COLLR · LEGAL

Privacy Policy

This is a draft for review by a qualified Australian legal adviser before publication. Text in square brackets must be confirmed or completed by the business.

Effective date: [EFFECTIVE DATE]

This Privacy Policy explains how [LEGAL ENTITY NAME] (ABN [ABN]) (Collr, we, us or our) collects, uses, discloses and protects your personal information when you visit our website at collr.com.au, buy a Collr tag, or use the Collr mobile app and the pet finder page linked to your tag.

We are committed to handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). In this policy, personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not it is true and whether or not it is recorded in a material form.

Please read this policy together with our Terms of Sale and Service.

1. Who we are and how to contact us

Collr sells physical pet identification tags (The Pendant, The Plate, The Keeper and The Crest). Each tag carries a QR code and NFC chip and has no battery. It is not a GPS tracker or location device and does not transmit or record your pet's location. It simply displays information when a person physically finds your pet and scans or taps the tag with a phone, opening a public finder page that shows the information the pet owner has chosen to share. Owners manage what is shown through the free Collr mobile app.

If you have any questions about this policy, wish to access or correct your personal information, or want to make a privacy complaint, you can contact our Privacy Officer:

Email: support@collr.com.au
Post: [BUSINESS ADDRESS]

2. The personal information we collect

The types of personal information we collect depend on how you interact with us. We collect personal information directly from you where reasonable and practicable to do so, and in some cases from third parties such as our payment, app-store and identity providers, or from a person who finds your pet and scans your tag.

2.1 When you buy from our website

To process and fulfil an order, we collect your name, email address, phone number, your shipping address and, where required, your billing address, and order details such as the products ordered, quantity, price and order status.

We ship within Australia only. Payments on our website are processed by Stripe (including via card, Apple Pay and Google Pay). Your full card number and related payment credentials are entered directly into Stripe's secure payment fields. We do not collect, see or store your full card details on our own systems. Stripe provides us with limited information needed to confirm and fulfil the order (for example, that payment succeeded, and the name, contact and address details you provided at checkout).

2.2 When you use the Collr app and create a pet profile

To create and use an account and pet profile, you may provide:

Account information, such as your name, email address, a password, and a username, short bio and profile photo if you take part in the community. You can also sign in using Apple or Google, in which case we receive a login identifier and the details you allow that provider to share (which may include an anonymised relay email address).
Owner contact details, such as your name, phone number, email and, if you choose, your home address, and any backup or emergency contact details you add, so that a finder or your chosen contacts can reach you.
Pet profile information that you choose to enter, which may include your pet's name, photo, breed, description, distinguishing features, microchip and council registration numbers, and its current status (for example, a Missing status).
Pet health and care information that you choose to record, such as vaccinations, medications, conditions, allergies, weight, vet details, insurance details, and care, feeding, toileting or behaviour notes. This information is about your pet. You decide what to record and what, if anything, to make visible on the finder page.
Documents and media you upload, such as vaccination certificates, registration or insurance documents, and photos or videos of your pet. Documents are stored privately and are not shown on the public finder page; photos you add to a public profile or the community may be publicly visible.
Details of other people you add to help care for or manage your pet, such as a household member, vet, groomer, sitter or an authorised pickup contact, including their name and contact details. You are responsible for having a lawful basis to provide their information, and you should make sure they are aware of, and consent to, you sharing it with us. Where we contact a person you have invited, we will tell them what we collect and link them to this policy.

2.3 When someone finds your pet (finder information)

When a person finds your pet and scans or taps the tag, they open the public finder page without needing an account. If they choose to help, they may submit their name, a contact number or email, a message, and (if they allow it) their device's location so we can tell you where your pet was seen. We also automatically record limited technical information about that scan, such as the device type, the IP address and an approximate location derived from it, so we can operate the finder page, pass the report to you, and detect misuse.

We use finder information only to help reunite you with your pet: we pass the finder's message, contact details and any shared location to you (for example by email or app notification) so you can make contact. Sharing a precise location is the finder's choice. We keep this information for a limited period and then delete or de-identify it. [PLACEHOLDER: confirm the finder-data retention period, for example 24 months.]

2.4 Location information

We collect location information in a few specific ways: the approximate or, if allowed, precise location shared by a person who scans your tag (see 2.3); a last-seen location while your pet is in Missing mode; and, if you use the walk-tracking feature, your device's location while a walk is in progress so we can record the route. Walk location is used only while you are actively recording a walk and can be turned off. [PLACEHOLDER: confirm the app's location-permission prompts and that walk tracking is opt-in per walk, consistent with the app-store privacy labels.] We use a mapping and geocoding service to turn coordinates into a readable place name.

2.5 Community and social features

If you use the optional community features, we collect the posts, comments, photos, videos, reactions and the follow or block lists you create, along with any reports you make or that are made about your content, so we can operate and moderate the community. Content you post to the community may be visible to other users according to the settings you choose.

