9th January 2019
1.1. At Pod, we’re committed to making sure you don’t have to worry about losing your pet. There are some aspects of using tracking technology which may affect your privacy, so we’ve put together a policy to define how we use information gathered from the Website, App and Service to help you understand how this works.
1.2. Pod Trackers UK Ltd (Company Number 9886136) located at 10 John Street, London, WC1N 2EB United Kingdom (Pod Trackers, our, us, we) is the data controller. We publish and maintain the website at podtrackers.com (the “Website”), the web application at app.podtrackers.com and various mobile applications (collectively, the “App”) and deliver a GPS tracking product (the “Product”) and associates services (the “Services”).
a) Collection of Personal Information
b) Storage and Security of Personal Information
c) Use and Disclosure of Personal Information
d) Access to Personal Information
e) Children’s Privacy
g) Contact Us
i) Applicable law
2. COLLECTION OF PERSONAL INFORMATION
2.1. Pod Trackers collects and uses information that may personally identify you such as your name, e-mail address, home address, location and contact telephone number (“Personal Information”). Pod Trackers may also collect information about your pets including your pet’s age, breed, location and activity data (“Pet Data”) – we don’t consider this to be personal information about you.
2.2. You have the right to withhold your name or to use a pseudonym in place of your real name to identify yourself when registering for the App, but you will appreciate that in some cases, such as the purchase of goods by means of a credit card, you will need to supply your real name.
2.3. Pod Trackers collects Personal Information from you when you visit the Website, use the App or Service and when you purchase our products. We may collect your Personal Information through on-line shopping purchases, in-store purchases, entry into trade promotions and competitions, subscribing to our newsletter, signing up as a member, creating a user account, sending ‘contact us’ messages or other correspondence through the Website or by post, through advertising, research and direct marketing and by other means including information you supply to third party retail stores selling our products.
2.4. If you choose to engage in communication with us that may be accessible by others, such as through social media, we strongly recommend that you don’t include any Personal Information. If any communication sent by you through public channels includes Personal Information, we can’t be held liable for any breach of privacy in doing so. To help protect your privacy, our preferred method for support is via email to firstname.lastname@example.org.
2.6. Your Personal Information may also be collected by the network operator providing the connectivity for the SIM card and you agree that such information is accessible by them and may be passed onto us.
2.7. Pod Trackers may collect Personal Information about you from other members of the Pod Trackers Group, distributors, retailers, marketing partners and other service providers when you request information about our products and services. This may include your name, email address and which Product/s and Services you may be interested in.
2.8. The Purposes for data processing are to enable us to:
1. complete your retail transactions
2. register and service your use of our products
3. deliver the features of the App
4. improve our service to you where possible
5. enhance your use of the Website; and
6. assist us to gain an understanding of your preferences and requirements in order that we can provide information, goods and services that are of interest to you.
2.9. Some of the information collected will not personally identify you but will instead track your use of the Website so that we can better understand how the Website is used by customers and in turn enhance and improve your experience in shopping on the Website and when shopping for Pod Trackers’ products in third party retail stores.
3. STORAGE AND SECURITY OF PERSONAL INFORMATION
3.1. Pod Trackers will use its reasonable endeavours to protect and maintain the security of your Personal Information and to make the Website, App and Services as secure as reasonably possible against unauthorised access, modification or disclosure and against interference, misuse and loss. This includes the implementation of security software in our cloud infrastructure and following industry best practices for authorization, encryption and access controls. We also apply recommended security measures to our Products and perform security reviews of our environment. Pod Trackers’ officers, employees, agents and contractors are expected to observe the confidentiality of your Personal Information.
3.2. To assist Pod Trackers with protecting all Personal Information, we request that you email us at email@example.com immediately if you become aware of any unauthorised use of your Personal Information in connection with the Website. We will confirm receipt of your complaint and advise you what steps will be taken to investigate the matter and endeavour to resolve the matter.
4. USE AND DISCLOSURE OF PERSONAL INFORMATION
4.2. Pod Trackers may disclose your Personal Information to any and all of the following where it is required to provide you the services:
a) Any members of Pod Trackers Group;
b) To third party contractors, business partners, distributors, suppliers and other entities (Partners).
4.3. By opting-in to receive marketing material, you accept that members of Pod Trackers Group and/or our Partners may occasionally send you information about products, services, offers, research or other material which we believe may be of interest to you. .
4.4. Members of Pod Trackers Group and our Partners may be located both within and outside of the European Economic Area (EEA) and you acknowledge that your Personal Information will be disclosed to and stored outside of the EEA in order to deliver the Services to you. We have implemented appropriate safeguards to ensure the privacy of your Personal Information is maintained and details of these safeguards can be provided upon request to our support team.
4.5. If you would like to unsubscribe from receiving direct marketing communications from Pod Trackers or do not want us to share your Personal Information with any Partners, you may email us at firstname.lastname@example.org or follow the steps to unsubscribe which are presented in every email communication you receive from us. Pod Trackers will comply with your request within a reasonable period of receipt of such request.
5. RIGHTS OVER YOUR PERSONAL INFORMATION
5.1. Pod Trackers respects your right to control how we process your personal information, and as such you may exercise the following rights over your personal information:
1. Right to access to the personal information which Pod Trackers has collected about you through the Website, App and from third party sources
2. Right to correct your personal information by amending your details on the Website or App, or by contacting us
3. Right to request deletion of your personal information in certain circumstances
4. Right to temporarily suspend the processing of your personal information
5. Right to take your data with you
6. Right to object to processing in certain circumstances
7. Right to opt-out of automatic decision making
5.2 You can contact us directly at email@example.com to exercise any of your rights under the GDPR. We may require you to provide particulars of your identity before acting on your request. In certain circumstances, we can reject your request to exercise your rights, in such a case we will let you know and provide you with the reasons why.
6. CHILDREN’S PRIVACY
6.2. All persons under the age of 18 must obtain the consent of their parent or legal guardian before using this Website or submitting any information to this Website.
6.3. If a minor has provided us with Personal Information without the consent of his or her parent or legal guardian, such information may be removed by emailing us at firstname.lastname@example.org.
7.1. We will only collect, use or disclose your Personal Information as follows:
b) to comply with any applicable law;
c) to protect the rights or property of any member of Pod Trackers’ Group; or
d) for confidential dispute resolution processes.
7.2. You may link directly to Websites operated by Partners (Linked Websites) in the Website. Although certain Linked Websites may be co-branded with Pod Trackers’ logo or name, you acknowledge that such Websites may not be operated or controlled by Pod Trackers.
8. CONTACT US
9.2. The suppliers of SIM cards within the Products, including Vodafone Procurement Company S.à r.l. (RCS Luxembourg B 97.920), Vodafone Hutchison Australia Pty Limited (ABN 76 096 304 620), Twilio Inc. and others as updated on the website from time-to-time (Operators), are authorised to collect, use and disclose your Personal Information for the purposes of:
a) assisting law enforcement agencies in relation to the enforcement of criminal and other laws;
b) all purposes associated with the provision of services to Pod Trackers including any billing and account management for Pod Trackers;
c) implementing The Operators’ agreement with Pod Trackers for the supply and servicing of the SIM cards;
d) The Operators’ business planning and product development;
e) assisting internal investigations conducted by The Operators into suspected fraud, misuse of SIM card services or other unlawful activities;
f) complying with all applicable laws, regulations and industry codes;
g) sharing your Personal Information with members of the Operators’ group.
9.3. In the event of a merger, acquisition or sale of the whole or part of the business of Pod Trackers, we reserve the right to transfer your Personal Information as part of any such transaction.