our business. We may need to update this Privacy Policy at any time and from time to time, in our sole and exclusive discretion, and we reserve the right to do so. If we revise this Privacy Policy, we will send you prior notice of our Privacy Policy update at the email address you provide us and you expressly consent to the receipt of this email correspondence. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Your use of the Services constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us from time to time.
13.DISPUTE RESOLUTION.
IF YOU HAVE ANY COMPLAINTS REGARDING OUR COMPLIANCE WITH THIS PRIVACY POLICY, PLEASE CONTACT US FIRST. WE WILL DO OUR BEST TO INVESTIGATE AND ATTEMPT TO RESOLVE ANY COMPLAINTS AND DISPUTES REGARDING THE USE AND DISCLOSURE OF PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF A DISPUTE IS ESCALATED IN ANY FASHION, YOU REPRESENT, WARRANT, ACKNOWLEDGE, AND AGREE THAT SUCH DISPUTE SHALL BE RESOLVED IN ACCORDANCE WITH THE DISPUTE RESOLUTION TERMS AND CONDITIONS INCLUDED IN OUR TERMS OF USE.
14. INFORMATION SECURITY.
Without limiting the terms of our Terms of Service, this Privacy Policy, you understand that we do not guarantee, represent or warrant that your use of the Services and/or information provided by you will be private or secure and we are not responsible or liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the Services. You also understand that any information provided by you or collected by us or our affiliates in connection with your use of the Services will be used in the manner described in our Terms. Any information that you provide to us is done so entirely at your own risk. Please do not use the Services if you do not agree to the terms and conditions described in this Privacy Policy.
Please remember no Internet transmission is every fully secure or error free. Please keep this in mind when disclosing any information to Offleash’d via the Internet. Although Offleash’d makes efforts to ensure that your information is not intercepted, accessed, manipulated, used, or disclosed by unauthorized persons, you should know that Offleash’d cannot fully eliminate security risks associated with your information and any transmission is at your sole and exclusive risk.
In case of a data breach, Offleash’d will notify affected individuals within ten (10) business days of its receipt of knowledge of such data breach.
15. HOW TO CONTACT US.
If you have questions about this Privacy Policy, you may contact us at:
By email : support@offleashd.com
By physical mail:
Offleash’d Inc.
15600 NE 8th St., Suite B1 #288
Bellevue, WA 98008
16. STATE-SPECIFIC PRIVACY RIGHTS.
For California residents only: If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of User information, as well as the names and addresses of those businesses with which we shared User information for the immediately prior calendar year. To make such a request, please send an email to the address listed above.
For Nevada residents only: Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at the email, above. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.