Privacy Policy

1. Who we are

Data protection officer: Given the size and activities of our business, we are not required to appoint a data protection officer under § 38 BDSG. Please send privacy requests directly to the contact address above.

Cogswell IT is based in Germany. For users in the European Union we act under the General Data Protection Regulation (GDPR). For users in the United States and Canada, see section 15 for your rights under the CCPA/CPRA and PIPEDA.

2. Principles

• Local first. Everything you enter in the app is stored on your device. Without a server account, data only leaves your iPhone when you share it yourself (backup export, PDF by email).
• No ads, no tracking. Neither the app nor this website contains advertising, analytics or tracking SDKs, third-party cookies or fingerprinting.
• Data minimisation. External services only receive what the respective feature needs (sections 6 to 10).

3. Your role as an app user

With Dog Walkers you manage personal data of your own clients (dog owners): contact details, addresses, information about dogs including health data, contracts, invoices and keys. For this data you are the controller (or, under Canadian and US law, the business responsible for it). Cogswell IT processes it only if you use a server account – and then solely on your behalf as a processor / service provider. A data processing agreement is available on request from [email protected].

4. Data in the app (local storage)

The app stores the following categories locally on your device, inside the protected app container encrypted by iOS:

• Business data: business name, address, contact details, tax and bank details for invoices, prices and packages.
• Client data: name, address, phone, email, emergency contacts, intake form, care contract and its schedule, signatures, key status.
• Dog data: name, breed, date of birth, health, medication, vaccinations, behaviour, photos.
• Appointments and walks: times, dogs, notes, reports, recorded routes, photos.
• Boarding: bookings, check-in/out, daily reports, incidents.
• Invoices, reminders, e-invoice files, mileage log, inquiries, staff and vehicle data (depending on plan).
• Settings and an app log (technical events without client data).

Backups. Under “Data & backup” you can export a JSON file. Where you store it (iCloud Drive, Files, email) is up to you. If iCloud Backup is enabled, iOS also backs up the app container to your iCloud; Apple's privacy policy applies.

Face ID / Touch ID. The optional app lock uses the biometric check built into iOS. Biometric data never leaves the device and is not accessible to us.

Deletion. You can delete data at any time in the app, or completely by uninstalling the app.

5. Optional server account and client portal

For the client portal, synchronisation across devices and sending email from the app, you can create a server account at dogwalks.cogswell-it.com. This is voluntary; without an account all local features keep working.

5.1 Data processed

• Account data: email address, password (stored only as a hash), business name, registration time, subscription status.
• Synchronised business data: clients, dogs, appointments/walks, invoices, bookings, contracts and signatures – to the extent you synchronise them.
• Portal data entered by your clients: information dog owners submit via token-based links (intake form, package booking, contract signature, walk ratings).
• Technical data: IP address, time and type of request in server logs (deleted after 14 days at the latest), an installation identifier used for synchronisation.

5.2 Purpose and legal basis

Providing the server account and client portal (Art. 6(1)(b) GDPR – performance of a contract); security and abuse prevention (Art. 6(1)(f) GDPR). For your clients' data we act as your processor (section 3).

5.3 Hosting

The server is operated in a data centre in the EU; the database is provided by Supabase (Supabase, Inc.) in an EU region. Data processing agreements under Art. 28 GDPR are in place with both providers. Data from users in the US and Canada is therefore stored and processed in Germany/the EU.

5.4 Portal links for dog owners

Dog owners receive links by email containing a random access token. Opening a link displays the data the dog walker has stored and submits the data they enter to the server. The portal uses only strictly necessary cookies/storage (session, form draft) and no analytics cookies.

5.5 Retention and deletion

Account data is kept as long as the account exists. You can delete your account in the app (“More → Server account”) or by email to [email protected]; all server-side data is then deleted within 30 days unless statutory retention duties apply. Invoice records are subject to the commercial and tax retention periods that apply to you as a business; you keep those yourself.

6. Location data and live walks

The app only requests location permission (“While using the app”) when you start a live walk or display the weather for your location.

