Privacy Policy

1Data controller

This Privacy Policy applies to personal information we process in connection with our website, mobile application, newsletter, social media pages and any other resources that link to this Privacy Policy (together, the “Services”).

OVO Corp Inc., 30 N Gould St Ste R Sheridan, WY 82801 (“Company”, “we”), is responsible for the collection, use, disclosure, storage and other processing of personal information in connection with the Services.

We provide a pet care platform that helps Pet Owners, Pet Guardians and Rescue Professionals manage their pets’ lives, including by maintaining pet health records, using lost and found features and making pet care arrangements.

If you have any questions regarding the processing of your personal information, please contact us at hello@kumaapets.com.

2Information practices across our Services

2.1Service-specific information

Our Services vary in the following respects:

1) Content and functionality

Our Services are accessible in the US and Canada. We may make the Services available in additional territories over time. The personal information you share with us will depend on the specific Service, feature and user path that you access or use.

2) Ways to exercise your privacy rights

The only universal method for exercising your privacy rights across our Services is to contact us at hello@kumaapets.com. Other methods depend on the specific Service you access or use.

2.2Definitions

For the purposes of this Privacy Policy:

2.2.1.“User” means:

Users may include Pet Owners, Pet Guardians and Rescue Professionals, depending on the features they access or use.

2.2.2.“Pet Owner” means an individual who uses or intends to use the Services to manage the everyday life, safety and care of their pets.

2.2.3.“Pet Guardian” means an individual or organisation that has been appointed by a Pet Owner to act as a pet guardian and has accepted that appointment. A Pet Guardian may assume responsibility for a pet in the circumstances specified by the Pet Owner through the Services.

2.2.4.“Rescue Professional” means:

2.2.5.“Account” means a User account created or used to access and use some or all of the Services, whether created directly through the Services or accessed using an account maintained with a Third-Party Provider.

2.2.6.“User Fund” means an amount of money that a User places, allocates, transfers, releases, withdraws or otherwise manages using services provided by an applicable service provider and made accessible through the Services for purposes supported by the Services, including the care of a specified pet, subject to the applicable Fund release conditions and other user instructions supported by the Services.

2.2.7.“Fund release conditions” means the conditions, instructions and requirements governing whether, when, to whom and for what purpose a User Fund may be released or made available, as specified through the Services and subject to the applicable terms and conditions.

3Data subjects

3.1Categories of subjects

We process the personal information of Users who may have different statuses depending on how they access and use our Services, such as Pet Owners, Pet Guardians and Rescue Professionals.

The same person may fall into more than one category. For example, a Pet Owner may also be a Pet Guardian. The categorisation is made solely for convenience and to clarify which personal information is processed in relation to each category. It does not in any way limit the scope of the information processing described in this Privacy Policy.

If you access our Services and share information about another person, you must ensure that the person has read our Privacy Policy and agreed to our processing of their personal information. You are responsible for ensuring that you have the right to share that personal information with us and that we may collect, use and disclose it in accordance with this Privacy Policy.

3.2Minimum age of access and use of our Services

Use of our Services is restricted to Users who are at least 18 years old and meet any additional eligibility requirements specified in our Terms of Service.

If you are under 18, you shall not access or use our Services.

If you believe that we might have any information from or about a child under the age of 18, please contact us at hello@kumaapets.com.

We do not knowingly collect or solicit personal information from anyone under 18 or knowingly allow such persons to use the Services.

Once we become aware that a User is under 18, we will block the Account or relevant feature, suspend public visibility, stop marketing, disable Community, chat and location features, cancel Pet Guardian acceptance where relevant and delete or retain information according to legal, security and safety requirements.

4Personal information we process

We want to make clear that processing your personal information is necessary to provide our Services. Without it, we cannot provide our Services to you, either technically or organisationally.

You are not required to share your personal information with us if you do not agree with our information processing activities or for any other reason. However, if you do not provide information that is necessary for the Service functionality, you may not be able to use that Service functionality.

We do not intentionally collect special categories of personal information unless this is strictly necessary and lawful, for example, where you choose to provide such information in a support request, complaint, attachment, emergency instruction or other free-text field.

Pet-related information does not constitute personal information of a human being. References to pet-related information are made only for convenience and clarity to explain the processing of personal information in a way that is closely linked to the user experience.

4.1Categories of personal information

We may collect certain categories of personal information as described below.

1) Account information, including

• User name, including the name of the Rescue Professional and the name of the Rescue Professional’s contact person;
• Email address;
• Phone number;
• Account credentials;
• Third-party sign-in information (Apple/Google sign-in);
• User ID;
• Service status (Pet Owner, Pet Guardian, Rescue Professional);
• Profile photo;
• Contact details;
• Rescue Professional website or public profile;
• Rescue Professional address or territory of operation;
• Proof of authority to represent the Rescue Professional;
• Team-member names, emails, roles and access permissions, if a workspace is created.

2) Pet-related information, including

• Pet name;
• Pet photo;
• Species, breed and other identifying details;
• Birth date, weight, ancestry and similar pet profile details, where provided;
• Relationship to the pet (Pet Owner, Pet Guardian, Rescue Professional);
• Pet microchip or other identification number;
• Pet care instructions;
• Vaccination and medication information;
• Names of veterinarians, veterinary specialists, clinic staff and other third parties identified in pet medical or care records;
• Adoption, foster or other notes relevant to care or matching;
• Foster placement or shelter location;
• Pet last-seen or found location information;
• Date and time when the pet was lost or found;
• Lost/Found report status (open, updated, closed).

3) Service-use (device and technical) information, including

• Device information;
• IP address;
• Operating system and app version;
• Device and application identifiers;
• Crash reports, diagnostics, logs and technical events;
• Feature-specific logs or records;
• App interactions and feature-use information;
• Notification token and notification delivery status, where applicable;
• Newsletter subscription status;
• Cookie and similar technology information from the website.

4) Location information, including

• Precise GPS information only where location permission is requested and granted for Community, Lost and found or another map-based functionality;
• Approximate area or approximate distance used for Community discovery;
• Manual location entered by the User where technically possible.

The app does not request location access unless it is necessary for the operation of the map-based features, including Community or Lost and found.

5) Communication information, including

• Communication details, including feedback, ratings and comments that you submit;
• Service message or notification content;
• Issue type;
• Attachments and screenshots;
• Response history.

6) Payment information, including

• Wallet identifier;
• Transaction amount;
• Transaction status;
• Receipt information;
• User Fund status and amount (created, released, spent);
• Fund release conditions.

4.2Personal information processed per functionality

1) Community

This functionality may allow Users to connect with other Users, discover nearby pet-related profiles, exchange pet-care tips and arrange pet-related meetings, walks or other interactions.

If you choose to use Community features, certain information may be made visible to other Users depending on your settings, actions and the functionality you use. This may include:

• User name, including the name of the Rescue Professional and the name of the Rescue Professional’s contact person;
• Profile photo;
• Selected pet-related information, such as pet name, pet photo, species, breed or other pet-related details you choose to make visible;
• Location information based on the permissions granted;
• Connection status with other Users;
• Information relating to meetups that you create, join or interact with;
• Posts, comments, messages, reports or other content that you submit through community functionality, where such functionality is available.

2) Lost and found

This functionality is designed to help identify missing pets, notify relevant Users and support communication between persons who may help return a pet.

If you choose to create, publish, search for or respond to a missing-pet report, certain information may be made visible to other Users of the Services depending on your settings, actions and the functionality you use. This may include:

• User name, including the name of the Rescue Professional and the name of the Rescue Professional’s contact person;
• Contact details;
• Pet name;
• Pet photo;
• Species, breed and other identifying details;
• Birth date, weight, ancestry and similar pet profile details, where provided;
• Relationship to the pet (Pet Owner or Pet Guardian);
• Pet last-seen or found location information;
• Pet microchip or other identification number;
• Date and time when the pet was lost or found;
• Report status (open, updated, closed);
• Messages, updates or other information that you choose to include in or send in connection with this functionality.

3) Pet health care functionality

This functionality may allow you to organise and manage pet health and care information in one place, including medical history, vaccination information, medication details, treatment records, care instructions and other information relevant to the health and wellbeing of your pets.

Pet health information records are private by default. If you choose to use sharing functionality, certain information may be made available to selected Users, such as Pet Guardians or Rescue Professionals, depending on your settings and the functionality you use.

This functionality may require processing of the following personal information:

• Pet name;
• Pet photo;
• Species, breed and other identifying details;
• Birth date, weight, ancestry and similar pet profile details, where provided;
• Pet microchip or other identification number;
• Pet’s care instructions;
• Vaccination and medication information;
• Names of veterinarians, veterinary specialists, clinic staff and other third parties identified in pet medical or care records.

4) User Fund functionality

This functionality allows Users to make care arrangements for their pets. This may include appointing a Pet Guardian, creating a User Fund and defining Fund release conditions.

User may create a Pet Guardian invitation. To become a Pet Guardian, the invited person must accept the invitation. If you create, send, receive or accept a Pet Guardian invitation, certain information may be made available to the other User.

This functionality may require processing of the following personal information:

• User name, including the name of the Rescue Professional and the name of the Rescue Professional’s contact person;
• Contact details;
• Relationship to the pet (Pet Owner, Pet Guardian, Rescue Professional);
• Invitation details for the Pet Guardian;
• Accepted Pet Guardian status;
• Pet name;
• Pet photo;
• Pet species, breed and other identifying details;
• Birth date, weight, ancestry and similar pet profile details, where provided;
• Pet microchip or other identification number;
• Pet care instructions;
• Wallet identifier;
• Transaction amount;
• Transaction status;
• Receipt information;
• User Fund status and amount (created, released, spent);
• Fund release conditions;
• Vaccination and medication information;
• Names of veterinarians, veterinary specialists, clinic staff and other third parties identified in pet medical or care records.

This functionality may be provided through third-party payment, wallet or financial service providers. Where you create, change, cancel, release or use a User Fund, relevant fund-related information may be processed by the relevant service providers in accordance with the applicable terms and this Privacy Policy.

5) Communication functionality

When you communicate with other Users through our Services, we may process your name and contact details, as well as the content of your communication and any information necessary to provide, deliver, display, moderate or secure that communication or to respond to issues relating to it.

When you contact us by any means, we may process your name and contact details, as well as the content of your communication, including feedback, ratings and comments that you submit, attachments and screenshots, issue type, response history and any other information necessary to respond to your request.

We also process feedback, ratings and comments that you submit.

6) Service and promotional notifications and messages

We may send you service notifications and messages that are necessary or useful for the operation of our Services, including account-related messages, security alerts, Pet Guardian invitation updates.

We may also send you promotional notifications and messages, including newsletters, launch updates, product news, feature announcements and other communications relating to the Services, where permitted by applicable law and based on your consent where required.

This may require processing of:

• User name, including the name of the Rescue Professional and the name of the Rescue Professional’s contact person;
• Email address;
• Phone number;
• User ID;
• Service status (Pet Owner, Pet Guardian, Rescue Professional);
• Notification token and notification delivery status, where applicable;

• Notification preferences and opt-in or opt-out status;
• Newsletter subscription status;
• Service message or notification content;
• Pet-related information necessary to send the relevant notification, such as pet name, Lost/Found status, Pet Guardian invitation status or other Service-related messages;
• Location information, where this is necessary for location-based alerts and where the relevant permission has been granted;
• Device, technical and service-use information necessary to deliver, display, secure and troubleshoot notifications and messages.

You can manage certain notifications through the settings available in our Services or through your device settings. You can opt out of promotional communications by using the unsubscribe link in the relevant message or by contacting us through the contact details provided in this Privacy Policy.

Even if you opt out of promotional communications, we may still send you service-related messages where they are necessary to provide, secure or administer the Services.

7) Rescue ORG

RescueORG allows Rescue Professionals to use our Services for rescue-related operations, including AI-assisted sorting of pet records, medical tracking and foster management. This may require processing of:

• User name, including the name of the Rescue Professional and the name of the Rescue Professional’s contact person;
• Rescue Professional website or public profile;
• Rescue Professional address or territory of operation;
• Name, role and email address of the contact person;
• Contact details;
• Proof of authority to represent the Rescue Professional, if required;
• Team-member names, emails, roles and access permissions, if a workspace is created;
• Pet name;
• Pet photo;
• Species, breed and other identifying details;
• Birth date, weight, ancestry and similar pet profile details, where provided;
• Relationship to the pet (Pet Owner or Pet Guardian);
• Pet microchip or other identification number;
• Pet care instructions;
• Vaccination and medication information;
• Names of veterinarians, veterinary specialists, clinic staff and other third parties identified in pet medical or care records;
• Lost/Found status;
• Adoption, foster or other notes relevant to care or matching.

4.3Means of collecting your personal information

We collect personal information in different ways depending on the Service, functionality, User role and interaction path that you choose to use.

We may collect personal information directly from you when you create or manage an Account, create or update a pet profile, use functionality such as Community, Lost and Found, Pet Health Care and User Fund, submit feedback, ratings or comments, contact us for support, subscribe to our newsletter or otherwise provide information in connection with the Services.

We may collect device, technical and service-use information automatically when you access or use our Services.

We may collect personal information from other Users where this is part of the Services. For example, a Pet Owner may provide information about a Pet Guardian when creating an invitation and a Pet Guardian may provide information when accepting an invitation.

We may collect personal information from third-party services that you choose to use in connection with the Services. For example, if you use Apple or Google sign-in, we may receive third-party sign-in information necessary to create or access your Account.

5How we process your personal information

To process your personal information, we need a purpose and, where required by applicable law, a legal basis.

5.1We do not sell or share your personal information

We do not sell your personal information.

By “sell”, we mean disclosing, transferring, making available or otherwise providing personal information to a third party in exchange for money, other valuable consideration or another commercial benefit. The exact meaning of “sell” may differ depending on the applicable law.

We do not share your personal information.

By “share”, we mean disclosing, transferring, making available or otherwise providing personal information to a third party for targeted advertising, cross-context behavioural advertising or similar advertising purposes. The exact meaning of “share” may differ depending on the applicable law.

We may disclose personal information to service providers and other recipients described in this Privacy Policy where this is necessary for the purposes described in this Privacy Policy, as updated from time to time.

We use service providers that process personal information on our behalf and receive it for specified purposes under contracts that prohibit:

If our practices change and we begin to sell personal information or share personal information for targeted advertising or cross-context behavioural advertising, we will update this Privacy Policy and provide the notices, choices and opt-out mechanisms required by applicable laws.

5.2Purposes of information processing

We process only those categories of personal information that are reasonably necessary and proportionate for the purposes described below:

5.3Legal bases for information processing for data subjects in Canada

Your consent (implied or explicit) is required for our collection, use and disclosure of your personal information, unless the collection, use or disclosure is otherwise required or permitted by law, for example, for the collection, use and disclosure of personal information related to investigating a breach of an agreement or a contravention of the laws.

Right to withdraw your consent

You may withdraw or vary your consent to the collection, use or disclosure at any time.

If you withdraw or vary your consent to the collection, use or disclosure of personal information, we will:

Please note that if you withdraw your consent, we may need to limit the scope of the Services available to you and may be unable to maintain our relationship with you or interact with you, but only to the extent that your personal information is necessary for such purposes.

If withdrawing or varying consent would impede the performance of a legal obligation, the withdrawal or variation does not operate to the extent that it would impede such performance.

We rely on your implied consent for the use of your personal information for the following purposes:

We require your explicit consent for the use of your location information for the following purposes:

We rely on legal obligations under applicable law as the legal basis for processing your personal information where necessary to comply with applicable laws, lawful requests, regulatory requirements and legal obligations.

5.4How we communicate your personal information

We may communicate your personal information to the following categories of recipients where this is necessary for the purposes described in this Privacy Policy.

A. Service providers

We use third-party service providers that help us provide, operate, secure, maintain and improve the Services.

These recipients may include providers of the following services:

• hosting and cloud infrastructure;
• information storage;
• technical support and internal operations;
• user authentication and login services, including Apple/Google sign-in;
• analytics and performance measurement;
• application support, software development tools and updates;
• infrastructure monitoring;
• network and DNS services;
• form, newsletter and CRM services;
• support-ticket services;
• map and location services;
• push notification services;
• payment, wallet and safety-fund services;
• app store and platform services.

