Privacy policy

Introduction

We, Moggie Ltd. (“Moggie”, “we”, “us”, or “our”) manufacture and sell “smart” activity tracker devices for cats (“Activity Tracker”) using accelerometer technology to enable you to track your cats’ activities.

We value the privacy of our users and strive to be transparent about how we collect and use personal data.

We provide online and mobile services (collectively, the “Services”) including our website (the “Website”), Moggie Hub and Activity Tracker devices (the “Devices”), mobile application software (the “App”) and other web-based services including through social media, marketing activities, live events and other activities described in this Privacy Policy.

1.Important information and how to contact us

This Privacy Policy sets out how we collect, protect, disclose, store, transfer, and use any personal data you may provide when you access or use any of our Services. If you would like to find out how we use any data collected about your cat via your Activity Tracker, please visit our Terms of Service.

Our Services are not intended for use by anyone under 16 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal data in a manner prohibited by law, please contact us. If we learn that we have collected personal data through the Services from a child without the permission of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Controller

In relation to the provision of the Services, we are the data controller and are responsible for your personal data.

Contact details

Moggie Ltd

860-862 Garratt Lane

SW17 0NB London, UK

Company number 14356760

Email addresses: hello@moggie.me

2. Personal data we collect about you

    Personal data means any information about an individual from which that person can be identified. 

    We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

    • Identity Data includes first and last name, any previous names, username or similar identifier, title, date of birth and gender.


    • Contact Data includes email address, billing address, delivery address, and phone number.


    • Financial Data includes such as payment card information or bank account number.


    • Transaction Data includes information relating to, or needed to complete, your orders on or through the Services, including subscription information, order numbers and transaction history.


    • Profile Data includes username and password, your unique account reference number, actions or transactions made by you via the Services, preferences, feedback, survey responses and other correspondence.


    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website and App including precise connection data, such as when you expressly opt-in to allow us to use your Bluetooth connection.


    • Marketing and Communications Data, includes information regarding your preferences for receiving marketing communications from us and our third parties, and your communications preferences.


    • Usage Data includes information about how you use the Services.


    We may also collect, use and share Aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identify. For example, we may aggregate individuals Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Services to help improve the Services and our offering.

    We may also aggregate and use data about your cat collected by your Activity Tracker in accordance with our Terms of Service. This data is not personal data as it does not (directly or indirectly) identify any individuals and this Privacy Policy does not apply to such data or our use of such data.

    Please note that if we need to collect and use certain personal data about you in order to provide you with the Services or to perform a contract with you, and you decide to withhold your personal data or object to us using your personal data, we may not be able to provide you with the Services and / or we may need to cancel our contract with you.

    3. How we collect your personal data

      We use different methods to collect data from you through: 

      • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

        • Use our Services;

        • Create an account via the Website and/or App; 

        • Request marketing to be sent to you; 

        • Enter a competition, promotion or survey; or 

        • Give us feedback or contact us.


      • Third-party or publicly available sources. We may receive personal data about you from various third parties, including: 


      1. Public sources, such as social media platforms, and other publicly available sources.


      1. Third-party services, such as social media services, that you use to log into, or otherwise link to, your account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.


      Automatic data collection. As you interact with our Services, we will automatically collect Usage Data and Technical Data about your computer or mobile device, your interactions and browsing patterns. We collect this personal data by using cookies, service logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy at the end of this document for further details.

      4. How we use your personal data

        We may use your personal data for the following purposes or as otherwise described at the time of collection.

        We rely on one or more of the following legal bases:

        • Performance of a contract with you. Where we need to perform the contract we are about to enter into or have entered into with you (such as a contract for you to purchase an Activity Tracker from us).

        • Legitimate Interests. We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests (or those of a third party), for example to prevent fraud and enable us to give you the best and more secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

        • Legal obligation. We may use your personal data where it is necessary for compliance with a legal or regulatory obligation.

        • Consent.  We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or agree to the use of certain cookies when you interact with and use our Website.

          Purposes for which we will use your personal data

          We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

        Purpose / Use

        Type of data

        Legal basis

        To register you as a new Customer or User

        (a) Identity


        (b) Contact

        Performance of a contract with you

        To process and deliver your order including:

        (a) managing payments, fees and charges; and

        (b) collecting and recovering money owed to us.