• Live walk. While a live walk is running, the app records your route. If you send the “live link” to the owners, current positions are relayed via the server to that link so the owners can follow the walk. “Finish & save” immediately invalidates the link and stops the transfer. The route is saved locally in the walk report (and synchronised if you have a server account).
• Without a live link the route stays exclusively on your device.
• There is no background location tracking outside a live walk.

Legal basis: your consent via the iOS permission (Art. 6(1)(a) GDPR), revocable at any time in iOS Settings.

7. Weather data (Open-Meteo)

For the weather on the “Today” tab, the app fetches forecast data from Open-Meteo (Open-Meteo GmbH, Switzerland, open-meteo.com). The (rounded) coordinates of your location and, technically, your IP address are transmitted to Open-Meteo. No accounts, names or identifiers are sent. Open-Meteo is an open-source service without ad tracking; see open-meteo.com/en/terms. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a useful weather display) together with your location permission. The weather display can be turned off in Settings.

8. Photos, camera and QR scanner

Photos you add to dogs, walks or reports are stored only on your device. The app accesses the camera or photo library only with your permission. The QR scanner processes images locally on the device; no images are transmitted to us. If you include photos in PDF reports that you send, you choose the recipient.

9. In-app purchases (Apple StoreKit)

Subscriptions are purchased and billed through Apple's App Store. We do not receive any payment details. Apple only provides us with an anonymised transaction identifier and the subscription status so we can unlock the features you bought; if you have a server account, this status is also sent to our server via Apple server notifications. Apple's privacy policy applies to payment. Legal basis: Art. 6(1)(b) GDPR.

10. Transactional email (Resend)

Invitations, intake-form links, package links, contract links, live-walk links and support requests that you send through the server are delivered via Resend (Resend, Inc., 2261 Market Street, San Francisco, CA 94114, USA). Recipient address, sender details, subject, message content and delivery status are transmitted. Resend acts as our processor; transfers from the EU to the US are based on the EU Standard Contractual Clauses. Without a server account the app opens your Mail app instead, and nothing is sent to Resend.

11. Notifications, widgets, Live Activity and Siri

Walk, arrival and departure reminders are local notifications scheduled by the app on your device. No push tokens are transmitted to us. Widgets, the Live Activity on the lock screen and in the Dynamic Island, and the Siri shortcuts read their data locally from the app on your device; no data is sent to us for them.

11a. AI walk report (Apple Intelligence)

The app can draft the text of walk reports with the Apple Intelligence language model directly on your iPhone (Apple Foundation Models). Your keywords, dog names and walk data do not leave your device for this and are not sent to us or to any other AI provider. Whether and how Apple Intelligence is available on your device is governed by Apple; Apple's privacy policy applies. You review and send the report yourself.

11b. Route planning (Apple Maps)

When you let the app optimise the order of a pick-up and drop-off tour, it calculates travel times between the stops using Apple's map service (MapKit). The coordinates or addresses of the stops are sent to Apple, but not names or other client data. Legal basis: Art. 6(1)(f) GDPR (our interest in efficient route planning). Apple's privacy policy applies.

11c. Online invoice payment (Stripe)

You can optionally connect your own Stripe account to Dog Walkers (Stripe Connect) and send your clients a payment link for an invoice. Payment takes place on Stripe's checkout page (Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland). Your clients enter payment details such as card number or IBAN directly with Stripe; we never receive them. Our server only sends Stripe the invoice number, amount, currency and, if available, the client's email address, and receives the payment confirmation from Stripe. The money goes straight to your Stripe account.

Stripe processes payment data as an independent controller, in particular for payment processing, fraud prevention and regulatory compliance. Data may be transferred to Stripe, Inc. in the USA; Stripe, Inc. is certified under the EU-US Data Privacy Framework, and EU Standard Contractual Clauses apply in addition. Legal bases: Art. 6(1)(b) GDPR (payment processing) and Art. 6(1)(f) GDPR (fraud prevention). Stripe's privacy policy: stripe.com/privacy.

12. Support

If you contact us via the support form or email, we process your details to handle the request (Art. 6(1)(b) or (f) GDPR). The optional diagnostics report contains technical information only (app version, iOS version, device type, record counts, app log) – no client data. Support requests are deleted once resolved, at the latest after 12 months.

13. This website

Hosting. This website is static and is delivered via Cloudflare Pages by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. When you visit it, Cloudflare processes technically necessary access data (IP address, time, page requested, browser identifier) to deliver the pages, fend off attacks and keep the site running. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure and stable operation of the website. A data processing agreement is in place with Cloudflare. Cloudflare is certified under the EU-US Data Privacy Framework, and EU Standard Contractual Clauses apply in addition. Privacy policy: cloudflare.com/privacypolicy.

No cookies, no analytics, no advertising. The website sets no cookies. We use no web analytics (such as Google Analytics), no conversion tracking and no remarketing, and no usage profiles are created. Consent under § 25(1) of the German TDDDG is therefore not required, so instead of a consent banner we only show a notice. When you close it, we store the entry dw-privacy-notice in your browser's local storage so it doesn't reappear on every page. The entry contains no personal data, is never sent to us and stays until you clear it in your browser. Legal basis: § 25(2) no. 2 TDDDG (strictly necessary for a service you requested). You can reopen the notice at any time via “Cookie notice” in the footer.

Self-hosted fonts. The fonts used (Be Vietnam Pro, Old Standard TT) are served from our own web space. No connection is made to Google Fonts or any other font provider, and no third-party scripts are loaded.

Support form. When you submit the form on the support page, your details (name, email, topic, message) are sent to our server and forwarded by email to our support inbox (see sections 10 and 12). If the server cannot be reached, your email app opens instead.

Links. Links to the App Store lead to Apple, where Apple's privacy notices apply.

14. Recipients and international transfers

Recipients of personal data are only the service providers named in this policy (hosting, Supabase, Resend, Open-Meteo, Apple, Cloudflare and – if you use online payment – Stripe). Transfers outside the EU, in particular to the USA, may take place to Resend, Apple, Cloudflare and Stripe – each based on an adequacy decision (EU-US Data Privacy Framework, Art. 45 GDPR) or appropriate safeguards under Art. 46 GDPR (EU Standard Contractual Clauses). We do not sell personal data and do not share it for advertising. If you are in the US or Canada, your data is transferred to and processed in Germany/the EU, where it is protected by the GDPR.

15. Your rights

Everyone. You can ask us for access to your personal data, correction, deletion, restriction of processing, data portability and object to processing. You can withdraw any consent at any time with future effect. An informal email to [email protected] is enough; we respond within 30 days (under the GDPR within one month, extendable by two further months). We may ask for suitable proof of identity.

European Union / EEA (GDPR). In addition, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your residence or at our seat. The authority responsible for us is the Hessian Commissioner for Data Protection and Freedom of Information (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit), Postfach 3163, 65021 Wiesbaden, Germany, phone +49 611 1408-0, [email protected], datenschutz.hessen.de.

California (CCPA/CPRA). California residents have the right to know what personal information we collect and how we use it, to request deletion and correction, to opt out of the sale or sharing of personal information, and not to be discriminated against for exercising these rights. We do not sell or share personal information as defined by the CCPA and do not use sensitive personal information for purposes other than providing the service. Exercise your rights via the contact above; you may authorise an agent to act for you.

Canada (PIPEDA and provincial laws). Canadian residents may request access to and correction of the personal information we hold about them, withdraw consent subject to legal or contractual restrictions, and complain to the Office of the Privacy Commissioner of Canada. Your data is stored in the EU and may be subject to the laws of that jurisdiction.

Dog owners who are clients of a dog walker and wish to exercise their rights should first contact their dog walker, who is responsible for that data; we will support them.

16. Security

Connections between app, portal and server are encrypted with TLS. Passwords are stored hashed; portal links are protected by random, time-limited tokens. On the device the app relies on iOS data encryption and, optionally, the Face ID lock.

17. Children

The app is a business tool and not directed at children under 16. We do not knowingly collect personal data from children.

18. Changes

We update this policy when the app or the law changes. The current version is always available at this address and in the app under “More → Privacy”.