Privacy Policy

9th January 2019

1. OVERVIEW

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”).

1.3. Pod Trackers is committed to the protection of your personal information and has developed this Privacy Policy in line with the General Data Protection Regulations (GDPR).

1.4. This Privacy Policy is important. It applies to the collection, storage, use and dissemination by Pod Trackers and any related body corporate or affiliate of Pod Trackers (Pod Trackers’ Group) of your personal information obtained by your use of the Website, App and Services.

1.5. We may amend this Privacy Policy from time to time and will provide notice via the Website. Your continued use of the Website or App following any such amendment will be confirmation of your acceptance of the amendments.

1.6. Before you supply any Personal Information (as defined below) to Pod Trackers or any member of the Pod Trackers’ Group, please review this Privacy Policy. This Privacy Policy as amended from time to time on this Website will apply to your purchase and use of Pod Trackers’ products.

1.7. This Privacy Policy covers the following sections:

1. Overview
2. Collection of Personal Information
3. Storage and Security of Personal Information
4. Use and Disclosure of Personal Information
5. Access to Personal Information
6. Children’s Privacy
7. Disclaimer
8. Contact Us
9. Acceptance

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 [email protected]

2.5. Pod Trackers may collect Personal Information about you and your Pet Data through your use of the Product and Services to locate your pets. The Product and Services store a series of location data and activity data relating to your use and your pet’s use of the Product. This data is essential to provide the features of the App and without it, you will not be able to use the Product and Services. We may also use the data for pet research for example to better understand pet behavior and for relevant marketing communication in accordance with this Privacy Policy.

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:

a) complete your retail transactions
b) register and service your use of our products
c) deliver the features of the App
d) improve our service to you where possible
e) enhance your use of the Website; and
f) 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.

2.10. One of the means we use to track your use of the Website is by means of a ‘cookie’ stored on your computer’s hard drive by your web browser. On each visit to the Website, the Pod Trackers’ web browser will recognise the cookie and give Pod Trackers information about your visit. The cookie does not contain information that personally identifies you and Pod Trackers does not use cookies for that purpose. Pod Trackers uses cookies to learn about your preferences and the way that you use the Website, so that it can improve the Website. Most browsers accept cookies automatically, but you should also be able to alter the settings of the browser to refuse cookies. You should note that de-activating cookies may mean that you will no longer be able to enjoy the full operational capabilities of the Website.

2.11. We will only collect Personal Information that is necessary for one or more of our stated requirements or functions. We will destroy or de-identify any Personal Information that is no longer needed including any Personal Information that is unsolicited or that we inadvertently collect and that is not necessary for our stated requirements or functions. We will destroy any Personal Information it holds about you which it no longer requires under the terms of this Privacy Policy. We may keep Pet Data indefinitely for the purpose of pet research and to improve our Products and Services.

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 protected] 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

4.1. By accepting this privacy policy, Pod Trackers may send you service messages relating to your use of the Products and Services.

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 [email protected] 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:

a) Right to access to the personal information which Pod Trackers has collected about you through the Website, App and from third party sources
b) Right to correct your personal information by amending your details on the Website or App, or by contacting us
c) Right to request deletion of your personal information in certain circumstances
d) Right to temporarily suspend the processing of your personal information
e) Right to take your data with you
f) Right to object to processing in certain circumstances
g) Right to opt-out of automatic decision making

You can contact us directly at [email protected] 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

6.1. Pod Trackers requests that for all persons under 18 years of age, a parent or legal guardian consent to that person’s use of this Website and explain this Privacy Policy to them.

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 [email protected]

7. DISCLAIMER

7.1. We will only collect, use or disclose your Personal Information as follows:

a) in compliance with this Privacy Policy;
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.

7.3. Company Linked Websites may collect your Personal Information. You acknowledge that Pod Trackers is not responsible for the privacy Policy (if any), content or practices of the Linked Websites. We encourage you to always read the applicable privacy policy of any Linked Website on exiting this Website.

8. CONTACT US

8.1. If you have any queries regarding this Privacy Policy or should you have any trouble correcting any of your Personal Information or would like to gain access to your Personal Information or should you wish to lodge a complaint in relation to our use or disclosure of your Personal Information, please email us at [email protected]

9. ACCEPTANCE

9.1. By accepting this privacy policy, you acknowledge that the Pod Trackers’ Group, our Partners and each of their officers, employees, agents and contractors are permitted to collect, store, use and disclose your Personal Information in order to provide you with the Products and Services, in the manner set out in this Privacy Policy.

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.

9.4. This Privacy Policy has been translated into other languages for convenience, however, the original English version must be relied upon for the binding terms of this agreement.