PETSTAR PRIVACY POLICY

Effective & last modified: December 6, 2021

Please carefully read the following Privacy Policy by Good Boy Studios, Inc., before using the websites at petstar.app (the “PetStar Site”) or goodboystudios.com (the “GBS Site”) (collectively, the PetStar Site and the GBS Site referred to as the “Sites”), the PetStar mobile app (the “App”) or any of the services offered by or through the Sites and/or the App (collectively, the “Services”).  By accessing, using, or registering with the App and/or the Sites, or otherwise engaging in or using the Services, you agree to the terms of this Privacy Policy.

As used in this Privacy Policy, unless otherwise specified or not applicable, the terms “GBS,” “we,” “us” and “our” shall mean Good Boy Studios, Inc., the creator, developer, and owner of the Sites and the creator, developer, owner and licensor of the App and the Services provided by and through the App and the Sites.  As used in this Privacy Policy, unless otherwise specified or not applicable, the terms “User,” “you” and/or “your” specifically mean visitors and/or users of the Sites, the App and/or the Services.

This Privacy Policy governs the use of information that may personally identify you, that may be combined with other information that may identify you, or that may be used to contact you (collectively, your “Personal Information”), that is accessed, collected and/or stored when you access, use or register with the App, the Sites, and/or the Services, or that you may otherwise provide through any communications between us and you.

The App, the Sites, and the Services, or portions thereof, and our business model may change from time to time.  As a result, at times it may be necessary for GBS to make changes to this Privacy Policy.  We will not make changes that result in significant additional uses or disclosures of your Personal Information without allowing you to “opt in” and consent to such changes.

We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your Personal Information for which your opt-in and consent is not required.  We encourage you to check this page periodically for any changes.  If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the App, the Sites, and the Services, as applicable.  Your continued use of the App, the Sites, and/or the Services, following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.

To the extent that the App, the Site, and/or the Services are available to Users located in the European Economic Area and the United Kingdom, this Privacy Policy sets out our practices and obligations under the General Data Protection Regulation 2016/679 (the “GDPR”).  This Privacy Policy further sets out our practices and obligations under the California Consumer Privacy Act of 2018 (“CCPA”), the California Online Privacy Protection Act (“CalOPPA), Canada’s Personal Information Protection and Electronic Documents Act and Australia’s Privacy Act, all as applicable.

COLLECTING PERSONAL INFORMATION

General

When you visit the Sites, we collect certain information about your device and your interaction with the Site.  When you download and install the App on a mobile device, we also collect information regarding your device and your interaction with the App.  We also collect information voluntarily provided by you when you create a user profile for your pet, subscribe to our email list, or otherwise register with the Sites and/or the App.  This information may include, in part, Personal Information.

Device Information Collected

When your computer, tablet, mobile device, or any other device contacts our web servers (for example, when you use the App or visit and use the Sites), we may collect information in connection with the actions you take (your “Usage Data”).  Usage Data and device information that we collect from you when you use the App or visit and use the Sites includes the following:

·           Examples of Personal Information Collected: Version of web browser, IP address, time zone, cookie information, third party web sites that you visit, your media access control (MAC) address, your mobile carrier, your mobile Internet browsers, your location information, what sites or products you view, search terms, the time and duration of your visits to the Sites or uses of the App and how you interact with the App and/or the Sites.

·           Purpose of Collection: To load the Sites accurately for you, to perform analytics on your usage of the Sites to optimize the Sites, to provide you with information and advertising of interest to you, to communicate with you more effectively, to assist us in effectively managing any downloads you make from us, to assist us in effectively managing any purchases you make from us and to effectively manage any account you have with us.

·           Source of Collection: Collected automatically when you access our Sites and/or use the App using cookies, log files, web beacons, tags, or pixels; collected automatically when you subscribe to our email list, create a pet profile concerning your pet, or otherwise register with us.

·           Disclosure for a Business Purpose: Shared with various third-party processor marketing agencies and advertisers.

