Doggo Trading Pty Ltd (ABN 76 686 271 830) ("Doggo", "we", "us" or "our") operates www.doggo.com.au and any related mobile sites, apps and services (collectively, the "Doggo Services").
We are committed to protecting your privacy and managing personal information in an open and transparent way. This Privacy Policy explains how we collect, use, disclose and protect personal information, as well as how you can access or correct your information and make a privacy complaint.
Although some small businesses are exempt from the Privacy Act 1988 (Cth), Doggo has opted in to be treated as an "organisation" under section 6EA and complies with the Australian Privacy Principles. By using the Doggo Services you agree to the handling of personal information described below.
2. What this Privacy Policy covers
This Privacy Policy applies to personal information we collect in connection with:
- use of our website and any related subdomains or mobile applications
- membership accounts (including buyer, breeder or partner accounts)
- products and services we offer such as marketplace listings, messaging, payments and support
- Doggo marketing and communications
- job applications, employee, contractor or advisor arrangements
It does not cover third-party websites or services that may be linked from our site. Those services are responsible for their own privacy practices.
3. What is personal information?
"Personal information" has the meaning given in the Privacy Act: information or an opinion about an identified individual, or an individual who is reasonably identifiable, regardless of whether the information is true or recorded. Some personal information is "sensitive information" (for example, information about health, biometrics or criminal records). We only collect sensitive information where reasonably necessary for our functions and either with your consent or as otherwise permitted by law.
4. The kinds of personal information we collect and hold
We generally collect and hold the following categories of personal information.
4.1 Account and profile information
- name
- contact details (email, phone number, postal and/or residential address)
- date of birth
- account username, password and profile biography
- photos or other information you choose to display
4.2 Identity verification information
To help keep the Doggo marketplace safe and comply with legal obligations we may use third party providers for identity checks. We do not keep or store identity document details (e.g. driver licence, passport) or facial images/video captured by those providers. These details may include government-related identifiers, which we handle in accordance with the Privacy Act.
4.3 Transaction and payment information
- payment method details (handled primarily by our payment providers)
- transaction history covering purchases, sales, fees and charges
- subscription and membership details
- invoices, receipts and records of refunds or disputes
4.4 Marketplace and pet-related information
- listing details (e.g. puppy or dog profiles, breed, age, microchip number, pedigree and registration information)
- photos, videos and descriptions uploaded with your listings
- preferences relating to the kinds of dogs or products you are interested in
Information about pets is usually not personal information on its own but may become personal when reasonably linked with you.
4.5 Communications and support
- messages sent via the Doggo platform
- emails and other communications with us (including support requests, feedback, complaints and surveys)
- call notes and recordings where customer service calls are recorded (we will let you know if recording occurs)
4.6 Technical and usage data
- IP address, device identifiers, browser type and settings
- operating system, mobile network and device information
- pages visited, links clicked, time spent and referring URLs
- interactions with our emails and in-product notifications collected through cookies and similar technologies
4.7 Marketing and preference data
- your marketing preferences (email, SMS, push notifications)
- information about your interests and engagement with our content or offers
- participation in promotions, surveys or referral programs
4.8 Recruitment and contractor information
For job applicants, staff and contractors we may collect CVs, employment history, qualifications, referees, right-to-work information, background checks (where lawful and with consent), emergency contacts and other HR details. Where the employee records exemption applies, some information may be handled outside the APPs; however, we intend to treat employee and contractor data consistently with this Privacy Policy wherever practicable.
5. How we collect your personal information
We collect personal information in several ways.
5.1 Information you provide directly
You may provide personal information when you create or update an account, use the marketplace to list, buy or enquire about a dog or product, use our messaging tools, complete forms or surveys, contact us by email/phone/chat/social media, or apply to work with Doggo as a job applicant, advisor, contractor or partner.
5.2 Information collected automatically
When you use the Doggo Services we may automatically collect technical and usage data using cookies, pixels, SDKs and similar technologies implemented by us or by our service providers and partners.
