The terms used are not gender-specific.
Last updated: October 12, 2026
- Controller
- Overview of Processing
- Legal Bases
- Security Measures
- Cookies
- Business Services
- Payment Processing (Paddle)
- Provision of the Online Offering and Web Hosting
- Special Notes on Applications (Apps)
- Location Data and Walk Tracking in the Hundeo App
- In-App Subscriptions via RevenueCat
- Registration and User Accounts
- Contact
- Web Analytics and Optimization
- Error and Stability Monitoring (Sentry)
- Online Marketing
- Partner Program (Referly)
- Social Media Presences
- Rights of Data Subjects
- Changes to This Privacy Policy
Controller
RINACLA LTD Georgiou Karaiskaki, 11-13 CARISA SALONICA, Flat/Office 102 Pervolia, 7560, Larnaca, Cyprus
Registration Number: HE 469019
Managing Director: Enrico Bachmann
Email: support@hundeo.com Website: https://hundeo.com Legal Notice: Imprint
Overview of Processing
The following overview summarizes the types of data processed and the purposes of their processing.
Types of Data Processed
- Inventory data (e.g., names, addresses)
- Contact data (e.g., email, phone numbers)
- Content data (e.g., entries in online forms)
- Usage data (e.g., pages visited, interest in content, access times)
- Meta/communication data (e.g., device information, IP addresses)
- Location data (e.g., precise and approximate location, GPS coordinates, timestamps, accuracy, altitude, and speed when using walk tracking)
- Contract data (e.g., subject matter of contract, term, customer category)
- Payment data (e.g., bank details, invoices, payment history)
Categories of Data Subjects
- Customers, prospective customers, business and contractual partners
- Users (e.g., website visitors, users of online services)
- Communication partners
- Business and contractual partners
Purposes of Processing
- Provision of contractual services and customer support
- Contact requests and communication
- Security measures
- Recording and displaying GPS-based dog walks, including route, distance, duration, and recovery of active walks
- Range measurement and marketing
- Office and organizational procedures
- Managing and responding to inquiries
Legal Bases
The following is an overview of the legal bases of the GDPR on the basis of which we process personal data:
- Consent (Art. 6(1)(a) GDPR): The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Contract Performance (Art. 6(1)(b) GDPR): Processing is necessary for the performance of a contract to which the data subject is party.
- Legal Obligation (Art. 6(1)(c) GDPR): Processing is necessary for compliance with a legal obligation.
- Legitimate Interests (Art. 6(1)(f) GDPR): Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Security Measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability assurance, and separation of data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise.
Transfer of Personal Data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. The recipients of this data may include service providers commissioned with IT tasks or providers of services and content that are integrated into a website.
Data Processing in Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies, or companies, this is only done in accordance with the legal requirements.
Use of Cookies
Cookies are small text files or other memory notes that store information on end devices and read information from end devices. For example, to store the login status in a user account, the content of a shopping cart in an e-shop, the content accessed, or the functions used in an online offering.
We use cookies in accordance with legal requirements. We obtain consent from users where legally required. Where consent is not legally required, we rely on our legitimate interests.
Types of Cookies
- Essential cookies: Cookies that are essential for the operation of the website.
- Analytics cookies: Cookies that help us understand how visitors interact with the website.
- Marketing cookies: Cookies that are used to track visitors across websites to display relevant ads.
Consent Management
We ask for your consent with our own cookie banner, without an external provider. Your choice for the categories essential, analytics and marketing is stored in your browser's local storage under the keys hundeo_cookie_consent and hundeo_cookie_preferences. When you use our quiz, we also store your consent status for analytics and marketing with your quiz session on our server and update it when you change or withdraw your consent. We use this status when processing server-side marketing events. If you allow analytics or marketing, we load Google Tag Manager. It and the Google services loaded through it then send your choice (consent status) to Google with their requests. You can change or withdraw your choice at any time: click "Cookie settings" in the footer of our website. The banner then opens again with your current choice. Withdrawal applies to the future.
Payment Processing (Paddle)
Purchases on our website (hundeo.com and app.hundeo.com) are sold by Paddle as Merchant of Record. Paddle is a controller in its own right for checkout, payment processing, invoices, VAT, fraud prevention, subscription management and refunds. Paddle's privacy policy applies to this processing.
