🐾 PawLevel — Privacy Policy

Last updated: 25 June 2026

Who we are. PawLevel ("the app", "we", "us") is operated by Twisty Works & Services (Australia; ABN to be confirmed). Contact: twistyworksandservices@gmail.com. This policy explains what we collect, why, who we share it with, and your rights. It is written to meet the EU/UK GDPR, the California CCPA/CPRA, and the Australian Privacy Act (APPs), so it applies wherever you are.

1. The data we handle

Information you give us

Your dog's profile: name, breed, age, and any photo you upload.
Your training activity: completed skills, streaks, session history, potty/crate logs, and settings.

Where it's stored

On your device by default. If you do nothing, all of the above stays in your browser's local storage and is not sent to us.
On our servers if you turn on Cloud Sync (optional). To sync across your devices and people you invite, your profile and training data are stored in our database. Hosting is provided by Vercel (application) and Neon (database, hosted in the Sydney, Australia region) acting as our processors.

Information collected automatically

We do not run analytics or tracking in the app today. Our hosting providers may keep standard technical logs (e.g., IP address, timestamp) for security and reliability.
Demo videos are embedded from YouTube using its privacy-enhanced ("no-cookie") mode and only load when you choose to play one. At that point Google/YouTube may process data under Google's Privacy Policy.

Planned features (not active yet)

Advertising. A future free version may show ads. Ad partners can collect data for measurement/personalised ads. Before we enable ads we will add a consent mechanism and update this policy.
Payments. If we add paid features, a payment processor (e.g., Stripe) will handle billing. We will not store your full card details.

2. Why we use it & our lawful bases (GDPR)

Purpose	Lawful basis
Run the app and save your progress on your device	Performance of our service to you / legitimate interests
Cloud Sync and co-owner sharing	Your consent (you switch it on)
Security, abuse prevention, reliability	Legitimate interests
Future ads / payments	Consent (ads) / contract (payments) — when introduced

We do not sell your personal information, and we do not use it for automated decisions that produce legal effects.

3. The "household key" sharing model

When you turn on Cloud Sync, we create a long, random household key. Anyone you share your invite link with can read and update that shared training data — that's how co-owners (a partner, child or housemate) train the same dog together. Treat the link like a shared document link: only send it to people you trust. You can remove the shared copy at any time (see Your rights below).

4. Who we share data with

Hosting/processors: Vercel and Neon, who store and serve data on our behalf under their terms.
People you invite via your household key.
YouTube/Google when you play an embedded demo video.
Future: advertising and payment providers, only once those features launch and with appropriate notice/consent.
Legal: if required by law or to protect rights and safety.

5. International transfers

Our database is hosted in Australia. If you use the app from outside Australia, your data is transferred to and stored there. Where required, we rely on appropriate safeguards (such as standard contractual clauses) for international transfers.

6. How long we keep it

Data on your device stays until you clear it or use "Reset all progress". Cloud-synced data is kept until you delete it (Settings → Delete my cloud data) or it becomes inactive. You can erase your device data and your cloud data independently at any time.

7. Your rights

Depending on where you live, you may have the right to access, correct, delete, export/port, object to or restrict our use of your data, and to withdraw consent. Most of this you can do yourself in the app:

Access / export: your data is visible in the app and stored as plain JSON.
Correct: edit your dog's details in Settings.
Delete: "Reset all progress" (device) and "Delete my cloud data" (servers).
Withdraw consent: turn Cloud Sync off.

You can also email us to exercise any right. California residents have the right to know and delete, and to opt out of "sale"/"sharing" — we do not sell or share for cross-context behavioural advertising today. You may also complain to your data authority (e.g., the OAIC in Australia, or your local EU/UK supervisory authority).

8. Children

PawLevel is a general-audience app and is not directed at children under 16. A parent or guardian may set it up for family use, but we do not knowingly collect personal information from children. If you believe a child has provided data, contact us and we'll remove it.

9. Security

We use reasonable technical measures (encrypted connections, reputable hosting). No method is 100% secure. The household key is a capability secret — keep your invite link private.

10. Cookies & local storage

We use your browser's local storage to run the app (essential, not tracking). We do not set advertising or analytics cookies today. YouTube may set cookies if you play a video. If we add ads, we will request consent for any non-essential cookies first.

11. Changes

We'll update this page and the "last updated" date when things change. Significant changes (like enabling ads) will be highlighted in the app.

12. Contact

Twisty Works & Services — twistyworksandservices@gmail.com.

PawLevel provides general positive-reinforcement training guidance and is not a substitute for a veterinarian or qualified behaviourist. See our Terms of Use.