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Privacy Policy

Last updated: March 2026

François Aubeut, sole proprietor (hereinafter "we"), places great importance on the protection of your personal data. This Privacy Policy describes how we collect, use, and protect your information when you use the Wagly application (hereinafter "the Application").

1. Data controller

The data controller for personal data collected through the Application is:

François Aubeut
Sole proprietor (Entrepreneur individuel)
Contact: support@wagly.pet

2. Data collected

In the course of using the Application, we collect the following categories of data:

Account data

  • Email address
  • Password (stored in encrypted form)
  • Account creation date

Pet-related data

  • Name, species, breed, date of birth, sex, and weight of the pet
  • Pet profile photo
  • Health history: vaccinations, treatments, symptoms, veterinary visits
  • Vaccination and treatment reminders

Sharing data

  • Identifiers of users with whom you share or transfer a pet profile
  • History of shares and transfers

Technical data

  • Device type and operating system
  • Application version
  • Anonymized error logs

3. Purposes of processing

Your data is processed for the following purposes:

  • Providing and maintaining the digital health record service for your pets
  • Managing your user account and authentication
  • Enabling health tracking for your pets (vaccinations, treatments, symptoms)
  • Sending vaccination and treatment reminders
  • Enabling sharing of pet profiles with people of your choosing
  • Enabling transfer of pet ownership to another user
  • Improving the Application and fixing bugs
  • Communicating with you regarding your account or important service updates

4. Legal basis for processing

The processing of your data is based on the following legal grounds:

  • Performance of a contract: Processing is necessary for the performance of the service you requested by creating your account (Article 6(1)(b) of the GDPR).
  • Legitimate interest: Improving the Application and fixing bugs is based on our legitimate interest in providing a quality service (Article 6(1)(f) of the GDPR).
  • Consent: Sharing data with other users is based on your voluntary action of initiating the share or transfer (Article 6(1)(a) of the GDPR).

5. Data sharing

We do not sell or share your data with third parties for commercial purposes.

Your data may be shared only in the following cases:

  • Between users: When you use the Application's sharing or transfer features, the data from the relevant pet profile is made accessible to the recipients you designate. You have full control over these shares and can revoke them at any time (except in the case of a permanent transfer).
  • Technical service providers: We use technical service providers for hosting and operating the Application. These providers are bound by contractual obligations of confidentiality and security in compliance with the GDPR.
  • Legal obligation: If required by law, we may transmit your data to the competent authorities.

6. Data retention

Your data is retained for as long as your account is active.

Subscription expiration (without account deletion)

If your subscription expires without account deletion, your data is retained for 6 months after the end of the subscription, to allow you to resume tracking if you wish. After this period, the data is deleted.

Account deletion

You can delete your account directly from the Application. Deletion is immediate and irreversible:

  • All your personal data and your pets' data are permanently deleted and unrecoverable.
  • Photos are cleaned from our servers during the monthly cleanup cycle. Photos associated with a deleted account are thus removed within one month of deletion.
  • Pet data that you have transferred to another user remains associated with the new owner's account.

Data usage

Your data is never used for any purpose other than the operation of the Application. No data is used for advertising, commercial statistics, or resale.

7. User rights

In accordance with the General Data Protection Regulation (GDPR), you have the following rights:

  • Right of access: You can obtain a copy of all personal data we hold about you.
  • Right to rectification: You can request the correction of inaccurate or incomplete data.
  • Right to erasure: You can request the deletion of your personal data. You can also delete your account directly from the Application.
  • Right to data portability: You can request to receive your data in a structured, commonly used, and machine-readable format.
  • Right to object: You can object to the processing of your data on legitimate grounds.
  • Right to restriction of processing: You can request the restriction of processing of your data in certain cases provided by law.

To exercise these rights, contact us at: support@wagly.pet. We will respond to your request within a maximum of 30 days.

8. Cookies

The Wagly Application does not use any cookies. We do not use any advertising, analytics, or behavioral tracking tools.

9. Data security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, destruction, or alteration:

  • Data encryption in transit (HTTPS/TLS)
  • Password encryption (irreversible hashing)
  • Restricted access to production data
  • Regular backups
  • Access monitoring and logging

10. International transfers

Your data is hosted within the European Union. If a transfer to a third country were necessary, it would be governed by appropriate safeguards in accordance with the GDPR (standard contractual clauses, adequacy decision).

11. Changes to this policy

We reserve the right to modify this Privacy Policy at any time. In the event of a substantial change, we will notify you through a notification in the Application or by email. The last updated date at the top of this document will also be updated.

12. Contact

For any questions regarding this Privacy Policy or to exercise your rights, you can contact us at:

support@wagly.pet

13. Supervisory authority

If you believe that the processing of your personal data constitutes a violation of the GDPR, you have the right to lodge a complaint with the competent supervisory authority:

Commission Nationale de l'Informatique et des Libertés (CNIL)
3, Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07
Website: www.cnil.fr