- Data processed by Paddle: email address, country and postcode, payment details (stored only by Paddle), name where provided, transaction and subscription data, and IP address and device data for fraud checks.
- What we receive from Paddle: transaction and subscription status, email address, country, amounts, any discount code used and technical identifiers we pass to the checkout (for example an account or session ID and, where applicable, a partner ID). We do not receive card numbers or bank details.
- Purposes: concluding and processing the purchase, unlocking Hundeo Pro, customer support, refunds and settling partner commissions (see Partner Program).
- Legal basis: contract performance (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Provider: Paddle.com Market Limited, 30 Old Bailey, London EC4M 7AU, United Kingdom. Transfer to the United Kingdom based on the European Commission's adequacy decision.
- Privacy policy: paddle.com/legal/privacy
Provision of the Online Offering and Web Hosting
We process users' data to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to deliver the content and functions of our online services to the user's browser or end device.
Hosting Provider
We use Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA, to host and serve our website. Vercel delivers the website through a global server network, for visitors from Europe usually via Frankfurt am Main. Server functions, for example for checkout, the partner program and forms, currently run in the USA (Washington, D.C. region). Transfer to the USA based on standard contractual clauses, which are part of Vercel's data processing agreement. Privacy Policy.
The servers for the app and user accounts are run by DigitalOcean, LLC, 105 Edgeview Drive, Suite 425, Broomfield, CO 80021, USA, as processor, in its Frankfurt am Main data center. The data processing agreement is part of DigitalOcean's terms of service. Where data reaches the USA, DigitalOcean relies on its certification under the EU-US Data Privacy Framework and, as a fallback, on standard contractual clauses. Privacy Policy.
Content Delivery Network
We use a Content Delivery Network (CDN) to ensure faster and more secure delivery of our online offering's content.
Special Notes on Applications (Apps)
We process the data of users of our application insofar as this is necessary to provide the users with the application and its functionalities, to monitor its security, and to develop it further. We may also contact users in compliance with legal requirements if communication is necessary for purposes of administration or use of the application.
Location Data and Walk Tracking in the Hundeo App
If you choose to use the walk tracking feature in the Hundeo app, we access and collect your device location with your permission. This may include precise and approximate location data, including GPS coordinates such as latitude and longitude, timestamps, accuracy, altitude, and speed. We use this data to record your walk with your dog, calculate distance and duration, show your route on a map, continue tracking while the walk is active in the background or while the screen is locked, restore an interrupted active walk, and save the walk in your journal.
Location data is collected only when you start GPS-based walk tracking and while the walk is active. You can also log walks manually without GPS. Active walk data may be stored locally on your device for recovery and is synced with our servers when a walking session is created, updated, or saved. When maps are displayed, map providers such as Apple Maps on iOS and OpenStreetMap/map tile providers on Android may process map display data. We do not sell location data and we do not use precise walk location data for advertising. We do not use location data outside a GPS-based walk you have started to create general location histories or movement profiles of your device.
You can stop walk tracking at any time and revoke location permissions in your device settings. Saved walks can be deleted in the app; account deletion requests are handled as described in this Privacy Policy.
Obtaining Applications via App Stores
The acquisition of our application takes place via special online platforms operated by third-party providers (app stores such as Google Play or Apple App Store). The privacy policies of the respective app store providers apply.
In-App Purchases
In-app purchases are processed through the respective app store (Apple App Store or Google Play Store). The purchase and payment processing is subject to the terms and conditions and privacy policies of the respective platform.
In-App Subscriptions via RevenueCat
We use RevenueCat to manage subscriptions bought in the app. RevenueCat manages the purchase receipts, syncs the subscription status between the app and the website and reports purchases, renewals and cancellations to us.
- Data processed: pseudonymous app user ID, receipts and transaction IDs, product, price, country and currency, platform and device data, subscription status.
- Purposes: unlocking and managing Hundeo Pro, syncing between app and website, customer support.
- Legal basis: contract performance (Art. 6(1)(b) GDPR) and legitimate interests (Art. 6(1)(f) GDPR).
- Provider: RevenueCat, Inc., 1032 E Brandon Blvd #3003, Brandon, FL 33511, USA, as processor. The data processing agreement is part of RevenueCat's terms. Transfer to the USA based on the standard contractual clauses it contains.