        (a) Identity


        (b) Contact


        (c) Finance


        (d) Transaction


        (e) Marketing and Communications

        (a) Performance of a contract with you.


        (b) Necessary for our legitimate interest (to recover debts due to us).


        (c) Necessary for legitimate interest of others (preventing fraud).


        (d) Where you provide your explicit consent

         

        To manage our relationship with you which will include:

        (a) notifying you about changes to our terms or privacy policy;

        (b) dealing with your request, complaints and queries; and

        (c) to notify you about changes to our Services.

         

        (a) Identity


        (b) Contact


        (c) Profile


        (d) Marketing and Communications

        (a) Performance of a contract with you


        (b) Necessary to comply with a legal obligation


        (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you).

        To ask you to leave a review of take a survey.

        (a) Identity


        (b) Contact


        (c) Profile

        (d) Marketing and Communications

        (a) Performance of a contract with you.


        (b) Necessary to comply with a legal obligation.

        (c) Necessary for our legitimate interests (to keep our records updated, study how users and customers use the Services and to improve our products and the Services in the future).

        To administer and protect our business, the products, and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

        (a) Identity


        (b) Contact


        (c) Technical 

        (d) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

        (e) Necessary to comply with a legal obligation.

        To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you

        (a) Identity


        (b) Contact


        (c) Profile


        (d) Usage

        (e) Marketing and Communications

        (f) Technical

        Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

        To use data analytics to improve our products, the Services, marketing, customer relationships and experiences.

        (a) Identity


        (b) Contact


        (c) Technical


        (d) Usage

        Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business).

        To send you communications (including e-mail marketing and other communications) with your consent where required, send you push notifications when using the Services and provide you with information, products or services that you request from us or which we feel may be of interest to you, where you have consented to be contacted for such purposes

        (a) Identity


        (b) Contact


        (c) Technical


        (d) Usage

        (e) Profile

        (f) Marketing and Communications

        Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) or consent, having obtained your prior consent to receiving direct marketing communications.

        To create anonymised and aggregated data sets for analysis and establishment of trends and user patterns (which we may licence to third parties directly).


        (a) Technical

        (b) Usage

        Necessary for our legitimate interest (to define types of customers for our products and services, to keep our Services updated and relevant, to develop our business strategy and to inform our marketing strategy.

        To help us create profiled audiences for social media marketing campaigns.


        (a) Technical

        (b) Marketing and Communications

        Necessary for our legitimate interests (to promote our products on social media and to ensure our social media adverts are seen by relevant and interested audiences)


        5. Marketing

        We, our service providers, and our third-party advertising partners may collect and use your personal data for marketing and advertising purposes:

        Direct marketing. We may send you direct marketing communications if you have requested information from us or purchased products or services from us and you have not opted out of receiving marketing.  We may also analyse your Identity, Contact, Technical, Usage and Profile data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

        Affiliate marketing. We may display links to websites of affiliated companies via the Services. Should you click on any of these links, some information such as contact data may be shared with the affiliate.

        Third-party marketing. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

        Social Media marketing: We may use social media platform tools to advertise our products.  For this purpose, we may share your personal data (such as your email address) with social media platforms for them to use to present sponsored posts in your social media feed, or for use by them to create audiences for our sponsored social media content.  We take steps to ensure any personal data shared with social media platforms for this purpose is kept to a minimum and presented in hashed form where possible.  When you use our Website, we may ask your permission to use certain social media cookies and other tracking technologies (such as tags or pixels) which enable us to share data with social media platforms.  More information about this is provided in our Cookies Policy and at paragraph 12 below.  You will have the opportunity to reject these cookies or withdraw your consent to tracking at any time.

        Opting out of marketing. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

        Other than profiling for marketing purposes, we do not conduct any profiling or use your personal data in any automated decision-making processes to make any significant or legal decisions about you.

        6. How we share your personal data

          We may share your personal data where necessary with the parties set out below for the purposes set out in the table in section 4.

          • Our Affiliates. Our subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

          • Service providers. Third parties that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, marketing (including social media marketing), consumer research and website analytics). We may also share location data with our service providers to enable us to provide the Services.