The list of service providers, including their legal names, services and links to the applicable privacy policies, is available on the website: https://kumaapets.com/.

Where a service provider processes personal information on our behalf, we require it to process the information only on our documented instructions and to comply with appropriate confidentiality, security and information protection obligations. Service providers are not allowed to use personal information for their own advertising, audience building, resale, commercial analytics or unrelated business purposes.

B. Users of our Services

If you use any social, community or chat features in our Services, please note that any personal information you share may be visible to others according to the selected Service settings. Once your personal information is shared, you lose some control over it, as others may extract and use it in breach of our Terms of Service.

Our Terms of Service outline the limitations and restrictions on the use of the Services and their content. As we cannot fully control how other Users use information available through the Services, we strongly recommend that you do not share information that could adversely affect you, your pet, us or the Services.

C. Affiliates and corporate group companies

We may disclose your personal information to our affiliated companies, including companies under common control with us, where this is necessary for internal administration, customer support, technical operations, security, compliance, business management or other purposes consistent with this Privacy Policy.

D. Corporate transactions

We may disclose your personal information to actual or prospective buyers, investors, lenders, advisers or other relevant third parties in connection with a contemplated or completed corporate transaction, such as a merger, acquisition, reorganisation, financing, sale of assets or transfer of all or part of our business.

E. Courts and legal authorities

We may disclose your personal information to courts, law enforcement authorities, regulators, government authorities or other third parties where we believe such disclosure is necessary:

• to comply with applicable laws or enforceable governmental requests;
• to establish, exercise or defend legal claims;
• to investigate, prevent or take action regarding suspected fraud, abuse, security incidents or other unlawful or unauthorised activity;
• to enforce our Terms of Service or other applicable terms and policies;
• to protect the rights, property, safety and security of us, our Users, other persons, as well as the safety of pets.

5.5Cross-border transfer of your personal information

Personal information is processed in the places where we, our service providers and other categories of recipients are located. We are based in the United States. This means that your personal information may be transferred to and maintained on servers located outside your state, province, country or other governmental jurisdiction, where the applicable laws and regulations may differ from those of your jurisdiction.

Taking into account differences among the legal regimes of states, provinces, countries and other governmental jurisdictions, we transfer personal information across borders only where permitted by applicable law.

Where required, we take appropriate measures designed to protect personal information during cross-border processing. Specifically, the communication of information is subject to a contract with the recipient establishing the means and conditions of processing personal information so that it receives adequate protection, in particular in light of generally recognised principles regarding the protection of personal information.

5.6How we store your personal information

We process your personal information only as long as necessary to provide our Services and fulfil the purposes described above in the section entitled “How we process your personal information”.

The retention period for your personal information is determined by the following criteria:

• the duration for which personal information is needed to provide the Services;
• the nature of personal information, including whether it is sensitive or requires enhanced protection;
• any User request to withdraw consent or object to processing;
• any need to retain records for moderating content and handling User disputes, maintaining the security and integrity of the Services, establishing, exercising or defending legal claims, enforcing our terms and protecting our rights, our Users and the Services, complying with applicable laws, lawful requests, regulatory requirements and legal obligations;
• any contractual or legal obligations requiring the ongoing processing of personal information.

After an Account is deleted, all User information is deleted or anonymised unless retention is required:

5.7Profiling

We do not evaluate, analyze or predict personal aspects, including preferences, interests, behaviour, location or movements.

We may provide service-related notifications based solely on records of User activity, not on inferred data predicting the User’s next movement.

If our profiling practices change, we will update this Privacy Policy and provide Users of the Services with relevant information.

5.8Push notifications and unsolicited messages

We may send service-related messages via push notifications, email and other communication channels.

We may send marketing messages. Depending on your state, province, country or other governmental jurisdiction, we may be required to obtain your consent before sending certain marketing messages. Where this is the case, we will obtain your consent before sending those marketing communications.

You can opt out of marketing messages through the opt-out mechanism provided in the marketing communication or by writing to us at hello@kumaapets.com.

You can deactivate push notifications by changing the notification settings on your device.

