Wagglo Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how Wagglo collects, uses, discloses, stores, protects and manages personal data in connection with the Wagglo iOS and Android mobile applications, services, features, content, communications and related online or offline activities (collectively, the “Service”).

For the purposes of this Privacy Policy, “Wagglo”, “we”, “us” and “our” refer to Timus Tan Shao Qi, operating Wagglo. “You” and “your” refer to any person who accesses or uses the Service.

The Service is intended for users in Singapore. This Privacy Policy is prepared with reference to the Personal Data Protection Act 2012 of Singapore (“PDPA”). As at the effective date, Wagglo is not incorporated and does not have a UEN or registered business address.

2. Privacy Consent and App Checkbox Acceptance

Before you create an account, the Wagglo app requires you to tick or select a separate unchecked checkbox, button or similar affirmative control confirming that you have read, understood and consent to this Privacy Policy. This Privacy Policy consent is separate from your acceptance of the Terms and Conditions. The wording may be substantially similar to:

“I have read and consent to Wagglo’s Privacy Policy, including the collection, use and disclosure of my personal data as described in it.”

You cannot create an account unless you provide the required Privacy Policy consent and accept the Terms and Conditions. By ticking the Privacy Policy checkbox, creating an account, enabling app permissions, submitting information to us, or using the Service after being notified of this Privacy Policy, you consent to our collection, use and disclosure of your personal data as described in this Privacy Policy, unless another basis is permitted under applicable law.

You should not create an account or use the Service if you do not agree with this Privacy Policy. If you withdraw consent for personal data that is necessary for the Service, we may be unable to provide all or part of the Service to you.

We keep or may keep electronic records of your acceptance and consent, including user ID, email address, date and time of acceptance, Privacy Policy version, Terms and Conditions version, IP address where available, device or browser information where available, and other related technical information, for audit, legal, compliance and operational purposes.

3. Summary of the Service

Wagglo is a peer-to-peer dog owner matching platform. It helps dog owners create owner and dog profiles, receive compatibility-based match recommendations, swipe, match and connect with compatible dog owners nearby for walks, playdates and shared pet-related experiences through iOS and Android mobile applications.

Wagglo only connects users. Wagglo does not organise, supervise, manage or attend dog walks, does not provide professional dog-walking services, and does not employ dog walkers.

4. Personal Data We Collect

We may collect the following categories of personal data and related information, depending on how you use the Service.

4.1 Account and profile information

• email address;
• display name or nickname;
• profile photograph;
• date of birth for age eligibility checks;
• postal code and approximate area (collected at account creation to enable core matching functionality; this is required to use the Service, distinct from the optional precise location permissions described in Section 4.4);
• email one-time passcodes (OTPs), verification codes, authentication records and related login information;
• account settings;
• information received through Google OAuth or any approved login provider used by the Service; and
• any other information you voluntarily add to your profile or provide to us.

At launch, you do not need to provide a real full name. Email OTPs or verification codes may be sent to the email address linked to your account for account verification, login or security purposes. At launch, Wagglo does not collect mobile numbers, send OTPs by SMS, collect NRIC numbers, FIN numbers, passport numbers, home addresses or payment card details.

4.2 Acceptance and consent records

When you accept this Privacy Policy or the Terms and Conditions, we may collect and store acceptance records, including user ID, email address, date and time of acceptance, document versions accepted, IP address where available, and device or browser information where available. We use these records to evidence consent, account creation, contractual acceptance, compliance and audit history.

4.3 Dog profile information

• dog name; breed; age; size; sex or gender; dog photographs;
• personality, temperament, energy level and social behaviour;
• walking preferences and lifestyle compatibility information;
• user-declared vaccination status;
• user-declared sterilisation status; and
• user-declared information about aggression, reactivity or safety-related behaviour.

Dog information may be personal data where it is associated with an identifiable owner or user. You are responsible for ensuring that the information you provide about your dog is accurate, complete and not misleading. Vaccination and sterilisation status are user-declared only and are not independently verified by Wagglo.

