Privacy Policy

This Privacy Policy applies to the Traini mobile application and websites; PetGPT, PEBI, and other artificial intelligence features; smart collars, sensors, and connected hardware; subscriptions and collar memberships; the Traini store and hardware pre-orders; digital and online training services; affiliate, referral, rewards, and promotional programs; gift cards and store credit; SMS, email, and push communications; and any other Traini service that links to this Privacy Policy (collectively, the "Services").

This Privacy Policy does not apply to content that we process on behalf of customers of our business offerings, such as our API. This Privacy Policy does not apply to a third party's independent products, websites, applications, or services, even if they are linked to or accessible through the Services. Those third parties process information under their own privacy notices.

For purposes of this Privacy Policy:

• "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable person or household. The term includes "personal data" and similar terms under applicable law.
• "User Content" means information and material that you submit to, upload to, record through, or generate using the Services, including prompts, messages, chat history, feedback, photographs, images, audio, video, documents, pet records, behavioral information, sensor or wearable data, and AI-generated outputs.
• "Model Improvement" means training, fine-tuning, evaluating, testing, or otherwise improving Traini's artificial intelligence and machine-learning models, including PetGPT and PEBI.

The Personal Information we collect depends on the Services you use, the features you enable, the permissions you grant, and how you interact with us. We may collect the following categories:

Account and identity information: Your name, username, email address, telephone number, account credentials, date of birth or age information, profile details, and communication preferences.

User Content: Prompts, messages, chat history, AI-generated outputs, feedback, images, photographs, audio, video, documents, behavioral labels, pet observations, recordings, and other content submitted to or generated through the Services.

Pet and household information: Information about your pet, such as its name, species, breed, age, sex, weight, health and training history, routines, behavior, location, and emergency details. This may also include information about household members, veterinarians, trainers, or caregivers that you choose to provide.

Connected product and sensor information: Motion, activity, temperature, physiological measurements, location information, device status, battery status, Bluetooth connectivity, firmware information, diagnostics, and other telemetry generated by a smart collar or connected product.

Transaction information: Information relating to orders, subscriptions, memberships, pre-orders, returns, shipping and billing addresses, gift cards, store credit, payment status, and limited payment-related records. Payment card information is generally processed by our third-party payment providers rather than stored directly by Traini.

Device and technical information: IP address, device type, operating system, browser type, app version, language, time zone, mobile or app-instance identifiers, advertising identifiers where permitted, network status, log information, crash data, and security events.

Usage and analytics information: Information about how you use and interact with the Services, including sessions, screens or pages viewed, feature interactions, clicks, referrals, searches, latency, model feedback, advertisement impressions and clicks, conversions, and interests or preferences inferred from your activity.

Communications and program information: Customer-support communications, survey responses, research participation, training bookings, promotional entries, affiliate or rewards program participation, and SMS or email communications.

We collect Personal Information from the following sources:

• Directly from you, including when you create an account, submit User Content, purchase a product, enroll in a subscription or training service, participate in a program, or communicate with us.
• Automatically from your device and use of the Services, including through software development kits, cookies, pixels, local storage, logs, APIs, and similar technologies.
• From connected products and sensors that you pair with the Services.
• From service providers and business partners, including Apple, Google, Stripe, authentication providers, analytics and advertising providers, shipping partners, trainers, affiliates, research partners, and fraud-prevention providers.
• From other users or persons when you authorize them to share a pet profile or other information with Traini.

We use Personal Information for the following purposes:

• Provide, administer, maintain, and personalize the Services, including accounts, AI responses, smart-collar functions, pet profiles, training services, orders, subscriptions, and customer support.
• Process User Content and related context to generate requested analyses, recommendations, alerts, communications, and other outputs.
• Research, develop, test, and improve the Services, including Model Improvement when permitted by your settings and applicable law.
• Analyze usage, measure performance, troubleshoot errors, monitor availability, and understand how users interact with the Services.
• Provide and measure personalized or contextual advertising for eligible adult users, subject to consent, account settings, device settings, and applicable law.
• Process purchases, subscriptions, memberships, pre-orders, returns, refunds, gift cards, rewards, taxes, and related communications.
• Communicate with you about the Services, security, support, transactions, product updates, research, surveys, promotions, and marketing, where permitted.
• Detect, investigate, and prevent fraud, abuse, security incidents, policy violations, harmful activity, and attempts to misuse Traini's systems.
• Comply with law, respond to lawful requests, establish or defend legal claims, enforce agreements, and protect Traini, users, animals, and others.

Where applicable law requires a legal basis, Traini processes Personal Information as necessary to perform a contract with you, comply with legal obligations, protect vital interests, pursue legitimate interests that are not overridden by your rights and interests, or with your consent. Our legitimate interests include providing and securing the Services, improving their quality and safety, communicating with users, understanding use of the Services, preventing fraud and abuse, and conducting responsible research and development. Where processing is based on consent, you may withdraw consent at any time, subject to applicable law. Withdrawal does not affect processing that occurred before withdrawal.

