This Personal Data Processing Policy governs the collection, use, storage, transfer, protection, and deletion of personal data of users of the Where-My-Pet website and related services.

This Policy has been developed with regard to international requirements and best practices in the field of personal data protection, including, where applicable, the European Union GDPR, the UK GDPR and the United Kingdom Data Protection Act 2018, the CCPA/CPRA and other laws of certain U.S. states, Canada’s PIPEDA, Brazil’s LGPD, Australia’s Privacy Act 1988, Japan’s APPI, South Africa’s POPIA, as well as other applicable privacy and data protection laws.

By using the Where-My-Pet website and services, the user confirms that they have read this Policy and understand how their personal data is processed.

1. General Provisions

This Policy applies to all users of the website, mobile and web interfaces, feedback forms, personal accounts, listings, comments, notifications, and other functions of the Where-My-Pet service.

If, in a specific country, state, or other jurisdiction, additional mandatory requirements apply to the processing of personal data, such requirements shall apply to the extent that they are mandatory for the operator.

2. Terms

Personal Data — any information relating directly or indirectly to an identified or identifiable natural person.

Processing of Personal Data — any action or set of actions performed on personal data, including collection, recording, storage, use, transfer, restriction, deletion, and destruction.

User — any person using the Where-My-Pet website or services.

Operator / Controller — a person or entity that determines the purposes and means of processing personal data. For the purposes of this Policy, such entity is EIG Company.

3. What Data We May Collect

3.1. Data Provided by the User

• name, alias, or nickname;
• email address;
• phone number, if provided by the user;
• account and authentication data;
• information about pets, including name, description, photographs, identifying features, place of disappearance or discovery, date, and other information posted in listings;
• messages, support requests, comments, reviews, applications, and other materials submitted by the user through the service.

3.2. Data Collected Automatically

• IP address;
• device type, browser, operating system, and interface language;
• technical logs, information about page visits, actions on the website, access time, and referral sources;
• cookies, local identifiers, pixels, tags, and similar technologies;
• analytics data collected through web analytics and statistical tools.

3.3. Data from Third-Party Sources

• data obtained through authentication via third-party services, if such functionality is used;
• data received from partners or service providers to the extent necessary for the operation of the service;
• information that the user has made publicly available themselves, if it is used within the scope of the service functionality.

3.4. Sensitive and Special Categories of Data

The service is not intended for the systematic collection of special categories of personal data, such as health information, biometric data, political opinions, religious beliefs, racial or ethnic origin, unless otherwise expressly required by law or voluntarily provided by the user on their own initiative.

4. Purposes of Personal Data Processing

Personal data may be processed for the following purposes:

• providing access to the website and its functions;
• creating, publishing, and promoting listings about lost, found, and adoptable pets;
• matching listings, sending match notifications, and assisting in the search for animals;
• facilitating communication between users of the service;
• processing inquiries, applications, and support requests;
• sending service notifications, emails, push notifications, and other messages related to the operation of the service;
• ensuring security, preventing abuse, fraud, spam, and violations of the service rules;
• analytics, statistics, audits, product development, and service quality improvement;
• compliance with applicable laws, court orders, and mandatory requirements of public authorities;
• protection of the rights and legitimate interests of the operator, users, and third parties.

5. Legal Bases for Processing

Personal data may be processed on one or more of the following legal bases:

• the user’s consent;
• the necessity to perform a contract or provide a service at the user’s request;
• the legitimate interests of the operator, provided that such interests do not override the user’s rights and freedoms;
• compliance with legal obligations.

6. Cookies and Tracking Technologies

The website may use cookies and similar technologies for the proper functioning of the service, remembering user settings, analyzing user behavior, improving interfaces, measuring the effectiveness of features, and, where there is a lawful basis, for marketing and advertising purposes.

In jurisdictions where required by law, prior user consent is requested for the use of non-essential cookies and similar technologies.

The user has the right to change cookie settings in their browser, on their device, or through consent management tools available on the website.