          • Payment processors. Any payment card information you use to make a purchase via the Services is collected and processed directly by our payment processors, who may use your personal data in accordance with their privacy policies. You may also sign up to be billed by your mobile communications provider, who may use your payment data in accordance with their privacy policies.

          • Advertising partners. Third-party advertising companies for interest-based advertising purposes.

          • Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

          • Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

          • Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.
          • Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganisation, sale or other disposition of all or any portion of the business or assets of, or equity interests in, our or our affiliates (including, in connection with a bankruptcy or similar proceedings).
          • Other users and the public. Your profile and other user-generated content data (except for messages) may be visible to other users of the Services and the public. For example, other users of the Services or the public may have access to your information if you chose to make your profile or other personal data available to them through the Services, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected, and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.


          We make commercially reasonable efforts to verify that the parties with whom we share personal data provide a level of protection of personal data consistent with applicable data protection laws.  Where any data recipients act as a controller of your personal data in their own rights, they will. use personal data as described in their own privacy policies.

          7.Other websites and services

            The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

            8. International data transfers

              We may transfer your personal data to service providers and other third parties located outside the UK to countries which have laws that do not provide the same level of data protection as UK laws.

              Whenever we transfer your personal data out of the UK, we take steps to ensure a similar degree of protection is afforded to it, for example, by imposing standard contractual obligations on the data recipients to protect your personal data.

              Please contact us at the details above for more information about where your personal data may be transferred to, and the measures put in place to ensure that any such transfers are compliant with UK data protection laws.

              9. Data Security

              We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

              We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

              10. Data Retention

                We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

                To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

                In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

                11. Your legal rights

                Under certain circumstances, you have rights under data protection laws in relation to your personal data.

                Access to information: You have the right to request a copy of the information Moggie holds about you.

                Ensuring accuracy of information: Moggie wants to make sure that your personal information is accurate and up to date. You may ask Moggie to correct or complete information that is inaccurate or incomplete. 

                Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require Moggie to delete personal information held about you.

                Ability to restrict processing: You may also have the right to require Moggie to restrict Moggie’s use of your personal information in certain circumstances. This may apply, for example, where you have notified Moggie that the information Moggie holds about you is incorrect and you would like Moggie to stop using such information until Moggie has verified that it is accurate.

                Right to data portability: You may have the right to receive personal data Moggie holds about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider). 

                Objecting to use of your information: You may also have the right to object to Moggie’s use of your information in other circumstances. 

                Withdrawal of consent: Where you have consented to our use of your personal data, you have the right to withdraw such consent at any time.  This does not impact the lawfulness of our use of your personal data prior to your withdrawal of consent.

                Complaint: You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

                If you would like further information on how you can exercise these rights, please email us at hello@moggie.me.

                No fee usually required

                You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

                What we may need from you

                We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

                Time limit to respond

                We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

                11. Your choices

                Mobile location data. You can disable our access to your location in your mobile device settings. However, note that we may be unable to provide you with our Service if you disable our access to your device’s Bluetooth connection.

                Privacy settings. We make available certain privacy settings on the Service, including options to customise content provided on the App. 

                Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

                • Browser settings. Changing your internet web browser settings to block third-party cookies.

                • Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.

                • Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites (Google / Facebook).

                • Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. Find out more about “Do Not Track” here

                Declining to provide location information. We need to collect personal data to provide our Services, particularly with respect to your mobile device Bluetooth connection and home Wi-Fi connection so that we can connect to your Activity Tracker and Hub. If you do not provide the information we identify as required or mandatory, then we may not be able to provide those activity tracking services.

                Linked third-party platforms. If you choose to connect to the Services through your social media account, such as Instagram, or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

                Cookie Policy 

                A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

                We use the following cookies:

                • Strictly necessary cookies. These are cookies that are required for the operation of our Website. These essential cookies are always enabled because our Website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.

                • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

                • Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

                • Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.


                Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

                Choices about cookies

                You can choose which analytic, functionality and targeting cookies we can set by clicking on the button(s): 

                Strictly necessary cookies ALWAYS ACTIVE 

                Analytical or performance cookies OFF 

                Functionality cookies OFF 

                You can also choose to “Reject All” cookies in the cookie banner. 

                However, if you use your browser setting to block all cookies (including essential cookies), you may not be able to access all or parts of our 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.

                If you have any questions or concerns about our use of cookies, please send us an email at support@moggie.me.