1.1. This Policy sets out how personal data is processed and protected in the DogGear service in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”).
1.2. The personal data operator is the individual Dmitry Viktorovich Kuznetsov (the “Operator”). Contact for personal data matters: dmitry.kuznetsov.dev@yandex.ru. Information about the Operator is entered in the Roskomnadzor register of personal data operators.
1.3. The DogGear service (the “Service”) consists of a mobile app for Android and iOS and a server at https://api.doggears.ru. The Service is intended for keeping the profile of an owner and their dogs, recording workouts, taking part in amateur events, keeping results and a map of treadmills.
1.4. This Policy is a publicly available document and does not replace consent to personal data processing. Where processing requires consent, the consent is a separate document given by a separate user action.
1.5. The Service is intended for adult users. Persons under 18 may not register. If processing of a minor’s data is detected, the Operator stops it and deletes the data unless another lawful basis exists.
2.1. The Operator processes personal data for the following purposes:
| Purpose | Data processed | Legal basis | Period |
|---|---|---|---|
| Registration, sign-in and personal account | email address (login), password hash, one-time confirmation codes, display name, session data, technical sign-in data including failed sign-in attempts; for accounts created before revision 6, the user identifier in an external sign-in service (VK ID, Yandex ID or Sign in with Apple) received when the account was created | the user’s separate consent to personal data processing | until the account is deleted or consent is withdrawn, then deletion within the periods of section 7 |
| Keeping the user profile and dog profiles | display name; email address and phone number if provided voluntarily; user photo; dog’s name, parameters and photo | the user’s separate consent | until the account is deleted or consent is withdrawn |
| Recording workouts and personal statistics | date and time of the workout, duration, distance, workout parameters, user, dog and treadmill identifiers, app and firmware versions | the user’s separate consent | until the account is deleted or consent is withdrawn |
| Taking part in events | entry, category, dog information, results, distance, time, event stage; phone number — for the organizer to contact the participant and to appoint event co-administrators | the user’s separate consent | until the account is deleted or consent is withdrawn |
| Keeping the treadmill map | treadmill identifier and name, model, coordinates, coordinate accuracy, address label, visibility setting | the user’s separate consent | until the account is deleted or consent is withdrawn |
| Keeping treadmills and the app working and safe, including without signing in | app installation identifier, treadmill controller identifier, device model and operating system version, app and firmware versions; workout records not linked to an account (start and end time, duration, distance, speed, power and torque samples, pauses, stop reason, time zone); device and app diagnostic logs; controller authenticity check records | the Operator’s legitimate interest in the proper and safe operation of the equipment and the Service (Art. 6(1)(7) of the Law) | periods of section 6 |
| Information security and abuse prevention | IP address, session information, technical device and app data, security events, audit log | performance of the Operator’s duties to keep data secure and the Operator’s legitimate interest in protecting the Service (Art. 6(1)(6) of the Law) | periods of section 6 |
| Support and requests | name, email address, content of the request, technical information attached by the user | the user’s request; performance of the Operator’s duties to handle requests of data subjects | up to 3 years after the request is closed, unless earlier deletion is required |
| Proving lawful processing | fact, date, version and method of giving or withdrawing consent; account deletion records | the Operator’s duty to prove that consent was obtained (Art. 9(3) of the Law) and protection of the Operator’s rights | 3 years after processing ends, unless there is a dispute or a duty to keep the data longer |
2.2. The Operator does not process special categories of personal data or biometric personal data and does not use photos to identify persons. The Service uses no face recognition, advertising trackers, advertising identifiers, advertising profiling or analytics counters. No cookies are used: the Service is provided through a native mobile app, and api.doggears.ru is a programming interface without a web interface. No automated decisions with legal effects for the user are made.
2.3. The phone number is an optional contact field of the profile: the user provides it voluntarily, it is not verified and is not used for sign-in. It is used for the event organizer to contact a participant and to find a user when appointing them as an event co-administrator.
2.4. The email address is the required account login. Only service emails are sent to it: a confirmation code on registration and when linking an address, a password reset code and notices about account actions (password change, address linking, a repeated registration attempt). No advertising or newsletter mailings are sent. The password is stored only as an irreversible hash (Argon2id) and is unknown to the Operator; confirmation codes are stored in a form that does not allow the code or the address to be recovered.
3.1. Data may come:
3.2. Photos of users and dogs are stored as derived reduced copies. Original photos are not kept after processing.
3.3. Device and app diagnostic logs are generated and sent to the Service automatically. The log files contain technical information: app installation and treadmill controller identifiers, device model and operating system version, software versions, the time and description of technical events. Email addresses, names, phone numbers, photos, coordinates, passwords and access keys are not written to log files.
