Privacy Policy

This privacy policy describes how PupEEE Enterprises Lessor Dancor Pty Ltd and / or Future Prospects Pty Ltd of National Offices, 737 Burwood Road, Hawthorn East, Victoria 3123, Australia (hereinafter referred to as "PupEEE" or "we" and "us") processes the data you provide to us when using the web sites and app and which is required when installing the PupEEE app on your Android end device (e.g. compatible Android smartphone or Android tablet) and your iOS end device (e.g. iPhone, iPod or iPad) in accordance with the requirements of the General Data Protection Regulation (GDPR).

In this privacy policy, common information is provided for the web site (PupEEE.com) and the use of the PupEEE app and separately in each case.

Person Responsible

The person responsible in the sense of the data protection regulations for all data processing and data transfer processes is: The Privacy Officer of PupEEE – National Offices, 737 Burwood Road, Hawthorn East, Victoria 3123, Australia.

If you have any questions, comments, complaints or wish to exercise your rights as a data subject in connection with this privacy policy and the processing of your personal data, please contact us directly using the contact details above or by e-mail at hello@PupEEE.com. We will be happy to answer any questions you may have.

What data do we process?

We process your personal data. This is any information relating to an identified or identifiable individual (Art. 4 No. 1 GDPR). We process contact data of our users, business partners and other third parties. We also process payment data and, where applicable, other information on personal and economic circumstances, insofar as this is necessary for the provision of our services. We also process data that we do not receive from you directly, but from other third parties. In this context, we also include data from publicly accessible sources, namely directories, registers and the freely accessible Internet. The specification of the data processing depends on the use of the respective platform. On the web site, data processing may be different from that on the app. You will find further supplementary information there in each case.

Contacting us

If you contact us, your enquiry including all personal data resulting from it (name, enquiry) will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent. The processing of this data is based on Art. 6 (1) lit. b GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested. The data you send us via contact requests will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies. (e.g. after your request has been processed). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Direct marketing

The legal basis for the processing of your personal data in the context of direct marketing measures is either your consent or our legitimate interest in marketing and promoting our courses and services. The purpose of processing your personal data in the context of direct marketing measures is to send information, offers and, if applicable, to promote sales.

Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected; this is the case in particular upon receipt of the revocation or objection. You can revoke your consent at any time for the future or object to the processing of your personal data in the context of direct marketing measures at any time for the future.

When you send a data subject access request

The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of the data subject access request is both our legitimate interest and our legal obligation. The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfil the legally required accountability.

Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process. You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future. In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.

Legal defence and enforcement of our rights

The legal basis for the processing of your personal data in the context of legal defence and enforcement of our rights is our legitimate interest. The purpose of processing your personal data in the context of legal defence and enforcement of our rights is the defence against unjustified claims and the legal enforcement and assertion of claims and rights.

Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The processing of your personal data in the context of legal defence and enforcement is mandatory for legal defence and enforcement of our rights. Consequently, there is no possibility for you to object.

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. We only disclose the data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities).

We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and organisational procedures, administration and response to requests, visit action evaluation, interest-based and behavioural marketing, profiling (creating profiles of users). And, the

Legal bases are Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR), and our Legitimate interests (Art. 6 para. 1 p. 1 lit. f GDPR).

Offering software and platform services

We process the data of our users, registered users and any test users in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information.

Technical services

We process the data of our customers and clients in order to enable them to select, purchase or commission the selected services or works as well as associated activities and to pay for and deliver them or to execute or provide them. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information.

Commercial services

We process the data of our customers and clients in order to enable them to select, purchase or commission the selected services or works and associated activities as well as their payment and delivery or execution or performance. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information.

What is the purpose and legal basis of data processing?