Service Delivery Processing

Traini processes User Content and related information to provide the AI feature or other Service you request. This processing is necessary whether the Model Improvement setting is enabled or disabled. Traini may also process limited User Content for security, abuse prevention, legal compliance, customer support, and service reliability, as permitted by law.

Model Improvement Setting

For adult users in the United States, the setting that permits Traini to use eligible User Content for Model Improvement is enabled by default. You may disable it at any time in Traini's privacy settings. Outside the United States, Traini will apply the default and obtain any consent required by applicable law before using Personal Information for Model Improvement.

When Model Improvement is enabled, Traini may use text, images, video, audio, chat outputs, behavioral tags, sensor or wearable data, and feedback to train, fine-tune, evaluate, test, and improve Traini models, including PetGPT and PEBI. Traini may remove, mask, aggregate, or separate direct account identifiers before using information for these purposes.

Disabling Model Improvement applies to eligible inputs and outputs created after the setting change takes effect. It does not reverse training that has already occurred, remove information already incorporated into a trained model, or require deletion of records that Traini must retain for security, legal, or other permitted purposes. You may separately request deletion of eligible account data as described in Section 13.

Traini does not use content from users it knows are under 18 for Model Improvement. A parent or guardian may not enable Model Improvement for a known minor.

Human Review and Service Providers

A limited number of authorized Traini personnel and service providers may access selected User Content when reasonably necessary to investigate abuse or security incidents, provide support, comply with law, evaluate safety or quality, or conduct Model Improvement when the user's setting permits it. Access is limited by role, purpose, and confidentiality obligations. Research or technical partners may receive limited or de-identified information under contractual restrictions and may not use that information for unrelated advertising.

Traini uses Google and Firebase services to operate and understand the Services, deliver notifications, analyze performance, store and query data, and provide advertising. Depending on Traini's configuration, your location, and your choices, these services may process the following information:

Service

Primary purpose

Information typically processed

Firebase Analytics

Application measurement and feature analysis

App-instance identifiers, device and app information, sessions, interactions, approximate location, and configured events.

Google Analytics

Website and service measurement

Cookies or similar identifiers, IP-derived location, browser and device information, pages, sessions, referrals, and interactions.

Firebase Cloud Messaging

Push notifications

Device or registration token, app information, message-delivery status, and related technical data.

Google AdMob

Personalized and contextual advertising for eligible users

Advertising or device identifiers where permitted, IP address, device and app information, approximate location, consent signals, impressions, clicks, and conversions.

Google BigQuery

Data storage, analysis, reporting, fraud detection, and research

Analytics events, pseudonymous identifiers, usage records, and other information exported or uploaded by Traini for authorized business purposes.

Traini may show personalized and contextual advertising to eligible adult users. Personalized advertising may use prior activity, inferred interests, demographics, identifiers, or approximate location. Contextual advertising is based primarily on the content or context of the current screen or Service, although limited identifiers may still be used for frequency capping, fraud prevention, security, and aggregated reporting.

Traini does not provide personalized advertising to users it knows are under 18. For known minors, Traini applies available child or teen advertising treatment and may show only restricted contextual advertising where permitted.

Where consent is required, Traini or its consent-management provider will request consent before activating nonessential analytics, advertising identifiers, or personalized advertising. Available choices may be managed through Traini's privacy settings, a consent interface, device settings, or regional privacy controls. Where legally required and technically applicable, Traini recognizes Global Privacy Control signals.

We may disclose Personal Information to the following categories of recipients for the purposes described in this Privacy Policy:

• Service providers and contractors that support hosting, cloud infrastructure, artificial intelligence, analytics, data warehousing, notifications, advertising, payments, subscriptions, shipping, communications, support, security, content review, research, and professional services.
• Apple and Google in connection with app distribution, authentication, subscriptions, purchases, analytics, notifications, and advertising, as applicable.
• Stripe in connection with smart-collar purchases, collar memberships, direct subscriptions, refunds, fraud prevention, and transaction processing.
• Trainers, research institutions, technical partners, veterinarians, caregivers, or other users when you request a feature that requires the disclosure or direct Traini to make it.
• Government authorities, regulators, courts, law enforcement, and other parties when disclosure is required by law or reasonably necessary to protect rights, safety, property, animals, users, or the public.
• A buyer, investor, lender, professional adviser, or successor in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of Traini's business or assets, subject to appropriate safeguards.

Traini does not sell Personal Information for monetary consideration. Traini's use of AdMob and similar advertising technology may be considered a "sale," "sharing," or processing for targeted advertising under certain privacy laws. Eligible users may opt out as described in Section 13.

You must have the legal right to provide Traini with Personal Information about another person. This includes recordings, images, voices, contact information, messages, and information involving household members, veterinarians, trainers, caregivers, or bystanders. You are responsible for providing any required notice and obtaining any consent required to record, upload, or otherwise process that information.