4.4 Location and proximity information

Postal code and approximate area, collected during account creation, are used as the baseline for proximity-based matching. In addition, Wagglo may use further approximate location information to estimate proximity between users for matching purposes.

Further approximate location information may include your postal code, approximate area, manually selected area, or app-derived approximate location where you have enabled the relevant permission. Any optional device-level location permissions, including precise location permissions where requested by your operating system, are separate from the required postal code and approximate area collected at account creation. Where enabled, such permissions are used to estimate proximity for matching and are not intended to display your exact location or home address to other users.

At launch:

• we do not collect or display precise real-time GPS location;
• we do not collect background location while the app is not in active use;
• we do not show your exact location or home address to other users;
• we do not store walking routes; and
• we do not store location history beyond what is reasonably necessary for a matching session or operation of the Service.

If you disable location-related permissions or do not provide location or area information, certain matching and nearby-user features may not work properly or may be unavailable.

4.5 Matching and preference information

We may collect and use information relating to your dog profile, owner preferences, walking preferences, approximate location, swipe actions, match actions and compatibility signals to operate the matching system.

The matching system may be AI-assisted or machine-learning-assisted. Match suggestions are recommendations only. We do not guarantee that any match will be accurate, successful, safe or suitable.

4.6 Chat, messages and user communications

If you use in-app chat, we may collect and store messages and related content, including text messages and images sent through chat. At launch, chat is intended to support text and images; location pins and voice messages are not part of the launch version unless introduced later.

Chat content is stored while your account is active. Features for deleting individual messages or entire conversations may not be available at launch. Chat content may be deleted within 30 days after account deletion, subject to any retention required for safety, legal, enforcement, audit, backup or technical reasons.

We may review chat content, profiles, reports and related activity only where reasonably necessary for safety, moderation, policy enforcement, dispute handling, suspected misuse, technical support, legal compliance or protection of users. We may use manual or automated safety tools, but we do not guarantee that all chats, profiles or activity will be monitored or reviewed.

4.7 User-generated content

We may collect content that you upload, submit or create through the Service, including profile photographs, dog photographs, dog profile text, preferences, reports and other materials you choose to provide.

You should not upload content that contains another person’s personal data unless you have obtained the necessary consent or have another lawful basis to do so.

4.8 Device, technical and analytics information

• device type, browser type, operating system and app version;
• IP address and approximate network information;
• usage logs, feature interactions and app performance information;
• crash, diagnostic and troubleshooting information;
• analytics identifiers and similar technical identifiers; and
• information collected through analytics tools such as Google Analytics or Firebase Analytics.

4.9 Reports, complaints and safety records

If you report another user, dog, message, incident or unsafe behaviour, we may collect the contents of your report, supporting evidence, relevant account information, chat records, profile information and other information reasonably necessary to assess, investigate and respond to the report.

4.10 Marketing preferences

At launch, Wagglo does not send marketing communications to users. If marketing communications are introduced later, and if you opt in to receive them, we may collect your marketing preferences, email address, interaction history with marketing communications and unsubscribe status. Wagglo does not sell personal data for advertising.

4.11 Business promotion information

Where Wagglo permits local pet businesses or promotional partners to manage promotions through the Service, we may collect business-related information, such as business name, business contact details, contact person information, logos, promotion details, outlet or event information, and supporting materials. Some of this information may be personal data where it identifies an individual business contact person.

5. Purposes for Collection, Use and Disclosure

We collect, use and disclose personal data for purposes that are reasonably necessary for providing, operating, improving and protecting the Service, including: creating, maintaining, authenticating and managing user accounts; enabling owner and dog profile creation; operating the swipe, match and compatibility-based recommendation system; estimating proximity and suggesting nearby or relevant matches; enabling matched users to communicate through in-app chat; displaying profiles, dog profiles and approximate areas to other users; providing local pet deals, promotions and events on the main page; providing customer support and responding to enquiries; processing account deletion, data access, correction and withdrawal requests; sending service-related communications, including account, safety, administrative and policy notices; sending marketing communications if introduced and where you have opted in; improving app functionality, user experience, analytics, performance and reliability; preventing, detecting and responding to misuse, scams, harassment, unsafe conduct, abuse or security issues; investigating reports, complaints, disputes and safety incidents; enforcing our Terms and Conditions, Community Guidelines and other policies; complying with applicable laws, regulations, legal processes and lawful requests; protecting the rights, property, safety and legitimate interests of Wagglo, users, dogs and the public; and facilitating any actual or proposed merger, acquisition, restructuring, financing or business transfer where permitted by law.