Other Personal Information Collected

When you download and install the App and/or access and use the Sites, particularly the PetStar Site, you may voluntarily provide us with various general non-Personal Information and limited Personal Information, such as, your email address, which is encrypted via an SHA1, SHA-256, or MD5 hashed email identifier, which may be associated with a device identifier, such as a cookie.  We may then associate the non-Personal Information with this limited Personal Information for the purposes stated further below in this Privacy Policy.

Specific non-Personal Information and Personal Information that you may provide to us is as follows:

Information Collected About Others

The App and the PetStar Site may allow you to (i) submit information about other people, such as their name, e-mail, zip code, address, information about their interest in and use of various content, products, programs and services, and other information, and/or (ii) invite friends to join the App and/or the PetStar Site and to connect with you through our social media pages associated with Social Networking Sites (as defined below).  We may collect any such information submitted or shared by you. The decision to provide such information is optional.

Location Information

In addition to other information described in this Privacy Policy, we may collect and share precise location information.  This location information may be used by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and shared with third parties for purposes related to advertising, attribution (e.g., measuring ad performance) analytics and research.  You may remove your consent to having your location data collected by changing the settings on your device.  You may also opt-out from any interest-based advertising through your device settings.  When you have opted out using this setting on a device, advertisers will not use in-App information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.

Minors

The PetStar Site and the App are not intended for individuals under the age of 13.  The GBS Site is not intended for individuals under the age of 18 or the age of majority of the state or jurisdiction in which they reside who are not legally capable of entering into binding contracts.  We do not intentionally collect Personal Information from children.  If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

If and to the extent that we offer any program open to children under 13 years of age through the App, we will collect Personal Information about them from parents and guardians for purposes of considering their admission, enrollment, and other administrative purposes.  We will not share the Personal Information of anyone under 13 years of age with any third party without the consent of a parent or legal guardian.

If and to the extent that we knowingly collect, use, or disclose Personal Information from children under the age of 13, we will comply with the Children’s Online Privacy Protection Act (“COPPA”) (and other applicable laws) and obtain parental consent.

SHARING PERSONAL INFORMATION

General

We share your Personal Information we have collected with various third-party service providers (processors) to help us provide our services and fulfill our contracts with you, as described above.  For example:

Behavioral Advertising

We use your Personal Information in combination with non-Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For example:

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at

http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You may opt out of targeted advertising using any of your Personal and non-Personal Information by:

·           Requesting that we delete the profile you voluntarily created through the App and/or the PetStar Site by sending us an email at hello@goodboystudios.com.  Please be sure to include your full name and email address and specifically state that you would like personal data and your pet’s data deleted from our system.

·           Clicking the “Do not sell my personal information” link on the footer of the Site from which you signed up for our Services or otherwise deleting the profile you voluntarily created through the App and/or the PetStar Site.

·           Opting out from receiving targeted advertising on the following platforms by using the following links:

FACEBOOK:  https://www.facebook.com/settings/?tab=ads

GOOGLE:  https://www.google.com/settings/ads/anonymous

BING: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

LIVERAMP:  https://optout.liveramp.com/opt_out

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

USING PERSONAL INFORMATION

General

We use Personal Information for internal purposes, such as to improve the App and the Sites, to fulfill requests for products and services, to notify you of new products or services, and to otherwise communicate with you about us, our products, and our affiliated companies.

We also use your Personal Information to provide our services to you, which include offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers, and to provide you with the Services.  We also use limited Personal Information to provide you with information and advertising that may of interest to you as described more fully above.

We may use Usage Data for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the App and/or the Sites.  We may associate your Usage Data with the Personal Information you provide.  We may disclose to third parties certain of your Usage Data regarding the App and/or Sites.  However, in such cases, your Usage Data will be aggregated with the Usage Data of others and will not identify you individually or include your Personal Information.

Third-Party Providers

From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Third-Party Providers”).  For example, we contract with Third-Party Providers to provide certain services, such as hosting and maintenance, data storage and management, marketing, and promotions, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. We generally only provide our Third-Party Providers with the information necessary for them to perform these services on our behalf.

