Thank you for using our mobile application pupurogu.cyberailabs.ai or accessing our website (hereinafter referred to as the Website) and contacting us via email, SMS, or SNS account (if applicable) (collectively referred to as the Services).
In accordance with data protection and privacy laws, Tiya PteLtd and CYBER AI LABS PTE. LTD. (hereinafter referred to as the Company) are responsible as joint controllers for the processing of your personal data. We are committed to protecting your privacy through the data handling policies described in this Privacy Policy.
This Privacy Policy explains the following:
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How we collect your personal information and its purposes
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How to use by us or our Authorized Partners
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What you can choose about your personal information
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Measures we take to protect personal information
In this Privacy Policy, “personal information” and “personal data” are used as synonyms. This Privacy Policy does not apply to our information collection activities outside the scope of the Services or offline (except as expressly stated below or at the time of collection).
[Explicit Consent]
By using the Services, you consent to the collection, use, transfer and processing of your personal data in accordance with this Privacy Policy.
[Change of Privacy Policy]
The Company reserves the right to change the contents of this Privacy Policy without notice and will update it periodically as necessary. The revised Privacy Policy shall take effect from the time it is posted on our website.
If there is an important change, we will try to notify you by posting a notice in “Pupulog.” By continuing to use the Services after such changes, you agree to the changes.
[Handling when a part of the clause becomes invalid]
Even if any provision of this Privacy Policy is determined to be invalid or unenforceable by a court of competent jurisdiction, such provision will be separated to the extent necessary, and the remaining provisions will continue to be valid and enforceable.
Article 1 About inquiries
As a joint controller representative for the protection of personal information, CYBER AI LABS PTE. LTD. is designated. The company has the authority to act on behalf of Tiya Pte Ltd and shall be responsible for responding to and processing requests regarding data from customers or public authorities.
If you have any questions about how we collect, use, process or protect your personal information, or if you have a request regarding your personal information, please contact us at the following contact information.
■ Information on Co-Manager Representative (Contact):
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Legal Name: CYBER AI LABS PTE. LTD.
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Address: 107-0052 Akasaka, Minato-ku, Tokyo 8-11-26 + SHIFT NOGIZAKA 2F
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Division: Data Protection Officer
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E-mail: pupurogu.support@cyberailabs.ai
We will respond to your request in accordance with applicable laws and regulations.
For identity verification, additional procedures within a reasonable range (e.g. confirmation of your terminal information, etc.) may be asked.
You may also appoint an agent to make a claim, but we reserve the right to verify the identity and authority of the agent and may reject the claim if it is not appropriate.
We will endeavor to respond to all requests as quickly as possible.
However, for excessive or unreasonable claims, we may charge processing costs to a reasonable extent, and in that case we will inform you in advance.
If your privacy rights or personal data protection concerns are not resolved in response to our response, you may also contact the supervisory authority in your country or region (e.g., the Personal Data Protection Commission).
Article 2 Collection of Personal Information
(I) Information you provide.
| Category | explain |
|---|---|
| User data | You do not need to provide personal identifiers such as your name and phone number to start using "Pupulog." You can enter information in pseudonyms such as nickname and username.When you use the Services, we may collect information such as your country, device information, and subscription validity, some of which are automatically collected from your device.
For details on how this information is collected and used, please refer to the “Approximate location information (non-precise)” item described in the “Usage data” category in the next section (II) Information obtained automatically when using our service. In addition, if you send us an opinion, request or inquiry, we may collect contact information such as name and e-mail address in addition to the content. |
| User Content | All text, photos, audio and other content that you enter, fill out, upload, transmit or use in connection with the use of Pupulog (hereinafter referred to as Submitted Content) will be stored in encrypted form on your mobile device and on our servers.If you have activated the analytics feature, the Submission Content will be transmitted to our servers via encrypted communications and made available to our Authorised Partners for processing as necessary.Output generated based on Submitted Content (Output Results) is transmitted via our servers to your device and stored on your device and our servers.We may use your submitted content and output for the following purposes:
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| Personal Information Provided Voluntarily | |
| Category | explain |
| Data on surveys and user research | We may collect and use the personal information you provide when you complete a survey or participate in user research. |
(II) Information automatically acquired when using our service
When you use our Services, we may automatically collect information about you and your use of our Services.