5.9Security of your personal information

We implement technical, organisational and legal measures in an effort to protect personal information from loss, theft, misuse, unauthorised access, disclosure, alteration and destruction, taking into account the nature of the personal information that we process and the risks associated with it.

Depending on the specific processing operation, these measures may include encryption, access controls, role- based permissions, logging, provider due diligence, contractual confidentiality obligations and security monitoring.

Service providers also support the security and protection of your personal information. Their information processing practices are described in their privacy policies and in the table below.

No security system is perfect. Therefore, we cannot guarantee that our Services will be absolutely secure or that personal information will not be intercepted while being transmitted to us.

For your protection, we recommend accessing or using our Services within a secure environment.

6List of rights

The list and scope of your rights, as well as the timing and manner of responding to your requests to exercise those rights, may differ depending on the law applicable to the processing of your personal information.

6.1Right of access

You may request that we provide you with:

6.2Right to information portability

You may obtain personal information concerning you that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means.

6.3Right of rectification

If personal information concerning you is inaccurate, incomplete or equivocal, or if its collection, communication or retention is not authorised by law, you may require that the information be rectified.

Rectification may involve correction, deletion or addition. Where appropriate, amended information must be transmitted to third parties having access to the information.

6.4Right to delete personal information concerning you

You may request that we delete any personal information about you that we have collected from you.

6.5Right to non-retaliation following opt-out or exercise of other rights

We shall not discriminate against you because you have exercised any of your rights under this Section, including by:

This right does not prohibit us:

6.6Right to complain to us

You may challenge our compliance with applicable laws by contacting the person in charge of the protection of personal information.

The title and contact information of the person in charge of the protection of personal information shall be made available on the website: https://kumaapets.com/.

6.7Right to lodge a complaint with the relevant legal authority

You may file a written complaint with the relevant legal authority responsible for supervising our compliance with applicable laws.

The list of relevant legal authorities and their official websites is available in the table below.

7How to exercise your rights

You can exercise your rights within our Services where the relevant control is available or by contacting us at hello@kumaapets.com.

When you exercise your rights, we will confirm your identity by comparing the details in your request with the information you have previously shared with us. This may involve contacting you at the email address associated with your use of our Services.

To respond to your request, we must verify your identity. Therefore, you can only exercise the above rights by submitting a verifiable request, which must:

We use the information provided solely for verification purposes and will not request additional details unless essential. Any extra information you provide will be deleted once the verification process is complete, unless retention is required by law or for security, fraud-prevention, complaint-handling or legal reasons.

We will not respond to requests if we cannot verify your identity and therefore cannot confirm that the personal information we hold pertains to you.

8Cookies

Our Services may use cookies and similar technologies to:

• operate website functionality;
• analyse traffic;
• improve user experience;
• support website security.

We do not currently use advertising cookies or pixels. Authentication tokens are stored in your browser’s local storage rather than in cookies. We use Google Analytics cookies for analytics purposes and Amazon CloudFront security cookies solely to deliver email assets, not for general app traffic.

We obtain your consent to place cookies on your device by providing transparent information in this Privacy Policy and making a cookie consent mechanism available on our Services where we use cookies that are not strictly necessary. Please note that we are not required to obtain your consent for cookies that are strictly necessary to provide our Services.

You can control cookies through your browser settings. Some browsers provide a “Do Not Track” feature. There is currently no universal standard for responding to these signals, and the Services may not respond to them.

Your web browser may also allow you to manage your cookie preferences, including deleting or disabling Stripe cookies. You can consult the help section of your web browser or follow the links below to understand your options. If you choose to disable cookies, some features of our Site or Services may not operate as intended.

• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage- cookies
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

9Updates

We may update this Privacy Policy from time to time as necessary to protect you, provide up-to-date information and address legal and technical changes. The most current version of the Privacy Policy will govern our processing of your information and will be available on our website.

If we make material changes, we may notify you by posting the new policy on our website, sending notifications or using another method required or permitted by applicable law.

10Contact us

If you have any questions, complaints or requests regarding this Privacy Policy or your information, you can contact us by email at hello@kumaapets.com.

Table 1. List of service providers

Table 2. List of legal authorities

United States

Canada