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Privacy Policy

 

Last modified: 08.26.2024 

 

  1. Introduction

This Privacy Policy for Pawsync describes how L&H Y Trading Inc. and its subsidiaries and affiliates (collectively, "Pawsync", "our", "us" or "we") collect, use, share, and store information. Our goal is to provide you with a positive experience when using our Websites, App, products, and services, while at the same time keeping your personal information secure.

This policy applies to information we collect:

  • when you install, register with, access, or use Pawsync App (“App”), or Pawsync websites (“Websites”), and our services;
  • when you use smart products and/or their functionalities connected to, or through, the App;
  • when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy;
  • when you subscribe to our newsletters, promotions or other marketing initiatives; and
  • when you contact or interact with us, for example, in email, text, and other electronic messages between you and our Websites, App, or our Customer Service team.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, or do not want us to collect the information, do not download, register with, or use the App or Websites. By registering with, or using the App, Websites, or services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of our App, Websites, or services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

  1. Information We May Collect and How We Collect It

Information we may collect

When You Use Our App, Websites, or Related Products and Services, We May Collect the Following Information:

  • Profile Data, such as your username, password, email address, region, and profile photo.  
  • Logistics Data, such as receiver’s name, phone number, delivery address, postal code, and related product information.
  • Financial Data, before placing orders, you'll be asked to provide financial data, including card numbers, card expiration dates, CVC codes, account holder name, and billing addresses. Importantly, we do not store this information. Instead, it is securely processed by our credit card payment service providers, such as PayPal.
  • Contact Data, such as veterinarian’s name, pet clinic’s name, address, and phone.  
  • Technical Data, such as IP address, your mobile phone device information, smart pet device information, internet connection data, and Wi-Fi information.  
  • Usage Data, such as details of your use of any of our devices, the App, the Websites, the history of operation, your pet feeding records, and records of your sound of calling the pets to eat or drink.  
  • Consumer Preference Data, such as products purchased, motivation for purchase, your preferences in receiving marketing from us and third parties, and other behavior and preferences.  
  • Communication Data, such as your communication preferences, your contact information, the audio recordings of calls when you call the Customer Service team and records and copies of your correspondence (including email addresses and phone numbers), if you contact us.  
  • The correspondence may include information like proof of identification, gender, employment, medical information, or health insurance information when needed for Customer Service team to provide related support.  
  • Content Data, such as the content you post on the Websites or the App, and records of your visit to the pet clinic you provide to us. The content data that you post on public areas may be transmitted to other users or third parties at your own risk. Therefore, we cannot and do not guarantee that your content data will not be viewed by unauthorized persons.  
  • Pet Data, such as pet's profile photo, species, weight, age, nickname, birthday, breed, life condition, body condition, the food it takes, certain veterinary clinical health data. 
  • Aggregated Data

We may store and use any anonymized or aggregated data such as statistical or demographic data that incorporates or is derived from your personal information, which is not itself personal information (“Aggregated Data”); however, we will not do so in a way that identifies you personally. For example, we may aggregate users’ behavioral data to calculate the percentage of users accessing a specific App feature, as well as facilitate and measure the effectiveness of advertisements. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Cookies and Similar Technology

The Technologies We Use for Automatic Information Collection May Include (for more information, see Cookie Policy ):

  • Cookies (or browser cookies). 
  • Web Beacons. 
  • Flash Cookies. 
  • Click-through URL. 
  • And other similar technologies.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may include personal information. It helps us to improve our Websites or App and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Websites and App according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Websites or App, including identifying you as a member of Pawsync Membership Program.
  • Most websites will prompt you before accepting cookies. You may also change your cookies settings in your browser. Note, depending on your device or browser, it may not be possible to disable all tracking mechanisms. Also, if you set your browser to reject all cookies, parts of this Websites may not work for you. For more information, please see our Cookie Policy .

Categories of Personal Information We Collected

The Company has collected the following categories of personal information directly and/or indirectly from consumers within the last 12 months:

Category

Examples

Collected

Identifiers.

Profile Data, Logistics Data, Technical Data, or Communication Data.

YES

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Profile Data, Logistics Data, Financial Data, or Communication Data.

YES

Protected classification characteristics under California or federal law.