We will not collect, use or disclose your personal data for purposes that a reasonable person would consider inappropriate in the circumstances.

6. Consent, Permissions and Withdrawal of Consent

We may collect, use or disclose your personal data with your consent, deemed consent, or where otherwise permitted or required under applicable law. You may provide consent by ticking an acceptance box for this Privacy Policy during sign-up, creating an account or using the Service after being notified of the relevant purposes, enabling app permissions (including location permissions where applicable), opting in to marketing communications if introduced, giving separate consent for the use of your photographs or dog photographs for external marketing, or voluntarily providing information to us through the Service or by email.

You may withdraw consent by using in-app settings where available or by contacting wagglosg@gmail.com. If you withdraw consent for data that is necessary to provide the Service, certain features may become unavailable and we may be unable to continue providing all or part of the Service to you. Withdrawal of consent does not affect any collection, use or disclosure that occurred before the withdrawal, or any continued use, disclosure or retention permitted or required by law.

7. What Other Users May See

At launch, your user profile and dog profile may be visible to other users. Other users may see your display name, profile photograph, dog name, breed, age, size, sex or gender, dog photographs, temperament, energy level, social behaviour, walking preferences and approximate area.

Your email address, phone number, full legal name, exact location and home address are not intended to be shown to other users. Profile hiding or pause controls may not be available at launch, although you may edit your profile or delete your account through the available settings. If you send messages or images through in-app chat, the matched recipient may see the content you send. You should avoid sharing sensitive personal data, exact home addresses, government identifiers, financial information or information about third parties through chat.

8. Disclosure of Personal Data

We may disclose personal data to other users as necessary to operate the Service; to vendors and service providers who process data on our behalf (including Supabase for backend, database, hosting and authentication, including email OTP or email verification functionality where used; AWS infrastructure used by Supabase; Google OAuth for login; Google Analytics and/or Firebase Analytics; and other technical service providers); to pet businesses, event partners and promotional partners (we do not share user personal data with them for their own marketing unless you interact with them directly, you consent, or it is otherwise permitted or required by law); to authorities, legal advisers and for safety-related disclosures where we believe in good faith it is necessary or appropriate; and as part of a merger, acquisition, financing, restructuring, sale of assets or business transfer, subject to applicable law.

9. Overseas Transfers

The Service may use cloud, analytics, authentication and technical service providers that process or store personal data outside Singapore (for example, Supabase, AWS infrastructure and Google services), depending on the relevant provider’s infrastructure, settings and service locations. Where personal data is transferred outside Singapore, we will take reasonable steps to ensure it receives a standard of protection comparable to the protection under the PDPA, as required by applicable law.

10. Accuracy of Personal Data

You are responsible for ensuring that the personal data and dog profile information you provide is accurate, complete and up to date. You may update certain information through the app. If you cannot update information through the app, you may contact us at wagglosg@gmail.com.

11. Access, Correction, Deletion and Privacy Requests

You may request access to or correction of your personal data by using in-app settings where available or by contacting wagglosg@gmail.com. You may request account deletion through in-app settings. After account deletion, we will delete or anonymise personal data in accordance with our retention practices, subject to information we may retain for legal, safety, security, enforcement, audit, dispute resolution, backup or legitimate business purposes.

We may verify your identity before processing a request, including through your logged-in account session, your registered email address, or other reasonable verification steps. We aim to respond to privacy requests within 14 calendar days where reasonably practicable. More complex requests may require additional time, and we may inform you if more time is needed. We may decline, limit or charge for a request where permitted by applicable law.

