Privacy Policy
Welcome to DOTTpet
application (the “App“). This App and web service provides you a simple
way to monitor the health of your pets by collecting health data from different
DOTTpet devices. The App is published by DOTT Limited (“DOTT” or “We”
or “Us“), a company registered in Hong Kong Special Administrative
Region of The People’s Republic of China. Our Privacy Policy explains how we
and some of the companies we work with collect, use, share and protect
information in relation to our mobile services, web site, and any software
provided on or in connection with DOTTpet services (collectively, the "Service"),
and your choices about the collection and use of your information. We will handle all
user information concerned with the Service in accordance with the Personal
Data (Privacy) Ordinance (Chapter 486) of the Laws of the Hong Kong Special
Administrative Region of The People's Republic of China. The Ordinance provides
data subjects with rights to ascertain whether DOTT Limited holds personal data
relating to them, to obtain a copy of that data, and to correct any data that
is inaccurate. Our Privacy Policy applies to all visitors, users, and others who access
the Service ("Users"). By using our Service you understand
and agree that we are providing a platform for you to post content, including
photos, comments and other materials ("User Content"), to the
Service and to share User Content publicly. This means that other Users may
search for, see, use, or share any of your User Content that you make publicly
available through the Service, consistent with the terms and conditions of this
Privacy Policy and our Terms of Use (which can be found at http://dottpet.com/privacy.html).
We collect the
following types of information.
1.1 User Information
When creating a new account, e-mail address or Facebook login
credential will be used for the following purposes:
· To confirm the
identity of the user and prevent any unauthorized use of the Service.
· For Facebook login,
user’s name, email and profile picture will be collected to auto-complete some
of the required App profile creation processes.
1.2 Other User
Information
Users may be asked to register additional details such as his/her pet’s
information (Pet names, species, breed, age, profile photos, messages etc.).
Furthermore, other Users within the service can view profile and other
information (in the form of text, videos, photos etc.) which the users
themselves have registered or posted with the aim of sharing with other users.
1.3 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: Rm602, Shing Yip Industrial Building, 19-21 Shing
Yip Street, Kwun Tong, HK. We can be contacted by email at info@dottpet.com.
1.4 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.
1.5 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.
1.6 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.
2.1Cookies
To provide the best possible service to users, as well as for
maintenance and security purposes, Cookies will be used to store user settings,
to record access figures as well as monitoring usage patterns and statistics.
2.2 Logs
Upon access to the Service, the user’s IP address, browser type, and
browser language etc., will be automatically obtained and stored. Such
information will be used to analyze user environments, thereby enabling DOTT to
provide a better Service, as well as to prevent any unauthorized/fraudulent
practices which interfere with normal Service operations.
2.3 Location Information
Some of the Service may use location information transmitted from users'
mobile phones/devices. DOTT only uses such information within the scope that is
necessary in order to provide the designated service.
2.4 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
DOTTpet app is activated on a user's mobile device or websites via third
party’s or associated services including but not limited to Max and Molly Urban
Pets, we will collect detailed location information about any DOTTpet device(s)
in reach of such mobile device, as collected and sent to us by the mobile
device.
Any location information we receive
about DOTTpet device(s) located through a DOTTpet app will be stored by us on
our cloud server. Such information can be associated by us with the account for
which the DOTTpet device(s) have been registered (by linking the unique DOTTpet
device identifier with the account information), for instance, where necessary
to help you to track your DOTTpet device(s) in reach of other users' mobile
devices with an activated DOTTpet 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.
2.5 Device Information
The user’s device information (OS type) may be acquired at times. This
information shall be used for the provision of a better service, as well as for
identification purposes and prevention of any unauthorized/fraudulent practices
which interfere with normal Service operations.
DOTT may use the data
collected and provided by you for one or more of the following purposes.
DOTT will never
provide user information to any third parties without the user’s consent,
unless DOTT is obliged and/or permitted to do so under applicable laws.
All personal data
held by DOTT will be kept confidential but we may, where such disclosure is
necessary to satisfy the purpose, or a directly related purpose, for which the
data was collected provide such information to the following parties.
Personal data may
also be disclosed to any person or persons pursuant to any statutory or
contractual obligations or as required by court of law, provided such person or
persons are able to prove the required right/authority to access such
information. In addition, personal data may be disclosed under any of the
circumstances described in Part VIII of the Ordinance in which the concerned
personal data are exempt from the provisions of Data Protection Principle 3 of
the Ordinance.
The data you provide
to us will be stored at DOTT office or our servers accessible only to our
authorized employees. However, we give no warranty against third parties
hacking into the data or any unauthorized access to the data by anyone.
DOTT will take
reasonable steps to ensure that all information we collect, use or disclose is
accurate, complete and up-to-date and stored in a secure environment accessed
only by authorized persons.
Users may, through
the procedures determined by DOTT, send DOTT a request for the disclosure of
personal information which the users cannot confirm/access via the Service. DOTT,
in turn shall disclose such information except under the following conditions.