We only use pseudonymized or anonymized data that has undergone privacy protection processing for the purpose of protecting and improving the functionality of the Service.
| Category | explain |
|---|---|
| Usage Data | The following are personal information collected and processed when you access or use the Services.1. Information on the use of the serviceThis is information about how customers use “Pupulog.” It mainly includes the following data: Saved usage setting information Operation history of services and functions (including date and time)2. Technical Usage DataData is automatically collected by technical means when using “Pupulog.” Mainly includes the following contents: Online identifier (e.g. IP address)Information about your device:Device Brand Name and Device IDType of network connection (e.g. Wi-Fi, 4G, LTE, Bluetooth)Types of operating systems (OS)App version of “Pupulog”Crash log (error information during application operation)Data for fraud prevention3. Approximate location information (non-precise)Information about the country, region, prefecture, and time zone may be obtained from the language setting or IP address of the terminal.We do not collect accurate location information such as GPS.This location information is used for the following purposes:Load Balancing and Network OptimizationStrengthening security measuresProviding app functions and realizing optimal display for each region |
(III) Information obtained from third parties
| Third Party Categories | explain | Data Categories |
|---|---|---|
| Payment Processing and Transaction Fulfillment Providers | When you pay the Subscription Fee (if applicable) to use the Pupplog feature, the Apple App Store where you download the App is responsible for processing all in-app purchases. Apple collects identification information such as your credit card information, name, billing address, and email address. After the transaction is completed, the purchase account is created and managed by Apple. Apple uses this information to process purchases, send order confirmation emails, facilitate future purchases, and process refunds (if applicable). We do not collect or process personal information directly. However, Apple may provide non-sensitive pseudo-anonymized records of payment-related data (e.g. order number, order time, user ID, subscription type, etc.). This allows us to enable paid features and improve app performance. | Pseudo-anonymized payment transaction information (order number, order date and time, user ID, subscription type, etc.) |
| Technical Service Partners | We work with technical service partners that provide specific data. This includes the process of identifying non-precise location information such as country, region, city, prefecture, etc. from IP addresses. This information allows Pupulog to appropriately provide services, content, and various functions. We also work with security service providers (including external anti-fraud APIs) to help protect user accounts. | User dataUsage Data |
| Marketing Partners | If you download Pupulog through a channel of one of our marketing partners, that partner may provide you with information about the channel (e.g., the source of the advertisement, the referring URL, etc.). | Usage Data |
| law enforcement agency | We may receive information from law enforcement agencies about potential violations of our Terms of Use. This information will be used for investigation and legal responses as necessary. | User dataUser Content |
Article 3 Purpose of Use of Customer Information
We do not sell, transfer, disclose, or share your personal information with third parties.
However, this does not mean that we transfer, disclose or share information to our authorized third-party partners to the extent necessary to provide services to you. These partners are contractually obligated to use and process such information only for the purpose of providing the Services on our behalf in accordance with our instructions.
We use your personal information on the following legitimate grounds and in accordance with applicable law:
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When there is clear consent of the customer
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When necessary to comply with laws and regulations
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When necessary to provide services to customers
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Where necessary to protect your rights and interests
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To pursue our legitimate business interests.
