πŸ‡ΉπŸ‡· TR πŸ‡¬πŸ‡§ EN

Petlifly β€” Privacy Policy

Last Updated: November 11, 2025
Owner/Publisher: ToughWing
Contact: support@toughwing.app

This Privacy Policy ("Policy") applies to the Petlifly application for mobile devices (iOS and Android) created by ToughWing. This Policy describes how we collect, use, disclose, and handle your information when you use our Application.

1. Information We Collect

1.1 Information You Provide Directly

When you use the Application, we collect the following information that you provide:

  • Pet information (pet name, pet type: dog/cat, pet characteristics/personality notes)
  • Pet photographs (for health and behavior analysis)
  • Language preference (selected interface language)
  • Avatar selection (for profile customization)
  • Voice recordings (when using Animal Translator feature)
  • Payment information (processed securely through RevenueCat and app store providers)
  • Feedback and support requests (when contacting us)

1.2 Automatically Collected Information

We automatically collect certain information about your device and usage patterns:

  • Device identifiers (Device ID, advertising ID)
  • Device type and operating system (iOS/Android version)
  • Internet Protocol address (IP address)
  • Application usage analytics (features used, time spent, navigation patterns)
  • Device specifications (screen resolution, mobile network carrier)
  • Crash logs and error reports

1.3 Location Information

The Application does not collect precise geolocation data unless explicitly granted permission. If you enable location permissions, we may collect approximate location data to provide location-based features. Location data is anonymized and used only with your explicit consent.

1.4 Permission Requests

The Application requires the following device permissions:

  • Camera & Photo Library: To capture or upload pet photographs for analysis
  • Microphone & Audio Recording: To record animal sounds for translation through the Animal Translator feature
  • Internet Access: To communicate with our servers and AI services

2. How We Use Your Information

We use the collected information for the following purposes:

  • Pet Analysis Service: To process pet photographs through FAL AI and Google Gemini to provide health assessments and behavior analysis
  • Animal Translator Service: To analyze animal sounds and provide translations and behavioral insights
  • Account Management: To maintain your account, track credits, and manage subscriptions through RevenueCat
  • Service Improvement: To improve our AI models, features, and user experience
  • Payment Processing: To process in-app purchases and subscription transactions
  • Customer Support: To respond to your inquiries and technical support requests
  • Security & Fraud Prevention: To detect and prevent fraudulent credit usage

3. Third-Party Services and Data Sharing

3.1 Third-Party Service Providers

We utilize the following third-party services that may collect and process your data:

  • Google Firebase/Firestore - For storing and retrieving your account data, pet information, and analysis history
  • RevenueCat - For managing subscriptions and in-app purchases
  • FAL AI - For AI-powered pet image analysis
  • Google Gemini AI - For natural language processing and recommendations
  • Apple App Store & Google Play Store - For payment processing

3.2 Data Sharing Practices

We will only share your information with third parties in the following circumstances:

  • With your explicit consent or authorization
  • To comply with legal obligations
  • To protect our rights or the safety of others
  • To investigate or prevent fraud and security issues
  • With service providers who process data on our behalf
  • In case of merger, acquisition, or sale of assets

4. Data Retention

We retain your personal data for as long as necessary to provide our services. Specifically:

  • Account & Pet Data: Retained while your account is active and accessible
  • Analysis History: Stored in your account for historical reference
  • Credit & Subscription Information: Retained for active subscription period and 90 days after cancellation
  • Transaction Data: Retained for 7 years for tax compliance
  • Pet Photographs: Processed temporarily for analysis but not stored unless you save the analysis

If you wish to delete your personal data and account, please contact us at support@toughwing.app. We will delete your data within 30 days.

5. Cookies and Similar Technologies

Our Application uses cookies, device identifiers, and similar tracking technologies to enhance your experience and gather analytics:

5.1 Types of Cookies and Identifiers

  • Device ID and Advertising ID: Used for user identification, analytics, and personalization without requiring username/password login
  • Analytics Cookies: Google Analytics and Firebase Analytics collect information about how you use the Application (features accessed, session duration, crash reports)
  • SDK Tracking: Third-party SDKs (RevenueCat, FAL AI) may use device identifiers for subscription management and AI analysis tracking
  • Functional Cookies: Store your language preference, avatar selection, and account customization

5.2 Purposes of Cookies and Identifiers

  • User identification and session management
  • Application performance monitoring and crash reporting
  • Feature usage analytics and product improvement
  • Subscription and payment processing tracking
  • Personalization of user interface (language, avatar, theme)

5.3 Cookie Management and Opt-Out

  • Device Settings: You can disable advertising ID tracking through your device settings (iOS: Settings β†’ Privacy β†’ Tracking; Android: Settings β†’ Google β†’ Manage your Google Account β†’ Data & Privacy)
  • Analytics Opt-Out: You can opt out of analytics collection by disabling Firebase Analytics in Application settings
  • Cookie Control: While we cannot disable essential device ID functionality (required for Application operation), you can limit non-essential tracking through device privacy settings

5.4 Do Not Track (DNT) and Global Privacy Control (GPC)

The Application does not respond to Do Not Track (DNT) or Global Privacy Control (GPC) signals, as mobile applications operate differently from web browsers. However, you can achieve similar effects through device-level privacy settings and opt-out options listed above.

