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Privacy Policy

This Privacy Policy explains how Frostplant LLC (“Pupcoach”, “we”, “us”) collects, uses, and protects your information when you use the Pupcoach app and website. We’ve tried to keep it clear and practical.

Who we are

Pupcoach is a dog-training app operated by Frostplant LLC, a company registered in New York, United States, at 418 Broadway, Ste N, Albany, NY 12207. Frostplant LLC is the data controller responsible for your personal information. If you have any questions about this policy or your data, contact us at hello@pupcoach.com.

Information we collect

How we use your information

We do not sell your personal information or share it for cross-context behavioral advertising, and we don’t use your dog’s profile, training history, or messages for advertising.

Our legal bases (UK and EU)

If you are in the United Kingdom or the European Economic Area, we rely on the following legal bases under the UK GDPR and EU GDPR:

How your information is processed and shared

We share information only with service providers who help us run Pupcoach, under contracts that require them to protect it:

To provide personalized coaching, your dog’s profile, training goals, coaching preferences, training history and feedback, and messages are shared with Google Gemini, a third-party AI service on Google Cloud, to create personalized training plans, coaching replies, and progress signals. This includes conversation history and useful coaching details remembered for future training, and scheduled training prepared while the app is closed. These are recommendations to help you train your dog — not decisions that have legal or similarly significant effects on you. We do not use your personal data to train these systems or any third-party foundation models.

This processing is how the coaching features work, so it is not something you can switch off while continuing to use them; deleting your account ends it. Managing your subscription and deleting your account do not involve it. Avoid including sensitive personal information in messages to your coach.

The third parties named above with whom we share user data — Google (Google Cloud, Firebase, Firebase Analytics, Firebase Crashlytics, and Google Gemini) and Apple — will provide the same or equal protection of that user data as stated in this Privacy Policy and as required by Apple’s App Review Guidelines.

We may also disclose information if required by law, or to protect the rights, safety, and security of our users and Pupcoach.

Short links and QR codes

Some printed materials, such as business cards, use short links and QR codes like pupcoa.ch/c/a7Dx that forward you to the App Store or to this website. When you open one, our hosting provider (Google Firebase Hosting) records a standard web request log: the link you opened, your IP address, your browser’s user agent (which describes your device and browser), the referring page, and an approximate location (such as country and city) derived from your IP address. We use these logs only to count how often each link is followed and from which kinds of devices and countries. We keep the raw logs for 30 days and then delete them. We keep daily totals for each link, which contain no IP address, user agent, referring page, or city, for up to two years. We don’t use these logs to identify you, link them to your Pupcoach account, or use them for advertising.

International transfers

Pupcoach is operated from the United States, and your information is processed there and in other countries where our service providers operate. When we transfer personal data out of the UK or EEA, we rely on appropriate safeguards — such as the European Commission’s Standard Contractual Clauses and the UK’s International Data Transfer Agreement or Addendum — together with the data-protection commitments of providers like Google and Apple. You can ask us for more information about these safeguards using the contact details below.

How long we keep your information

We keep your account and training data for as long as your account is active. Chat history is retained while your account remains active and is deleted when you delete your account. If you delete your account or ask us to erase your data, we will delete it within 30 days, except where we’re required to keep certain records by law. Backup copies are cleared on our regular backup cycle and aren’t restored except for security or disaster recovery.

Your rights

Depending on where you live (including under the UK GDPR, EU GDPR, and California’s CCPA/CPRA), you may have the right to access, correct, export, delete, or restrict the use of your personal information, to object to certain processing, and to withdraw any consent you have given. To exercise any of these rights, email hello@pupcoach.com, or delete your account at any time from within the app; we will respond within the time the law allows. If you are in the UK or EEA and remain unsatisfied, you also have the right to complain to your local data protection authority (in the UK, the Information Commissioner’s Office).

Your California privacy rights

If you are a California resident, the CCPA and CPRA give you specific rights. In the past 12 months we have collected these categories of personal information: identifiers (such as your Apple account identifier and, if you share them, your name and email); your dog’s profile and your training activity; commercial information (your subscription and purchase history); and internet, device, and usage information (such as app version, device type, and diagnostics). We collect this from you, from your device, and from Apple, and use it for the purposes described above.

We do not sell your personal information and do not share it for cross-context behavioral advertising. You have the right to know about, access, correct, and delete your personal information, and the right not to be treated differently for exercising these rights. To make a request, email hello@pupcoach.com; we will verify it against the information we hold, and you may use an authorized agent.

Children

Pupcoach is for people aged 13 and over and is not directed at children under 13. We do not knowingly collect personal information from anyone under 13. Where local law sets a higher age for consenting to a service like this — 16 in parts of the European Economic Area — we rely on a parent or guardian’s consent below that age. If you believe a child has given us information, contact us and we’ll delete it.

Security

We protect your information with encryption in transit and at rest, access controls, and other safeguards. No system is perfectly secure, but we work hard to keep your data safe.

Changes to this policy

We may update this policy from time to time. If we make significant changes, we’ll let you know in the app or by email. The “last updated” date above shows when this version took effect.

Contact us

Questions or requests? Email us at hello@pupcoach.com.