WhalePet App Privacy Policy

Effective date: October 20, 2026 Data controller: TelWhale Limited ("WhalePet", "we", "us") Contact: support@telwhale.com

This policy explains what the WhalePet mobile application (the "App") and the WhalePet pet tracker collar and charging base (the "Device") collect, why, how long we keep it, and the choices you have. It applies in addition to the general privacy policy of our online store.

If you use WhalePet through a partner brand (for example a reseller's branded version of the App), that partner is the data controller for your account and this policy applies to WhalePet's processing on their behalf.

---

1. What we collect

Category	Data	Source	Why
Account	Email address; or Apple / Google sign-in identifier; display name you choose	You	Create and secure your account, send service emails
Pet profile	Pet name, species, breed, birthday, weight, photo (optional)	You	Show your pet in the App; personalise notifications
Device & location	Collar identifier (IMEI, SIM identifier), GPS position, nearby Wi-Fi access point and cell tower identifiers, battery, step count, activity state, charging-base presence	Device, over cellular network	Show your pet's location, draw safe zones (geofences), send alerts, estimate battery
Phone location	Your phone's location while the App is open	Your phone (with permission)	Show the distance and direction between you and your pet; place a new safe zone
Bluetooth	Collar and charging-base Bluetooth identifiers and signal strength	Your phone (with permission)	Pair the collar, detect when the pet is near the base, send wake-up commands
Notifications	Push notification token, notification preferences, quiet hours	Your phone	Deliver safe-zone, low-battery and SOS alerts
Diagnostics	App version, platform, crash/error messages (no account identifier)	App	Fix bugs. Kept separate from your account
Usage	Commands you send to the collar (e.g. "find pet"), alert history, messages read	App	Operate the service, show history
Purchase / activation	Activation code redemption, subscription period	You / our store	Provide the service you paid for

We do not collect: contacts, photos other than the ones you choose to upload, microphone audio, advertising identifiers, or precise location when the App is closed (the App does not request background location).

2. How location data is processed

• GPS positions are sent by the collar directly to our servers over the cellular network and stored as your pet's location history.
• When the collar cannot get a GPS fix (for example indoors), it sends nearby Wi-Fi access point and cell tower identifiers. We may send those identifiers to a geolocation provider (currently Google Geolocation API) to estimate a position. The provider receives only the radio identifiers, never your account or pet details. We cache results to minimise these requests.
• When the collar is on its charging base, we record "at home" rather than a new GPS position.
• Maps are displayed using Google Maps; Google receives map tile requests from your phone under Google's own privacy policy.

3. Legal basis (EU/UK/Chile and similar jurisdictions)

Performance of our contract with you (providing the tracking service); your consent (phone location, Bluetooth, notifications — each can be withdrawn in your phone's settings); our legitimate interest in keeping the service secure and fixing errors.

4. Sharing

We share data only with processors that help us run the service, under contract:

• Hosting: Google Cloud Platform (EU region) — servers and database
• Push notifications: Google Firebase Cloud Messaging (also delivers to Apple devices via Apple Push Notification service)
• Sign-in: Apple and Google, when you choose those sign-in methods
• Maps and geolocation: Google Maps Platform
• Cellular connectivity: mobile network operators that carry the collar's data traffic
• Partner brands: if you obtained the Device from a reseller, that reseller can see devices and accounts registered under their brand in an administration console; they cannot see other brands' data

We do not sell personal data and do not use it for advertising.

5. Retention

Data	Kept for
Account and pet profile	Until you delete your account
Location history	12 months rolling, then deleted; or until account deletion
Alert and command history	12 months rolling
Push tokens	Until you sign out, delete the account, or the token becomes invalid
Crash diagnostics	30 days
Activation / subscription records	7 years (accounting law) — not linked to location data

6. Your rights and controls

• Delete your account in the App: Pet → Settings → Delete account. This removes your account, pet profiles, location history and push tokens within 30 days (backups within 90 days). Devices are unbound and can be bound by a new owner.
• Export your data: email support@telwhale.com; we respond within 30 days.
• Access, correct, object, restrict, portability and the right to complain to your data protection authority (EU: your national authority; Chile: Agencia de Protección de Datos Personales once operational; UK: ICO).
• Permissions: location, Bluetooth and notifications can be turned off in your phone's settings at any time; some features will stop working.
• Notifications: per-type switches and quiet hours in Pet → Settings → Notifications.

7. Children

The App is not directed to children under 16 and we do not knowingly collect their data. Contact us to remove any such data.

8. Security

Data is encrypted in transit (TLS) between the App and our servers. Collar-to-server traffic uses the mobile network and a private APN where available. Access to production systems is restricted and logged.

9. International transfers

Our servers are in the European Union. Where data is accessed from outside the EU/UK (for example by our support team), we rely on standard contractual clauses.

10. Changes

We will post changes here and, for material changes, notify you in the App. Continued use after the effective date means you accept the updated policy.

11. Contact

TelWhale Limited · support@telwhale.com