Privacy Policy

Introduction

This is the Privacy Statement of Wuuff LLC., hereinafter Data Controller, as the operator of the web site available at the wuuff.dog web address.

In this Privacy Statement, Data Controller lays down its practice pertaining to the management of personal data included in the User Database of the Web Site, organizational and technical measures taken to protect data and information given of the rights of data subjects and the enforcement of such rights.

Data Controller declares to respect User's rights to privacy. In consideration of these rights and fully respecting the provisions of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter: GDPR), Data Controller shall manage and record data given voluntarily by registered User only in the extent for which User gave explicit consent.

This Privacy Statement must be considered as an inseparable part of the General Terms and Conditions that set forth the conditions of the use of the Web Site and the services available therein. Terms used in this Privacy Statement must be interpreted according to the definitions included in the General Terms and Conditions.

This Privacy Statement is applicable to the personal data provided by User for the correct operation of the advertising site. The Privacy Statement is not applicable to cases when User voluntarily discloses any of his\her personal data.

Data Controller

Name: Wuuff LLC.

Registered office: 2132 Göd, Hunyadi utca 18.

Commercial register number: Cg.13-09-184810

Name of the authority registering Data Controller: Budapest Environs Regional Court

Tax identification number: 25843480-2-13

Telephone number: +36 30 384-5524

Email address privacy@wuuff.dog

Collected Data

Summary: You can find detailed information about what kind of personal data Wuuff LLC. collects while you are using the website and its services. The collected data can be grouped into three categories:

• Information that you provide to Wuuff, such as when you create your account
• Information created when you use Wuuff’s services, such us details about the purchased puppy, date of visiting an ad, preferences, etc;
• Information from other sources, for example if you use your Facebook account to register.

Information you provide

Visitors may visit the advertising site without disclosing their identity or providing any personal information. However, some of our services require data to work, such as purchasing/reserving a dog, posting an ad, etc.

Registration: We collect your first and last name, email address and password when you create your account. You can also add a profile photo to make your account more complete.

Posting an ad: We support only real breeders, therefore we collect information about your kennel (kennel name, country, city, phone number) to filter puppy mills. In order to post the ad, you need to add information about the dog (description, price, information about parents etc.) You can also add additional information about your kennel, like Facebook and website links.

Payment: We collect your billing information (full name, address) if you use our payment service.

Newsletter: We collect your email address to deliver news, tips and advice to the given address.

Puppy Match service: We collect provided data in the filled questionnaire to fulfill your request.

Puppy Alert: If you use our Puppy Alert service, we collect your email address and the puppy you are looking for.

Chatbot service: ManyChat’s chatbot service shares your publicly available Facebook data, such as name, profile photo, language and time zone with us. You can also provide your email address and location to make customer service even faster. We collect the data created in the chat to find a solution to your problem and to give you a quote for shipping.

Information created by using our services

Transactional data: We collect transaction details related to your use of the payment service, including date of purchase, price or deposit paid, details about the purchased dog, date of visiting an ad.

Usage data and preferences: We may collect information about how you interact with our services, and what are your preferences.

Device information: We may collect information about the devices you use to access our services, such as operating system, browser, device type.

Logs: When visiting any site, the data is created and logged automatically. This is true for Wuuff as well. Wuuff.dog logs data, such as IP address, date of visiting the site, visited webpages, country.

This information gathered is not suitable for identifying individual users, but it may be if associated with additional data. While we collect this data, we do not seek to identify individual users when analysing log files.

Purpose of Data Management

Summary: We collect and use data to enable and improve our services. We may also use it to:

• Provide additional services
• Customer service
• Deliver news, tips and advices
• Legal obligations

We do not associate collected data to identify our visitors and we do not disclose any information to third parties without your explicit consent.

Providing services

We use collected data to provide, maintain and improve our products and services. This enables the site to remember your settings and preferences like language, currency and to inform you about dogs/breeds you care about.

Data collected about the advertiser and the advertised dog helps future puppy owners make a good decision. Some of our services are impossible to provide without collecting data, for example Puppy Match, where we find the most suitable dog, based on your preferences.

News, tips and advice

If you opted-in, we send news about our services, tips and advice for puppy buying/advertising in our newsletter. Anytime we send you an email, you can unsubscribe from our mailing list by clicking ‘unsubscribe’ in the letters footer.