Communication Data.

YES, only when needed in conversation with Customer Service for related support.

Commercial information.

Logistics Data, or Consumer Preference Data.

YES

Internet or other similar network activity.

Technical Data, Usage Data.

YES

Sensory data.

Communication Data.

YES

Professional or employment-related information.

Communication Data.

YES, only when needed in conversation with Customer Service for related support.

Inferences drawn from other personal information.

Consumer Preference Data.

YES

Third-Parties, Service Providers, Sites, and Features 

For information you share publicly or provide to us through social media platforms, we may use that information to understand your preferences related to our current and future services and product lines. We may also analyze feedback on the quality of our applications and related services to improve our applications and services. We are also interested in requests for future applications and services. 

 

  1. How We Use the Collected Information

We use information that we collect about you or that you provide to us, including any personal data, generally based on the following purposes:

Types of Data

Specific Purposes

Legal Basis for Processing under GDPR (for EEA and UK Users)

Profile Data

l  To allow you to register and log in to your account.

l  To enable you to place orders.

l  To investigate and prevent fraud.

l  To enable you to personalize your profile and provide you with region-available services.

l  To include you in Pawsync Membership Program.

l  Your consent

l  Performance of a contract with you

l  Necessary for our legitimate interests (for developing our products/services, running and growing our business, to prevent fraud)

Logistics Data

l  To fulfil your orders and deliver products to you.

l  To process warranty, returns and/or repairs.

l  To include you in Pawsync Membership Program.

l  Your consent

l  Performance of a contract with you

l  Necessary for our legitimate interests (to keep records updated and to analyze how customers use our products/ services)

Financial Data

l  To process payments.

l  To detect and prevent fraud.

l  Your consent

l  Performance of a contract with you

l  Necessary for our legitimate interests (to prevent fraud)

Contact Data

l  To operate, maintain, and provide you with the features and functionalities. 

l  Your consent

Technical Data

l  To operate, maintain, and provide you with the features and functionalities.

l  To identify your device for diagnostic purposes and fraud prevention.

l  To improve or develop our products and new technologies via analytics.

l  To personalize the product functionalities and services and improve our marketing strategies.

l  Necessary for our legitimate interests (for developing our products/services, running and growing our business, provision of administration and IT services, network security)

Usage Data

l  To operate, maintain, and provide to you the features and functionalities, to identify your device for diagnostic purposes and fraud prevention, to improve or develop our products and new technologies via analytics, and to personalize the product functionalities and improve our marketing strategies.

l  To enable you to manually input and track your record about pets, tailor available features to your particularized needs, and provide you with personalized recommendations, product offerings and promotions.  

l  To provide personalized recommended services.

l  To provide customer services, such as dealing with any inquiries and complaints.

l  Your consent

l  Necessary for our legitimate interests (for developing our products/services, running and growing our business, provision of administration and IT services, network security)

Consumer Preference Data

l  To provide personalized recommended content and services which you can turn off through visiting account setting in the App.

l  To develop new products and features available through our service or otherwise improve our service.

l  To include you in Pawsync Membership Program.

l  Your consent

l  Necessary for our legitimate interests (for developing our products/services, running and growing our business)

Communication Data

l  To communicate with you.

l  To provide customer services, such as dealing with any inquiries and complaints.

l  To provide new promotions to you and to provide you with information on new products and/or services.

l  Your consent

l  Necessary for our legitimate interests (for developing our products/services, running and growing our business)

Content Data

l  To operate, maintain, and provide to you the features and functionalities, to improve or develop our products and new technologies via analytics, and to personalize the product functionalities and improve our marketing strategies.

l  Your consent

l  Necessary for our legitimate interests (for developing our products/services, running and growing our business)

Pet Data

l  To operate, maintain, and provide to you the features and functionalities, to improve or develop our products and new technologies via analytics, and to personalize the product functionalities and improve our marketing strategies.  

l  Your consent

l  Necessary for our legitimate interests (for developing our products/services, running and growing our business)

  1. Personal Information Sharing and Disclosures

We may disclose personal information that we collect or you provide in the following ways:

  • Sharing with consent: with your consent or at your request, we will share your personal data within the scope of your consent/request with specific third parties or categories of third parties authorized or designated by you.
  • Sharing with our subsidiaries, parents and affiliates: we may share your personal information with our subsidiaries, parents, affiliates only for explicit, and legitimate purposes, and the sharing is limited only to information required by services.
  • Sharing with service providers: we also may disclose your information to contractors, service providers, or third parties we use to support our business. They usually perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, marketing, analytics, membership program, and other similar services. These service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements.
  • Sharing for complying with the law or legal process: we may be required to respond to a subpoena, court order, search warrant, administrative or judicial process, requests by law enforcement agencies, or other requests that we must respond to under applicable law. We may disclose your personal information in response to any of these requirements.
  • Sharing for protection of our legal rights and/or those of others: we may disclose your personal information to preserve the security of our mobile applications, websites, or social media accounts; resolve disputes; or assess any possible wrongdoing.
  • Sharing during asset transfer: to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
  • To enforce our rights arising from any contracts entered into between you and us, including the Terms of Use, and for billing and collection.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.

We will ensure that the lawfulness of this sharing and, if applicable, sign stringent non-disclosure agreements (NDAs) and/or data processing clauses with the companies, organizations, and individuals with whom personal data is shared, requiring them to comply with this policy and take appropriate confidentiality and security measures when processing personal information.

We may also share Aggregate Data collected about the application and device usage, as long as the data does not identify any specific individuals, to analyze trends about home networking and utility use, to show third parties how their products could work with our products and to generally improve our products and services.

In the preceding twelve (12) months, the Company has shared personal information with the categories of third parties indicated in the chart below.

Disclosure of "Sale" of Personal Data defined in Applicable States in the U.S.

While we don't sell your information for money, it's important to note that the use of cookies or sharing information with advertisers for cross-context behavioral advertising may be considered a "sale" of information in certain states. In this specific context, we are considered to be "selling" information by making personal information available to third parties through third-party website cookies. You have the option to decline these cookies through our cookie banner.

 

Personal Information Category

Category of Third-Party Recipients

Business Purpose Disclosures

Sales

Identifiers.

Affiliates, Parent, subsidiary organizations or service providers/processors.

Internet cookie data recipients like Google Analytics. See Cookie Policy .

California Customer Records personal information categories.

Affiliates, Parent, subsidiary organizations or service providers/processors.

For identifiers, we use Internet cookie data recipients like Google Analytics.  See Cookie Policy .

For Financial Data, none.  Our Websites collect payment card or banking information to complete product purchases, but we do not store such information. All payments are processed by our payment service providers.

Protected classification characteristics under California or federal law.

Affiliates, Parent, subsidiary organizations or service providers/processors.

None

Commercial information.

Affiliates, Parent, subsidiary organizations or service providers/processors.

Internet cookie data recipients like Google Analytics. See Cookie Policy .

Internet or other similar network activity.

Affiliates, Parent, subsidiary organizations or service providers/processors.

Internet cookie data recipients like Google Analytics.  See Cookie Policy .

Sensory data.

Affiliates, Parent, subsidiary organizations or service providers/processors.

None

Professional or employment-related information.

Affiliates, Parent, subsidiary organizations or service providers/processors.

None

Non-public education information.

Affiliates, Parent, subsidiary organizations or service providers/processors.

None

Inferences drawn from other personal information.

Affiliates, Parent, subsidiary organizations or service providers/processors.

Internet cookie data recipients like Google Analytics. See Cookie Policy .

  1. Retention of Personal Information

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. You may delete your Pawsync online account at any time. After you delete your online account, Pawsync will delete the personal information stored in it, including any personal information collected by smart devices, unless under which we are obligated to keep them.     

This (Section 5) does not apply to deidentified or Aggregated Data.

  1. How We Secure Personal Information

Pawsync implements reasonable and appropriate industry-standard security controls to protect personal information in its possession. Pawsync’s administrative, physical, and technical safeguards:

  • Provide assurances of the integrity and confidentiality of personal information covered by this policy.
  • Protect against reasonably anticipated threats or hazards to the security or integrity of personal information, and unauthorized uses or disclosures of such personal information; and
  • Facilitate compliance with legal frameworks of requirements under applicable data protection laws.