6. Your Privacy Rights and Controls

6.1 Opt-Out Options

  • Delete Account: You can delete your account and all associated data through your account settings
  • Uninstall: You can stop all data collection by uninstalling the Application
  • Privacy Preferences: Modify your language, avatar, and privacy settings within the Application
  • Camera & Microphone Permissions: Disable these permissions through your device settings

6.2 Data Subject Rights

Depending on your location, you may have rights to:

  • Access: Request a copy of your personal data
  • Deletion: Request deletion of your personal data
  • Portability: Request your data in a structured, machine-readable format
  • Correction: Request corrections to inaccurate information

To exercise any of these rights, please contact us at support@toughwing.app.

7. Security and Data Breach Notification

We implement security measures to protect your personal data:

  • Encryption of data in transit using HTTPS/TLS protocols
  • Device ID-based identification (no username/password required)
  • Firebase Firestore security rules to restrict unauthorized access
  • Secure API connections to FAL AI and Google Gemini services
  • RevenueCat's PCI-DSS compliant payment processing

6.1 Data Breach Notification

In the event of a data breach or unauthorized access to your personal information, we will:

  • Notify affected users without undue delay (within 72 hours in accordance with GDPR)
  • Provide a clear description of the breach, affected data types, and potential impacts
  • Recommend protective measures (password changes, account monitoring, etc.)
  • Offer free security monitoring where applicable
  • Preserve and provide evidence of the breach notification to data protection authorities

We will also comply with applicable data protection laws regarding breach notification to relevant authorities and regulatory bodies.

8. GDPR and KVKK Compliance

For users in the European Union and Turkey, we comply with the following data protection regulations:

7.1 General Data Protection Regulation (GDPR)

For users in EU member states, we comply with GDPR requirements:

  • Lawful Basis: We process your data based on your consent (account creation) and our legitimate interests (service improvement)
  • Data Subject Rights: You have the right to access, rectify, erase, restrict processing, data portability, and object to processing
  • Automated Decision Making: You have rights regarding automated decision-making and profiling; our AI recommendations include confidence scores for transparency
  • Data Protection Officer: Contact support@toughwing.app for any GDPR-related inquiries

7.2 Turkish Data Protection Law (KVKK)

For users in Turkey, we comply with Law No. 6698 on Personal Data Protection (KVKK):

  • Data Processing Purpose: We process personal data only for specified, explicit, and legitimate purposes
  • Processing Conditions: Processing is conducted only with explicit consent or as required by law
  • User Rights: You have the right to access, modify, delete, and restrict processing of your personal data
  • Data Authority Contact: Inquiries to Turkish Data Protection Authority (Kişisel Verileri Koruma Kurumu) can be made through www.kvk.gov.tr

9. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Union and Turkey:

  • Locations: Data may be transferred to the United States (Google Firebase, FAL AI, Google Gemini) for processing and storage
  • Legal Safeguards: We rely on Standard Contractual Clauses (SCCs) and other appropriate safeguards to ensure adequate protection
  • Adequacy Decisions: Where applicable, we rely on EU Adequacy Decisions or Supplementary Measures
  • Your Consent: By using the Application, you consent to the transfer of your data to countries outside the EU/EEA for processing

10. Enhanced Children's Privacy

The Application is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided personal information, we will immediately delete such information.

9.1 COPPA Compliance (Children's Online Privacy Protection Act)

We comply with COPPA requirements for U.S.-based users:

  • We do not collect personal information from children under 13 without verifiable parental consent
  • We do not condition a child's participation on the disclosure of more personal information than is reasonably necessary
  • We maintain procedures to protect children's privacy and the confidentiality of parental information
  • Parents may request access to, review, and request deletion of their child's personal information

9.2 Parental Rights and Controls

Parents and guardians have the following rights:

  • Right to Review: Parents may request a copy of all personal information we hold about their child
  • Right to Delete: Parents may request deletion of their child's account and associated data
  • Right to Opt-Out: Parents may prevent further collection or use of their child's information
  • Right to Request Consent: Parents may consent to collection and use of information without consenting to disclosure to third parties
  • Contact for Parental Requests: Email support@toughwing.app with proof of guardianship for parental requests

9.3 Age-Restricted Features

Certain features within the Application may have age restrictions:

  • Premium subscription purchases require age verification (13+ in most regions)
  • Animal Translator feature with voice recording may require additional parental consent
  • Pet data collection is limited for users under 13

11. AI and Automated Decision Making

The Application uses artificial intelligence to provide pet health analysis and recommendations:

  • Pet Photo Analysis: FAL AI and Google Gemini analyze pet photographs to provide health assessments and behavior insights
  • Animal Sound Translation: AI models translate animal vocalizations into human-readable emotions and behavioral advice
  • Confidence Scores: All AI analyses include confidence scores to indicate reliability
Important Note: AI-generated recommendations are informational only and should not replace professional veterinary advice. Always consult a licensed veterinarian for serious health concerns.

12. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices. When we make material changes, we will notify you via email and update the "Last Updated" date. Your continued use of the Application following notification of changes constitutes your acceptance of the updated Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us: