Fello Privacy Policy

The controller responsible for the processing described in this Privacy Policy is:

Fello

Zürich, Switzerland

Privacy contact: hello@fello.services

In this Privacy Policy, "Fello", "we", "us" and "our" refer to the above controller.

Fello determines the purposes and means by which personal data is processed through the Platform.

Fello's initial service is operated from Switzerland and is intended primarily for Users in Zürich, Switzerland.

Our processing of personal data is governed principally by the Swiss Federal Act on Data Protection ("FADP" / DSG) and its implementing legislation.

Where another data-protection law applies to a particular User or processing activity, Fello will comply with that law to the extent required.

When processing personal data, Fello aims to:

• process data lawfully, fairly and transparently;
• collect data only for specified and legitimate purposes;
• collect no more data than reasonably necessary;
• keep personal data accurate and, where appropriate, current;
• protect personal data through appropriate technical and organisational measures;
• restrict access on a need-to-know basis;
• retain personal data only as long as reasonably necessary or legally required; and
• design the Platform to minimise unnecessary disclosure between Users.

In particular, an Owner's precise residential address, access information and other sensitive household information are not intended to be publicly visible through Fello.

The personal data we process depends on how you use Fello.

When an Owner submits a Booking Request or an Owner and Sitter enter into a Care Agreement through Fello, we may process information including:

• Owner identifier;
• Sitter identifier;
• relevant pet or pets;
• requested service;
• Booking date;
• Booking start and end time;
• duration;
• service location;
• agreed price;
• Booking status;
• payment method selected or reported;
• payment status;
• cancellation status;
• cancellation timestamp;
• cancellation reason;
• care instructions;
• safety information;
• special requirements;
• communications relating to the Booking; and
• incident information.

This information is used to facilitate, administer and provide a record of the Booking.

If you communicate with Fello, we may process:

• your identity and contact information;
• the content of your message;
• attachments;
• Booking references;
• complaint information;
• support history;
• payment-status disputes;
• cancellation disputes;
• safety reports; and
• other information reasonably necessary to deal with your request.

Where Fello introduces User-to-User messaging through the Platform, the Privacy Policy and applicable retention rules will be updated to reflect that functionality where necessary.

If a safety, animal-welfare, behavioural, property or other serious incident occurs, we may process information concerning:

• Users involved;
• the relevant pet;
• the Booking;
• date, time and place of the incident;
• circumstances of the incident;
• photographs or documentation voluntarily submitted;
• witness information;
• communications between relevant parties;
• veterinary information;
• property damage;
• insurance information;
• injury information voluntarily supplied;
• action taken by Fello; and
• communications with insurers, veterinarians, legal advisers or competent authorities where necessary.

Incident information may sometimes contain sensitive personal data.

Access to such information will be restricted appropriately.

When you access or use the Platform, Fello and its infrastructure providers may automatically process technical information including:

• IP address;
• browser type;
• device type;
• operating system;
• application version;
• language;
• date and time of access;
• authentication events;
• security events;
• session identifiers;
• pages or functions accessed;
• server logs;
• diagnostic information;
• errors;
• performance data; and
• other technical information required to provide and secure the Platform.

We use this information primarily to:

• operate the Platform;
• authenticate Users;
• maintain security;
• investigate suspicious activity;
• prevent misuse;
• diagnose faults; and
• improve technical reliability.

Swiss data-protection law does not require private controllers to assign a GDPR-style legal basis to every ordinary processing activity.

Fello nevertheless processes personal data only for legitimate and transparent purposes and in accordance with the principles and requirements of the FADP.

Depending on the circumstances, processing may be necessary or justified in connection with:

• providing the Platform;
• performing Fello's agreement with a User;
• taking steps requested by a User before entering into an agreement;
• facilitating a Care Agreement between an Owner and Sitter;
• Fello's legitimate private interests;
• the legitimate interests of Users or third parties;
• protecting persons or animals;
• preventing fraud or misuse;
• compliance with legal obligations;
• establishment, exercise or defence of legal claims; or
• the User's consent where consent is required or relied upon.

Where processing is based on consent, you may withdraw that consent for future processing.

Withdrawal does not affect processing already lawfully undertaken and does not prevent processing that remains necessary or permitted for another lawful reason.

Fello does not sell User personal data.

We disclose personal data only where reasonably necessary for the purposes described in this Privacy Policy.

Recipients may include the following.

An Owner may be able to see information about a Sitter such as:

• first name;
• profile photograph;
• general service area;
• biography;
• languages;
• services offered;
• availability;
• price;
• relevant pet-care experience;
• verification indicators, if offered; and
• whether the Sitter is a Junior Sitter.

Fello will not ordinarily display to Owners a Sitter's:

• full residential address;
• private telephone number before it is reasonably required;
• exact date of birth;
• government identification information;
• Guardian contact information; or
• other information not reasonably necessary for the marketplace interaction.