2.6 Optional voice and AI features

Some optional features let you dictate a note or generate a summary of your pet's care. If you use them, the audio you record and the related care notes are sent to a third-party artificial-intelligence provider to convert speech to text and to produce the summary. These features are optional and you do not have to use them. [PLACEHOLDER: confirm the AI provider, the country of processing, and that it does not retain or train on your data.]

2.7 Website and app usage information

We and our analytics provider automatically collect certain technical information, which may include your device type, operating system, browser type, approximate location derived from your IP address, the pages or screens you view, and how you interact with our website and app. Some of this information may be personal information, or may become personal information when combined with other information.

2.8 The COLLR+ subscription

The optional paid COLLR+ subscription is offered inside the app and is billed through the Apple App Store or Google Play, not through our website. Payment is handled by Apple or Google under their own terms and privacy policies. We use a subscription-management provider to receive confirmation of your subscription status (such as the product, tier and expiry) so we can unlock premium features. We do not receive your card details from these stores.

2.9 Sensitive information

We do not seek to collect sensitive information (as defined in the Privacy Act) about you. Any care or medical notes you add relate to your pet, not to you, and are entered and published at your discretion. Please do not include your own health information or other sensitive personal information in a pet profile or finder page.

2.10 If you do not provide information

If you do not provide the information we reasonably need, we may be unable to process your order, deliver your tag, create or maintain your account, or provide the finder page and related features.

3. How and why we use your personal information

We collect, hold and use your personal information for the following purposes:

to process, fulfil and deliver your order, and to arrange shipping and returns;
to take payment and issue receipts;
to create and manage your Collr account, pet profiles and community profile;
to operate the pet finder page and display the information you have chosen to share;
to notify you when your pet is found and to pass on a finder's report, contact details and shared location;
to provide the app's care, sharing, community and optional features you choose to use;
to provide customer support and respond to your enquiries;
to send you transactional communications, such as order confirmations, dispatch notices and service messages;
to send you marketing communications where permitted by law and where you have not opted out (see section 9);
to understand how our website and app are used, to measure performance and to improve our products and services;
to maintain the security and integrity of our systems and to detect and prevent fraud or misuse; and
to comply with our legal obligations and to establish, exercise or defend legal claims.

We will only use your personal information for a purpose you would reasonably expect, for the purpose for which it was collected, or for a related purpose (or, for sensitive information, a directly related purpose), unless you have consented to another use or the use is otherwise permitted or required by law.

4. The pet finder page is public

The finder page linked to your tag is public. Anyone who physically finds your pet and scans or taps the tag with a phone can see the information you have chosen to display, without logging in and without the Collr app. You control what appears on the finder page through the app, and you can change or remove that information at any time.

You are responsible for the accuracy of the information you display and for deciding how much contact or other detail to make public. Please consider carefully before publishing a personal phone number, email address, home address or any other information you would not want shown to any member of the public who scans the tag.

Home address and Missing mode. Sharing your home address on the finder page is off by default. If you choose to turn it on while your pet is in Missing mode, your address becomes visible to anyone who scans the tag until you turn it off or end Missing mode. When your pet is in Missing mode, your phone number is also shown so a finder can call you. You can turn these off at any time in the app, and you may prefer to share only a suburb rather than a full address. Because the finder page only displays information when someone physically scans the tag, it does not track or report your pet's location, and it cannot guarantee that a lost pet will be found or returned.

5. Who we disclose your personal information to

We do not sell your personal information. We disclose personal information to the following categories of recipients, and only for the purposes described:

Amazon Web Services (AWS), which hosts our app and databases and stores pet profiles, photos, documents and related information, sends our transactional and notification emails, and holds our operational logs. Our primary data is stored in AWS's Sydney, Australia region. [PLACEHOLDER: confirm all AWS regions used.]
Stripe, to process payments and detect and prevent payment fraud.
Airtable, where we record orders so that we can pick, pack and fulfil them.
Vercel, which hosts our website and processes information as part of serving the site.
Australia Post, to which we provide the name, address and contact details needed to deliver your order.
PostHog, our product analytics provider, which processes device and usage information to help us understand and improve how our website and app are used.
Apple and Google, in connection with sign-in, push notifications and the COLLR+ subscription billed through their app stores, and a subscription-management provider that processes your subscription status.
Expo, which delivers push notifications to your device.
A mapping and geocoding provider, to which we send coordinates to produce a readable place name for a scan, last-seen location or walk.
An artificial-intelligence provider, if you use the optional voice or summary features, to convert speech to text and generate summaries (see 2.6).
Our error-monitoring and support tools, which help us diagnose faults and manage support requests. A support request may carry limited context (such as your app version and account identifier) so we can help you faster.
Collr Business, where you connect your pet to a participating vet, groomer or other provider, so that permitted records (such as vaccinations recorded at a visit) can be shared between you and that provider.
Professional advisers (such as our lawyers and accountants), and other service providers who help us operate our business, where reasonably necessary.
Government agencies, regulators, courts or law enforcement, where we are required or authorised by law to disclose the information, or where disclosure is reasonably necessary to protect the safety of a person or to enforce our rights.
A purchaser or successor, if all or part of our business or assets is sold, transferred or reorganised, subject to appropriate confidentiality arrangements.

We may also disclose information you have chosen to make public on the finder page or in the community to any person who can see it, as described in sections 4 and 2.5. We provide a finder's report and any shared location to the relevant pet owner so they can be reunited with their pet.

6. Overseas disclosure

We store our primary personal information in Australia (in AWS's Sydney region). Some of our other service providers store or process personal information outside Australia, so your personal information may be disclosed to, and handled by, recipients located overseas. In particular:

PostHog processes our analytics data in the European Union, and our support tooling may also be hosted in the European Union.
Stripe, Airtable, Vercel, Expo, our error-monitoring, subscription-management and artificial-intelligence providers, and Apple and Google, are located, and may store or process personal information, overseas, including in the United States. [PLACEHOLDER: confirm the full list of countries in which each provider stores or processes personal information.]

Where we disclose personal information overseas, we take steps that are reasonable in the circumstances to ensure the recipient handles it consistently with the Australian Privacy Principles.

7. Storage, security and retention

We take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include using reputable service providers, access controls, encryption of data in transit, storing uploaded documents in a private, access-controlled store, and encrypting payment information in transit through Stripe. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

If we experience a data breach that is likely to result in serious harm to any individual whose personal information is involved, we will assess and respond to it in accordance with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

We keep personal information only for as long as we reasonably need it for the purposes described in this policy, or for as long as required by law (for example, tax and consumer-law record-keeping obligations). When we no longer need your personal information, we will take reasonable steps to destroy it or to permanently de-identify it. [PLACEHOLDER: confirm specific retention periods, for example: order and receipt records kept for the period required by tax law; scan and finder reports kept for a limited period then de-identified; walk and analytics data kept for a limited period; and backups cycled on a rolling basis.]

8. Deleting your account and information

You can delete your account at any time from the app (Settings, then Account, then Delete account), or by emailing us at support@collr.com.au from the address on your account. When you delete your account, we delete or de-identify your account, pet profiles and finder pages within a reasonable period. [PLACEHOLDER: confirm the target erasure timeframe, for example 30 days.] We may retain limited information where we are required or permitted by law to keep it (such as transaction records for tax purposes), where it is needed to establish, exercise or defend a legal claim, or in de-identified form for analytics. Deleting the app alone does not delete your account.

9. Direct marketing and how to opt out

From time to time we may use your contact details to send you marketing communications about Collr products, offers and updates, where this is permitted by law. Every marketing email will include a way to unsubscribe.

You can opt out of direct marketing at any time by using the unsubscribe link in a marketing message, or by contacting us at support@collr.com.au. Once you opt out, we will stop sending you marketing communications, although we may still send you transactional or service messages relating to your orders and account. We do not use or disclose your personal information for the direct marketing of other organisations' products or services without your consent. If you ask us to tell you where we obtained your personal information, we will do so where it is reasonable and practicable.

10. Cookies and analytics

Our website uses cookies and similar technologies, and our website and app use PostHog analytics, to keep the site working, to remember your preferences (such as the contents of your cart), and to understand and improve how our services are used.

You can control or disable cookies through your browser settings. If you block or delete cookies, some parts of the website may not work as intended. [PLACEHOLDER: confirm whether a cookie or analytics consent banner is shown on the website, and describe the choices it offers.] In the app, you can turn off analytics in the privacy settings. [PLACEHOLDER: confirm the exact in-app analytics opt-out control and default, consistent with our analytics documentation.] You can also contact us at support@collr.com.au for assistance.

11. Accessing and correcting your personal information

You have the right to ask for access to the personal information we hold about you, and to ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Much of your account and pet profile information can be viewed and updated directly in the Collr app at any time.

To request access or correction, please contact our Privacy Officer at support@collr.com.au. We may need to verify your identity before acting on your request. We will respond within a reasonable period. Access is usually free, although we may charge a reasonable fee to cover the cost of retrieving and supplying more extensive information, and we will tell you about any fee in advance. If we refuse access or correction, we will give you reasons in writing (except where it would be unreasonable to do so) and tell you how you can complain.

12. How to make a complaint

If you believe we have breached the Australian Privacy Principles or otherwise mishandled your personal information, please contact our Privacy Officer at support@collr.com.au and set out the details of your concern. We will acknowledge your complaint, investigate it, and respond to you within a reasonable period. [PLACEHOLDER: confirm complaint response timeframe, for example 30 days.]

If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au
Phone: 1300 363 992

13. Children

Collr is not directed at young children. You must be at least 16 years old to hold a Collr account, and if you are aged 16 or 17 you must have a parent or guardian's consent. [PLACEHOLDER: confirm the minimum age and any guardian-consent requirement, and keep it consistent across our Terms and app.] We do not knowingly collect personal information from a child under that age. If you believe a child has provided us with personal information without the consent of a parent or guardian, please contact us at support@collr.com.au and we will take reasonable steps to delete it.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services or the law. The current version will always be available on our website, and the effective date at the top of this policy shows when it was last updated. Where changes are significant, we will take reasonable steps to notify you.