We process personal data within the scope of the provision and usability of the web site and the app, as well as for the fulfilment of contractual obligations (Art. 6 para. 1 sentence 1 b, f GDPR); for the provision of the service and for the fulfilment of legal requirements (Art. 6 para. 1 sentence 1 c, f GDPR); safeguarding legitimate interests (Art. 6 para. 1 sentence 1 f GDPR); sending a newsletter by e-mail to customers (Art. 6 para. 1 sentence 1 f GDPR); processing on the basis of consent given in a specific individual case (Art. 6 para. 1 sentence 1 a, in conjunction with Art. 7 GDPR). We store and use personal data for the assertion and defence of our rights. This data is collected in order to identify you as our customer; to initiate the contractual relationship; to correspond with you; to invoice you; to assert any claims against you. Further, purposes and legal bases can be found, where applicable.

Online Payment, Secure data transmission and Credit card information

The transmission of your personal information during an order transaction is encrypted using industry standard Secure Socket Layer ("SSL") technology, (SSL encryption version 3). Any credit card information you provide will not be stored by us, but will be encrypted and collected directly from our payment service provider via hypertext transfer protocol secure ("https").

We may share information with, and you may need to provide credit or debit card information directly to the provider in order to process payment details and authorize payment following a secure link. The information which you supply to in such cases is not within our control and is subject to our payment service provider ’s own Privacy Notice and Terms and Conditions.

Integration Of Services And Contents Of Third Parties

We use within our online offer on the basis of our legitimate interests (Art. 6 para. 1 lit. f. GDPR), content or services offered by third-party providers in order to integrate their content and services. This always requires that the third-party providers of this content are aware of your IP address, since the content or service could not send to your browser without the IP address. The IP address is thus required for the display of this content and we endeavor to use providers that only use your IP address for the delivery of the content or services. However, Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

Deletion Of Data And Storage Period

Your personal data will be deleted or blocked as soon as the purpose for storing it no longer applies. This is generally the case after the purpose of the data processing has ceased to exist. In addition, data may be stored if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or performance of a contract.

Who is the recipient of data? To whom is your data disclosed ?

Data is only disclosed to third parties if there is a legal basis for the processing. For example, we disclose personal data to persons or companies that act as processors for us in accordance with Art. 28 of the GDPR. A processor is anyone who processes personal data on our behalf, i.e. in particular in an instruction and control relationship with us. In accordance with the requirements of the GDPR, we conclude a contract with each of our processors to oblige them to comply with data protection regulations and thus to provide your data with comprehensive protection.

What security measures have we taken to protect your data?

The data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our servers. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.

What are your data subject rights?

If you have any questions, suggestions or complaints about data protection with us, please feel free to contact us at any time. All data subjects have the following rights: You have the right to information about the personal data we process about you (Art. 15 GDPR). In the case of a request for information that is not made in writing, we ask for your understanding that we may then require evidence from you that proves that you are the person you claim to be. You have the right to rectification, deletion or restriction of processing, insofar as you are entitled to this by law (Art. 16, 17, 18 GDPR). You have the right to object to processing where you are entitled to do so by law (Art. 21 GDPR). You have the right to data portability where you are entitled to do so by law (Art. 20 GDPR). If the personal data was collected because you gave your consent, you have the right to withdraw this consent at any time without giving reasons (Art. 7 (3) GDPR). You have a right of appeal. This gives you the opportunity to complain to the competent supervisory authority if you believe that we are not processing your personal data correctly (Art. 77 GDPR).

Online presences in social media

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.

Hosting

The services for hosting and displaying the App are partly provided by our service provider as part of processing on our behalf. Unless otherwise explained in this privacy policy, all access data and all data collected in forms provided for this purpose on this APP are processed on their servers. If you have any questions about our service providers and the basis of our relationship with them, please contact us.

Content Delivery Network

For the purpose of a shorter loading time, we use a so-called Content Delivery Network ("CDN"). With this service, content, e.g. large media files, are delivered via regionally distributed servers of external CDN service providers. Therefore, access data is processed on the servers of the service providers. Our service providers work for us within the framework of order processing. If you have any questions about our service providers and the basis of our cooperation with them, please contact us.