3.4. Treadmill coordinates are user data when they are linked to the user’s account. The Service does not collect the location of the user’s mobile device in the background.
3.5. Without signing in, the mobile app automatically, with no separate action by the user, sends to the Service records of finished workouts, diagnostic logs and controller authenticity check records together with the app installation identifier and the treadmill controller identifier. The installation identifier is a random value the app creates on first launch; a new one is created after the app is reinstalled. Such data is not linked to the user’s account, is not shown to other users and is processed only for the purpose “Keeping treadmills and the app working and safe” (clause 2.1).
4.1. The Operator processes personal data by automated means with transfer over the Internet: collection, recording, systematization, accumulation, storage, clarification, retrieval, use, provision of access, dissemination where separate consent exists, blocking, deletion and destruction.
4.2. Initial recording, systematization, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation are performed using databases located in the Russian Federation (Art. 18(5) of the Law).
4.3. The server infrastructure, the main database, file storage and backups are hosted on computing capacity rented from JSC Selectel (OGRN 1247800067790) in data centers in the Russian Federation. JSC Selectel provides infrastructure and has no access to the content of personal data; backups are transferred to storage in encrypted form. Service emails (clause 2.4) are sent through the JSC Selectel mail service on the Operator’s instruction (Art. 6(3) of the Law): to deliver an email, JSC Selectel receives the recipient’s email address and the text of the email (a confirmation code or a notice about an account action). After the email is sent, rejected or expires, the Operator erases the address and the text from its database. The Operator remains responsible to data subjects.
4.4. Sign-in to the Service is by email address and password. External sign-in services (VK ID, Yandex ID, Sign in with Apple) are not used for registration or sign-in, and no data is requested from them. Accounts created through these services before revision 6 are kept: the user identifier in the external service received at that time is stored as part of the account until it is deleted and is used only so that the account owner can link an email address and password to it.
4.5. The Yandex Mail service is used to receive and keep requests sent by email. LLC YANDEX independently processes data transferred when its mail service is used, in accordance with its own privacy policy.
4.6. Personal data may be provided to public authorities only in the cases and manner expressly provided for by the laws of the Russian Federation.
4.7. The Operator does not sell personal data, does not transfer it for advertising and does not use it for marketing profiling.
4.8. No cross-border transfer of personal data takes place. If such transfer becomes necessary, the Operator will, before it starts, meet the requirements of the laws of the Russian Federation, including sending the required notice to Roskomnadzor, and will update this Policy.
5.1. Data available to other users or to an unlimited number of persons may be disseminated only on the basis of a separate consent to processing of personal data permitted by the data subject for dissemination (Art. 10.1 of the Law).
5.2. Consent to dissemination is a separate document that lists the permitted categories of data:
5.3. The email address, password hash, user identifier in an external sign-in service, phone number, session information, technical and diagnostic data, app installation and controller identifiers, usage logs and workout telemetry are not disseminated.
5.4. Pre-selected settings, silence or inaction of the user are not consent to dissemination.
5.5. The user may set prohibitions and conditions for dissemination using the Service’s standard features (for example, making a treadmill private or withdrawing consent) or by a request to the Operator at dmitry.kuznetsov.dev@yandex.ru. If the scope of consent is unclear, the data is not published. The Operator publishes information about the conditions and prohibitions set within the period provided by the Law.
5.6. Refusing consent to dissemination does not limit the main functionality of the Service. If the user has not permitted a result to be published, the result is available only to the user, the event organizer and the Operator.
5.7. The user may withdraw consent to dissemination at any time. The Operator stops dissemination from the moment such a demand is received and removes the data from public access in the manner set out in section 7.
6.1. Retention periods:
| Data category | Retention period |
|---|---|
| Profile, dog profiles, workouts, treadmills, entries and results | until the account is deleted or consent is withdrawn |
| Treadmill usage log | no more than 13 months |
| Uploaded diagnostic logs and related file storage objects | no more than 40 calendar days |
| Workout records sent without signing in, and records linking app installation and controller identifiers | no more than 13 months |
| Controller authenticity check records | no more than 13 months |
| Email address, password hash, identifier in an external sign-in service (for accounts created before revision 6) | until the account is deleted |
| Confirmation codes | valid for 10 minutes, deleted no later than 1 day after use or expiry |
| Recipient address and text of a service email | erased after the email is sent, rejected or expires; a service record of the sending without the address — no more than 7 days |
| Information about failed sign-in attempts and email sending frequency (without the address in clear form) | no more than 2 days |
| Session information | no more than 90 days after the last activity |
| Server technical logs | no more than 14 calendar days |
| Backups | no more than 30 calendar days |
| Records of consents, account deletion and personalized security audit records | 3 years after processing ends, unless there is a dispute, an investigation or another lawful basis for keeping them |
| Irreversibly anonymized statistics | without time limit, if the link to the user cannot be restored |
6.2. Data is considered anonymized only if the Operator cannot directly or indirectly restore its link to a specific user.
