Data Protection Policy

1. DEFINITIONS

1.1 Pet Watch FZCO, (hereinafter referred to as “Pet Watch”, “Company” or “We” or “Us” or “Our”) and/or its subsidiaries and affiliates, are committed to safeguarding the privacy of the Personal Data that We gather.

1.2 The Pet Watch Internal Data Protection Policy (herewith referred to as the “Policy”) applies to Personal Data and to the collection, processing and/or management of that Personal Data in any form whether oral, electronic, or written.

1.3 This Policy gives effect to Pet Watch’s commitment to protect any Personal Data, including that of its Users.

1.4 This Policy and any other documents referred to in it set out the lawful bases on which We will process Personal Data that We collect from any Data Subjects, or that is provided to Us by Data Subjects or other sources.

1.5 This Policy may be amended at any time subject to the discretion of Pet Watch.

2. Compliance and Administration

2.1 Our Users have rights with regard to the way in which their Personal Data is collected, stored and processed. We acknowledge that treating this Data fairly and lawfully ensures its confidentiality within Pet Watch and underpins our successful operations.

2.2 All Pet Watch employees, and contractors must comply with this Policy when Processing Personal Data on Pet Watch’s behalf. Any breach of this Policy may result in disciplinary action.

2.3 The Personal Data, which we hold in relation to our Users and other Third Parties is subject to certain legal safeguards specified in applicable data protection laws and regulations, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL” or the “Applicable Laws”).

2.4 Pet Watch has taken the following steps to ensure compliance with the Applicable Laws:

1. Pet Watch shall appoint a qualified Data Protection Officer (“DPO”) with sufficient expertise in data protection law and practice. The DPO must act independently, report to senior management, and be responsible for:
2. ensuring compliance with the PDPL, Applicable Laws and this Policy;
3. Supporting the completion of any required documentation, including maintaining internal records of processing activities;
4. receiving and handling Data Subject requests and complaints related to Personal Data;
5. providing technical advice on impact assessments and evaluating internal systems and controls; and
6. acting as a point of contact with the UAE Data Office regarding the application of personal data processing provisions.

2.4.2 Pet Watch has taken the following steps to ensure compliance with the Applicable Laws:

3. DEFINITIONS

3.1 “Applicable Laws” means laws, regulations, orders, directives, guidelines within the legal jurisdiction of the United Arab Emirates including the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data.

3.2 “Account” means the personalized section of the Pet Watch Platform created upon User registration, containing personal, contact, and pet-related information.

3.3 “Consent” means the consent whereby the Data Subject authorizes a third party to process his/her Personal Data, provided that this consent indicates, in a specific, clear and unambiguous manner, that he/she accepts the processing of his/her Personal Data through a clear positive statement or action.

3.4 “Controller(s)” means entities or individuals who determine the Processing purposes and methods of Personal Data. Pet Watch, in compliance with the Applicable Law, acts as the Controller, setting practices and policies for Data usage.

3.5 “Data” means information processed either i) electronically through automated equipment based on specific instructions ii) on paper intended for electronic Processing. This includes, but is not limited to, User profiles, pet details, and transaction records on the Pet Watch Platform.

3.6 “Data Breach” means breaching information security and Personal Data through illegal or unauthorized access. This includes copying, sending, distributing, exchanging, transferring, circulating or processing it in a way which leads to disclosure of such data to third parties, or destroying or modifying it during storage, transfer and processing.

3.7 “Data Protection Impact Assessment (DPIA)” will be a comprehensive assessment process employed by Pet Watch to evaluate and manage the potential risks and impacts associated with the Processing of Personal Data particularly involving Special Categories of Personal Data or High-Risk Processing Activities.

3.8 “Data Erasure” means the process of safely and permanently removing stored Personal Data upon the request of the Data Subject or after it’s no longer necessary for its original purpose, as stipulated in the PDPL.

3.9 “Data Protection Officer” a Natural or Legal Person appointed by Pet Watch, that undertakes the tasks of ascertaining the extent to which Pet Watch complies with the controls, requirements, procedures and rules for processing Personal Data Protection stipulated in the PDPL.

3.10 “Data Subjects” means all natural persons who are the subject of Personal Data held by Pet Watch. This includes Pet Owners, Pet Sitters, and any other Users of the Pet Watch platform. All Data Subjects possess legal rights concerning their Personal Data.

3.11 “High-Risk Processing Activity” means certain types of Data Processing and activities that carry a higher risk to the individuals’ privacy rights and freedoms. For Pet Watch, this includes, but is not limited to, live location tracking of Pet Sitters and pets, Processing of sensitive pet medical data, and any other Processing activities that may result in significant risks to the privacy or security of Personal Data. Such Processing typically requires a thorough assessment and potentially additional safeguards to ensure the protection of Data Subjects’ rights.

3.12 “Pet Sitter” means an individual registered on the Pet Watch Platform who offers services related to pet care, including but not limited to pet sitting, walking, or grooming.

3.13 “Pet Owner” means an individual registered on the Pet Watch Platform who seeks services for their pets and may provide specific pet-related data for Service provisioning.

3.14 “Processors” means any entity or individual, including Pet Watch employees, who process Personal Data on behalf of Pet Watch and based on its directives. This might encompass Third-Party service providers or partners who manage Data for Pet Watch.

3.15 “Privacy Policy” means the privacy policy issued by Pet Watch for its Users to protect any confidential information and other information/Data processed and used by Pet Watch for the Services provided to the Users;

3.16 “Personal Data” means any data related to a specific natural person or related to a natural person that can be identified directly or indirectly by linking the data, through the use of identification elements such as his/her name, voice, image, identification number, his/her electronic identifier, his/her geographical location, or by one or more physical, physiological, economic, cultural or social characteristics.

3.17 “Platform” means the mobile application or any other digital interface provided by Pet Watch where Users interact, share Data, or avail Services.

3.18 “Processing” means any operation or set of operations performed on Personal Data using any electronic means, including processing and other means. This processing includes collecting, storing, recording, organizing, adapting, modifying, circulating, altering, retrieving, exchanging, sharing, using, characterizing, disclosing Personal Data by broadcasting, transmitting, distributing, making available, coordinating, merging, restricting, blocking, erasing or destroying it or creating forms thereof. This also includes the sharing of Personal Data with Third Parties, as mentioned in the Privacy Policy.

3.19 “Special Categories of Personal Data” means any data which directly or indirectly reveals a natural person’s family, ethnic origin, political or philosophical opinions, religious beliefs, criminal record, biometric data, or any data relating to such person’s health and physical, psychological, mental, genetic or sexual condition, including information related to the provision of healthcare services to him/her which reveals his/her health status and may include specific pet health details or behavioral traits.

3.20 “Services” means all pet-care-related services provided by Pet Watch through the Platform;

3.21 “Service Time” means the specific duration during which a Pet Sitter provides Services to a Pet Owner, and during which certain data, like location, might be shared between the two parties

3.22 “Third Party Sites” means websites or platforms other than Pet Watch, which might be linked or integrated with the Pet Watch platform, and have their own privacy policies.

3.23 “Third Parties” means entities or individuals other than Pet Watch and the User, who might receive Personal Data for specific purposes as outlined in the Privacy Policy.

3.23 “UAE Data Office” means the regulatory authority established under Federal Decree by Law No. (44) of 2021 who is responsible for supervising and enforcing compliance with the PDPL.

3.23 “Third Parties” means any individual or entity that interacts with the Pet Watch platform. This includes, but is not limited to, Pet Owners, Pet Sitters, and any other person(s) accessing any part of the Platform. Users provide, receive, or access Data and Services on the Platform and are subject to the terms of the Privacy Policy, Terms & Conditions, and any other Pet Watch policies.

4. Data collection and protection principles

4.1 Pet watch may in the ordinary course of business collect and process information about anyone who:

• uses Our Platform, or other Pet Watch digital interfaces;
• contacts Us for information about using our Services or for information about other products and services offered by Pet Watch;
• interacts and communicates with Us in a business capacity, including Pet Owners, Pet Sitters and other Users of our Platform;
• provides or handles information relating to suppliers, Third-Party platforms, and other partners associated with Pet Watch;
• participates in Our surveys, reviews, or promotions;
• engages with Pet Watch through social media channels;
• creates an Account on Our Platform, providing personal, contact, and pet-related information;
• acts as a Data Subject, providing Personal Data that is processed by Pet Watch in its role as a Controller;
• acts as a Processor, Processing Personal Data on behalf of Pet Watch;
• acts as a Pet Sitter, offering pet-care-related services on our Platform;
• acts as a Pet Owner, seeking pet-care-related services on our Platform;
• engages in High-Risk Processing Activities, such as live location tracking or sharing sensitive pet medical data;
• provides Special Categories of Personal Data, revealing sensitive personal details or opinions;
• engages with Third Party Sites or Third Parties linked or integrated with the Pet Watch platform

4.2 Pet Watch may in the regular course of business, collect and process the following information about its Users:

• User Profile Details: This includes name, gender, contact number, email address, and any other personal details provided during registration or profile setup.
• Pet Details: Information related to pets such as name, breed, age, medical history, and any specific care instructions.
• Location Data: Real-time location data for Pet Sitters during Service Times.
• Service Details: Information related to the Services availed, including Service Time, type of Service (e.g., pet sitting, walking, grooming), and any feedback or reviews provided post-service.
• Payment Information: While Pet Watch might not store complete payment details, it may process transaction IDs, payment methods used, and transaction amounts for record-keeping and Service provisioning.
• Interactions on the Platform: This includes messages exchanged between Pet Owners and Pet Sitters, feedback, reviews, and any other form of communication or interaction on the platform.
• Third-Party Integrations: Any data shared or received through Third-Party platforms or services integrated with Pet Watch, such as payment gateways or promotional partners.
• Technical Data: Information captured from devices accessing the Platform, including device type, operating system, IP address, and other relevant technical details.
• User Behavior: Data related to User behavior on the Platform, such as features used, frequency of use, preferences, and any other behavioral data that helps improve the Platform’s User experience.
• Emergency Contacts: In case of emergencies or specific services, Users might provide alternate contact details or emergency contacts.
• Special Categories of Personal Data: Any sensitive Data shared by Users that fall under the special categories, as defined in the Policy.

4.3. Anyone Processing such information, especially in the context of Pet Watch’s operations must adhere to the following principles of Data protection:

4.3.1 Nature of Processing: Personal Data shall be processed lawfully, fairly, and in a transparent manner in relation to the Data Subject.

4.3.2 Consent: Personal Data shall only be processed with the explicit Consent of the Data Subject, especially when it pertains to High-Risk Processing Activities or Special Categories of Personal Data

4.3.3 Processing for limited purposes:

• Personal Data shall only be used for the purpose it was collected for, ensuring that no Data is used for unsolicited purposes, especially without the knowledge or Consent of the Data Subject. Personal Data shall be adequate, relevant and limited to those which are necessary in relation to the purposes for which they are processed.
• Pet Watch may collect and process Personal Data from various sources, including directly from Data Subjects that include Pet Sitters, Pet Owners, and other Third Parties such as Service providers or partners.
• Pet Watch shall process Personal Data solely for the purposes communicated to the Data Subject, in line with the Applicable Law, and as detailed in the Privacy Policy.

4.3.4. Transparency: Data Subjects shall be informed about the nature, purpose, and extent of the Data Processing. This includes clear communication about any High-Risk Processing Activities or sharing with Third Parties.

4.3.5 Timely Processing:

• Pet Watch shall retain Personal Data only for the duration necessary for its intended purpose. All data no longer required, or upon a Data Subject’s request, will be deleted or modified.
• Regular reviews shall be conducted to assess the Processing and storage of Data, ensuring compliance with the Applicable Law and understanding the flow of Data within and outside of Pet Watch.
• Pet Watch commits to retaining Personal Data solely for the time period essential to serve the intended purposes of collection or as mandated by the legitimate interests in accordance with the Applicable Law.
• If the basis for processing changes, Pet Watch shall ensure that the Personal Data is either securely deleted, anonymized, pseudonymized, encrypted, or archived, as appropriate.

4.3.6 Data Minimization and Retention: Only the minimum necessary Data shall be collected and processed, ensuring that no excessive Data is stored or used beyond the Service requirements.

4.3.7 Integrity and Confidentiality: Personal Data shall be protected against any unauthorized access, alteration, or disclosure. This includes ensuring the confidentiality of User interactions, especially between Pet Owners and Pet Sitters.

4.3.8 Fair Processing:

• Legal Grounds: For Personal Data to be processed lawfully within the Pet Watch platform, Pet Watch shall adhere to one of the legal bases defined in the Applicable Law. This shall include the Data Subject’s explicit Consent, necessity for the performance of a Service or contract with the Data Subject, compliance with a legal obligation, or other grounds expressly permitted under the PDPL. When Processing Special Categories of Personal Data or engaging in High-Risk Processing Activities, stricter conditions shall be met to ensure the utmost protection of the Data Subject’s rights.
• Controller Responsibility: As the Controller, Pet Watch commits to ensuring that all Processing activities align with the Applicable Law. This includes ensuring that all Pet Sitters, Pet Owners, and other users of the Platform are aware of their rights and the measures in place to protect their Personal Data.

4.3.9 Accountability: Pet Watch, as the Controller, shall take responsibility for the Data it processes and ensure that all Processing activities are compliant with the Applicable Law.

• Pet Watch ensures that the use or disclosure of Personal Data aligns with the purpose(s) for which it was collected. Except in specific circumstances, including where mandated by law, Personal Data will be used and disclosed in ways that are consistent with these purposes.
• Pet Watch is committed to transparency and shall inform Data Subjects through publicly available privacy notices, such as on the Pet Watch platform, about:
• The specific purposes for which their Personal Data shall be processed.
• How Pet Watch Processes their Personal Data, including details about Third-Party suppliers or partners who might Process it on Pet Watch’s behalf.
• The types of Third Parties, if any, with whom Pet Watch may share or disclose their Personal Data.
• Available methods through which Data Subjects can limit the use and disclosure of their Personal Data.
• The rights Data Subjects have concerning the use of their Personal Data, in line with the Applicable Law.
• The transparency and accountability measures Pet Watch has implemented to ensure the protection of Personal Data.
• Pet Watch’s role as a Controller of their Personal Data and the means to contact the Data Protection Officer, for any concerns or inquiries.
• Pet Watch recognizes the importance of assessing the potential risks associated with Processing Personal Data, especially when introducing new Data Processing technologies or engaging in High-Risk Processing activities.
• A Data Protection Impact Assessment (“DPIA”) will be conducted in situations where Data Processing, particularly involving Special Categories of Personal Data or High-Risk Processing Activities, may result in a high risk to the rights and freedoms of Data Subjects. This includes, but is not limited to, systematic and extensive profiling, large scale Processing of Special Categories of Personal Data, and large-scale monitoring of public areas.

4.3.10 User Rights: The rights of Data Subjects as per the PDPL (also mentioned in this Policy and in the Privacy Policy), including the right to access, rectify, erase, and object to the Processing of their Personal Data shall be recognized and respected.

4.3.11 Data Breach Notification: In the event of a Data B reach, Pet Watch shall promptly notify the UAE Data Office and any affected Data Subjects and take appropriate mitigating measures in accordance with its Incident Management Policy and the requirements under Applicable Laws.

4.3.12 Continuous Review: Shall regularly review and update Data protection practices to ensure they remain compliant and effective, especially in light of evolving technologies and User needs. High-Risk Processing activities will be reviewed regularly to ensure that all potential risks are identified and mitigated.

4.3.13 Transferring Personal Data: Pet Watch may transfer any Personal Data it holds to and from the jurisdiction in which it is collected. Specifically, when transferring Personal Data out of the UAE, Pet Watch ensures that one of the following conditions is met:

• The transfer is to a country or territory that ensures an adequate level of protection, as approved by the UAE Data Office.
• Appropriate safeguards are in place in accordance with the PDPL and its Executive Regulations (such as contractual clauses or intra-group binding corporate rules).
• The Data Subject has provided explicit and informed Consent for the transfer.
• The transfer is necessary for the performance of a contract with the Data Subject, to protect their vital interests, for legal claims, or for significant public interest reasons.

4.3.14 Data Security: Pet Watch prioritizes the security of Personal Data, implementing measures to protect against unauthorized or unlawful Processing and accidental loss or damage and that security protocols are in place from the point of data collection to its destruction. Personal Data shall only be shared with a Processor if they adhere to Pet Watch’s security standards or provide equivalent safeguards.

Due to the nature of High-Risk Processing, Pet Watch will implement additional security measures, including advanced encryption, regular audits, and continuous monitoring, to ensure the utmost protection of Personal Data.

4.3.15 Training and Awareness: Pet Watch shall ensure that all employees, contractors, and Third Parties involved in Data Processing are adequately trained and aware of their responsibilities regarding Data protection.

5. Disclosure and sharing of Personal Data

5.1 Pet Watch may share Personal Data it holds with any affiliated entities or partners, ensuring confidentiality in all instances, provided such disclosure is based on a valid legal ground under the PDPL.

