Last updated January 26, 2025

This Privacy Policy for Pug Sports Ltd (‘we’, ‘us’, or ‘our’) describes how and why we might access, collect, store, use and share (collectively, ‘process’) your personal information when you use our services, including when you:

• Download and use our mobile application (‘Pug’), or any other application of ours that links to this Privacy Policy

• Use Pug, our mobile platform and website enabling users to host and play pick-up sports

• Engage with us in other related ways, including any sales, marketing, promotional events, or direct communications

Questions or concerns? This Privacy Policy will help you to understand your privacy rights and elections. We are responsible for making decisions about how your personal information is processed. If you do not consent to our policies, please do not use our services. Please contact us at founders@pugsports.co if you have questions or concerns.

What information do we collect?

We collect personal information that you voluntarily provide to us when you register with Pug, register your interest in our products and services, participate in activities on Pug, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and Pug, the choices you make, and the product features that you use. Personal information that we collect may include: names, phone numbers, email addresses, usernames, passwords, contact preferences, and contact or authentication data.

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payments if you choose to make purchases, such as your payment instrument number, security code, and address associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy policy link here: https://stripe.com/gb/privacy.

Social Media login data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media accounts. If you choose to register in this way, we will collect certain information about you from the social media provider.

Application data. If you use Pug, we may also collect the following information, provided that you choose to permit access:

• Geolocation information. We may request access or permission to your location information from your mobile device, either continuously or while using Pug, to provide location-based services. If you wish to change our access, you may do so in your device’s settings.

• Mobile device access. We may request access to certain features on your mobile device, including your mobile device calendar, camera, contacts, and other features. If you wish to change our access, you may do so in your device’s settings.

• Mobile device data. We automatically collect device information, operating system, version information and system configuration information, device and application identification numbers, browser type, version, hardware model and mobile carrier, alongside your IP address or proxy server.

• Push notifications. We may request to send you push notifications about your account or features on Pug. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

The foregoing information is needed to maintain the security and operation of Pug, for troubleshooting, and internal analytics and reporting purposes. All personal information that you provide to us must be true, complete and accurate and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate Pug. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device details, operating system, language preferences, country location, and information about how and when you use our services. This information is needed to maintain the security and operation of Pug, and for internal analytics and reporting. Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and usage data. Log and usage data is service-related, diagnostic, usage and performance information our services automatically collect when you access or use Pug and which we record in log files.

• Device data. We collect device data such as information about your computer, phone, tablet, or other device used to access Pug. Depending on the device, this data may include your IP address or proxy server, device and application identification numbers, location, browser type, model, internet service provider or mobile carrier, operating system and system configuration information.

• Location data. We collect location data which varies from precise to imprecise and depends on the type and settings of your device used to access Pug. We may use GPS and other technologies to collect geolocation data that tells us your current location based on IP address. You can opt out of allowing us to collect this information either by refusing access or disabling Location setting on your device. By choosing to opt out, you may not be able to use certain aspects of the Services.

• Google API. Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with Pug, including:

• To facilitate account creation and authentication and otherwise manage user accounts.

• To deliver and facilitate delivery of services to the user.

• To respond to user inquiries and offer support to users.

• To send administrative information to you.

• To enable user-to-user communications.

What legal bases do we rely on to process your information?

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of Contract. We may process your personal information when we believe it necessary to fulfil our obligations to you, including providing our services.

• Legal Obligations. We may process your information when we believe it is necessary for compliance with our legal obligations, such as to cooperate with law enforcement or regulatory agencies, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or those of a third party, such as in situations involving potential threats to safety.

Pug is a data controller, under EU data protection laws, of the personal information described in this Privacy Policy, since we determine the means and purposes of the data processing we perform.

Visit the Information Commissioner’s Office to find out more about the types of lawful basis that we will rely on to process your personal data.

When and with whom do we share your personal information?

Vendors, consultants and other third-party service providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require this information to operate. The category of third parties that we may share personal information with are as follows: Payment processors, user account registration and authentication services, data storage service providers, data analytics services, cloud computing services, product engineering tools, performance monitoring tools, sales and marketing tools, social networks, testing tools, and website hosting service providers.

We may also share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.

• Google Maps Platform APIs. We may share your information with certain APIs, including Google Maps, which uses GPS, Wi-Fi and cell towers to estimate your location. This data helps Google Maps to provide directions, but is not always perfectly precise, and will be used to enable certain location functions accessed via Pug.

• Other users. Sharing your personal information or interacting with public areas of Pug will enable your information to be viewed by other users and may be publicly available on Pug. If you interact with other users on Pug and register for Pug through a social network, your contacts on the social network may be able to see your name, profile, and activity history with your consent. Similarly, other users will be able to view activity, communicate with you, and view your profile, with your consent.

Do we use cookies and other tracking technologies?

We may use cookies and other similar technology to gather information when you interact with Pug. Some online technologies help us maintain the security of our services and your account, prevent crashes, fix bugs and save your preferences to assist with basic site functions.

We may also permit third-parties and service providers to use tracking technologies on Pug for analytics and advertising.

Google Analytics

We may share your information with Google Analytics to track use of Pug. To opt out, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit Google’s Privacy and Terms page.

How do we handle your social logins?

Pug offers the ability to register and log in with third-party social media accounts. When you opt to do this, we will receive certain profile information about you from your social media provider, which may vary by social media provider chosen. This information will often include your name, email address, contact list, and profile picture.

We will use this information only for purposes described in this Privacy Policy or otherwise made clear to you on Pug. Please note that we do not control, nor are we responsible for, other uses of your personal information by your third-party social media provider.

How long do we keep your information?

We only keep information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. No purpose in this notice will require us to keep your personal information for longer than the period of time in which you maintain an account with us.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymise such information, and where impossible, will securely store your personal information and isolate it from further processing until deletion is possible.

How do we keep your information safe?

We have appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. We do not warrant that these measures are 100% secure, and cannot guarantee unauthorised third-parties will not be able to defeat our security measures. We will do our best to protect your personal information, but maintain that transmission or personal information to use Pug is at the user’s own risk. You should only access Pug within a secure environment.

What are your privacy rights?

In regions like the EEA, UK, and Switzerland, you have certain limited and absolute rights including (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information and (iv) not to be subject to automated decision-making. We will consider and act upon any privacy rights request in accordance with the applicable data protection laws.

Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided. Withdrawal of consent will not affect the lawfulness of the processing prior to withdrawal, not will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are located in the EEA or UK, and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

Marketing and promotional opt-out

You may unsubscribe from our marketing and promotional communications at any time by licking on the unsubscribe link in the emails that we sent, or by contacting us using the details provided at the bottom of this Policy. You will be removed from marketing lists but we may still communicate with you for service-related messages necessary for the administration and use of your account.

Account information

If you would like to review or change the information in your account or terminate your account, you can do so from your account settings within Pug and from your device settings. Upon a request to terminate your account, we will deactivate or delete your account and personal information within our active databases. We may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigation, enforce our legal terms and comply with applicable legal requirements.

Do we make updates to this policy?

Yes. We may update this Privacy Policy from time to time, automatically indicated with the date of the Privacy Policy. Material changes may be notified either by prominent posting or direct notification.

How can you contact us about this policy?

If you have questions about our policies, please contact our Data Protection Officer (DPO) by email at founders@pugsports.co, or contract us by post at:

Pug Sports Ltd

Data Protection Officer

27 Kensington Church Street

London W8 4LL

United Kingdom