Children Data

Our Platform is not intended for children. We do not knowingly collect data and information relating to children. We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act).

Advertising

Advertisers and third parties also may collect information about your activity on our sites and application, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our sites and applications and on third-party sites and applications. You can opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. You may also be able to choose to control targeted advertising on other websites and platforms that you visit. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.

Profile Data

Within the Platform you may be able to display certain profile information, share certain details, engage with others, exchange knowledge and insights, post and view relevant content. Content and data is publicly viewable. You have choices about the information on your profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the storage is Article 6 lit. f) GDPR.

Changes to this privacy policy

PupEEE may update this Privacy Policy from time to time. Such changes will be displayed on the PupEEE web site or within the PupEEE app.

Additions for the web site of PupEEE.com

How do we collect your data?

On the one hand, your data is collected by you providing it to us. This may, for example, be data that you enter in a contact form. Other data is collected automatically by our IT systems when you visit the website. This is mainly technical data (e.g., internet browser, operating system or time of page view). This data is collected automatically as soon as you enter our website.

What do we use your data for?

For technical reasons, in particular to ensure a secure and stable internet presence, data is transmitted by your internet browser to us or to our web space provider. These so-called server log files are used to collect, among other things, the type and version of your internet browser, the operating system, the website from which you accessed our website (referrer URL), the website(s) of our website and services that you visit, the date and time of the respective access as well as the IP address of the internet connection from which our website is used. The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Therefore, there is no possibility for the user to object. The data collected in this way is temporarily stored, but not together with other data from you. This storage takes place on the legal basis of Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in the improvement, stability, functionality and security of our website. The data is deleted again after seven days at the latest, unless further storage is required for evidence purposes. Otherwise, the data is exempt from deletion in whole or in part until the final clarification of an incident.

Google Analytics

This website uses functions of the web analysis service Google Analytics. Google Analytics uses so-called "cookies". These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

The storage of Google Analytics cookies and the use of this analysis tool are based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. If a corresponding consent has been requested (e.g., consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. In addition, you can prevent the collection of the data generated by the cookie and related to your use of the website (incl. your IP address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Data stored by Google at user and event level that are linked to cookies, user IDs or advertising IDs are anonymised or deleted after 14 months. Details can be found under the following link: https://support.google.com/analytics/answer/7667196?hl=en

You can permanently prevent the collection of your data by Google Analytics at any time and with effect in the end device/browser currently used by revoking the corresponding consent in the data protection settings of this website. You can find more information on how Google Analytics handles user data in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you have provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent. The processing of this data is based on Art. 6 (1) lit. b of the GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested. The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after we have completed processing your enquiry). Mandatory legal provisions - in particular retention periods - remain unaffected.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Additions for the PupEEE app

Downloading the app

We have no influence on and are not responsible for the collection of data required to download the app from the app store, e.g. username, email address and customer number of your account and time of download. When using the app, we collect data for support purposes (device name, device type, OS model information).

Push notifications

In the settings of your device, you can confirm whether you want to receive news via push notification, even if you are not actively using our app at the moment or the device is in idle mode.

You can switch this function on or off at any time later in the settings of your mobile device. The delivery of push notifications takes place with the help of servers that are provided by the manufacturers of the operating systems. The mobile devices must therefore be registered with these servers, which requires the transmission of a UUID (iOS) or the device ID assigned to the device (Android).

The legal basis here results from Art. 6 para. 1 p. 1 lit. b GDPR for the provision of our services based on the request you have made, as well as from our legitimate interest, Art. 6 para. 1 p. 1 lit. f GDPR.

Creating and editing a profile

A user profile will be created for you based on the information you provide during the sign up. In particular, your Email, Name, Phone number, Country. You have the option of adjusting, changing or deleting the information in your profile to edit within the app or by contacting our team at hello@PupEEE.com.