5.3 Information from third parties
We may collect information about you from identity verification providers, payment and financial service providers, breeders, shelters, rescues or business partners you interact with through Doggo, analytics and advertising partners, referees, recruiters or background checking services, and public sources (e.g. ASIC or other registries). If we receive unsolicited information we will handle it in accordance with the Privacy Act.
6. Why we collect, use and disclose personal information
We only collect, use and disclose personal information that is reasonably necessary for our functions and activities, or as permitted by law. This includes:
6.1 Operating the Doggo marketplace and services
- creating, verifying and managing user accounts
- enabling buyers, breeders, rescues and partners to connect and transact
- creating, displaying and managing listings plus search and recommendation features
- facilitating communications between users (messages and enquiries)
6.2 Identity verification, trust and safety
- verifying identity and eligibility to use certain features
- confirming breeder, rescue or business credentials
- monitoring, detecting and preventing fraud, scams and misuse
- investigating complaints, disputes or incidents and enforcing our policies
6.3 Payments and financial operations
- facilitating payments, payouts, refunds and chargebacks
- maintaining accurate transaction and accounting records
- complying with taxation, anti-money laundering and other legal obligations
6.4 Customer support and service improvement
- responding to questions, feedback and complaints
- diagnosing and fixing technical issues
- analysing usage and performance to improve the Services
- developing new features, products and offerings
6.5 Direct marketing and personalisation
- sending marketing communications about Doggo and partner offers (where permitted)
- personalising content, recommendations and offers
- running promotions, referral programs, loyalty or rewards programs
You can opt out of direct marketing at any time (see section 9).
6.6 Legal, risk and compliance
- complying with applicable laws, regulations and guidance
- responding to lawful requests from regulators, law enforcement and courts
- managing actual or potential claims, disputes and proceedings
- maintaining records to demonstrate compliance with the Privacy Act
7. Automated decision-making and AI
We may use algorithms, scoring models and other automated tools (including AI and machine learning) to rank or recommend listings, detect suspected fraud, spam or suspicious activities, and tailor content or offers. As at the date of this policy we do not rely on automated decision-making alone to make decisions that have legal or similarly significant effects without a degree of human review. Contact us if you have concerns and we will review the decision where practicable.
8. Cookies, tracking technologies and analytics
We use cookies and similar technologies to:
- recognise you and your devices and keep you signed in
- remember preferences such as language or location
- understand how the Doggo Services are used and improve performance
- measure the effectiveness of marketing and advertising
- deliver more relevant ads and content on Doggo and third-party services
You can control cookies through your browser settings and, in some cases, through in-product controls or third-party opt-out tools. Disabling cookies may limit some functionality.
We may use your personal information to send direct marketing communications (email, SMS, push notifications and online advertising) in accordance with applicable laws. You can opt out at any time by clicking the unsubscribe link in an email, replying STOP to an SMS where available, or contacting us using the details in section 16.
Even if you opt out of marketing we may still send service and transactional messages such as account notifications, important updates, security alerts and responses to your enquiries.
10. Who we disclose your personal information to
10.1 Other Doggo users
When you interact through the marketplace (for example, enquiring about a listing or completing a transaction) we may share relevant contact and transaction information between buyers, breeders, rescues and partners to enable the transaction and any follow-up.
10.2 Service providers
We may disclose information to trusted third parties who help us operate, secure and improve the Doggo Services, such as hosting and cloud providers, payment processors, identity verification and fraud-prevention providers, analytics and monitoring services, email/SMS/push vendors, customer support platforms and professional advisers. These providers are only given the information necessary to perform their services and are contractually required to handle it in accordance with applicable privacy laws where practicable.
10.3 Business partners
We may share limited personal information with Doggo partners (for example, pet insurers, trainers, pet product brands or benefit providers) when you choose to access or redeem an offer or we reasonably believe sharing is necessary to fulfil the benefit. Partners are responsible for their own privacy practices.
10.4 Corporate transactions
If we are involved in a merger, acquisition, asset sale, restructuring or similar corporate transaction, your personal information may be disclosed to prospective or actual purchasers (and their professional advisers) subject to appropriate confidentiality safeguards.