7. Transfer of Personal Data to Third Parties

We may transfer personal data to third parties only to the extent necessary to achieve lawful processing purposes, including:

• hosting providers, cloud platforms, email services, and other technical services;
• analytics and statistical systems;
• partner organizations, shelters, volunteer groups, or other participants in the service ecosystem — only if necessary for the operation of a declared function, for fulfilling a user request, or where another lawful basis exists;
• public authorities, courts, law enforcement agencies, and other authorized entities — where required by law.

We do not sell users’ personal data and do not transfer it for monetary consideration as a standalone product.

8. International Data Transfers

Since the service may use international infrastructure and service providers, personal data may be processed and stored outside the user’s country of residence.

In such cases, the operator takes reasonable measures to ensure an adequate level of data protection, including the use of contractual safeguards, standard contractual clauses, adequacy decisions, or other mechanisms provided by applicable law.

9. Data Retention Periods

Personal data is retained no longer than necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Once the processing purposes have been achieved, the data is deleted, anonymized, or otherwise removed from active use, unless its further retention is required for compliance with legal obligations, dispute resolution, rights protection, or mandatory recordkeeping.

10. Security of Personal Data

The operator takes reasonable technical, physical, and organizational measures to protect personal data against accidental or unlawful loss, destruction, alteration, disclosure, unauthorized access, and other unlawful actions.

Such measures may include:

• restricting access to data on a need-to-know basis;
• using secure protocols and security tools;
• internal access control and monitoring procedures;
• backups and other infrastructure resilience measures;
• screening vendors and contractors with access to data.

11. User Rights

Depending on the user’s country of residence and applicable law, the user may have the right to:

• request access to their personal data;
• require correction of inaccurate or incomplete data;
• request deletion of data where there are lawful grounds for doing so;
• request restriction of processing;
• object to certain types of processing;
• receive data in a portable format, where provided by law;
• withdraw previously given consent;
• lodge a complaint with a competent supervisory authority or other authorized data protection body.

To exercise these rights, the user may send a request to: info@where-my-pet.com.

12. Additional Provisions for Certain Jurisdictions

If special laws of a particular country or region apply to the relationship with the user, such laws shall prevail to the extent that they are mandatory.

This may include, among other things:

• additional rights of data subjects in the European Union and the European Economic Area;
• consumer rights in certain U.S. states, including the right to know, the right to delete, and the right to object to certain uses of data;
• requirements of the laws of Canada, the United Kingdom, Australia, Japan, Brazil, South Africa, and other countries where the service is used on a lawful basis.

13. Children’s Data

The service is not intended for persons who have not reached the minimum age established by applicable law for independently consenting to data processing.

If the operator becomes aware that a child’s personal data has been collected without an appropriate legal basis, such data will be deleted within a reasonable period of time.

14. Automated Processing and Profiling

The service may use automated algorithms for matching suggestions, ranking listings, filtering content, detecting suspicious activity, and improving search quality. Such mechanisms are used within the limits permitted by law.

If, in a specific jurisdiction, the user has special rights regarding decisions made solely by automated means, such rights shall be provided to the extent established by applicable law.

15. Security Breach Notifications

In the event of a personal data security breach, the operator shall act in accordance with applicable law, including taking measures to contain the incident, assess it, mitigate its consequences, and, where necessary, notify users and competent authorities within the time limits established by law.

16. Changes to the Policy

The operator has the right to amend this Policy at any time. The current version shall be published on the website and shall take effect from the moment of publication, unless otherwise expressly stated in the new version.

In the event of material changes, the operator may additionally notify users through available means of communication or through the service interface.

17. Contact Information

For any questions related to the processing of personal data, the user may contact the operator at: info@where-my-pet.com.

18. Final Provisions

By using the Where-My-Pet website and services, the user confirms that they have read this Policy and accept its provisions to the extent applicable to their interaction with the service.

If any provision of this Policy is found invalid or unenforceable in any jurisdiction, this shall not affect the validity of the remaining provisions.