Before or during a Booking, a Sitter may receive information reasonably necessary to assess or perform the requested service, including:

• Owner first name;
• general service location;
• pet profile;
• pet behaviour;
• known safety risks;
• requested service;
• requested date and time; and
• care requirements.

The precise home or service address should normally be disclosed only where reasonably necessary in connection with a relevant Booking.

Fello uses Supabase as part of its backend infrastructure.

Supabase functionality used by Fello may include:

• database services;
• authentication;
• data storage;
• application programming interfaces;
• access-control functionality; and
• supporting backend infrastructure.

The Fello project is configured to use infrastructure in the AWS eu-central-1 region in Frankfurt, Germany.

Supabase and its authorised subprocessors may process personal data as required to provide their services.

Fello remains responsible for assessing its processors and maintaining appropriate contractual arrangements in accordance with applicable data-protection law.

Before public production launch, Fello maintains an internal register identifying the service providers used to process personal data.

Depending on the production implementation, this may include providers for:

• frontend hosting;
• transactional email;
• maps and address search;
• error monitoring; and
• analytics.

Fello will identify material third-party integrations in this Privacy Policy where required before those integrations are used for production processing.

Production providers:

• Frontend hosting provider: Vercel Inc. (Vercel)
• Transactional email provider: Plus Five Five, Inc. (Resend)
• Address/maps provider: none
• Error-monitoring provider: none
• Analytics provider: none

Fello is based in Switzerland.

Some of the providers used to operate the Platform may process personal data outside Switzerland.

The primary Supabase infrastructure currently used for the Fello project is located in:

Germany — AWS eu-central-1 (Frankfurt).

Other provider personnel, subprocessors or infrastructure may operate from other countries.

Before public production launch, Fello will maintain an up-to-date record of relevant destination countries and will ensure that cross-border disclosures comply with Swiss data-protection law.

Personal data may be transferred to:

• countries recognised by the Swiss Federal Council as providing an adequate level of data protection; or
• other countries where appropriate safeguards or a legal exception permit the transfer.

Where the receiving country does not provide an adequate level of data protection under Swiss law, Fello may use legally recognised safeguards such as appropriate standard contractual clauses, together with supplementary measures where required.

Production destination countries:

Switzerland; Germany; United States.

Fello uses technical and organisational measures designed to protect personal data against:

• unauthorised access;
• accidental or unlawful loss;
• unauthorised disclosure;
• alteration;
• destruction; and
• misuse.

Depending on the relevant system, these measures may include:

• encrypted network transmission;
• authentication controls;
• access restrictions;
• database row-level security;
• role-based permissions;
• segregation of environments;
• logging;
• backups;
• software and dependency updates;
• secure development practices; and
• contractual requirements for service providers.

Access to personal data is restricted to persons and systems that reasonably require access for an authorised purpose.

No internet-connected system can provide an absolute guarantee of security.

Users are also responsible for protecting their login credentials and for avoiding unnecessary disclosure of sensitive information such as property access codes.

Information concerning access to an Owner's home deserves particular protection.

Users should avoid placing:

• door codes;
• alarm codes;
• lock-box codes;
• key locations; or
• similar security information

in public profile fields.

Where Fello later introduces dedicated functionality for property-access information, access will be restricted to Users for whom the information is reasonably necessary for the relevant Booking.

Such information should be removed or access restricted when it is no longer required.

Fello retains personal data only for as long as reasonably necessary for the purpose for which it was collected or where longer retention is justified or required by law.

Retention may vary according to the category of information.

Fello may use cookies, browser storage and similar technologies necessary to:

• authenticate Users;
• maintain secure sessions;
• remember essential settings;
• prevent security misuse; and
• provide Platform functionality.

These technologies are referred to as "essential technologies".

Fello will not introduce advertising, behavioural tracking or non-essential analytics technologies without first assessing the applicable legal requirements and updating its privacy information and consent mechanism where required.

Users may be able to restrict certain technologies through browser or device settings.

Blocking essential technologies may prevent parts of Fello from functioning correctly.

The MVP does not rely on personal data for advertising profiling.

If Fello uses product analytics, Fello will aim where reasonably possible to:

• minimise collected identifiers;
• limit the data collected;
• use aggregated information;
• avoid unnecessary cross-service tracking; and
• configure retention appropriately.

Where a third-party analytics service results in material additional processing, this Privacy Policy will be updated before or when that service is introduced.

MVP analytics provider: None

Fello distinguishes operational communications from marketing.

Operational communications may include:

• email confirmation;
• authentication notices;
• Booking Requests;
• Booking confirmations;
• cancellations;
• reminders;
• security alerts;
• safety information; and
• account administration.

Users cannot necessarily opt out of communications required to operate their account or active Bookings.

If Fello sends marketing communications, it will do so in accordance with applicable law and provide an appropriate way to unsubscribe.

Fello will not sell User contact information to third parties for their independent marketing.

