Privacy Policy

1.  Introduction and Our Commitment to Privacy

PAWLA LTD (“we”, “us”, “our”, or “Company”) is committed to protecting
your privacy and ensuring the security of your personal information.
This Privacy Policy explains how we collect, use, disclose, store, and
protect your personal data when you use Pawla, our social networking
application for dog owners and enthusiasts (“the App” or “Pawla”).

This Privacy Policy is governed by the laws of England and Wales and
complies with the UK General Data Protection Regulation (UK GDPR) and
the Data Protection Act 2018.

By using Pawla, you acknowledge that you have read, understood, and
agree to this Privacy Policy. If you do not agree with this policy,
please do not use the App.

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2.  Company Information and Data Controller

PAWLA LTD is the data controller responsible for your personal data.

Company Name: PAWLA LTD Company Number: 17137462 Registered Office
Address: 3rd Floor, 86-90 Paul Street London, England EC2A 4NE United
Kingdom

For privacy-related inquiries, please contact us at: Email:
support@pawla.app Website: www.heypawla.com

We comply with UK data protection law and, where required, with
Information Commissioner’s Office (ICO) guidance.

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3.  Personal Data We Collect

We collect the following categories of personal data:

ACCOUNT AND PROFILE INFORMATION: • Name, username, email address, date
of birth, gender, and profile photos • Interests, about-me text,
referral source, and notification preferences • Goals and walk
preferences you choose to save in the app

DOG INFORMATION: • Dog name, breed, age or birthday, gender, training
status, photos, and optional happy-moment photos • Optional details you
choose to add, such as size, weight, neuter or spay status, mixed-breed
percentage, energy or behaviour traits, favourite activities, walking
style, health or diet notes, and adoption story

LOCATION AND WALK DATA: • Approximate area labels, map location, and
activity location details • GPS route points, distance, duration, pace,
and related walk metadata when you record a walk • Optional weather
snapshot captured at walk save time • Optional dog and owner mood
check-ins after a walk • Records of walks you discard or cancel before
saving

SOCIAL AND COMMUNITY ACTIVITY: • Friends, messages, chats, club
membership, activities, posts, comments, likes, shares, and tagged
friends • Walk companions, event tags, and group activity links on
posts

SUPPORT AND FEEDBACK: • Messages you send to our team through the App
• Problem reports and other support requests

TECHNICAL AND USAGE INFORMATION: • Device and app information,
interaction signals such as last active timestamps, and diagnostic or
crash data • Push notification tokens where you enable notifications •
Limited technical data when you browse Pawla without signing in (for
example, device type and basic usage needed to run the App)

We collect this data directly from you when you register, complete your
profile, use location or walk features, post content, communicate with
other users, contact support, or interact with app features. If you
browse as a guest, we collect only the limited technical data needed to
provide the App until you create an account.

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4.  How We Use Your Personal Data

We use your personal data for the following purposes:

APP FUNCTIONALITY: • To create and manage your account • To display
profiles, posts, walks, chats, clubs, and activities • To enable
communication between users • To provide location-based matching,
activity discovery, and walk recording features • To save optional
goals, preferences, moods, and insights you choose to provide • To
operate streaks, walk history, and related in-app progress features •
To send notifications you have enabled

SERVICE IMPROVEMENT AND SECURITY: • To maintain, secure, and improve
Pawla • To understand how features are used and fix bugs or performance
issues • To provide customer support and respond to reports or team
messages • To prevent abuse, fraud, and misuse of the App

COMMUNICATIONS: • To send service-related messages about your account
or the App • To send marketing or promotional communications only where
permitted by law and, where required, with your consent

We do not sell your personal data. We use your data only for legitimate
purposes related to running Pawla and in accordance with applicable data
protection laws.

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5.  Legal Basis for Processing (GDPR)

Under UK GDPR, we process your personal data based on the following
legal bases:

CONSENT: • When you explicitly consent to data processing (e.g.,
marketing communications, optional product analytics on iOS via App
Tracking Transparency) • You can withdraw consent at any time through
app or device settings or by contacting us

CONTRACT PERFORMANCE: • To provide and maintain the App’s core
functionality • To fulfill our Terms of Service with you • To enable
features you request

LEGITIMATE INTERESTS: • To improve and develop our services • To
ensure app security and prevent fraud • To analyze usage patterns for
service improvement • To provide customer support

LEGAL OBLIGATION: • To comply with applicable laws and regulations •
To respond to legal requests or court orders • To protect our rights
and interests

We will always ensure that our legitimate interests do not override your
fundamental rights and freedoms.