The data processing carried out in this context is necessary in accordance with Art. 6 Para. 1 Sentence 1 lit. b GDPR to provide our service on the basis of the requests made by you. The data processing is also based on a legitimate interest pursuant to Art. 6 (1) sentence 1 lit. f GDPR, as our interest in providing

users with a platform for exchanging information with other users does not conflict with any overriding interest or right of yours. It should be noted that the majority of the data you provide is voluntary.

Contacting the support

You have the possibility to contact our support via the corresponding button and to send us questions and suggestions. Contacting our support is done by sending an email via the app responsible for this on your device. When sending an e-mail, your e-mail and the content of your message will inevitably be communicated to us and your e-mail will be stored on our servers. This data processing is necessary to make contacting us by e-mail technically possible at all and to make the e-mail retrievable for us. The data processing in this context is thus based on a legitimate interest pursuant to Art. 6 para. 1S. 1 lit. f GDPR, which is not opposed by any overriding interest or right of the data subject. Furthermore, the data processing is necessary to enable this function, so that the data processing is based on Art. 6 para. 1 p. 1 lit. b GDPR.

Firebase

The App uses the Firebase tool, which is part of the Firebase platform of Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA, to obtain statistics on how the App is used, in particular active user numbers, session length, stability rating and storage time. Answers logs the use of the app and we evaluate user behaviour and user activity in general, i.e. not on a personal basis.

For this purpose, the following data is transferred to the Analytics Engine: name and AppStore ID, build version, individual device installation key (e.g.. IDFA [iOS], Advertising ID, and Android ID), timestamp, device model, device name, device operating system name and version numbers, the language and country settings of the device (iOS), the number of CPU cores on the device (iOS), whether a device has the status "jailbreak" (iOS) or "root " (Android), app lifecycle events (iOS) and app activities (Android);

The legal basis for this data processing is our legitimate interest. The data collected via Google will be deleted after 6 months at the latest. You can select in the settings under data services whether or not you want to send data to Google. This setting also applies to the use of Crashlytics.

Crashlytics

The app uses the tool Crashlytics, which is part of the platform Firebase of Google Inc., 1600

Amphitheatre Parkway Mountain View, CA 94043, USA, to log crashes of the app. No personal data is transmitted. Only real-time crash reports with precise details of code locations and device information are sent, which is intended to simplify maintenance and improve the resulting stability of the app.

The legal basis for data processing is our legitimate interest. In the settings under data services, you can select whether you want to send crash reports or not. This setting also applies to the use of Google.

Authorisations and Access

We may request access or permission to certain functions from your mobile device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deactivate push notifications at any time via Settings/Messages (iOS) or Settings/Notifications/ (Android).

Push notifications for advertising purposes will only be sent to you if you have given your prior consent. The legal basis for sending promotional push notifications is consent. Deactivation is also possible via Settings/Messages (iOS) or Settings/Apps/ (Android).

Use of Google Play Store

For our app, we use Play Store from Google Inc. (1600 Amphitheatre Parkway, Mountain View, California, 94043), so that certain data are processed in a database on Google's servers. You can find more information about Play Store in the Google Play Store terms and conditions here: https://play.google.com/intl/en/about/privacy-security-deception/https://firebase.google.com/support/privacy/#data_processing_information.

The legal basis for processing this data is based on our legitimate interests according to Art. 6 para. 1 p.1 lit. f GDPR, as we want to constantly improve our APP and create a better and more pleasant user environment for you.

Use of Apple App Store. iTunes / App Connect and Push Messages

We use services of Apple Inc. One Infinite Loop Cupertino, CA 95014) for our service, so that certain data is processed in a database on Apple's servers. You can find more information here: https://www.apple.com/legal/privacy/en-ww/governance/. The legal basis for the processing of this data is based on our legitimate interests according to Art. 6 para. 1 p.1 lit. f GDPR, as we want to provide the app via Apple and content including push messages.