Fello may use automated rules to support functions such as:

• showing Sitters based on geographic area;
• filtering availability;
• matching requested services;
• enforcing Booking limits;
• preventing a Sitter from exceeding regulatory or Platform limits;
• identifying technical or security anomalies; and
• prioritising relevant marketplace information.

The Fello MVP does not intend to make decisions that produce legal effects or similarly significant effects concerning a User solely through automated processing.

Where an account restriction or safety decision requires material judgment, Fello may conduct a human review where appropriate.

If Fello later introduces automated individual decision-making within the meaning of applicable data-protection law, affected Users will receive the information and rights required by law.

Subject to applicable law and the circumstances of the request, you may have the right to:

• ask whether Fello processes personal data concerning you;
• receive information concerning that processing;
• obtain a copy of your personal data;
• request correction of inaccurate data;
• request deletion or destruction of personal data;
• request that certain processing cease;
• object to certain processing;
• request delivery or transfer of certain personal data in a commonly used electronic format where the statutory requirements are satisfied; and
• withdraw consent where processing is based on consent.

Rights are not absolute.

Fello may refuse, restrict or defer a request where permitted or required by law, for example where information must be retained because of:

• statutory retention obligations;
• an unresolved Booking;
• fraud or security concerns;
• animal-welfare or safety issues;
• overriding third-party rights; or
• pending or potential legal claims.

To exercise a privacy right, contact:

hello@fello.services

Please state sufficient information for us to identify your account and understand your request.

Fello may request reasonable proof of identity before disclosing, correcting or deleting personal data.

Users may request closure of their Fello account.

Account closure does not necessarily result in immediate deletion of every associated record.

Fello may retain information where necessary to:

• complete an outstanding Booking;
• administer a cancellation or dispute;
• maintain required accounting or legal records;
• protect Users or animals;
• investigate misuse;
• enforce legal rights; or
• comply with applicable law.

Information no longer required will be deleted, anonymised or otherwise removed from active use within a reasonable period.

You should not provide personal information concerning another person unless you are entitled to do so.

This may apply, for example, to:

• Guardians;
• emergency contacts;
• household members;
• witnesses; and
• other persons connected with a Booking.

Where appropriate, you should inform the person that their information has been provided to Fello and direct them to this Privacy Policy.

Owner accounts are intended for persons aged 18 or older unless Fello expressly states otherwise.

Fello may admit approved Junior Sitters aged 15 to 17 subject to:

• age verification;
• Guardian consent;
• safeguarding restrictions; and
• the Junior Sitter provisions of Fello's Terms of Service.

Fello does not intentionally permit children below Fello's approved minimum age to independently create paid Sitter accounts.

If Fello becomes aware that personal data relating to a child has been collected contrary to these requirements, we will investigate the situation and take appropriate measures, which may include restricting the account or deleting the information.

Fello maintains procedures for assessing suspected personal-data security breaches.

Where a personal-data breach is likely to result in a high risk to the personality or fundamental rights of affected individuals, Fello will notify the Swiss Federal Data Protection and Information Commissioner where required by applicable law.

Affected persons will also be informed where required by law or where notification is necessary for their protection.

Fello may in the future be:

• incorporated into a company;
• reorganised;
• financed;
• acquired;
• sold;
• merged; or
• transferred together with its business or assets.

Where legally permissible, personal data may form part of such a transaction or preparatory due-diligence process.

Any disclosure will be limited appropriately and subject to applicable confidentiality and data-protection requirements.

If the identity of the data controller changes, affected Users will be informed where required.

Fello may retain, use or disclose personal data where reasonably necessary to:

• comply with applicable law;
• respond to binding legal proceedings;
• enforce the Terms of Service;
• protect Fello's legal rights;
• investigate suspected fraud;
• investigate serious Platform misuse;
• protect an Owner, Sitter or third party;
• protect an animal; or
• establish, exercise or defend legal claims.

Nothing in this Privacy Policy requires Fello to disclose information where disclosure would breach another person's rights or applicable law.

Fello may update this Privacy Policy where necessary because of:

• changes to the Platform;
• new functionality;
• new service providers;
• changes to data processing;
• changes to our business model;
• geographic expansion; or
• legal or regulatory developments.

The current version number and date will be displayed at the beginning of the Policy.

Where a change materially affects how personal data is processed, Fello will bring the change to Users' attention in an appropriate manner.

Where consent is legally required for new processing, Fello will obtain it.

Fello may make this Privacy Policy available in more than one language.

Each language version should be drafted to reflect the same substantive privacy protections.

Where legally permissible and a discrepancy exists between translations, German will prevail.

Nothing in this provision restricts mandatory rights available under applicable law.

If you have a question, concern or request concerning personal data or this Privacy Policy, contact:

Fello

Zürich, Switzerland

Email: hello@fello.services

We encourage Users to contact Fello first so that we can investigate and respond to the concern.

You may also contact the competent Swiss data-protection authority:

Federal Data Protection and Information Commissioner (FDPIC / EDÖB)

Switzerland

regarding matters falling within its statutory competence.