Privacy Policy

Last updated: June 2, 2026

POWERSNACK OÜ (“we”, “us”, “our”), Estonian registry code 17303443, operates the Digital Pet mobile application and the website digitalpet.app (collectively, the “Service”). This Privacy Policy explains what personal data we collect, how we use it, with whom we share it, and what rights you have under the EU General Data Protection Regulation (GDPR) and applicable laws.

By using the Service, you agree to the collection and use of information in accordance with this Policy. If you do not agree, please do not use the Service.

1. Who is the Data Controller

The data controller responsible for your personal data is:

2. Information We Collect

2.1 Information you provide directly

• Account information: email address, password (stored hashed), display name.
• Pet profile: pet name, breed, date of birth, photos you upload.
• Identity verification (optional, for Sitter/Walker accounts): passport or ID document scan, selfie, processed by our identity verification partner.
• Payment information: processed by our payment providers and the official Apple App Store / Google Play billing systems for subscriptions. We do not store full payment card numbers on our servers.
• Communications: messages you send in chats (district chat, booking chat, lost-dog SOS chat). Encrypted in transit; chat content visible to participants only.

2.2 Information collected automatically

• Device data: device model, operating system version, app version, language, push notification token.
• Crash and diagnostic data: collected via our crash-reporting tool to help us fix bugs.
• Approximate location (foreground): used to show map and nearby places.
• Precise location(foreground and background, with explicit permission): used for the Walk Tracker, SOS- Radar, geo-fence alerts, and to broadcast your pet's live walk position to nearby users when you choose to share it.

2.3 Why we ask for background location specifically

The SOS-Radar feature allows users to find lost pets by triggering a silent ping that wakes nearby devices and asks them to look around. To respond when the app is in the background or closed, we need the operating system's “Always Allow” location permission. We use background location only for:

1. SOS proximity sampling (one position read when an SOS push arrives).
2. Geo-fence breach alerts (if you defined a virtual fence for your pet).
3. Active Walk Tracker session (when you tap “Start Walk”).

We do not track your background location continuously outside of these features.

3. How We Use Your Information

We process your data on the following legal bases (GDPR Art. 6):

• Create and operate your account — performance of contract.
• Process subscription and one-time payments — performance of contract.
• Send service-related notifications (push, email) — performance of contract.
• Show map markers, nearby pets, and SOS alerts — legitimate interest, consent.
• Generate AI-stylized pet avatars (Pixar style) — consent.
• Background location for SOS / fences / walk tracker — explicit consent.
• KYC verification for service providers — legal obligation, contract.
• Crash reporting and analytics — legitimate interest.
• Comply with tax, accounting, and legal requests — legal obligation.

4. Third-Party Service Providers

We share specific data with carefully selected service providers (“processors”) strictly to operate the Service. We do not sell your data and we do not share it with advertisers. The Service contains no third-party advertising.

The categories of processors we use are:

• Cloud infrastructure and authentication (incl. Google Firebase): account management, data storage, push notifications, crash reports. Region: EU and US.
• Payment processing (incl. Stripe and the official Apple App Store / Google Play billing systems): card and bank payments, subscription management. Region: EU and US.
• Subscription analytics platform: cross- device subscription state synchronization. Region: US.
• AI image generation provider: one-time generation of stylized pet avatar from a photo you upload. Region: US.
• AI vision provider: brief textual description of the pet photo for the avatar pipeline. Region: US.
• Mapping and geocoding provider: map rendering, walking directions, neighborhood data. Region: US, EU edge.
• Identity verification provider (Sitter/Walker only): KYC document and selfie verification. Region: EU.

International data transfers outside the EEA are protected by Standard Contractual Clauses (SCCs) where applicable.

5. AI Processing of Pet Photos

When you create a pet profile, you may opt in to generate an AI-stylized “Pixar-look” avatar of your pet. To do this, we send your pet photo to a third-party AI image generation provider, and a brief textual description to a third-party AI vision provider. The original and generated images are stored in our own cloud storage; the third-party copies are processed and discarded according to those providers' retention policies (typically 30 days or less). You can decline this feature without affecting other functionality of the app.

6. Permissions We Request

• Camera: when adding a pet photo or for KYC. Used to capture a photo.
• Photos / Photo Library: when adding a pet photo. Used to pick an existing photo.
• Location — While in Use: on the map screen and places search. Used to show your area, nearby pets, and the SOS map.
• Location — Always (Background): when you start a Walk, enable a Geo-fence, or to receive SOS- Radar pings. See section 2.3.
• Notifications: at first launch. Used for pet reminders, SOS alerts, booking updates.
• Microphone: optional, for voice messages in chat.

Each permission can be revoked at any time in your device settings, with the corresponding feature gracefully degrading.

7. Data Retention

• Active accounts: data is kept as long as your account is active.
• Closed accounts: most personal data is deleted within 30 days of an account deletion request. Some data (invoices, transaction logs) may be retained for up to 7 years to meet Estonian accounting and tax obligations.
• Live walk positions (broadcast to nearby users): retained for 20 minutes after the walk ends, then automatically purged by a scheduled function.
• District chat messages: retained for 30 days by default.
• AI-avatar source photos: retained as long as you keep the pet profile.

8. Your Rights Under GDPR

You have the right to:

1. Access the personal data we hold about you.
2. Rectify inaccurate data.
3. Erase (“right to be forgotten”) your data.
4. Restrict processing in certain cases.
5. Portability — receive your data in machine-readable format.
6. Object to processing based on legitimate interest.
7. Withdraw consent at any time (e.g., disable AI avatar, stop background location).
8. Lodge a complaint with your local Data Protection Authority.

How to exercise your rights:

• In-app:Open the app, go to Settings, then Privacy and Account, and tap “Delete my account” or “Export my data”.
• By email: send a request to support@digitalpet.app from the email associated with your account. We respond within 30 days.

9. Children

The Service is not intended for children under 16. We do not knowingly collect personal data from children under 16 in the EEA, or under 13 in the United States. If you believe a child has provided us with personal data, please contact us at support@digitalpet.app and we will delete the data promptly.

10. Security

We implement industry-standard technical and organizational measures including:

• HTTPS/TLS for all client-server communication.
• Application integrity verification to prevent abusive API access from cloned apps.
• Encrypted storage of authentication tokens (Keychain / Keystore).
• End-to-end ECDH + AES-256-GCM encryption for sensitive chat messages.
• Server-side enforcement of access rules.

No system is 100% secure. We continuously review and improve our security posture, but cannot guarantee absolute security.

11. Cookies (Website)

The website digitalpet.app uses only essential cookies required for session management. We do not use advertising or tracking cookies. The mobile app does not use cookies.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified via email or in-app banner at least 30 days before they take effect. The “Last updated” date at the top reflects the most recent revision.

13. Contact