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
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 firstname.lastname@example.org.
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)
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/.
Please further see the "Your Sharing of your Personal Information with Social Networks" above for more details on sharing your information through social networks.
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.
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 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.
EU use bases table
Purposes of the data processing
To prevent any unauthorized/fraudulent use of the Service
To offer an undisturbed Service to Users
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
11.4.1 The legal grounds for our use of Personal Data are as follows:
(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:
(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.
11.6 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
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
safeguards we apply to the export of your Personal Data.
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.
(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.
11.9.4 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