10.5 Regulators, law enforcement and legal claims
We may disclose personal information where we reasonably believe it is required or authorised by law, including to regulators, law enforcement agencies, courts or tribunals, the Office of the Australian Information Commissioner (OAIC), or other parties where necessary to establish, exercise or defend legal claims or to protect the rights, property or safety of Doggo or others.
11. Overseas disclosure of personal information
We may disclose personal information to recipients located outside Australia, including in the United States, the United Kingdom, member states of the European Union, New Zealand and other countries in which our service providers maintain operations or infrastructure (for example, cloud hosting, analytics, email, customer support or identity verification providers).
When disclosing information overseas we take reasonable steps to ensure recipients do not breach applicable privacy principles, such as through contractual commitments and due diligence on security practices. However, overseas recipients may not be subject to Australian privacy laws and may not have equivalent protections. By using the Doggo Services and providing personal information you consent to this overseas disclosure where required by law.
12. Security of your personal information
We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. Measures include:
- secure data centres and cloud infrastructure
- encryption in transit and at rest where appropriate
- access controls, role-based permissions and multi-factor authentication
- regular security testing, monitoring and logging
- staff training on privacy and security
- incident response and data breach response procedures
No system can be guaranteed completely secure. If you suspect unauthorised access to your account or other security issues, please contact us immediately.
13. Data retention and destruction
We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy or as required by law (for example, taxation or financial record-keeping obligations). When information is no longer required and we are not legally required to retain it, we take reasonable steps to destroy or de-identify it, such as secure deletion of electronic records and shredding of physical records.
14. Access to and correction of your personal information
You have the right to request access to the personal information we hold about you and to request correction if it is inaccurate, out of date, incomplete, irrelevant or misleading.
14.1 How to request access or correction
You can usually access and update information via your account settings. If you cannot locate what you need, contact us using the details in section 16. We may need to verify your identity before providing access or making changes. In some cases we may charge a reasonable fee for providing access (for example, to cover retrieval or copying costs), but we will not charge you to make a request.
14.2 When we may refuse access or correction
There may be circumstances where we cannot provide access to some or all information, such as where:
- providing access would unreasonably impact the privacy of others
- the information is subject to legal professional privilege
- providing access would be unlawful or we are required by law to refuse
- the information relates to an existing or anticipated legal dispute and would not be discoverable in legal proceedings
If we refuse your request (in whole or in part) we will provide written reasons and explain how you can complain about the decision.
15. Notifiable data breaches
If we experience a data breach involving personal information we will assess and respond in accordance with the Notifiable Data Breaches scheme. Where we have reasonable grounds to believe an eligible data breach has occurred (one likely to result in serious harm and we are unable to prevent the risk through remedial action) we will:
- notify affected individuals and the OAIC as soon as practicable
- provide recommendations about steps individuals can take in response
16. Your privacy rights and complaints
Depending on where you are located you may have additional rights under other privacy regimes (for example, EU or UK data protection laws). If you believe such rights apply, please contact us and we will consider your request in accordance with applicable law.
16.1 How to contact us
Privacy Officer – Doggo Trading Pty Ltd
Level 2A, 120 Old Pittwater Road
Brookvale NSW 2100 Australia
Email: [email protected]
16.2 Complaints
If you believe we have breached any applicable privacy law, please contact us in writing with as much detail as possible. We will:
- acknowledge receipt of your complaint
- investigate and seek to resolve the complaint within a reasonable period (usually 30 days)
- inform you of the outcome of our investigation
If you are not satisfied with our response you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | 1300 363 992 (within Australia) | GPO Box 5218, Sydney NSW 2001. You may also seek independent legal advice regarding other remedies.
17. Children and young people
The Doggo Services are primarily designed for adults. We do not knowingly collect personal information from children under 18 without the involvement of a parent or guardian. If we become aware that information has been collected without appropriate consent, we will take reasonable steps to delete or de-identify it consistent with our legal obligations and regulatory guidance.
18. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, particularly to reflect changes to the law or our practices. The most current version will always be available on www.doggo.com.au and will be effective from the date it is posted. Where changes are material, we will take reasonable steps to notify you, such as by email, in-product notification or a prominent website notice.