To this end, we take the following measures:

  • We take reasonable and feasible measures to ensure that the personal information collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We retain your personal information for no longer than is necessary for the purposes stated in this policy and privacy notice of specific product or service, unless extending the retention period is required or permitted by law.
  • We use a range of technologies such as cryptographic technologies to ensure the confidentiality of information in transmission. We implement trusted protection mechanisms to protect data and data storage servers from attacks.
  • We deploy access control mechanisms to ensure that only authorized personnel can access your personal information. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels.
  • We strictly select business partners and service providers and incorporate personal information protection requirements into commercial contracts, audits, and/or appraisal activities that are at least as stringent as the ones Pawsync itself uses, consistent with this policy.
  • We hold security and privacy protection training courses or other equivalent publicity activities to raise employees' personal information protection awareness.

The safety and security of your data also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Although we do our best to protect your personal information, unfortunately, no security measures can provide absolute protection. To cope with possible risks, such as personal information leakage, damage, and loss, we have procedures in place to deal with suspected data security breaches. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with Contact Information below.

  1. Pawsync Loyalty Program & Financial Incentives

The Pawsync Loyalty Program (the “Program”) lets participants earn or otherwise receive rewards and discounts, in return for registering and/or making purchases, including:

  • Spend-based incentives, where you earn points based upon spend levels
  • Periodic promotional discounts and offers

You can sign up for the Program by registering on our Websites. We collect and use the categories of personal information described in the “Information we may collect” section. Registration requires you to provide your first name, last name, email address, password used to create the account, and you may also elect to provide other information, including your birthday (month / day only). We will then associate that and other categories of personal information with your account, such as Technical Data, Usage Data, or Consumer Preference Data, to identify you as a member of the Program and provide you with relevant messaging, discounts, and points. These financial incentives are reasonably related to the value of the information you provide.

Full terms for the Program are available here.

You may withdraw from the Program at any time and forfeit any ongoing incentives by contacting us using the contact information below. Please also note that if you submit a request to delete your personal information, this will also automatically withdraw you from the Program and will result in the forfeiture of your incentives, including your points that you may have accumulated. Requesting the deletion of your personal information may result in the deletion of your account and accumulated incentives because we require your personal data (e.g., your name, email address, and log-in information) to be able to associate you to your account. You may elect to rejoin the Program at any time, at which time we will once again begin collecting your personal information.

Based on our reasonable and good faith estimate, we receive value from the Program in increased customer loyalty and patronage, though any value will vary by members depending on purchases made, which offers a member takes advantage of, and many other factors.

 

  1. Your Rights and Choices

Data protection laws in your country of residence may give you a number of legal rights in relation to the personal information that we hold about you. Subject to limitations set out in applicable laws, these rights may include:

Right to Know, Correct and Data Portability

You can access, correct, or modify the information you provided to us by editing your profile and adjusting your account settings.

You can also contact us to submit your right to access, correct, or modify your information.

To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with a deletion, portability, or other related request. We may, in certain situations, reject your request for access, correction, or portability, for example, we may reject access where you are unable to verify your identity.

Right to Delete

Pawsync App Account -

You can delete your App account in your account settings (Pawsync App > More > Settings > Account & Security > Delete Account), or you can delete your App account using from our link here . You can also contact us to submit your right to delete your information.  

Pawsync Website Account -

You can contact us to submit your right to delete your information.

Please note that if you request deletion of your personal information, or if you delete your account, we may retain your personal information for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Also, because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

 

Right to Opt-Out

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, please see our Cookies Policy here .
  • Promotional Offers from Pawsync. You may utilize the unsubscribe function in each promotional email. You may also submit your request to opt-out by sending us an email stating your request.

This opt-out does not apply to information provided to us as a result of a legal notice, product purchase, warranty registration, product service experience or other transactions. 

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's  .

Right to Request a List of Third Parties

If applicable under states’ law or other regulations, you may have the right to request a list of third parties whom we have shared your personal information with.

Right to Appeal a Refusal

If we can't confirm your identity or authority to make a request, or if the information is legally required to be retained, we may not be able to honor your request. If your request is denied, like in cases where we can't verify your identity, you can appeal our decision by contacting us.

Non-Discrimination

We won't treat you differently for exercising your rights and choices. However, please note that some features or functionality on our App or Websites may change or become unavailable to you based on the information you provide.

