Privacy Policy | Privacybeleid

Version 2.0 | 1 April 2026

Camicoo (Ambulatio Consulting B.V., KVK 77272471, BTW NL860955357B01)

Effective date: 1 April 2026

1. WHO WE ARE

Ambulatio Consulting B.V. is registered in the Netherlands (KVK 77272471), with its registered office at Ceresstraat 13, 4811 CA Breda, Netherlands. We trade under the name Camicoo and act as the data controller for all personal data collected through the Camicoo app, website (camicoo.com), and associated services.

Legal name: Ambulatio Consulting B.V.

Trade name: Camicoo

KVK: 77272471

VAT: NL860955357B01

Address: Ceresstraat 13, 4811 CA Breda, Netherlands

Phone: +31 85 124 8910

Email: [email protected]

Website: camicoo.com

Supervisory authority: Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl)

2. DATA WE COLLECT

2.1 DEVICE AND SENSOR DATA (via Bluetooth Low Energy — no GPS)

We collect the following data from your Camicoo smart collar via BLE synchronisation:

  • Skin temperature readings (trend data — not absolute core body temperature)
  • Activity levels derived from the accelerometer (steps, rest periods, active periods)
  • Sleep pattern data (movement and inactivity analysis)
  • Device identifier (BLE pairing address, internal serial number)
  • Battery status and synchronisation timestamps

The collar has no GPS chip. Location data is never collected.

2.2 BARK AND ANTI-BARK DATA (only if anti-bark feature is enabled)

If you enable the Anti-Bark Feature, we collect the following metadata about bark events:

  • Bark event timestamp
  • Duration in seconds
  • Intensity score (0–100)
  • Trigger classification (bark or environmental sound)
  • Anti-bark correction log: correction type (vibration only), intensity level applied, owner-configured settings

We do NOT collect, transmit, or store raw audio recordings of any kind. Bark detection runs entirely on the collar's own processor using on-device LiteRT inference. The audio signal is processed locally and is never digitised for transmission. No audio ever reaches Camicoo servers or any third-party server.

If you disable the Anti-Bark Feature, bark metadata collection stops immediately for new events. Previously collected bark logs are retained until you request account deletion (see Section 7).

2.3 BEHAVIORAL WELLBEING SCREENING DATA

During app onboarding and at periodic intervals, we ask you 4 short questions about your dog's observed behaviour (for example: trembling, hiding, restlessness, and unusual vocalisation patterns). These questions are based on the Lincoln Canine Anxiety Scale (LCAS), a scientifically validated behavioural assessment tool.

We store:

  • Your answers (yes/no per question)
  • A derived anxiety indicator score (0–4)
  • Your dog's breed and age at the time of screening
  • The follow-up action you selected

This data is used to: (a) recommend appropriate correction settings for your dog, (b) track behavioural change over time, and (c) generate vet-shareable health reports.

With your separate, explicit opt-in consent, anonymised and aggregated screening data (minimum group size k=10) may be shared with pet insurance partners for preventive health programmes. No individual personal data is shared without your explicit consent.

IMPORTANT — CLASSIFICATION UNDER GDPR:

This data describes your dog's observable behaviour. It is ORDINARY PERSONAL DATA processed under Article 6 GDPR. It is NOT special category data under Article 9 GDPR. Article 9 applies exclusively to data revealing the health, racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data, or sex life of a NATURAL PERSON (a human being). Pet health and behavioural data does not fall within Article 9 and is not subject to those heightened requirements.

2.4 ACCOUNT DATA

  • Email address (required)
  • Password (stored as a one-way bcrypt hash — never in plain text)
  • Dog profile: name, breed, age, weight, sex, neutered status
  • Profile photo (optional)

2.5 USAGE DATA

  • App session events (screen views, feature interactions, navigation paths)
  • Alert acknowledgements and response actions
  • Notification preferences

2.6 PAYMENT DATA

Payment processing is handled exclusively by Stripe. We never see or store full card numbers, CVV codes, or bank details. We store only: subscription status, plan type (Care or Waker Care), and your Stripe customer ID for billing management purposes.

2.7 WEBSITE DATA

  • Standard web server logs (IP address, browser type, referrer URL, access timestamps)
  • Cookies and tracking technologies (see Section 8)

3. HOW WE USE YOUR DATA

All processing has a documented lawful basis under GDPR Article 6. We do NOT use your data for advertising profiling. We do NOT sell data to any third party.