· When the disclosure
is likely to harm the life, body, property or other rights or interests of the
user or any other third party
· When the disclosure
is likely to severely interfere with DOTT's proper operation
· When disclosure
itself would constitute a violation of laws and/or regulations
· When DOTT is unable
to verify the user’s ownership of the personal information requested for
disclosure.
After the disclosure,
users may, through the procedures determined by DOTT, send DOTT a request to
correct, add or delete the user’s personal information, if the users find
personal information registered with DOTT to be incorrect. Under such
circumstances, DOTT shall swiftly investigate the request to achieve the
desired user intention and correct, add or delete the personal information on
the basis of DOTT's findings.
Upon withdrawing from
our Services, when a user account is deleted, all user information will be
disposed of in the correct manner in accordance with the law and DOTT’s
regulations.
This Privacy Policy
may be revised periodically. Users will be notified of important changes in a
recognizable manner.
If users have any uncertainty about
this Privacy Policy or questions, complaints, or comments on the handling of
personal information related to the Service, You can contact DOTT via email: info@dottpet.com
This Appendix applies if you are based
in the European Economic Area (the EEA) during your interactions with us
(other than where you are in the EEA solely for travel purposes).
In this Section 11.1 we have set out:
(a) the general
categories of Personal Data that we may process;
(b)
in the case of personal data that we did not obtain directly from you, the
source and specific categories of that data;
11.1.1 We may process data about your use of
our website and services ("usage data"). The usage data may
include your IP address, geographical location, browser type and version,
operating system, referral source, length of visit, page views and website
navigation paths, as well as information about the timing, frequency and
pattern of your service use. The source of the usage data is our analytics
tracking system.
11.1.2 We may
process your information included in your personal profile on our website
("profile data"). The profile data may include your name,
address, telephone number, email address, profile pictures, gender, date of
birth, relationship status, interests and hobbies, educational details and
employment details.
11.1.3 We may
process your personal data that are provided in the course of the use of our
services ("service data"). The source of the service data is
you or your employer.
11.1.4 We may process information that you post
for publication on our website or through our services ("publication
data").
11.1.5 We may
process information contained in any enquiry you submit to us regarding goods
and/or services ("enquiry data").
11.1.6 We may
process information relating to our customer relationships, including customer
contact information ("customer relationship data"). The
customer relationship data may include your name, your employer, your job title
or role, your contact details, and information contained in communications
between us and you or your employer.
The source of the customer relationship data is you or your employer.
11.1.7 We may
process information contained in or relating to any communication that you send
to us ("correspondence data"). The correspondence data may
include the communication content and metadata associated with the
communication. Our website will
generate the metadata associated with communications made using the website
contact forms.
11.1.8 Please do not supply any other person's
personal data to us, unless we prompt you to do so.
11.2.1 We will collect and handle general and
sensitive Personal Data1.
The categories of general Personal Data are outlined in Section 11.1.
11.2.2 We will typically ask you for your
consent when collecting and handling Personal Data, unless we are otherwise
permitted to process such Personal Data under European data protection law (EU
DP Law) or the laws of the EU member state in which you are based.
The legal basis or “grounds” for our
use of your Personal Data are set out below, as required under EU DP Law. In
the table below, we have linked each purpose mentioned in section 3 of our
Privacy Policy to the relevant legal ground/s:
EU use bases table
|
Purposes of the
data processing |
Use bases |
|
To prevent any unauthorized/fraudulent
use of the Service |
- contract
performance |
|
To offer an
undisturbed Service to Users |
- contract
performance |
|
To aggregate
statistical data regarding the Service |
- consent (which
can be withdrawn at any time) |
|
To conduct research
and analysis aimed at reviewing and improving the Service |
- legitimate
interests (to allow us to maintain and improve the quality of our services
and products) |
|
To comply with our
legal obligations and for safety and security purposes |
- legal
obligation - legal claims |
|
To enable DOTT to
deal effectively with user inquiries |
- contract
performance |
11.4.1 The legal grounds for our use of
Personal Data are as follows:
(a) Consent: where you have
consented to our use of your Personal Data. You may withdraw your consent to
the use of your Personal Data by contacting us as set out in section 10 of the
Privacy Policy.
(b) Contract performance: where we
are required to collect and handle your Personal Data in order to provide you
with the services that we have contractually agreed to provide to you.
(c) Legal obligation: where we
need to use your Personal Data to comply with our legal obligations.
(d) Vital interests: where we need
to process your Personal Data in order to protect the vital interests of you or
another natural person or pet, e.g. where you require urgent assistance.
(e) Public interest: where we need
to process your Personal Data in order to carry out a task that is in the
public interest.
(f) Legitimate interests: where we
have a legitimate interest in using your information. We will only rely on this
legal ground if we consider that our interest in using your Personal Data for
the relevant purpose is not outweighed by any interests that you may have, or
any prejudice that you may suffer, from the relevant use of your Personal Data.