Customer service

Our customer service is there for you if you encounter a problem or have a question, however we need to know who to help and what kind of problem he/she may have.

Legal obligations

In a number of cases it is our legal obligation to store your collected data, such as your billing information.

Legal ground of Data Management

Summary: Data management is carried out on the basis of your voluntary consent, or if it’s necessary for the performance of a contract.

Data management is carried out on the basis of the user’s consent to the processing of his or her personal data for one or more specific purposes (Article 6, 1.§ point b) of GDPR) or if processing is necessary for the performance of a contract to which the user is party or in order to take steps at the request of the user prior to entering into a contract (Art. 6, 1.§ point b) of GDPR).

Cookies and third-party technologies

Summary: We use cookies and similar technologies on wuuff.dog, our emails and advertisements for purposes described in this Privacy Policy.

Cookies

When visiting Wuuff, cookies are placed on your computer to provide more effective services. Cookie is an information package that the server sends to the browser, then the browser sends it back to the server every time a request is made to the server. Cookie is basically a text file used for the subsequent identification of the user. This file may provide information of the earlier use of the web site. This process cannot be used to identify you, but only for recognizing your computer. By using this process we may analyze habits to enhance the service provided. Most browsers, as a default, accept the use of cookies, but you may opt for disabling this setting. In such an event, some features may not be available.

Analytics and advertisements

To improve your experience on the site, we use technologies from third parties, as developing it for ourselves would be extremely costly. These technologies help us understand what’s great and what needs to be improved on the site.

Our website uses Google Analytics, a service which transmits website traffic data to Google Servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage use. You can read more about this here.

Hotjar helps us better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Newsletter

To measure the effectiveness of our marketing and communications, we use tools to monitor opening and click-through of our letters.

You can unsubscribe anytime from our newsletter by clicking ‘unsubscribe’ in the letters or by sending a letter to privacy@wuuff.dog with the subject ‘Unsubscribe’.

We use SalesAutopilot to manage our mailing lists and newsletter.

Our Data Processor partners in the EU

1. SalesAutopilot (registered office: 1024 Budapest, Margit krt. 31-33, félemelet 4-5.)

2. HotJar - GDPR compliance (registered office:  II. floor, St Julian’s Business Centre, 3, Elia Zammit street, St Julian’s STJ 1000, Malta)

Our Data Processor partners outside the EU

All of our partners outside are fully compliant with the USA - European Union and US - Swiss Privacy Shield Framework. The framework regulates how personal data can be transferred from the EU and Switzerland to the USA. You can read more about the Privacy Shield Framework here.

1. Google - Privacy Shield Framework

2. ManyChat - Privacy Policy

3. Facebook - Privacy Shield Framework

4. Compose - Privacy Shield Framework

5. Amazon Web Services - Privacy Shield Framework

Data Sharing and Disclosure

Summary: Some of our services and features require that we share information with other users or at your request. We may also share your information with our business partners for the performance of a contract.

At your request

If the nature of the service or feature requires it, we share your information at your request with other users or third parties.

For example, if you use our Puppy Match service we send the filled questionnaire (with your preferences about the desired dog) to breeders we think may have dog(s) you are searching for.

For legal reasons

We may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request.

With your consent

We may share your information other than as described in this policy if we notify you and you consent to the sharing.

Wuuff will not disclose personal data to third parties in any event without your explicit consent, with the exception of cases mentioned above or if we use subcontractors (courier or postal service providers) to fulfill our contractual obligations. In the latter case, the subcontractor performing delivery services are bound by contractual terms to use your data only to fulfill contractual obligations. Subcontractors are not entitled to keep such data or disclose them to third parties for further use in any manner.

Data Retention and Deletion

Summary: We retain your user profile and other information for as long as you maintain your account. In some cases we may retain some of your information after you delete your account to fulfill our legal obligations (for example, transaction information).