7.1. The user may:
7.2. To protect the account, the Operator may ask for identity confirmation sufficient to rule out deletion of the account by a third party (in the app, entering the account password).
7.3. After a confirmed account deletion, the Operator stops ordinary processing of the data, blocks access to the account and stops public display of the data linked to it.
7.4. Records of the main database linked to the user (profile, email address and password hash, dogs, workouts, entries and results, treadmills) are destroyed immediately after the deletion is confirmed, and all sign-in sessions are ended; photos, diagnostic files and other file storage objects — no later than 7 days; links between the remaining statistics and the user are removed.
7.5. Data in backups is not used in the ordinary operation of the Service and is destroyed by automatic rotation no later than 30 calendar days after the account is deleted (Art. 21(5) of the Law). If a backup is restored before it is deleted, the user’s deletion request is applied again before normal operation resumes.
7.6. The Operator may keep limited records of consent, deletion and security events for the period of section 6 solely to prove lawful processing, protect the Operator’s rights and perform legal duties. Such records are not used for running the account, advertising or publication.
7.7. The Operator cannot guarantee deletion of copies of data that the user has passed to third parties, published outside the Service, or that were stored in caches or search engines before deletion. The Operator stops serving such data from its own resources.
7.8. When an account created before revision 6 through an external sign-in service is deleted, the user identifier in that service is destroyed together with the account. The Operator does not send requests to external services; the user can revoke the DogGear app’s access in the settings of their VK ID, Yandex ID or Apple ID account.
7.9. Data sent without signing in (clause 3.5) is destroyed when the period of section 6 expires. It can be deleted earlier on request to dmitry.kuznetsov.dev@yandex.ru with details that let the Operator identify the treadmill or the app installation (for example, the controller identifier); the Operator destroys the related records within the periods of section 8.
8.1. The user has the right to receive information about the processing of their personal data, to demand clarification, blocking, deletion or destruction of the data, to withdraw consent, to demand that dissemination of the data be stopped, and to appeal the Operator’s actions to Roskomnadzor or a court.
8.2. Requests are sent to dmitry.kuznetsov.dev@yandex.ru or through the Service’s features.
8.3. The Operator provides information about data processing within 10 working days. The period may be extended by no more than 5 working days with a stated reason.
8.4. Data confirmed to be inaccurate is clarified, and data obtained unlawfully or not needed for the purpose is destroyed within 7 working days.
8.5. Unlawful processing is stopped within 3 working days. If it cannot be made lawful, the data is destroyed within 10 working days.
8.6. When consent is withdrawn or the purpose is achieved, the data is destroyed no later than 30 calendar days, unless another lawful basis for processing exists.
8.7. Dissemination of data permitted for dissemination stops from the moment the user’s demand is received. If the rules are breached, dissemination stops no later than 3 working days.
9.1. The Operator takes the legal, organizational and technical measures necessary to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision and dissemination.
9.2. In particular, the Operator applies access control and the principle of least privilege, stores passwords only as an irreversible hash (Argon2id), temporarily blocks sign-in after a series of failed attempts, logs significant actions in a tamper-protected log, protects data in transit with TLS, encrypts backups, restricts access to secrets and regularly reviews the measures. Security level 4 of personal data protection is determined (Decree of the Government of the Russian Federation No. 1119); the measures are implemented under FSTEC of Russia Order No. 21 using non-certified information security tools.
9.3. Access to personal data is granted only to persons and processors who need it for the purposes stated in this Policy.
9.4. In an incident affecting personal data, the Operator acts in the manner and within the periods established by the laws of the Russian Federation.
10.1. The Operator may update this Policy. The revision is stated in its header, and the current version is always published at api.doggears.ru/privacy.
10.2. A new revision of the Policy does not extend consents given earlier. If a change affects the purposes of processing, data categories, recipients or dissemination and requires new consent, such processing starts only after the user’s separate consent is obtained.
10.3. Questions about this Policy are sent to dmitry.kuznetsov.dev@yandex.ru.