The legal grounds for
our use of the sensitive categories of Personal Data are:
(g) Consent: where you have
explicitly consented to our use of your Personal Data. You may withdraw your
consent to the use of your Personal Data by contacting us as set out in section
10 of the Privacy Policy.
(h) Vital interest: where we need
to process your Personal Data in order to protect the vital interests of you or
another natural person where you or the other person is physically or legally
incapable of giving consent.
(i) Legal claims: where your
Personal Data is necessary for us to establish, exercise of defend any legal
claims.
(j) Substantial public interest:
where we need to process your Personal Data for reasons of substantial public
interest set out in EU law or the laws of the member state in which you are
based.
(k) Public interest in area of
public health: where we need to process your Personal Data for reasons of
public interest in the area of public health, such as protecting against
serious cross-border threats to health, set out in EU law or the laws of the
member state in which you are based.
11.5.1
In connection with our marketing activities, we analyse some of the
information that we collect about our Users and the pets (together with
information about Users and the pets that we collect from our loyalty and other
partners) to determine what offers are most likely to be of interest to
different categories of Users in different circumstances and at different
times. We call this the creation of “segments”. To do this, we combine Personal
Data that we have collected from Users directly together with Personal Data
that we have collected from our affiliates and other partners, if any. From
time to time, we will assess the Personal Data that we hold about you in order
to assign you to a particular segment. We will use the segment that you have
been assigned to in order to tailor our marketing communications to include
offers and content that are relevant to you or your pets.
11.5.1
You have the right to opt out of our direct marketing, and the
underlying analysis of your Personal Data that we use to tailor the direct
marketing that we send to you, at any time. You can exercise this right, by
contacting us in accordance with section 10 of the Privacy Policy.
11.6 Our decision-making processes
In connection with our business, we
will use your Personal Data to make various decisions about you and your
eligibility to access our services, to prevent abusive use of our services, to
ensure security of our systems, or to detect fraud. Some of these decisions may
be taken on an automated basis including, by matching your Personal Data
against information in certain risk models that we have created based on the
behaviour of other individuals and using your Personal Data to further enhance
such models.
11.7.1
Your Personal Data may be
accessed by staff or suppliers, transferred, and/or stored outside the EEA,
including to countries which may have a lower level of data protection
than under EU DP law.
11.7.2 We must comply with specific rules when
we transfer Personal Data from inside the EEA to outside the EEA. When we do
this, we will use appropriate safeguards to protect any Personal Data being
transferred.
11.7.3 We will transfer your Personal Data subject
to European Commission approved contractual terms that impose different data
protection obligations directly on the recipient, or as otherwise permitted
under EU DP Law.
11.7.4 Please contact us as set out in section
10 of the Privacy Policy if you would like to see a copy of the specific
safeguards we apply to the export of your Personal Data.
11.8.1
Our retention periods for Personal Data are based on business needs and
legal requirements. We will retain your Personal Data for as long as is
necessary for the processing purpose(s) for which it was collected and any
other permitted linked purpose. For example, we may retain: (i) certain details
and correspondence until the time limit for claims arising from the transaction
with us has expired (which is typically between 6 to 10 years after the
relevant transaction occurred, and in some cases much less than this); or (ii)
certain data to comply with regulatory requirements regarding the retention of
such data. Where Personal Data is no longer needed, we either irreversibly
anonymise the data (in which case we may further retain and use the anonymised
data) or securely destroy the data.
11.9.1 In addition to the section 7 of the
Privacy Policy, in certain circumstances, you may have the rights under EU DP
Law to ask us to:
(a) provide you with
further details on how we use and process your Personal Data;
(b) delete Personal
Data we no longer have grounds to process; and
(c) restrict how we process your
Personal Data whilst we consider an inquiry you have raised.
Please note that we will not charge a
fee when we deal with your requests in the exercise of the above rights.
11.9.2 In addition, under certain conditions,
you have the right to:
(a) where processing
is based on consent, withdraw the consent; and
(b) object to any processing of
Personal Data that we process on the "legitimate interests" or
"public interests" grounds, unless our reasons for the underlying
processing outweighs your interests, rights and freedoms.
(c) object to direct marketing
(including any profiling for such purposes) at any time.
11.9.3 You may exercise these rights by
contacting us at the contact details in section 10 of the Privacy Policy.
Please note that we will not charge a fee when we deal with your requests in
the exercise of these rights.
11.9.4 These rights are subject to certain
exemptions to safeguard the public interest (e.g. the prevention or detection
of crime) and our interests (e.g. the maintenance of legal privilege). We will
aim to respond to requests within 30 days.
11.9.5 If we are unable to resolve an inquiry
or a complaint, you have the right to contact the data protection regulator in
the country in which you are based.
NOTE 1 : Under European
data protection law (EU DP Law), certain categories of Personal Data are
considered particularly sensitive and therefore as needing additional
protection. These categories include information about health, racial or ethnic
origin, political opinions, religious beliefs, trade union membership or your
sexual orientation and genetic and biometric data. Information concerning
criminal convictions and offences is also viewed as sensitive under EU DP Law.
Last update: Oct 2018