- Privacy policy: revenuecat.com/privacy
Registration, Login, and User Account
Users can create a user account. During registration, users are provided with the required mandatory information and it is processed for the purpose of providing the user account based on the contractual fulfillment of obligations.
- Processed data types: Inventory data, contact data, content data, meta/communication data.
- Legal basis: Contract performance, consent, legitimate interests.
Single Sign-On Login
We offer users the option of registering and logging in using a single sign-on procedure via providers such as Apple, Facebook, or Google. Authentication takes place directly with the respective provider.
Contact
When contacting us (e.g., via contact form, email, or social media), the data of the inquiring persons is processed insofar as this is necessary to answer the contact requests and any requested measures.
- Processed data types: Contact data, content data, usage data, meta/communication data.
- Legal basis: Contract performance, legitimate interests.
Push Notifications
With the consent of users, we may send push notifications. Users can adjust or revoke their consent at any time via the device settings.
Web Analytics, Monitoring, and Optimization
Web analytics are used to evaluate visitor traffic to our online offering and may include behavioral patterns, interests, or demographic information about users.
Services Used
- Google Analytics: Web analytics service provided by Google Ireland Limited. Data may be transferred to the USA. Google is certified under the EU-US Data Privacy Framework. Privacy Policy. Opt-Out.
- PostHog: Product and web analytics by PostHog Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA. Data is stored in PostHog's EU cloud (eu.i.posthog.com). On the website we only load PostHog after you consent to the analytics category. We then record page views and events (for example quiz and checkout steps or the detection of a partner link) and record sessions (session recording: clicks, scrolling and page content; form inputs are masked). Data processed: pseudonymous IDs, event and device data, IP address. Legal basis on the website: consent (Art. 6(1)(a) GDPR). In the app we use PostHog without session recording to analyse events and errors. If you are signed in to the app, we link this data to your user account (user ID, email address, name, sign-in method, language and registration date). Once per installation we also store there which source and campaign the app was installed from according to AppsFlyer. Legal basis in the app: legitimate interests in improving the app and keeping it stable (Art. 6(1)(f) GDPR). Transfer to the USA where PostHog Inc. has access: according to PostHog, it participates in the EU-US Data Privacy Framework; PostHog's data processing agreement also provides for standard contractual clauses. Privacy Policy.
- Vercel Web Analytics and Speed Insights: Reach and page-speed measurement by Vercel Inc. We only load both after you consent to the analytics category. Legal basis: consent (Art. 6(1)(a) GDPR). Privacy Policy.
Error and Stability Monitoring (Sentry)
We use Sentry to detect errors and crashes in the app and on the website quickly. When an error occurs, an error report is sent to Sentry. In addition, we measure load times for about 10% of requests to our website's servers, even when no error occurs. In the browser this only starts after an error has occurred on the page.
- Data processed: error messages and technical traces (stack traces), the address (URL) of the page or request, the last steps before the error such as page changes, clicks and network requests (breadcrumbs), for performance measurements load times and the steps of the request, device, operating system and browser, app version, time and the IP address needed for the transfer. We do not send any other default personal data, nor an ID of your user account. In the app we also measure load times for about 1% of operations.
- Purposes: stability, security and load times of our services, error analysis.
- Legal basis: legitimate interests (Art. 6(1)(f) GDPR) in a secure, error-free service.
- Provider: Functional Software, Inc. (Sentry), 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA. Sentry stores the app's data in Germany (EU region). Transfer to the USA where Sentry has access: according to Sentry, it participates in the EU-US Data Privacy Framework; as a fallback, Sentry's data processing agreement provides for standard contractual clauses.
- Privacy policy: sentry.io/privacy
Online Marketing
We process personal data for online marketing purposes, which may include marketing of advertising space or display of promotional and other content based on potential user interests.
Services Used
- Google Ads: Online marketing via Google's advertising platform. Privacy Policy.
- Meta Ads (Facebook/Instagram): Social media advertising. Privacy Policy.
- Apple Search Ads: App store advertising. Privacy Policy.
- AppsFlyer: Mobile attribution and marketing analytics. Privacy Policy.
Affiliate Programs and Links
We include in our online offering so-called affiliate links or other references to the offerings of third-party providers. If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefit from these third-party providers.
