We want you to know that your privacy is extremely important to us. Please review our privacy practices carefully. Here are a few highlights:

We do not share or sell any of your personal or aggregate information with anyone. You can you control who sees your location-based activity and content. Your position on the map is set to “Everyone” by default. Everything else is set to “Friends Only”. You can change your Privacy Controls inside the mobile application at any time. We only track your device location when you are using the app. We use cookies in order to improve our service. We retain your data for as long as we need it, unless you request deletion or delete your account.

Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our mobile application, services and website (collectively, the “Services”). Oldo is headquartered in Madeira Island, Portugal and our Services are provided to you by Oldo, Lda. This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services. Please also read our Terms of Service which sets out the terms governing the Services.

Information Oldo Collects

Oldo collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with Oldo. We receive information in a few different ways, including when you track, complete or upload activities using the Services. Oldo also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with Oldo. For example: Account, Profile, Activity, and Use Information We collect basic account information such as your name, email address and password that helps secure and provide you with access to our Services. Profile, activity and use information is collected about you when you choose to upload a picture, activity (including date, time and geo-location information) or otherwise use the Services. We use your contact information so we can respond to your support requests and comments. Location Information We collect and process location information when you sign up for and use the Services. We do not track your device location while you are not using Oldo, but in order to provide Oldo’s core Services, it is necessary for us to track your device location while you use Oldo. Content You Share We gather information from the photos, dog encounters, dog ratings, reviews, and other content you share on the Services. Contacts Information You can choose to add your contacts’ information by connecting your contacts from your mobile device or social networking accounts to Oldo. If you choose to share your contacts with Oldo, Oldo will, in accordance with your instructions, access and store your contacts’ information in order to identify connections and help you connect with them. Connected Devices and Apps Oldo collects information from devices and apps you connect to Oldo. For example, you may connect your Smart Phone or Smart Watch to Oldo and information from these devices will be passed along to Oldo. Third-Party Accounts Oldo allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Google or Facebook (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences. This information is collected by the Third-Party Account provider and is provided to Oldo under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account. Technical Information and Log Files We collect information from your mobile device, browser or computer, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. Learn more about how we use cookies and manage your preferences by visiting our Cookies Policy. The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to session IDs, dog owner IDs and device identifiers. Other Information We may collect information from you through third parties, such as when we collect your feedback through surveys. We may also collect information about you from other members such as when they give you dog ratings or comment on your activities.

Oldo uses the information we collect and receive as described below.

We use the information we collect and receive to provide the Services, including providing you with the ability to: Record your activities and rate your encounters: For example, to compare your past walks, analyze your dog encounters, and to provide you with interesting and useful dog interaction analysis. Interact with other dog owners: For example, to know where your friends are walking. Manage your dog training: For example, to improve our dog compatibility algorithm. Explore new places to go: For example, to discover new areas where you can walk your dog. Visualize your activities in new ways: For example, by creating dog heatmaps and hotspots. Subject to your Privacy Controls, your information, including parts of your profile, dog characteristics, photos, your past walks, the devices you use, and dog encounter ratings you give and receive will be shared on Oldo so that you may be able to participate in the Services, for example to show your place on a leaderboard. Your precise location information, such as where you walk, may also be shared on Oldo in accordance with your privacy controls. To customize your experience We use the information we collect about you, your friends, and your activities to customize your experience. For example, we may suggest walk routes or challenges that may interest you, dog owners that you may want to befriend, or new features that you may want to try. To protect you and the Services We use the information we collect to protect members, enforce our Terms of Service and Community Standards, and promote safety. For example, we find and remove content that violates our terms, such as hate speech or spam, as well as suspend or terminate accounts that share such content. To improve our Services We also use the information we collect to analyze, develop and improve the Services. To do this, Oldo may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services. To communicate with you We use the information we collect to provide support in response to your requests and comments. We may also use the information we collect to market and promote the Services, activities and events on Oldo, and other commercial products or services. This includes marketing and push communications, where you have not opted out of receiving such messages and notifications. Aggregate Information We do not sell your personal or aggregate information with anyone.