| Purpose of Use or Purpose of Use of Information | legal basis or legal basis for use |
|---|---|
| To enable you to use the Services and manage your account in general | Because it is necessary to provide the service |
| To provide services and to facilitate their provision. Also, to enable customers to use various functions of “Pupulog.” | Because it is necessary to provide the service.You also agree to us by providing us with certain information or by continuing to use our features. |
| To be able to subscribe to paid services | Because it is necessary to provide paid services. You also agree to us by performing an upgrade to a paid service or by providing us with the information necessary to use the Premium features. |
| To provide additional optional functions that are part of the “Pupulog” service. In using it, we will obtain your explicit consent individually. | With the express consent of the customer. |
| To better understand how users of “Pupulog” use and operate our services.To identify areas that need improvement and work on continuous improvement.To optimize the user experience. | Processing based on our legitimate interest in developing and improving our products and features for our users. |
| To process and synthesize user content and utilize it for learning and improving accuracy of our AI service.Synthetic Data is artificially generated, is not associated with personally identifiable information (PII), and does not contain identifiable or sensitive personal information. | Processing based on our legitimate interest in developing and improving our products and features for our users. |
| To detect and prevent fraud within the service environment or through software and tools used by end users.To identify accounts and devices that have received suspension measures. | Processing based on our legitimate interest in ensuring the environmental safety of our Services and the protection of our users. |
| To comply with our legal obligations.To respond to requests from law enforcement agencies such as police, prisons and courts.To exercise, establish or defend our legal rights. | Compliance with legal obligations |
| To respond appropriately to claims of infringement of intellectual property rights or reports of inappropriate content or activities. | Processing based on the legitimate interest of protecting our legal rights. |
| To diagnose problems related to the service, troubleshoot, and fix defects.To understand the frequency and trends of errors and maintain the functionality of the service at a high level. | processing necessary to provide the service. |
| To provide customer and technical support, including responding to inquiries and feedback, troubleshooting, fixing bugs, or assisting with issues when using the Services. | In responding to inquiries, processing based on user consent. |
| To collect and use personal information as specified in the questionnaire or user research when the user of Pupulog answers the questionnaire or participates in user research. | Regarding the handling of personal information, processing will be performed only if the user has provided consent. |
| To perform business planning, reporting and forecasting.For example, based on aggregated user data such as the number of new registrants in a country, it is used to consider new deployment areas for a product or feature. | Legitimate interestsOur legitimate interests include research and planning to operate our business smoothly and sustainably. |
| To evaluate and develop new features and technologies. | Legitimate interestsOur legitimate interests include improving our products, improving the user experience, and developing new products for our users. |
Article 4 Third Parties Who Can Use Your Information
We may share your information with other parties in the following circumstances:
A) Related Companies
We may share your personal information with affiliates belonging to the same corporate group. Each affiliate will handle your personal information in accordance with the contractual obligations established by us and after taking the necessary security control measures. If an affiliate is located overseas, it may transfer your personal information after taking appropriate protection measures in accordance with applicable laws and regulations. The purposes of sharing are as follows:
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Technical processing tasks (e.g. data hosting, analysis, maintenance, etc.)
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Financial, legal, human resources and accounting support
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Enhanced security against spam, fraud, and infringement
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Improvement of Service
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Monitoring, analysis, strategic planning, research and development
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Business-to-business transactions (e.g. mergers and acquisitions, asset sales, financing, etc.)
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Compliance with Applicable Laws
Each affiliate will only use your personal information in accordance with this Privacy Policy.
B) Certified Partner
We work with third-party vendors (Authorized Partners or Vendors) to provide the Pupulog App.
We will endeavor to update the list of certified partners as quickly as possible. These partners will process your information only on our behalf, based on our instructions. Their main activities include:
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Hosting
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User Support
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Analysis
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Fraud Detection and Prevention
For more information, please refer to the privacy policy of each authorized partner.
| Consignor (vendor) | Purpose |
|---|---|
| Firebase | Statistics and Analysis: To understand the usage of the Service and to improve functionality and optimize user experience. |
| Shumei | Risk Management: To detect and prevent fraud, maintain security, and monitor and counter abnormal behavior when using the Service. |
| Appsflyer | Statistics and Analysis: To understand the usage of the Service and to improve functionality and optimize user experience. |
| SensorsAnalyticsSDK | For data statistics and behavioral analysis: To optimize product functionality and user experience by analyzing feature usage and identifying user behavior patterns. |
| Google Gemini | To help owners more accurately understand the health of their pets by identifying the status of pet waste and making intelligent judgments in combination with analytical models. |
C) government agencies
We may share information with other organizations or provide information in response to lawful requests from government agencies in order to combat fraud or illegal activity. We may disclose your personal information as necessary in response to a legally legitimate request from a government agency or court, such as for law enforcement or to prevent violations of the law. These disclosures will be made to the extent necessary or permitted under applicable law.