Traini retains Personal Information for no longer than reasonably necessary for the purposes for which it was collected, including providing the Services, maintaining security, resolving disputes, enforcing agreements, meeting legal obligations, and supporting permitted Model Improvement. Retention periods vary according to the nature, sensitivity, context, and purpose of the information; the risk of harm from unauthorized use or disclosure; technical requirements; and applicable legal obligations.

• Account, profile, pet, and User Content may be retained while your account is active. Following a verified deletion request, eligible active-system data is generally scheduled for deletion within 30 days, subject to legal and operational exceptions.
• Residual copies may remain in encrypted backups for a limited backup cycle and will be deleted or overwritten according to Traini's backup schedule.
• Transaction, tax, warranty, fraud-prevention, safety, and dispute records may be retained for the period required by law or reasonably necessary to establish, exercise, or defend legal claims.
• Analytics, advertising, notification, and BigQuery information is retained according to Traini's configured settings and the applicable provider's retention controls. Aggregated reports may be retained longer when they no longer identify an individual.
• Information lawfully used for Model Improvement may be retained for model-development cycles. Disabling Model Improvement does not remove information from completed training or trained models.

Traini may retain information in de-identified or aggregated form when it takes reasonable measures to prevent re-identification and does not attempt to re-identify the information except as permitted by law.

Traini uses administrative, technical, and physical safeguards designed to protect Personal Information, including access controls, encryption in transit, security monitoring, and measures appropriate to the nature of the information. No method of transmission, storage, or security is completely secure, and Traini cannot guarantee absolute security. You are responsible for protecting your account credentials and devices and should notify support@traini.app promptly if you suspect unauthorized access.

Account and Communication Choices

• Review or update certain account information through available account settings.
• Enable or disable Model Improvement in Traini's privacy settings, subject to the future-only effect described in Section 7.
• Manage available analytics and advertising preferences through Traini, a consent interface, or device settings.
• Unsubscribe from marketing email using the link in the message and opt out of marketing SMS by replying STOP. Transactional, security, and administrative communications may continue.

Privacy Rights

Depending on where you live and subject to applicable exceptions, you may have the right to request access to Personal Information; obtain information about its collection, use, and disclosure; correct inaccuracies; request deletion; receive a portable copy; object to or restrict processing; withdraw consent; limit certain uses of sensitive Personal Information; and opt out of sale, sharing, targeted advertising, or certain profiling. You may also have the right to appeal a denied request or complain to a privacy regulator.

To exercise a privacy right, contact privacy@traini.app and describe your request. Traini may verify your identity and authority before completing a request. An authorized agent may submit a request where permitted by law, but Traini may require proof of authorization and direct confirmation from you. Traini will not discriminate against you for exercising a privacy right.

This section supplements the remainder of this Privacy Policy for California residents. During the preceding 12 months, Traini may have collected the categories of Personal Information described in Section 3; used them for the purposes described in Sections 5 through 8; and disclosed them to the categories of recipients described in Section 9. These categories may include identifiers; customer-record information; commercial information; internet or electronic-network activity; geolocation data; audio, electronic, visual, or similar information; inferences; and sensitive Personal Information, depending on how you use the Services.

California residents may have rights to know, access, correct, or delete Personal Information; obtain information about categories, sources, purposes, and recipients; limit certain uses or disclosures of sensitive Personal Information; and opt out of sale or sharing for cross-context behavioral advertising. Traini does not sell Personal Information for money. Traini may share identifiers, internet or electronic activity, approximate location, and advertising information with AdMob for cross-context behavioral advertising to eligible adult users unless they opt out.

Traini does not knowingly sell or share the Personal Information of users under 16 and does not provide personalized advertising to users it knows are under 18. California users may submit an opt-out request through available Traini privacy controls, by sending a Global Privacy Control signal where applicable, or by contacting privacy@traini.app.

The Services are not directed to children under 13. Children under 13 may not create an account or use the Services, and Traini does not knowingly collect Personal Information directly from children under 13. If you believe a child under 13 has provided Personal Information, contact support@traini.app so that Traini can investigate and, where appropriate, delete the information.

Users who are at least 13 but under 18 must have permission from a parent or legal guardian. Traini does not use content from known users under 18 for Model Improvement and does not provide personalized advertising to them. Traini may use age information and available age-assurance measures to apply appropriate privacy and safety protections.

A parent or guardian may contact Traini to ask about, correct, or request deletion of eligible information associated with a minor's account, subject to verification of identity and authority.

Traini and its service providers may process Personal Information in the United States and other countries where they operate. Those countries may have data-protection laws that differ from the laws where you live. Where required, Traini uses contractual, organizational, or other approved safeguards for international transfers.

Traini may update this Privacy Policy to reflect changes in the Services, technology, law, or business practices. Traini will post the revised Privacy Policy with an updated effective date and will provide additional notice when required by law. If a change requires consent, Traini will request consent before applying the change to processing that depends on it.

Questions, concerns, and privacy requests may be sent to support@traini.app or trainipet@gmail.com. Written correspondence may be mailed to Traini Inc, 1520 Sand Hill Road, Palo Alto, California 94304.