Definition of Personal Information

In this Privacy Policy, the term "personal information" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, or, in certain circumstances, location information, an IP address or the unique identifier allocated to each DOTT device.

Data Controller

The owner and data controller of your personal information collected, processed, used and stored by the Services and/or the DOTT device(s) is: Rm 811, Block B, Hoi Luen Ctr., 55 Hoi Yuen Rd., Kwun Tong, HK. We can be contacted by email at info@dottpet.com.

Location of Storage and Processing of Personal Information

Your personal information is stored and processed at our headquarters in the Hong Kong, unless stated otherwise in the rest of this document.

Personal Information and other information that we collect

When you register for our Services we will collect and store certain personal information necessary to set up your account with us, such as your first and last name, home address, and email address. We will further generate, and store with your account, a unique identifier allocated to each DOTT device that will be registered for your account.

Whenever you sign in on your account through the DOTT app on a mobile device, we will further collect your location information and your DOTT devices' location information (provided your DOTT devices are in reach of the mobile device), as collected and sent by the DOTT app, and associate such information with your account with us.

In addition, we will collect, and store with your account, detailed location information about your DOTT device(s) as collected and sent via other users' mobile devices with an installed and activated DOTT app; these users will not have access to such information (see Section 6 on "Our Use and Sharing of your DOTT Device Location Information" below). Likewise, we will collect location information about other users' DOTT device(s) tracked and transmitted to us by the DOTT app on your mobile device (provided the DOTT app is activated on your mobile device).

Whenever you use our Services, we may further collect additional information about your usage of our Services, including by making use of third party web analysis tools (see Section 11 on "Integration of Third Party Web Analysis Services and Social Functionalities" below), such as your frequency and scope of your use of the Services, the duration of your online sessions, the sites you visit, information you read, content that you use or create, advertisements that you view or click on, your communications with other users and third parties, information about the mobile device on which you have installed the DOTT app, and the geographic location of the computer system or device that you are using to log-into our Services.

If you decide to interact with a social network when using our Services, we may further collect certain personal information made available through your social network account (see Section 8 on "Your Sharing of your Personal Information with Social Networks" below). We will further collect any personal information you may actively provide to our service personnel if you contact our customer support hotline through our Website and/or DOTT app.

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Our Object Location Services

We will use and process:

• Your personal information from your registration and usage of our Services (including your location information and your DOTT devices' location information) to provide you with our location services, e.g., to help you track and find your DOTT devices which are in reach of your mobile device, to remember the last known location of your DOTT devices, and/or to communicate to you the location of your DOTT device(s) in reach of other users' mobile devices;
• Your location information (i.e., the location of your mobile device that has tracked a DOTT device of another user) to help other users of the Services to find their lost DOTT device(s) by sending anonymous location updates to those other users when the DOTT app on your mobile device "finds" their lost DOTT device(s); (see Section 6 on "Our Use and Sharing of your DOTT Device location information" for further details on how our service works).

Further Uses of your Personal Information and other information

In addition, we may use and process your personal information and other information (including your location information and your DOTT devices' location information

• To provide you with support and handle requests and complaints;
• To send you updates, notices, additional information, and marketing information related to the Services;
• To create anonymous, statistical and aggregated data and reports (i.e., in a form where such data does not enable the identification of a specific user). See Section 9 on "Our Use and Sharing of Aggregated Information" below;
• To comply with any applicable law and assist law enforcement agencies under any applicable law, when we have a good faith belief that our cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
• To prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services.

Our Use and Sharing of your DOTT Device Location Information

The Services are based on a community of all users of the Services sharing location information with us. Whenever a DOTT app is activated on a user's mobile device, we will collect detailed location information about any DOTT device(s) in reach of such mobile device, as collected and sent to us by the mobile device.

Any location information we receive about DOTTdevice(s) located through a DOTT app will be stored by us on our cloud server. Such information can be associated by us with the account for which the DOTT device(s) have been registered (by linking the unique DOTT device identifier with the account information), for instance, where necessary to help you to track your DOTT device(s) in reach of other users' mobile devices with an activated DOTT app.

However, your location information will be completely anonymous to other users, unless you actively decide to share these data, e.g., by choosing to share access to your Services' account with other people you trust, or by using social networks (see Section 8 on "Your Sharing of your Personal Information with Social Networks" below). We will not identify you personally to other users or otherwise make your location information available to any third party in personal identifiable form without your prior consent.

Your contact information will be shown to other users upon report loss of your pets or items in order to facilitate to finding on lost pets or items.

Our Use and Sharing of your Personal Information

We may share your personal information (including your location information and your DOTT devices' location information) with our third party service providers or affiliates, as authorized by us to collect, process and use your personal information as data processors on our behalf, such as, for instance, cloud based and hosting services, technical service providers, mail carriers, communication agencies and customer support service providers; these parties may be located in countries outside of your jurisdiction.

Your Sharing of your Personal Information with Social Networks

You may choose to share information between your Services' account and some of your social network accounts (such as your Facebook account). Through this option, you may choose to have personal information and other content about you (e.g., the location of your DOTT device(s) and thus also of your tracked items) available, transmitted and shared through the Services with your other social network account(s).

By setting your Services' account to integrate with social networks including by signing onto the Services by using your social network account (such as your Facebook account), you share information (including personal information) between the Services and such social networks.