We retain your user profile and other information for as long as you maintain your account, unless you request the deletion of your information. If one of these conditions apply, we delete your information without undue delay:

• the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw consent on which the processing is based and there is no other legal ground for the processing;
• you object to the processing and there are no overriding legitimate grounds for the processing;
• the personal data has been unlawfully processed;
• the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the Wuuff LLC. is subject;

Registration: While you maintain your account.
Kennel information: While you maintain your account.
Newsletter: Until you unsubscribe from our mailing list.
Puppy Match service: For up to 40 days, but in special cases (if you would like to purchase the dog later than 40 days) we may retain it with your consent for a longer period.
Puppy Alert: Until you unsubscribe from Puppy Alert.
Chatbot service: Until you unsubscribe from ManyChat.
Transactional data: While you maintain your account.
Billing: According to the Accounting Act, we retain billing information for 8 years.

Data Security measures

Data of the User Database is stored on our and on the Data Processors’ computer system.

IT tools selected by us and Data Processors are used to provide data management, data processing and data security. These systems ensure that data may be:

• Read, recorded, transferred, modified or deleted only by authorized persons
• The integrity of data is preserved

Wuuff informs users that electronic messages transferred via the Internet are vulnerable to threats, which may result in fraudulent activities, information disclosures or modifications.

Wuuff ensures the security of personal data with due care and diligence, apply the necessary technical measures, protect personal data especially from unauthorized access, modification, disclosure, deletion and destruction. If, in spite of our due care and diligence, unauthorized access takes place, we will be exempt from liability.

Your rights pertaining to the management of your data

Explanation

We do everything to provide requested information in a clear and easily understandable way. To exercise these rights, please see below or submit your request to privacy@wuuff.dog. After verifying identity, information can also be given via phone.

Access

You have the right to request an explanation of the information that we have about you and how we use that information. You can also request a copy of this information in written or electronic form. We give this information in up to 30 days.

If we transfer your personal data to a third country, you have the right to request information about the guarantees for the processing of his/her data.

Correction

If we have information about you that you believe is inaccurate, you have the right to request correction of your information. Please see the section titled “Explanation, Copies and Correction” below for more information on correcting, or requesting correction of, your information.

Erasure

You have the right to obtain from us the erasure of personal data concerning you without undue delay and we have the obligation to erase it if one of the following grounds applies:

• the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• you withdraw consent on which the processing is based and there is no other legal ground for the processing;
• you object to the processing and there are no overriding legitimate grounds for the processing;
• the personal data has been unlawfully processed;
• the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the Wuuff LLC. is subject.

Restriction of processing

You have the right to obtain from us restriction of processing where one of the following applies:

• the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of your use instead;
• we no longer need the personal data for the purposes of the processing, but we are required by you for the establishment, exercise or defence of legal claims;
• You have objected to processing pursuant to Article 21. (1) of the GDPR pending the verification whether our legitimate grounds override those of you.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
If you have obtained restriction of processing, you will be informed by us before the restriction of processing is lifted.

Portability

You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

Objection

Where personal data is processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing.
If you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Withdraw consent

You have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before it's withdrawal.

Right to effective judicial remedy

You have the right to lodge a complaint with supervisory authority, if you consider that the processing of your personal data relating to you infringes the GDPR.

Compensation

Any person, who has suffered material or non-material damage as a result of an infringement of the GDPR shall have the right to receive compensation from the controller or processor for the damage suffered. A processor shall be liable for the damage caused by processing only where it has not complied with obligations of the GDPR specifically directed to processors or where it has acted outside or contrary to lawful instructions of the controller.

Where more than one controller or processor, or both a controller and a processor, are involved in the same processing and where they are responsible for any damage caused by processing, each controller or processor shall be held liable for the entire damage in order to ensure effective compensation of the data subject.

If data controller or processor proves that it had no control over the damaging event, it shall be exempt from liability.

Modalities for the exercise of the rights of the data subject

The controller shall provide information on action taken on a request mentioned above to the data subject without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests

The controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.

If the controller does not take action on the request of the data subject, the controller shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Such information provided shall be provided free of charge. Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the controller may either:

• charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
• refuse to act on the request.

The controller shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.

Supervisory authority

You have the right to lodge a complaint with the National Authority for Data Protection and Freedom of Information.

National Authority for Data Protection and Freedom of Information

Registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Post address: 1530 Budapest, Pf.: 5.

Phone number: +36 1 391 1400

Fax: +36 1 391 1410

Website: http://www.naih.hu