How Information is Shared

We share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below. Service Providers We may share your information with third parties who provide services to Oldo such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, so that we may promote Oldo. Publicly Available Information When you join the Oldo community and when you use Oldo services, your location appears on the map to everyone, yet your profile information is anonymized. By default, your profile information is viewable only by other Oldo members that you add as friends on the mobile application. We provide a variety of tools to control the sharing of your information and encourage our members to adjust their controls to align with their desired experience. Sharing Information and Activities As a social network, we share your information with other Oldo members in accordance with your privacy controls. You can change the visibility of the activities you upload to Oldo. Also, you can tell us about important locations, such as your home or work address, by enabling a Privacy Zone in your settings. We will make private any portion of your activity that starts or ends in your Privacy Zone. You can also share your activities with your contacts via text, email, or on social media applications like Facebook, Instagram, and Twitter. If you link your Oldo account to other social networks and share your activities, they will be viewable on such third-party platforms, including your location information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties. Third Party Business via API or Other Integrations We enable you to share your information and content with third party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with Oldo to offer an integrated feature. You can choose to share your profile data and activity data (including private activities). Information collected by these third parties is subject to their terms and policies. Oldo is not responsible for the terms or policies of third parties. Affiliates and Acquirers of our Business or Assets We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Oldo becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction. Legal Requirements We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of Oldo or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

How We Protect Information

We take several measures to safeguard the collection, transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Oldo engages providers that are industry leaders in online security, including Services verification, to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm Oldo’s identity before any personal information is sent. In addition, Oldo’s secure servers protect this information using advanced firewall technology. Managing Your Settings Privacy Controls Oldo offers several features and settings to help you manage your privacy and share your activities. All privacy controls are located in your privacy controls page. Oldo provides you the option to make your activities private. Adjust Notification and Email Preferences Oldo offers various ways to manage the notifications you receive. You can choose to stop receiving certain notifications by indicating your preference here. You may also unsubscribe from receiving emails from us by following the instructions contained at the bottom of marketing or promotional emails. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or our Terms of Service, etc.) generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested. Updating Account Information You may correct, amend or update profile or account information at any time by adjusting that information in your account settings. If you need further assistance correcting inaccurate information, please email Oldo at [email protected]. Deleting Information and Accounts and Downloading Your Data You can delete your account or download your data using our self-service tools. Three months after you make a deletion request, we permanently and irreversibly delete your personal data from our systems, including backups. Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated. Following your deletion of your account, it may take up to 90 days to delete your personal information and system logs from our systems. Additionally, we may retain information where deletion requests are made to comply with the law and take other actions permitted by law. Note that content you have shared with others, such as photos, or that others have copied may also remain visible after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache. Oldo also provides you the option to remove individual activities you have posted without deleting your account. Once removed, the activities may remain on Oldo’s systems until you delete your account. Your Rights and Our Legal Bases We provide the same suite of privacy tools and controls to all of our members worldwide. Our Legal Bases Oldo relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including: As necessary to provide the Services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide the Services unless we collect and use your location information; Where you have consented to the processing; Where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims; To protect your vital interests, or those of others, such as in the case of emergencies; Where necessary for the purposes of Oldo’s or a third party’s legitimate interests, such as our interests in protecting our members, our partners’ interests in collaborating with our members, and our commercial interests in ensuring the sustainability of the Services. Retention of Information We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account. For example, after you withdraw your consent to Oldo processing your health-related information, Oldo will delete all health-related information you upload. Following your deletion of your account, it may take up to 90 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy. Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Oldo, such as statistics of the use of the Services. For example, we may retain publicly available segments or routes and other depersonalized geolocation information to continue to improve the Services. This information will be de-associated with your name and other identifiers. Modification of the Privacy Policy Oldo reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Oldo makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account. Support and Questions

We will respond to any questions regarding the Services and these Terms via email at: [email protected]