Privacy Policy

Last updated: December 12, 2024

1. Introduction

Welcome to PN1 ("Company," "we," "us," or "our"). We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI Dog Translator application and website (collectively, the "Service").

Data Controller:
PN1
Donaustraße 44
12043 Berlin, Germany

By using our Service, you consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please do not use our Service.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide to us, including:

  • Account Information: Name, email address, and password when you create an account
  • Profile Information: Information about your dog(s), such as name, breed, age, and photos
  • User Content: Photos and videos of your dog that you upload for analysis
  • Communications: Messages, feedback, and support requests you send to us
  • Payment Information: Billing details processed through secure third-party payment providers
  • Beta Program: Email address when signing up for our beta testing program

2.2 Information Collected Automatically

When you use our Service, we automatically collect certain information:

  • Device Information: Device type, operating system, unique device identifiers, and mobile network information
  • Usage Data: Features used, time spent in the app, and interaction patterns
  • Log Data: IP address, browser type, pages visited, and access times
  • Location Data: General location based on IP address (we do not collect precise GPS location)

2.3 AI Analysis Data

When you use our AI dog translation feature, we process the photos and videos you submit to analyze your dog's body language. This data is processed to provide you with insights and may be used to improve our AI models (see Section 3).

3. How We Use Your Information

We use the information we collect for the following purposes:

  • Provide the Service: To analyze your dog's body language and deliver translations
  • Account Management: To create and manage your user account
  • Improve Our Service: To understand usage patterns and enhance our AI models
  • Communications: To send you updates, security alerts, and support messages
  • Marketing: To send promotional content (only with your consent)
  • Safety & Security: To detect, prevent, and address fraud and security issues
  • Legal Compliance: To comply with applicable laws and regulations

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

  • Contract Performance: Processing necessary to provide you with the Service you requested
  • Legitimate Interests: Processing for our legitimate business interests, such as improving our Service and preventing fraud
  • Consent: Processing based on your explicit consent, such as for marketing communications
  • Legal Obligation: Processing necessary to comply with legal requirements

5. Data Sharing and Disclosure

We may share your information in the following circumstances:

  • Service Providers: We share data with trusted third-party providers who assist us in operating our Service (e.g., cloud hosting, payment processing, analytics). These providers are contractually bound to protect your data.
  • AI Processing: Photos and videos may be processed by AI service providers to perform the dog behavior analysis.
  • Legal Requirements: We may disclose your information if required by law, court order, or governmental authority.
  • Business Transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity.
  • With Your Consent: We may share your information for other purposes with your explicit consent.

We do not sell your personal data to third parties.

6. International Data Transfers

Your information may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses approved by the European Commission
  • Transfers to countries with adequate data protection laws
  • Other legally recognized transfer mechanisms

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law.

  • Account Data: Retained while your account is active. Upon account deletion, all personal data is permanently deleted immediately.
  • User Content: Photos and videos are retained while you use the Service and permanently deleted immediately upon account deletion
  • Analytics Data: Retained in anonymized form (cannot be linked to you) for up to 2 years for service improvement purposes
  • Legal Records: Retained as required by applicable law (e.g., financial records for tax purposes)

8. Your Rights (GDPR)

Under the GDPR and other applicable data protection laws, you have the following rights:

  • Right of Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data ("right to be forgotten")
  • Right to Restrict Processing: Request limitation of how we use your data
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, please contact us using the information in Section 13. We will respond to your request within 30 days.

You also have the right to lodge a complaint with a supervisory authority, particularly in the EU member state of your residence. In Germany, you may contact the Berliner Beauftragte für Datenschutz und Informationsfreiheit.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience. These include:

  • Essential Cookies: Required for the Service to function properly
  • Analytics Cookies: Help us understand how users interact with our Service
  • Marketing Cookies: Used to deliver relevant advertisements (only with consent)

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of our Service.

10. Children's Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us, and we will delete such information.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit and at rest
  • Regular security assessments and audits
  • Access controls and authentication measures
  • Employee training on data protection

While we strive to protect your data, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by:

  • Posting the updated policy on this page
  • Updating the "Last updated" date
  • Sending you an email notification (for significant changes)

We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have concerns about our data practices, please contact us at:

PN1 - Data Protection

Donaustraße 44

12043 Berlin

Germany

We will respond to your inquiry within 30 days.