PURPOSE LEGAL BASIS RETENTION
Health monitoring and alerts Consent — Art. 6(1)(a) 90 days raw telemetry
AI health score analysis Legitimate interest — Art. 6(1)(f) 90 days raw telemetry
Bark behaviour monitoring Legitimate interest — Art. 6(1)(f) 90 days
Anti-bark correction logging Contract — Art. 6(1)(b) 90 days
Behavioral wellbeing screening Legitimate interest — Art. 6(1)(f) Account lifetime
Anonymised screening aggregates Consent — Art. 6(1)(a) Indefinite (anonymised, k>=10)
Account management Contract — Art. 6(1)(b) Until account deletion
Subscription billing Contract — Art. 6(1)(b) 7 years (tax law)
Customer support Legitimate interest — Art. 6(1)(f) 2 years after resolution
Service improvement Legitimate interest — Art. 6(1)(f) Indefinite (anonymised)
Legal compliance Legal obligation — Art. 6(1)(c) As required by law

Where we rely on legitimate interest, you have the right to object (see Section 7). We have conducted a balancing test for each legitimate interest purpose and determined that our interests do not override your rights and freedoms as a data subject.

4. DATA RETENTION

Raw sensor telemetry: Rolling 90-day window. Aggregated daily summaries are retained for the lifetime of your account.

Account data: Retained until you request deletion under GDPR Article 17. We will complete deletion within 30 days of a verified request.

After subscription cancellation: Your data remains accessible in the app. You may request deletion at any time. Anonymised aggregates (where your individual data has been merged with that of at least 9 other users) may be retained indefinitely as they no longer constitute personal data.

Payment records: 7 years from the transaction date, as required by the Dutch General Tax Law (Artikel 52 Algemene wet inzake rijksbelastingen — AWR).

5. THIRD PARTIES AND SUB-PROCESSORS

We share personal data only with the following sub-processors, each bound by a Data Processing Agreement (DPA) and, where required, Standard Contractual Clauses (SCCs) for transfers outside the EEA:

SUB-PROCESSOR PURPOSE LOCATION SAFEGUARD
Supabase (EU region) Database, authentication, storage EU (Frankfurt) DPA executed; EU data region enforced
Stripe Payment processing EU / US Stripe DPA; SCCs for US data transfers
Expo / React Native App crash reporting (anonymised) EU EU region configured; anonymised only
Klaviyo Email marketing communications US DPA executed; SCCs for US data transfers
Google Analytics 4 Website traffic analysis US DPA executed; SCCs for US data transfers
Meta (Facebook) Pixel Advertising conversion tracking US DPA executed; SCCs for US data transfers
Hotjar Website heatmaps, session replay EU DPA executed; EU data region
Railway Application hosting US / EU DPA executed; EU region selected

No personal data is shared with our hardware manufacturer. They supply the collar hardware and firmware only. No customer data is transmitted to manufacturer systems.

6. INTERNATIONAL DATA TRANSFERS

The primary storage and processing of your personal data occurs within the European Union (Supabase Frankfurt, Railway EU region).

For the following services, personal data is transferred to the United States. Each transfer is covered by Standard Contractual Clauses (SCCs) approved by the European Commission under GDPR Article 46(2)(c):

  • Stripe (payment processing)
  • Klaviyo (email marketing)
  • Google Analytics 4 (website analytics)
  • Meta / Facebook Pixel (advertising)

We have conducted or are conducting Transfer Impact Assessments (TIAs) for each US transfer to confirm that the SCCs provide an essentially equivalent level of protection to that guaranteed within the EEA.

7. YOUR RIGHTS UNDER GDPR

As a data subject in the EU/EEA, you have the following rights:

RIGHT OF ACCESS — You may request a copy of all personal data we hold about you (GDPR Art. 15).

RIGHT TO RECTIFICATION — You may ask us to correct inaccurate or incomplete data (GDPR Art. 16).

RIGHT TO ERASURE — You may request deletion of your personal data. We will complete deletion within 30 days of a verified request. Certain data may be retained where required by law (e.g., 7-year tax records) (GDPR Art. 17).

RIGHT TO DATA PORTABILITY — You may receive your personal data in a structured, commonly used, machine-readable format (JSON export available directly in the app) (GDPR Art. 20).

RIGHT TO RESTRICTION — You may ask us to suspend processing of your data while a dispute or correction is pending (GDPR Art. 18).

RIGHT TO OBJECT — You may object to processing based on legitimate interest, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds (GDPR Art. 21).

RIGHT TO WITHDRAW CONSENT — Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal (GDPR Art. 7(3)).