The social network's use of (personal) information is governed by that social network's privacy policy and controlled by the social network, not by this Privacy Policy or us.

When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked to permit the social network to share your personal information stored on such social network with the Services. We collect your information from your social network account only in accordance with your privacy settings you have set up under your social network accounts.

Subscription of Newsletter/Promotional Materials/Marketing Materials

The Company and its affiliates may from time to time send to members and Users of the Channels newsletters, promotional materials and marketing materials based on the personal information and data that they have provided to the Company. The Company may use Users’ data in direct marketing and the Company requires the Users’ consent (which includes an indication of no objection) for that purpose. In this connection, please note that the following classes of services, products and subjects may be marketed:

• Products and services;
• Special events hosted by the Company and its affiliates for members and Users, including but not limited to courses, workshops, and competitions;
• Reward, loyalty or privileges programmes and related products and services;
• Special offers including coupons, discounts, group purchase offers and promotional campaigns;
• Products and services offered by the Company’s affiliates and advertisers;
• Donations and contributions for charitable and/or non-profit making purposes;

The above products, services and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or:

• The Company’s affiliates;
• Third party service providers providing the products, services and subjects listed in paragraph (b) above; and
• Charitable or non-profit marking organizations;

In addition to marketing the above services, products and subject itself, the Company also intends to provide the data described in paragraph (a) above to all or any of the persons described in paragraph (c) above for use by them in marketing those services, products and subjects, and the Company requires the Users’ written consent (which includes an indication of no objection) for that purpose; the Company may receive money or other property in return for providing the data to the other persons in paragraph (d) above and, when requesting the Users’ written consent as described in paragraph (d) above, the Company will inform the Users if the Company receives any money or other property in return for providing the data to the other persons.

Suitable measures are implemented to make available to such members the options to “opt-out” of receiving such materials. In this regard, Users may choose to sign up or unsubscribe for such materials by logging into the registration or user account maintenance webpage, or clicking on the automatic link appearing in each newsletter/message, or contact info@dottpet.com or call us at +852 2889 2339.

Our Use and Sharing of Aggregated Information

We use information about our users' website activities and usage of our Services (including location information) in anonymous, statistical or aggregated form, i.e., in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes.

We also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to our service providers or business partners.

Cookies

Cookies are small text files that our Services ask to place on your computer's hard drive and onto your mobile device's memory. If your browser is set to accept cookies, then your browser adds the text in a small file.

We use cookie technology for various purposes, such as to facilitate your use of our Services, e.g., to remember you when you return to our Website, identify you when you sign-in, authenticate your access, enable your use of specific functionalities, keep track of your specified preferences or choices, tailor content to your preferences or geographic region, display personalized browsing history, or provide technical support.

We may further use cookies to monitor site usage, conduct research and diagnostics to improve our content, products, and services, and to help us analyze web traffic in general.

Cookies also enable us to display interest-based advertising on our Website using information you make available to us when you interact with our sites, content, or services. Interest-based ads are displayed to you based on cookies linked to your online activities.

You can decide whether or not to accept cookies. The "Help" feature on most browsers will explain how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. To learn how to manage privacy and storage settings for Flash cookies click here. Because cookies allow you to take advantage of many of our online features and functionalities, consider leaving them turned on.

Integration of Third Party Web Analysis Services and Social Functionalities

In addition, our Services integrate the following services of third parties which may also place cookies on your computer’s hard drive and/or your mobile device's memory. We do not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Privacy Policy.

You can change your settings to refuse these third party cookies or to warn you before cookies are placed. However, if you choose not to accept cookies, you may not be able to take advantage of some of our features and services through our Services.

Google Analytics (Google)

Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use our Website, to track and examine the use of our DOTT app, to prepare reports on website activity and providing other services relating to usage of our Services. As a rule, any information generated by the cookies about your use of our Services will be transmitted to and stored by Google on servers.

Google may also use the data collected to contextualize and personalize the ads of its own advertising network and/or share the data with other Google services.

Social Plugins and Social Widgets

Our Services integrate social plugins, widgets and other features from third party social networks, including the following:

• Facebook Like-Button, social widgets and other features allowing interaction with the Facebook social network as provided by Facebook. Inc.; further information on Facebook's privacy practices can be found Under https://www.facebook.com/about/privacy/.

These social plugins, widgets and other features allow the respective third party social networks to place cookies on your browser and to collect certain information, which may be associated with your name and personal social network account information. These social plugins, widgets and other features are operated solely by the respective third parties, and their service providers, and you should carefully read their privacy policies before you decide to use the respective functionalities. We have no control over or access to the information collected, stored or used by such third party social networks, and the information practices by such third parties are not covered by this Privacy Policy.

Please further see the "Your Sharing of your Personal Information with Social Networks" above for more details on sharing your information through social networks.

Information Security

We implement commercially reasonable systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access, disclosure, modification or use of information. However, these measures are unable to provide absolute assurance. Therefore, although we take great efforts to protect your personal information, we cannot guarantee and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time. If you object to any of the changes to this Privacy Policy, you must cease using the. Unless stated otherwise, the then-current privacy policy applies to all personal information we have about you.

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services after being notified of such changes will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must cease any further use of the Services.

Last Updated: May 6, 2015