5.2 Pet Watch may also disclose Personal Data it holds to Third parties, in accordance with the PDPL and Applicable Law:

• In scenarios where Pet Watch is involved in the sale, acquisition, or merger of business assets, Personal Data may be shared with the prospective seller, buyer, or other involved parties.
• If Pet Watch or a significant portion of its assets are acquired by a Third Party, the Personal Data held by Pet Watch may be among the transferred assets.
• If Pet Watch is obligated to disclose or share a Data Subject’s Personal Data due to legal requirements, or to enforce or apply any contract with the Data Subject or other agreements; or to safeguard the rights, property, or safety of Pet Watch, its Users, or others. This might include sharing information with other companies and organizations for purposes like fraud protection.

5.3 Pet Watch may share Personal Data with selected Third Parties for purposes including, but not limited to, enhancing the User experience, facilitating Service provision by Pet Sitters, or to support relevant User engagements on the Platform, in accordance with the grounds under the PDPL.

6. Dealing with Data Subjects’ rights and requests

6.1 With some limited exceptions, any Data Subjects are entitled to:

1. Right to Receive Information: You have the right to request information regarding the Personal Data we hold about you.
2. Right to Request Transfer of Personal Data: You have the right to receive your Personal Data in an orderly and machine-readable manner and/or to request transfer of Personal Data to another controller when technically feasible.
3. Right to Rectification: You have the right to request the correction of inaccurate or incomplete Personal Data.
4. Right to Erasure: Subject to the exceptions included in the UAE Laws, you have the right to request the deletion of your Personal Data only if the Personal Data is no longer necessary for purposes it was collected or processed for, if you withdraw consent, if you object to processing and if Personal Data is processed in violation of UAE Laws.
5. Right to Restriction: You have the right to request the restriction of processing of your Personal Data.
6. Right to Stop Processing: You have the right to object to the processing of your Personal Data and stop it in certain circumstances.
7. Right to Processing and Automated Processing: Subject to the exceptions stipulated under the UAE Laws, you have the right to object to any decisions resulting from automated processing, including profiling.
8. Right to Consent:
9. Giving Consent: Before collecting or Processing any Personal Data, Pet Watch will ensure that clear, informed, and explicit Consent is obtained from the Data Subject. For any High-Risk Processing activities, Pet Watch shall obtain explicit and informed Consent from the Data Subjects. This Consent will detail the specific High-Risk activities and the potential implications for the Data Subject
10. Right to be informed about High-Risk Processing Activity: Pet Watch shall ensure that the Data Subjects shall be informed about, have the right to object to, or restrict High-Risk Processing activities concerning their Personal Data. They also have the right to access and rectify any of their Data involved in High-Risk Processing.
11. Withdrawal of Consent: Data Subjects have the right to withdraw their Consent at any time. Pet Watch will provide an easy and straightforward method for Data Subjects to withdraw their Consent, and such requests will be processed promptly.
12. Transparency in Consent: Pet Watch will ensure that Data Subjects are fully informed about how their Data will be used before obtaining their Consent.
13. Transparency in High-Risk Processing Activities: Pet Watch will ensure that all Data Subjects are fully informed about any High-Risk Processing activities and their rights concerning such Processing. In the event of any Data Breaches related to High-Risk Processing, affected Data Subjects will be notified promptly as per the Incident Management Policy that can be accessed via the Platform.
14. Right to Lodge a Complaint: Data Subjects shall possess the right to lodge a complaint to the UAE Data Office regarding the Processing of their Personal Data in case of any escalated issue.

6.2 Data Subjects may submit any request or complaint regarding their Personal Data directly to Pet Watch via the contact details mentioned at the end of this Policy, in accordance with the procedure outlined in the Incident Management Policy. If unresolved, they may escalate the matter to the UAE Data Office.

6.3 Any member of Pet Watch who receives a written or verbal request or complaint from a Data Subject shall immediately engage the procedure set out in Pet Watch’s Incident Management Policy, within 15 (fifteen) days of such requests, and a breach of the Applicable Laws may occur if Pet Watch does not respond accordingly.

7. Questions about this Policy

7.1 If you have any questions about this Policy, or any concerns or complaints with regard to the administration of this Policy, or if you would like to submit a request as described in Section 6 above for access to the Personal Data that We maintain about you, please contact us by any of the following means:

7.1.1 For current Pet Watch Users, including Pet Owners and Pet Sitters, you can reach out through the “Help” or st”Support” section within the Pet Watch platform.

7.1.2 For any other inquiries or concerns, please contact our Data Protection Officer by emailing info@petwatchapp.com. Any inquiries or concerns relating to Data Protection will be forwarded to the DPO.

7.2 Complaints or further escalation can be directed to the UAE Data Office.