- Data storage and cross-border data transfer
As a general rule, your personal information will be securely stored at our locations in the United States and at our authorized agencies. It may also be processed or stored on encrypted cloud servers located in the United States, subject to applicable law.
We work with our affiliates and authorized third-party partners around the world to provide our services efficiently. Therefore, your personal information may be accessed from around the world by our authorized parties, and legally personal information may be transferred for access, use and processing outside of the country by our authorized parties on our instructions and for specific purposes only.
Although data protection and privacy laws in other countries may differ from those in your country of residence, we will take adequate safeguards to protect your personal information as described in this Privacy Policy. This may include implementing legal mechanisms such as contractual Standard Contractual Clauses (SCCs) or other legally recognized safeguards.
We are justified in taking the above steps to fulfill our contractual obligations. By using the Services and providing information to us, you consent to the storage, transfer and processing of your personal information to jurisdictions other than your home country, in particular the United States, unless expressly stated otherwise. We use this consent as one of the grounds for a legal data transfer.
- Your Rights and Choices
A) Device settings In order to use the features of the Pupplog App, you may be asked for permission to access the clipboard, microphone, and other apps and smartphone features. You can opt out of these permissions at any time by changing the settings on your mobile device.
B) Access to your personal information held by us Upon your written request and upon proper identification, we will provide you with a copy of your personal information in electronic form.
C) Right to personal information You may withdraw your consent to our collection, use, disclosure or transfer of your personal information to third parties at any time. You also have the right to request that your personal information be corrected, deleted or restricted from processing.
After receiving a written request from you, we will process it within a reasonable period of time, depending on the complexity of the request and the impact on our relationship with you, and will notify you of the results and impact. We will generally endeavor to respond within 30 days of receipt of the request.
Depending on the content and scope of the request, you may not be able to use some or all of the functions of “Pupulog,” and you may be forced to terminate the usage agreement with us. In that case, we will notify you before processing is completed. If you withdraw your request, please contact us immediately.
Please note:
- If you fail to provide us with all the personal information we need for the following purposes, we may impose the following restrictions:
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(i) User Account Registration
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(ii) Use of the Services
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(iii) Responding to requests regarding your personal information
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(iv) Responding to comments, questions and other inquiries
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As a result, we: (x) may not be able to process or refuse to process personal information for any of the above purposes; (y) may not be able to perform or continue to perform any contractual obligations (if any) that we have to you; (z) may be forced to terminate your User Agreement, in which case we are not responsible.
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You can withdraw your consent to the use or disclosure of your personal information at any time by changing your in-app settings or by contacting us. However, the withdrawal of consent does not affect the legality of the processing prior to the withdrawal and the processing based on our legitimate interests, and does not affect the right to collect information in the following circumstances: (i) where the use or disclosure is required by law; (ii) where personal information is collected from publicly available sources; or (iii) where the use or disclosure is necessary in an emergency when the life or health of a person is at risk.
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By submitting a written notice to us, you may restrict the processing of your personal data (e.g., stop processing for direct marketing purposes or request not yet started). If you do so, we may have difficulty maintaining existing arrangements or contractual relationships, which may result in: (i) not being able to process your personal data for any of the purposes set out in this Privacy Policy; (ii) not being able to fulfill any contractual obligations (if any); or (iii) termination of a contract or agreement with you. We are not responsible for this.
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Even if you ask us to delete all or some of your personal information, we may retain certain data to the extent necessary for our legitimate business interests (e.g. to comply with legal obligations, resolve disputes, enforce contracts). We will explain in detail why we cannot do so if required by applicable law or if you reside in Japan.
Under applicable law, you may have the right to obtain your personal information in a transferable form and transfer it to other service providers (right to data portability).
If you wish to exercise your rights with respect to your personal information, please contact us using the method described in Section 1 above, “Information on Co-Controller Representatives (Contact Information).”