Joint Offerings

We may provide services jointly with other companies such as booking an appointment, scheduling a delivery, or ordering a product. In some cases, in order to facilitate such services, it may be necessary to share your Personal Information with such other companies. In these cases, the service provider will be identified to you and you will have the option to not participate in the service or transaction.

Sweepstakes, Contests and Other Promotions

If you choose to enter a contest, sweepstakes, or other promotion (each, a “Promotion”), your Personal Information may be disclosed to third parties in connection with such Promotion, including without limitation, for purposes of posting your entry with attribution or otherwise as permitted in the official rules for the Promotion in question, fulfilling your prize or including your name on a winners list.  Also, by entering a Promotion, we may require you to consent to the use of your Personal Information or other information, such as name, voice, or likeness, in advertising, promotional and marketing materials. In addition, we may offer a Promotion sponsored by or co-branded with a third party, who may obtain the Personal Information that you submit.

External Links

The App and/or the Site may contain links to, or advertisements about, non-GBS websites or properties (“Other Sites”). Other Sites may also reference, advertise, or link to the App and/or the Site.  GBS does not endorse or sponsor Other Sites, is not responsible for the privacy practices or the content of Other Sites, expressly disclaims any statements or assertions made on such Other Sites, and denies all liability associated with your use of, and the content on, such Other Sites. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through Other Sites.  We encourage you to read the privacy policies of each and every website that you visit.

Social Networking Sites

The App and/or the Site may enable you to access third-party services, social media sites, plug-ins and applications, such as Facebook, Twitter and other social networks (each, a “Social Networking Site”) and/or connect your accounts from such Social Networking Sites with the App and/or the Site by an application programming interface (API) or other software.  When you do so, you may be able to import information from and share content, including Personal Information, with those Social Networking Sites.  Some of those Social Networking Sites may also provide us with information from your accounts (e.g., photographs, gender, birthday, location, your “friends” list, people you follow and/or who follow you, your posts and “likes” and Usage Data), which may enable us to enhance and personalize your use of the App and/or the Site.  By allowing us to connect with your accounts on Social Networking Sites, you consent to our accessing the information in those accounts.  You likewise consent to our publishing on the App and/or the Site any such information or actions you take on other such Social Networking Sites.  If you elect to access such Social Networking Sites through the App and/or the Site or connect your accounts from such Social Networking Sites with the App and/or the Site, the information you share with such Social Networking Sites will be subject to their privacy policies and your privacy settings for such services. You also may be able to control or block such sharing by changing your privacy settings in such Social Networking Sites.

Security

We recognize the importance of safeguarding the confidentiality of your Personal Information.  Accordingly, we employ commercially reasonable measures designed to protect your information from unauthorized access, disclosure, and use.  However, no data transmission over the Internet or other network can be guaranteed to be 100% secure.  As a result, while we strive to protect information transmitted on or through the App and/or the Site, we cannot and do not guarantee the security of any information you transmit on or through the App and/or the Site, and you do so at your own risk.

Processing in the United States

Please be aware that the Site and the servers used by the App are operated solely in the United States and that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country.  By providing any information to us, all users, including, without limitation, users in the member states of the European Union, Canada or elsewhere outside of the United States, fully understand and unambiguously consent to this Privacy Policy.  If you are located outside of the United States, please be advised that the laws of the United States may not be as protective of your privacy as those in your location.  By using the App and/or the Site, you agree that the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

Choice of Law

This Privacy Policy, including all revisions and amendments thereto, is governed by the internal laws of the State of Connecticut, US, without regard to its conflict or choice of law principles which would require application of the laws of another jurisdiction.

FOR USERS LOCATED IN EUROPE

Lawful Basis

Pursuant to the General Data Protection Regulation (GDPR), if you are a resident of the European Economic Area (“EEA”), we process your Personal Information under the following lawful bases:

·           Your consent;

·           The performance of the contract between you and the Site and/or the App;

·           Compliance with our legal obligations;

·           To protect your vital interests;

·           For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you interact with the App and/or the Sites as described in this Privacy Policy, we will retain your Personal Information for our records unless and until you ask us to erase this information.  For more information on your right of erasure, please see the “Your Rights” section, below.  When you voluntarily opt in and subscribe to our email list, or otherwise voluntarily register with the App and/or the Sites, we retain your Personal Information for our records and various third-party processors, as described above, unless and until you ask us to erase this information.  For more information to your right of erasure, please see “Your Rights” section, below.

