Legal

Privacy Policy

What we collect in Fluffy, why, who we share it with, and the choices you have.

Draft. This policy is based on common app privacy policies and is being reviewed by our lawyers. It will be finalized before Fluffy launches.

Last updated: November 2, 2026

This Privacy Policy explains how Pawlo Technologies Inc. (“Pawlo”, “we”, “us”) collects, uses and shares information when you use the Fluffy mobile app, the Fluffy collar, and pawlotech.com (together, the “Services”). Pawlo is a Delaware corporation and is responsible for your information.

By using the Services, you agree to this policy. If you don’t agree, please don’t use the Services.

1. Information you give us

  • Account information. Your email address, used to send sign-in codes. If you sign in with Apple or Google, we receive the name, email address and identifier they share with us. If you use Apple’s “Hide My Email”, we only receive the relay address.
  • Pet profile. Your pet’s name, species, breed, birthday, personality traits and avatar.
  • Photos and images. Photos you add of your pet, and outfit or scene images you upload.
  • Sound clips. When you hold the mic, a short recording of your pet’s sound. We only use the microphone while you hold the button.
  • Things you write to us. Messages to support, feedback, and answers you give in the app (for example, what your pet was up to after a sound).

2. Information we create or collect automatically

  • Creations. Images, looks, outfit previews, scenes and lines that Fluffy creates for you.
  • Collar data. If you pair a Fluffy collar: its identifier and firmware version, battery level, your pet’s GPS location and location history, the safe zones you set, and activity and sleep data (steps, calories, running, jumping, resting, active time, deep and light sleep, current state).
  • Purchases. Records of credit packs and subscriptions you buy and your credit balance. Payments are handled by Apple; we never receive your card details.
  • Device and usage data. Device model, operating system, app version, language, time zone, IP address, crash logs, performance data, and which features you use. We use this to keep the app working and secure.
  • Permissions. Whether you allowed camera, photos, microphone and notifications. You can change these in iOS Settings at any time.

We don’t use the location of your phone. Location data comes only from a collar you pair, and describes where your pet is.

3. How we use information

  • To provide the Services: create your Fluffy, show your pet’s live state, keep your creations and credits, and sync across your devices.
  • To process your photos and sounds with AI, as described in How we use AI.
  • To send you sign-in codes, receipts, and important notices about your account or these policies.
  • To keep the Services safe: prevent fraud and abuse, enforce our Terms of Service, and fix security problems.
  • To understand how the Services are used and improve them, using aggregated or de-identified data where we can.
  • To send you news about Fluffy, only if you asked for it. You can unsubscribe at any time.
  • To comply with the law and respond to lawful requests.

4. How we share information

We don’t sell your personal information, and we don’t share it for cross-context behavioral advertising. We share it only as follows:

  • Service providers that work for us under contract, such as cloud hosting (Amazon Web Services, United States), email delivery, crash reporting and customer support tools. They may use your information only to provide their service to us.
  • AI processing providers that turn your photos and sound clips into results. See How we use AI.
  • Apple and Google when you sign in or buy through them, under their own privacy policies.
  • Legal and safety. When we believe in good faith that the law requires it, or to protect the rights, property or safety of you, our users, Pawlo or others.
  • Business transfers. If Pawlo is involved in a merger, acquisition or sale of assets, your information may be transferred as part of that deal. We’ll tell you before it becomes subject to a different policy.
  • With your consent, for example when you share a creation outside the app.

5. How long we keep it

  • Account, pet profile, photos and creations: while your account is open.
  • Sound clips you don’t save: deleted after processing. Saved lines keep their recording until you delete them.
  • Collar location history: only as long as needed to show your pet’s recent movements, then deleted or aggregated.
  • Purchase records: as long as tax and accounting laws require.

When you delete your account (Account → Delete account), we delete your profile, pets, photos, creations, recordings and collar data within 30 days, except what we must keep by law. Backups are overwritten on a regular cycle. Unused credits are forfeited when you delete your account.

6. Your choices

  • Edit your pet’s profile, delete photos, creations and saved lines, or unpair a collar in the app.
  • Turn camera, photos, microphone or notification permissions on or off in iOS Settings.
  • Unsubscribe from marketing emails with the link in each email. We’ll still send account emails such as sign-in codes.
  • Delete your account at any time in the app.

7. Your privacy rights

Depending on where you live, you may have the right to:

  • know what personal information we have about you and get a copy of it;
  • correct information that is wrong;
  • delete your information;
  • opt out of the sale or sharing of personal information, or of targeted advertising (we don’t do either);
  • limit the use of sensitive personal information (we use precise location only to show you where your pet is);
  • not be treated differently for using these rights.

To make a request, email admin@pawlotech.com from the address on your account. We’ll confirm your identity before acting, and reply within 45 days. You can use an authorized agent; we may ask for proof that they act for you. If we deny your request, you can appeal by replying to our answer.

California residents. In the last 12 months we collected the categories described in sections 1 and 2: identifiers, commercial information, internet or device activity, geolocation (of your pet’s collar), audio and visual information (pet photos and sound clips), and inferences (your pet’s personality). We use them for the purposes in section 3 and disclose them only as in section 4. We don’t sell or share personal information, and have no actual knowledge of selling or sharing information of anyone under 16.

Users outside the United States. We are based in the United States and process information there. If you are in the EEA, UK or Switzerland, our legal bases are performing our contract with you, our legitimate interests in running and improving the Services, your consent (for AI processing and marketing, which you can withdraw), and legal obligations. You may also complain to your local data protection authority.

8. Children

The Services are not directed to children under 13, and we don’t knowingly collect personal information from them. If you believe a child under 13 has given us information, contact us and we’ll delete it.

9. Security

We encrypt data in transit and at rest, limit access to people who need it, and review our systems regularly. No system is perfectly secure. If you find a security issue, please email us.

10. Changes to this policy

We may update this policy. If the changes are important, we’ll tell you in the app or by email before they take effect. The “Last updated” date shows when it last changed.

11. Contact us

Pawlo Technologies Inc.
admin@pawlotech.com