12. Retention of Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, or as permitted or required by law. Account data is retained while your account is active. Dog profile data is retained while your account is active and deleted with account deletion, subject to retention exceptions. Chat messages are retained while your account is active and deleted within 30 days after account deletion, subject to retention exceptions. Location information is used minimally for matching and not stored beyond the matching session unless necessary for operation, security or safety. Walk history is not applicable at launch because Wagglo does not record walks or walking routes. Reports and safety records may be retained longer where necessary for legal, safety, enforcement, trust and safety, dispute resolution or audit purposes. Payment records are not applicable at launch because Wagglo does not process payments. Analytics data may be retained in aggregated or anonymised form where reasonably possible. Deleted account data is subject to a 30-day grace period before full purge, except for legal, safety, backup, security, audit and anonymised analytics records. Backups may remain in encrypted or restricted technical backups for a limited period before being overwritten or deleted.

13. Protection and Security

We will take reasonable security arrangements to protect personal data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal, loss or similar risks. Such arrangements may include appropriate technical, administrative and organisational measures, such as access controls, authentication controls, encryption in transit, role-based access, limited administrative access, vendor security controls and internal access restrictions.

However, no method of transmission over the Internet or electronic storage is completely secure. You are responsible for keeping your login credentials secure and for notifying us if you suspect unauthorised access to your account.

14. Data Breaches

If we become aware of a suspected data breach affecting personal data, we will assess and manage the incident in accordance with applicable law and our incident response procedures. Where the breach is notifiable under the PDPA, we will notify the Personal Data Protection Commission and/or affected individuals as required by law.

15. Children and Age Eligibility

The Service is intended only for users who are at least 16 years old. Users below 16 years old are not permitted to create an account or use the Service. Date of birth is collected as a required field during sign-up to verify that you meet the minimum age requirement to use the Service.

If you are 16 or 17 years old, you should only create an account and use the Service if you understand this Privacy Policy, the purposes for which your personal data is collected, used and disclosed, and the consequences of providing or withdrawing consent. You should seek help from a parent or legal guardian if you do not understand any part of this Privacy Policy. Where required or appropriate, you should obtain permission from your parent or legal guardian before using the Service.

If we become aware that a user is below 16 years old, or if we have reason to believe that a user aged 16 or 17 does not have sufficient understanding of the nature and consequences of giving consent or is using the Service without any required permission, we may suspend or delete the account, request further confirmation, and take any other steps we consider appropriate.

16. Marketing Communications

At launch, Wagglo does not send marketing communications to users. If we introduce marketing emails, newsletters, promotional messages or updates in the future, we will seek opt-in consent where required or appropriate and provide a way to opt out, such as an unsubscribe function, in-app settings where available, or contact through wagglosg@gmail.com. Service-related communications, such as account, safety, security, administrative or legal notices, are not marketing communications and may continue to be sent even if you opt out of marketing. At launch, Wagglo does not send marketing by SMS, WhatsApp, Telegram or similar telephone-number-based channels. If we introduce those channels in the future, we will seek consent and comply with applicable Do Not Call Registry requirements where required.

17. Third-Party Links and Services

The Service may contain links to third-party websites, promotions, events, services, pet businesses or content. We are not responsible for the privacy practices, content, accuracy, availability or conduct of third parties. You should review the privacy policies and terms of third parties before interacting with them.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We may notify users of material changes by in-app notice, email or other appropriate means. The updated Privacy Policy will indicate the effective date. If a change materially affects how we collect, use or disclose personal data, we may seek fresh consent where required by applicable law. Your continued use of the Service after the updated Privacy Policy takes effect means that you acknowledge it. If you do not agree, you should stop using the Service and may delete your account.

19. Contact Us

For privacy questions, access or correction requests, withdrawal of consent, account deletion support, complaints or data protection matters, please contact our Data Protection Officer, Eydin Safin, at wagglosg@gmail.com. General support is also available at wagglosg@gmail.com. Operator: Timus Tan Shao Qi, operating Wagglo.