Automatic Decision-Making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We engage in limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.  Services that include elements of limited automated decision-making by us include:

·           Temporary denylist of IP addresses associated with repeated failed transactions.  This denylist persists for a small number of hours.

·           Temporary denylist of credit cards associated with denylisted IP addresses.  This denylist persists for a small number of days.

Our processors do not engage in automated decision-making.

Selling Personal Information

Our Site sells Personal Information, as defined by the California Consumer Privacy Act of 2018 (“CCPA”).

·           Categories of Information Sold.  Cookie information, what sites or products you viewed or purchased, search terms, and how you interact with the App and the Sites; non-Personal Information relative to your pet's profile; your email address, encrypted via a SHA1, SHA-256, or MD5 hashed email identifier; device identifier; usage data; IP address; postal code.

·           Opt-Out Instructions.  You may opt-out of having your Personal Information sold by requesting that we delete the pet profile you voluntarily created through the App and/or the PetStar Site by sending us an email at hello@goodboystudios.com.  Please be sure to include your full name and email address and specifically state that you would like personal data and pet's data deleted from our system.  You may also opt out of having your Personal Information sold by clicking the “Do not sell my personal information” link on the footer of the Site from which you signed up for our Services or otherwise deleting the pet profile you voluntarily created on our Site.

·           Minors.  We do not sell information of minors under the age of 16 and we obtain affirmative authorization.

·           Financial Incentives.  We currently do not offer financial incentives regarding the non-sale of Personal Information.

Your Rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased.  If you would like to exercise these rights, please contact us through the contact information below.

Information voluntarily provided by you when creating a profile and opting into our email list through the App or otherwise registering with the Site, including any Personal Information associated therewith, will be processed in the United States and stored in the United States unless and until you ask us to erase this information.

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the “Right to Know”), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased.  If you would like to exercise these rights, please contact us through the contact information below.

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site or use the App.  We use a number of different cookies, including functional, performance, advertising, and social media or content cookies.  Cookies make your browsing experience better by allowing the Site to remember your actions and preferences (such as login and region selection).  This means you don’t have to re-enter this information each time you return to the site or browse from one page to another.  Cookies also provide information on how people use the Site, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies for Reporting and Analytics

Cookie Name

Cookie Function

_fbp

Analytics relating to marketing.

_ga

Analytics relating to marketing.

utm_campaign

Analytics relating to marketing.

utm_medium

Analytics relating to marketing.

utm_source

Analytics relating to marketing.

token

Functionality of the website.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie.  Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted.  Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways.  Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu.  For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners.  To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioral Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@goodboystudios.com or by mail using the details provided below:

Good Boy Studios, Inc., 47 Benjamin St, Old Greenwich CT 06870, United States

For more information about our email subscription privacy practices, or if you have questions regarding our email subscription privacy practices, or if you would like to make a complaint regarding our email subscription privacy practices, please contact Good Boy Studios, Inc., by e-mail at hello@goodboystudios.com or by mail using the details provided below:

Good Boy Studios, Inc., 47 Benjamin St, Old Greenwich CT 06870, United States

Last updated: December 6, 2021

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority.  You can contact your local data protection authority, or our supervisory authority here:

Federal Trade Commission

600 Pennsylvania Avenue, NW

Washington, DC 20580

Telephone: (202) 326-2222

https://reportfraud.ftc.gov/#/

For complaints arising under the CCPA, please contact:

Rob Bonta

Attorney General

State of California Department of Justice

1300 "I" Street

Sacramento, CA 95814-2919

Telephone: (916) 445-9555

https://oag.ca.gov/contact/consumer-complaint-against-business-or-company