Partner Program (Referly)
We run our own partner program. Partners, for example creators, dog trainers or websites, recommend Hundeo with a personal link or code. Their audience gets a discount and the partners earn a commission on paid web purchases. We use the Referly platform for this. The rules for partners are set out in the program terms.
Visitors who arrive through a partner link
- Partner links contain a partner ID in the address (parameter ref, partner_ref or hundeo_ref).
- Only if you consent to the marketing category do we store this ID in your browser for up to 30 days (cookie and local storage, both named hundeo_partner_ref) and load Referly's tracking script. The script stores the partner code from the link and an ID for your click in its own cookies on our domain or, as a fallback, in local storage (the names end in _affiliate_ref and _affiliate_referral, where applicable _rsubID, each preceded by Hundeo's program ID at Referly). These entries last 60 days, and the period restarts with every visit. When you click, Referly records, among other things, the landing page, the referring page, campaign parameters and click IDs of ad networks, device, browser, operating system, screen size, language setting, IP address and approximate location. The script also loads a helper file from the jsDelivr service (cdn.jsdelivr.net), which receives your IP address.
- Without consent we do not store the ID in your browser. A purchase is then attributed to the partner if the partner ID is still in the address at checkout or you use the partner's code at checkout.
- Quiz: if the partner ID is in the address you start our quiz with, we store it with your quiz session on our server, even without consent to marketing. If you later complete the purchase through a link in one of our emails, we attribute it to this partner. Legal basis: legitimate interests (Art. 6(1)(f) GDPR) in correct commission accounting.
- Legal basis for the storage in your browser and the tracking script: consent (Art. 6(1)(a) GDPR and Section 25(1) of the German TDDDG). You can withdraw it at any time with effect for the future via "Cookie settings" in the footer of our website. We then delete the stored partner ID and the entries of Referly's script from your browser and no longer load Referly's tracking script.
Customers whose purchase is attributed to a partner
- When we report the purchase to Referly ourselves (web purchase through Paddle with a partner code or partner link), we send: transaction ID, the amount in euros and the tax included, the partner code or partner ID, and your email address. We do not send your name. Where Referly requires a name, we use the placeholder "Hundeo customer" instead.
- Referly is connected to Paddle through its own connection and receives notifications of all completed web purchases through it. According to Referly, it stores nothing about purchases without a partner. If the purchase is attributed through Referly's tracking (only after you consent to marketing), Referly fetches the purchase data directly from Paddle: the transaction with products, amounts, tax and currency, and through Paddle's interface the customer data, for example your email address and, if provided, your name. We cannot technically reduce this scope.
- Referly uses the email address to match renewals to the same customer and to detect self-referrals.
- Partners see the purchases attributed to them in their dashboard and in notifications from Referly, including your email address and, if Referly received it from Paddle, your name. Depending on the program settings, Referly shows these details only in part and masks the rest.
- Purposes: attributing the purchase, settling commissions, cancelling them after refunds or chargebacks, preventing abuse.
- Legal basis: legitimate interests (Art. 6(1)(f) GDPR) in correct commission accounting.
Partners and applicants
- Application: name, email address, brand, country, language, channels and sample content, audience, reach, recommendation idea, requested code and your consents. To prevent abuse we check the form with Cloudflare Turnstile.
- Automated pre-check: we fetch the public websites and profiles you list and analyse them with the services Supadata and Firecrawl, for example title, description, subscriber counts and topics. From this we calculate a score. Suitable applications can be approved automatically. A person decides on every rejection. You can ask at any time for a person to review your application and state your point of view.
- Storage of applications: we store your application together with the result of the pre-check, your consents (with the time and the version of the program terms) and our decision in our application database at Upstash. We delete open applications after 180 days and rejected ones 90 days after the rejection. We keep approved applications while the partnership runs and delete them when it ends. We also receive your application by email, sent via Mailgun (EU region).
- Partner account at Referly: name, email address, partner code and partner link, clicks, attributed purchases, commissions, payout and tax details. Referly issues the self-billing invoices and makes the payouts. Referly itself is responsible for managing your Referly account and for features across programs, such as your profile at Referly. Referly's privacy policy applies to this.
- Personal partner page (optional): on your partner page (www.hundeo.com/en/p/your-code) you can show a name, a short sentence, a photo, a link to your website or a profile, your partner type and a topic. We send the edit link only to the email address of your partner account; to do so, we compare the address you enter with Referly. We store your details together with the time and wording of your consent in our database at Upstash. We save a photo again as a square and without extra data such as location and camera at Cloudflare R2. Your details only become public once we have reviewed and approved them. Legal basis: your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time with effect for the future, for example by emailing support@hundeo.com. We then remove the details from the page and delete them, as we also do when the partnership ends. We delete rejected or replaced photos right away.
- Purposes: reviewing applications, running the partnership, settlement and payouts, tax obligations, and partner tips by email only with consent.
- Legal basis: pre-contractual steps and contract performance (Art. 6(1)(b) GDPR), legal retention obligations (Art. 6(1)(c) GDPR), consent for partner tips (Art. 6(1)(a) GDPR).
- Retention: we keep settlement and tax records for the statutory period.
Providers in the partner program
- Referly: Referly Technologies, LLC, 1207 Delaware Ave #3648, Wilmington, DE 19806, USA, as processor. According to Referly's privacy policy, Referly's data processing agreement applies to this processing. Transfer to the USA based on standard contractual clauses. Partner program data (for example clicks, attributed purchases and commissions) stays stored at Referly while we run the program there, unless we delete it earlier. After the end, Referly deletes it within 30 days according to its privacy policy. Privacy Policy.
- Cloudflare R2: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA, as processor for the photos of partner pages, which we deliver via media.hundeo.com. Transfer to the USA where Cloudflare has access: according to Cloudflare, it participates in the EU-US Data Privacy Framework; as a fallback, the data processing agreement provides for standard contractual clauses. Privacy Policy.
- Cloudflare Turnstile: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Privacy Policy.
- Mailgun (EU region): email delivery by Mailgun Technologies, Inc., USA. Privacy Policy.
- Supadata: Dumpling Software UG (haftungsbeschränkt), Kollwitzstraße 76, 10435 Berlin, Germany, as processor. Fetching public websites and profiles; we only send the addresses you list. Privacy Policy.
- Firecrawl: SideGuide Technologies, Inc., Delaware, USA. Used only when Supadata cannot fetch a website; we only send the address of the page. Firecrawl processes the data on servers in the USA. Privacy Policy.
- Upstash: Upstash, Inc., Delaware, USA, as processor for our application database and the details of partner pages. The data processing agreement is part of Upstash's terms. Transfer to the USA where Upstash has access: according to Upstash, it participates in the EU-US Data Privacy Framework; as a fallback, the data processing agreement provides for standard contractual clauses. Privacy Policy.
- jsDelivr: Volentio JSD Limited, England and Wales, United Kingdom. Delivers the helper file of Referly's script and processes the request data as a controller in its own right. jsDelivr uses further providers for this (Cloudflare, Fastly, Gcore), which also receive your IP address. Transfer to the United Kingdom based on the European Commission's adequacy decision. Privacy Policy.
Social Media Presences
We maintain online presences within social networks and process user data in this context to communicate with users active there or to offer information about us.
Platforms used:
Plugins and Embedded Functions
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers. These may include graphics, videos, or social media buttons.
The providers of this content may use cookies for statistical or marketing purposes.
Rights of Data Subjects
As a data subject, you are entitled to various rights under the GDPR:
- Right of Access (Art. 15 GDPR): You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data.
- Right to Rectification (Art. 16 GDPR): You have the right to request the completion of data concerning you or the correction of inaccurate data.
- Right to Erasure (Art. 17 GDPR): You have the right to request that data concerning you be deleted immediately.
- Right to Restriction (Art. 18 GDPR): You have the right to request the restriction of processing of your data.
- Right to Data Portability (Art. 20 GDPR): You have the right to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format.
- Right to Withdraw Consent (Art. 7(3) GDPR): You have the right to withdraw your consent at any time.
- Right to Lodge a Complaint (Art. 77 GDPR): You have the right to lodge a complaint with a supervisory authority.
Exercising Your Rights
To exercise your rights, please contact us at: support@hundeo.com
Changes to This Privacy Policy
We reserve the right to modify this privacy policy to adapt it to changed legal situations or changes in our services or data processing. Users are advised to regularly inform themselves about the content of our privacy policy.
This privacy policy was created with the assistance of the privacy policy generator from datenschutz-generator.de by Dr. Thomas Schwenke.