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6.  Data Sharing and Disclosure

We do NOT sell your personal data to third parties. We may share your
data only in the following circumstances:

WITH OTHER USERS: • Your profile information (name, photos, dog
information) is visible to other users as part of the App’s
functionality • Your approximate location is shared to enable matching
with nearby users • Your messages are shared with intended recipients
• Exact addresses are never publicly displayed

WITH SERVICE PROVIDERS: • Cloud hosting providers (for data storage) •
Analytics services (for app improvement) • Customer support platforms
• Payment processors (if applicable) • All service providers are bound
by strict confidentiality agreements

WHEN REQUIRED BY LAW: • To comply with legal obligations or court
orders • To respond to government requests • To protect our rights,
property, or safety • To prevent fraud or abuse

BUSINESS TRANSFERS: • In the event of a merger, acquisition, or sale of
assets • Users will be notified of any change in data ownership

WITH YOUR CONSENT: • We may share data with third parties if you
explicitly consent • You can withdraw consent at any time

We require all third parties to respect your privacy and handle your
data in accordance with applicable data protection laws.

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7.  App Activity, Analytics, and Notifications

Pawla records product and usage signals to operate and improve the
service. This can include feature interactions, screens viewed, content
you create, walk and engagement summaries stored on your account, and
technical or diagnostic information.

PRODUCT ANALYTICS: • We use product analytics providers, including
Mixpanel and PostHog (EU-hosted), to understand how features are used
and to improve Pawla • On iOS native builds, we may also use Firebase
Analytics • Analytics are linked to your Firebase user ID, not your
email address • On iOS, optional analytics tracking starts opted out
and is enabled only if you allow App Tracking Transparency when prompted
• Analytics events may include, for example, sign-up completion, screen
views, walk activity, messages sent, and reward claims

CRASH AND DIAGNOSTICS: • On iOS native builds, we use Firebase
Crashlytics to collect crash reports and diagnostic data to fix
stability issues

We do not sell your personal data. We do not use your data for
third-party advertising profiles across unrelated apps or websites.

If you enable push notifications, we may store a device push token so we
can deliver alerts according to your notification settings. You can
change or disable notifications in the App or your device settings.

If we introduce additional analytics or diagnostic tools, we will update
this policy and provide any choices required by law.

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8.  Location Data and Privacy

We collect and use location data to provide location-based and
walk-related features:

TYPES OF LOCATION DATA: • Approximate area labels and map location used
for discovery, posts, and activities • GPS route points, distance,
pace, and related metadata when you record a walk • Activity or meetup
location details you choose to create or join

HOW WE USE LOCATION DATA: • To show nearby users, activities, clubs,
and events • To label posts and walks with an approximate area • To
record and display walks you choose to save • To maintain
favourite-area and routine summaries derived from your saved activity

PRIVACY PROTECTIONS: • Exact home addresses are not publicly displayed
to other users • Walk routes and location-related content are shared
according to your visibility choices and feature settings • Location
data is stored securely • You can disable location permissions in your
device settings at any time • Disabling location services may limit app
functionality

We do not continuously track your location when you are not using
relevant features. Background location may be used only to support an
active walk you have started, subject to device permissions.

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9.  Data Security Measures

We implement comprehensive security measures to protect your personal
data:

TECHNICAL MEASURES: • Encryption of data in transit (using TLS/SSL) •
Encryption of data at rest (stored data) • Secure authentication and
access controls • Regular security audits and assessments • Firewall
and intrusion detection systems • Secure backup and disaster recovery
procedures

ORGANISATIONAL MEASURES: • Limited access to personal data on a
need-to-know basis • Employee training on data protection •
Confidentiality agreements with all staff • Regular security reviews
and updates • Incident response procedures

However, no method of transmission over the internet or electronic
storage is 100% secure. While we strive to protect your data, we cannot
guarantee absolute security. We encourage you to: • Use strong
passwords • Keep your account credentials confidential • Enable
two-factor authentication if available • Report any security concerns
immediately

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10. Data Retention and Storage

We retain your personal data only for as long as necessary:

RETENTION PERIODS: • Account Data: Retained while your account is
active and for 30 days after deletion • Location Data: Retained for 90
days after last use, then anonymized • Messages and Communications:
Retained for 1 year after last message • Usage Data: Retained for 2
years for analytics purposes • Crash and Diagnostic Data: Retained for
90 days • Marketing Data: Retained until you opt-out or unsubscribe

LEGAL REQUIREMENTS: • Some data may be retained longer if required by
law • Financial records: 7 years (if applicable) • Legal disputes:
Until resolution plus applicable limitation period

DELETION: • You can request deletion of your data at any time • We
will delete data within 30 days of your request • Some data may be
retained in anonymized form for analytics • Data may be retained if
required by law or for legitimate business purposes

STORAGE LOCATION: • Your data is stored on secure servers in the United
Kingdom and European Economic Area (EEA) • We do not transfer your data
outside the UK/EEA without adequate safeguards • If international
transfers occur, we ensure appropriate protection mechanisms are in
place

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11. Your Rights Under UK GDPR

Under UK GDPR and the Data Protection Act 2018, you have the following
rights:

RIGHT OF ACCESS: • You can request a copy of all personal data we hold
about you • We will provide this within 30 days (free of charge) •
Request through app settings or by contacting us

RIGHT TO RECTIFICATION: • You can correct inaccurate or incomplete data
• You can update your profile information through the App • We will
correct errors promptly upon request

RIGHT TO ERASURE (“Right to be Forgotten”): • You can request deletion
of your personal data • We will delete data within 30 days unless
retention is required by law • You can delete your account through app
settings

RIGHT TO RESTRICT PROCESSING: • You can request that we limit how we
use your data • We will comply while investigating your request •
Applicable when data accuracy is contested or processing is unlawful

RIGHT TO DATA PORTABILITY: • You can request your data in a structured,
machine-readable format • We will provide this within 30 days • Allows
you to transfer your data to another service

RIGHT TO OBJECT: • You can object to processing based on legitimate
interests • You can object to direct marketing (opt-out available) •
You can object to automated decision-making

RIGHT TO WITHDRAW CONSENT: • You can withdraw consent for data
processing at any time • Does not affect processing that occurred
before withdrawal • Withdraw through app settings or by contacting us

To exercise these rights, contact us at support@pawla.app or use the
app’s privacy settings.

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12. Cookies and Similar Technologies

Pawla is a mobile application. We do not use browser cookies in the same
way as a website.

We may use similar technologies to support sign-in, preferences,
notifications, security, and service operation. These may include local
storage on your device, authentication tokens, and technical identifiers
needed to run the App.

If we add website or embedded web features that use cookies or similar
technologies, we will explain them here and provide any choices required
by law.

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13. Third-Party Services and Integrations

Our App relies on third-party services to operate. Key providers
include:

• Google Firebase (authentication, cloud database, file storage, and on
iOS: analytics and crash reporting) • Mixpanel (product analytics) •
PostHog (product analytics, EU-hosted) • Apple and Google map services
(location and map display) • Expo / push notification services (where
you enable notifications) • Apple App Store and Google Play (app
distribution and, if introduced, in-app purchases)

DATA SHARING: • We share only the data needed for those services to
function on our behalf • Service providers are required to protect your
data under contract and applicable law • We do not sell your personal
data to third parties

THIRD-PARTY PRIVACY POLICIES: • Third-party services have their own
privacy policies • We encourage you to review them where relevant • We
are not responsible for third-party practices outside our control

We select providers carefully and review their security and privacy
standards.

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14. Children’s Privacy

Pawla is NOT intended for children under 13 years of age:

AGE REQUIREMENTS: • Users must be at least 16 years old to use Pawla •
Users under 16 may only use Pawla with parental consent and supervision
• We do not knowingly collect personal data from children under 13

IF WE DISCOVER CHILDREN’S DATA: • We will immediately delete the
account and associated data • We will notify parents or guardians if we
discover a child’s account • We will take steps to prevent future
collection of children’s data

PARENTAL RIGHTS: • Parents can request access to their child’s data •
Parents can request deletion of their child’s data • Parents can
withdraw consent for data processing

If you are a parent or guardian and believe your child has provided us
with personal data, please contact us immediately at support@pawla.app.
We will promptly investigate and take appropriate action.