To exercise any of these rights, contact us at: [email protected]

We will respond within 30 days. Identity verification may be required before we action a request.

If you are not satisfied with our response, or believe we are processing your data unlawfully, you have the right to lodge a complaint with the Autoriteit Persoonsgegevens:

Website: autoriteitpersoonsgegevens.nl

Post: Postbus 93374, 2509 AJ Den Haag, Netherlands

8. COOKIES AND TRACKING TECHNOLOGIES

Website (camicoo.com):

We use the following cookies and tracking technologies on our website. Non-essential cookies are only activated after you provide explicit opt-in consent through our cookie consent banner.

CATEGORY TOOL PURPOSE CONSENT REQUIRED
Essential Shopify session Cart, checkout, session management No (strictly necessary)
Analytics Google Analytics 4 Website traffic and behaviour Yes
Analytics Hotjar Heatmaps, session recordings Yes
Marketing Meta Pixel (Facebook) Ad conversion tracking Yes
Marketing Klaviyo Email marketing attribution Yes

You may withdraw cookie consent at any time via the cookie settings panel at the bottom of any page on camicoo.com.

App (iOS / Android):

We do not use cookies in the Camicoo mobile app. Authentication tokens are stored securely in the device keychain (iOS) or keystore (Android).

9. WHAT WE DO NOT COLLECT — ANTI-BARK TRANSPARENCY

This section is provided specifically to address reasonable concerns about the microphone on the Camicoo collar:

  • RAW AUDIO RECORDINGS: The collar's microphone processes sound locally on the hardware processor (LiteRT on-device inference). The audio signal is never converted into a stored digital recording, never transmitted over Bluetooth, and never reaches any Camicoo server or third-party system.
  • AMBIENT SOUND RECORDINGS: Only binary bark event metadata is transmitted (bark occurred: yes/no; timestamp; duration; intensity).
  • LOCATION DATA: The Camicoo collar contains no GPS hardware. No location information is ever collected.
  • CONTINUOUS BACKGROUND RECORDING: The bark detection model runs event-triggered inference, not continuous background recording.

10. AI TRANSPARENCY (EU AI Act Art. 50)

Camicoo uses artificial intelligence in the following ways:

ON-DEVICE BARK DETECTION: The collar firmware uses a LiteRT (TensorFlow Lite) model to classify bark events in real time. This is minimal-risk AI. No AI obligation applies under the EU AI Act for this function.

HEALTH SCORE AND ANOMALY ALERTS: The Camicoo app generates a daily AI Health Score (0–100) and may issue anomaly alerts based on sensor data trends. These are wellness indicators only. They are NOT veterinary diagnoses. This function is limited-risk AI under the EU AI Act. In compliance with Article 50, all AI-generated health outputs are clearly labelled as "Generated by AI" within the app.

BEHAVIORAL SCREENING: The anxiety indicator score derived from LCAS responses is a simple algorithmic calculation, not a learned model.

No Camicoo AI function constitutes a high-risk AI system under EU AI Act Annex III unless Camicoo explicitly builds B2B insurance risk scoring functionality, which would require separate regulatory assessment before deployment.

You may disable AI-driven features (health scoring, anti-bark correction) at any time in the app settings. You retain full control over whether automated bark correction is applied to your dog.

11. CHILDREN'S DATA

Camicoo is not directed at children under the age of 16. We do not knowingly collect personal data from anyone under 16. The data subject for account purposes is always the adult pet owner. Pet health data (sensor readings from your dog) is not personal data of a natural person and is therefore outside the scope of GDPR protections for children's data.

12. SECURITY

We implement the following security measures to protect your personal data:

  • All data in transit is encrypted using TLS 1.2 or higher
  • All data at rest is encrypted using AES-256 (via Supabase)
  • Passwords are hashed using bcrypt with a work factor appropriate for current hardware
  • Bluetooth Low Energy communication uses encrypted pairing
  • Access to production databases is restricted to authorised personnel via role-based access controls
  • Security reviews are conducted periodically

13. CHANGES TO THIS POLICY

We will notify you of any material changes to this Privacy Policy by email at least 14 days before the changes take effect. The current version of this Policy is always available at camicoo.com/privacy.

Continued use of the Services after the effective date of a revised Policy constitutes acceptance of the revised terms.

This Privacy Policy was last updated on 1 April 2026.

Ambulatio Consulting B.V. KVK 77272471 VAT NL860955357B01

Ceresstraat 13, 4811 CA Breda, Netherlands | +31 85 124 8910

[email protected] | camicoo.com