You will not be subjected to discriminatory treatment as a result of your exercising these rights.
D) Cancellation of the Subscription Plan
You may cancel your paid subscription plan at any time.
Even if you cancel, you will still be able to use the paid features until the end of the current billing cycle.
Please note that if you delete the “Pupplog” app from your mobile device during the validity period of your subscription, you may lose your account status, subscription status, personal information, and other related information.
When you delete your account, you will be notified of the impact of the deletion and will be asked to confirm.
However, we may continue to retain some information to the extent necessary for the following purposes:
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Prevention of Fraud
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Troubleshoot issues
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Investigation collaboration
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Fulfillment of Terms of Use
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Compliance with Laws and Regulations
E) Delete the Pupurogu app
You can delete your “Pupulog” account at any time from the account settings in the app. After deleting the account, the account and related information will be disabled from our active database. As a result of deletion, your personal information and related data may be lost.
Prior to account deletion, you will be notified of the impact of the deletion and will be asked to confirm.
However, to protect our legitimate business interests, we may retain some information for the following purposes:
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Prevention of Fraud
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Troubleshoot issues
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Investigation collaboration
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Fulfillment of Terms of Use
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Compliance with Laws and Regulations
Article 5 How to Protect Your Personal Information
A) Security measures
In order to ensure a safe usage environment and provide users with a safe experience, Pupurogu (hereinafter referred to as “this service”) always develops and introduces appropriate administrative, technical and physical safety measures, and customers’ personal information We strive to prevent it from being used or accessed, lost, misused or tampered with.
However, we cannot fully guarantee the security of information transmitted by you through our and our authorized partners’ systems or stored on those systems.
If you discover improper collection or misuse of personal information, please report it to our support ( pupurogu.support@cyberailabs.ai ) promptly.
B) Introduction of pseudonymization, anonymization and aggregation technologies
In order to strengthen privacy protection, we have introduced technologies such as pseudonymization, anonymization, and aggregation of information to modify or delete specific identification information.
As a result, we may use these processed data only for the purpose of improving the functionality of this service while preventing the identification of individual customers.
C) Retention period of personal information
We only store your personal information for as long as necessary for the following purposes:
・ Period necessary to achieve the purpose of use specified at the time of collection
・ How long you have an active Subscription or Active Account, or as long as necessary to provide the Service
・ When there is an obligation to save based on tax, accounting or other legal requirements
If we determine that any of the above purposes are no longer applicable, we will promptly terminate the storage of such personal information or anonymize such information and change it to a format that does not identify a specific individual.
Technical data, such as access logs, may be stored in pseudonymized form for up to one year and may then be deleted or anonymized.
Article 6 Protection of children’s privacy
The app is not intended for use by anyone under the age of 18. We do not knowingly collect personal information or data from anyone under the age of 18. This app is not intended for anyone under the age of 18. If you are under the age of 18, please do not use this app at all.
Anyone who provides Personal Information through our Services is expressly representing that they are 18 years of age or older.
If we learn that a person under the age of 18 has provided us with personal information, we will immediately stop the user’s use of the service and delete or anonymize the information except for information that is required to be stored by law.
If you are a parent or legal guardian who believes that your child or ward may have provided us with personal information, please contact us ( pupurogu.support@cyberailabs.ai ). We will verify the identity of the relevant user and parent or legal guardian and, if necessary, obtain their consent to take action, such as deleting the account or personal information.
Article 7 Cookies and Tracking Technologies
We use third-party services, such as Google Firebase and AppsFlyer, to understand how people use our app logs and to improve performance and user experience. These services may collect and analyze certain device information and usage data, such as mobile identifiers, app usage statistics, and crash reports.
These technologies have a similar function to cookies and may collect information that is considered personally identifiable information under applicable law. Such data may be acquired or accessed by the service provider for the purpose of analysis, attribution, or performance optimization of the public log.
We will obtain your prior consent before enabling such tracking technology, except as strictly necessary for the operation or security of Pupulog. You may withdraw your consent at any time by changing your device settings.