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15. International Data Transfers

We primarily store and process your data in the United Kingdom:

DATA STORAGE LOCATION: • Your data is stored on secure servers in the
United Kingdom • We may also store data in the European Economic Area
(EEA) • We ensure adequate protection for all data storage locations

INTERNATIONAL TRANSFERS: • If we transfer data outside the UK/EEA, we
ensure appropriate safeguards • We use Standard Contractual Clauses
(SCCs) where necessary • We ensure that international transfers comply
with UK GDPR • We only transfer data to countries with adequate data
protection laws

YOUR RIGHTS: • You will be notified of any international data transfers
• You can object to international transfers (may limit app
functionality) • You can request information about data transfer
locations

We are committed to protecting your data regardless of where it is
stored or processed.

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16. Automated Decision-Making and Profiling

We may use automated processing for certain features:

AUTOMATED PROCESSING: • Matching and discovery features based on
location, activity, and profile information • Recommendations for
activities, clubs, or content • Streak, walk-goal, and routine
summaries derived from your saved activity • Fraud, abuse, and security
checks

PROFILING: • We may use saved goals, preferences, walk history, and
optional profile details to personalise your experience • We do not
make significant decisions with legal or similarly serious effects about
you based solely on automated processing without appropriate safeguards

YOUR RIGHTS: • You can update or delete much of the information used
for personalisation in the App • You can object to certain processing
and exercise your GDPR rights as described in this policy • You can
contact us if you want more information about automated processing

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17. Data Breach Notification

In the event of a data breach:

OUR OBLIGATIONS: • We will notify the Information Commissioner’s Office
(ICO) within 72 hours if the breach poses a risk to your rights • We
will notify you without undue delay if the breach poses a high risk to
your rights • We will provide clear information about the nature of the
breach • We will explain measures taken to address the breach

NOTIFICATION DETAILS: • Description of the breach • Categories of data
affected • Likely consequences of the breach • Measures taken or
proposed to address the breach • Contact information for inquiries

PREVENTION: • We implement security measures to prevent breaches • We
regularly monitor for security incidents • We have incident response
procedures in place • We conduct regular security assessments

If you suspect a security breach, please contact us immediately at
support@pawla.app.

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18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time:

UPDATES: • We will update the “Last Updated” date when changes are made
• For material changes, we will notify you through: - Push
notifications - In-app messages - Email to your registered address -
Prominent notice in the App

YOUR CONTINUED USE: • Continued use of Pawla after changes constitutes
acceptance of the updated policy • If you do not agree with changes,
you should stop using the App and delete your account • You can review
the current policy at any time in the App

RECOMMENDATION: • We recommend reviewing this policy periodically to
stay informed • The most current version is always available in the App
• Previous versions are available upon request

We will not make retroactive changes that reduce your rights without
your explicit consent.

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19. Contact Information and Complaints

If you have questions, concerns, or wish to exercise your rights:

CONTACT US: PAWLA LTD Company Number: 17137462 3rd Floor, 86-90 Paul
Street London, England EC2A 4NE United Kingdom

Email: support@pawla.app Website: www.heypawla.com

We aim to respond to all privacy inquiries within 5 business days.

FILING A COMPLAINT: If you are not satisfied with how we handle your
personal data, you have the right to file a complaint with:

Information Commissioner’s Office (ICO) Wycliffe House Water Lane
Wilmslow Cheshire SK9 5AF United Kingdom

Website: www.ico.org.uk Phone: 0303 123 1113

We encourage you to contact us first to resolve any concerns before
filing a complaint with the ICO.

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20. Additional Information

DATA CONTROLLER: PAWLA LTD is the data controller for your personal data
processed through Pawla.

DATA PROTECTION OFFICER: For privacy-related inquiries, please contact
us at support@pawla.app. We will respond to all inquiries promptly and
in accordance with applicable data protection laws.

LINKS TO OTHER POLICIES: This Privacy Policy should be read in
conjunction with: • Our Terms and Conditions • Our Community
Guidelines • Our Safety Tips

These documents together form our complete privacy and data protection
framework.

YOUR RESPONSIBILITIES: • Please keep your account information accurate
and up-to-date • Do not share your account credentials with others •
Report any privacy concerns or security issues immediately • Respect
other users’ privacy and personal information

Thank you for trusting Pawla with your personal information. We are
committed to protecting your privacy and ensuring the security of your
data.