If you are a user in the EEA or in the UK, you may have additional rights

Right to restriction of processing

For users in the EEA or the UK, you have the right to restrict the processing of your personal data in accordance with applicable laws.

Right to object

For users in the EEA or the UK, you can object to the processing of certain personal data concerning you for any reason relating to your particular situation.

Withdraw consent

For users in the EEA or the UK, you have the right to withdraw consent at any time when we are relying on consent to process your personal data. However, this may not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

You can exercise your rights by contacting us. You can also lodge a complaint with the data protection regulator if you think that any of your rights have been infringed by us.

  1.  Links to Other Parties’ Websites, Products, and Services

The Websites, App, and services may contain links to third-party websites, products, and services of interest. All links to third-party websites, products, and services are provided for users' convenience only. You need to determine your interaction with such links on your own. We cannot be responsible for the protection and privacy of any information which you provide while visiting or using such third-party websites, products, and/or services and they are not governed by this policy. You should exercise caution and look at the privacy statement applicable in question.

In addition, when you download the App, certain third parties may use automatic data collection technologies to collect information about you or your device. These third parties may include: 1) your mobile device manufacturer, like Apple, Samsung and Google; and 2) your mobile service provider. These third parties may use tracking technologies to collect information about you or your online activities over time and across different websites, apps, and other online services websites. We do not control these third-party tracking technologies or how they may be used. If you have any questions, you should contact the responsible provider directly.

  1.  Data Transfer

Whenever we transfer personal data to countries outside of your country of residence, we will ensure that the data is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection. Our commitment includes ensuring that an equivalent level of protection is afforded to it by ensuring appropriate safeguards are implemented, such as, with no limitation, in the form of specific contracts approved by the European Commission. Please contact us if you want further information on the transfer of personal data outside of your country of residence.

  1.  Do Not Track Disclosures

With regard to Do Not Track (DNT), we currently don’t respond to DNT signals in browsers because no DNT standard has been adopted.

  1.   Entire Privacy Policy

We may provide you with separate privacy notices for specific products and services, and such privacy notices are incorporated into herein by reference. If there is any inconsistency between privacy notices and this Privacy Policy, the privacy notice shall prevail.

  1.   Changes to Our Privacy Policy

Our business changes constantly, and our privacy policy will also change accordingly. We may email periodic reminders of our policy, but you should check our Privacy Policy page on our Websites and/or App frequently to see the most recent changes. Unless stated otherwise, our current privacy policy applies to all data that we have about you and your account(s).

We stand behind the promises we make and will never materially change our policies and practices to make them materially less protective of user information collected in the past without the consent of affected users. However, we may amend this policy from time to time. We will make amendments to the policy by displaying an amended copy on our Websites and App, and, if necessary, by sending a notice to you by email. Any update to this Privacy Policy will be effective upon its posting on our Websites and/or App.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically checking our Privacy Policy page on our Websites and/or App for any changes.

  1.   Contact Information

Please direct all requests for assistance, questions, or complaints about our privacy practices to our team by email, postal mail, or phone at the following contact information: 

Attention: Privacy Team

Email: support@pawsync.com  

Tel: 1-888-233-4378

Postal Address: 1202 North Miller Street, Suite A, Anaheim, CA 92806 US 

If you are an EEA or UK user, please contact us via the following address:

Legal representative in EEA: ETEKCITY GmbH

Postal Address: Vossbarg 1,25524 Itzehoe, Germany

Legal representative in the UK: Vesync (UK) Co., Ltd

Postal Address: Unit G2 Havebside Industrial Estate, Fishtoft Road, Boston, PE21 0AH, United Kingdom

If you have any concerns or complaints about Pawsync’s Privacy Policy or practices, please provide information relevant to your complaint. Our privacy team will evaluate your concern or complaint based on the information you provide and send you a response. We may need to ask you for additional information to evaluate your concern or complaint. We will investigate and respond to your communications about a complaint. You may have other rights under the law and the right to contact the privacy regulator in your local jurisdiction about your concern or complaint. 

 

 

Phone

Toll-Free: 1-888-233-4378

Mon–Fri, 9:00 am–5:00 pm PST/PDT