Toodles Privacy Policy
DRAFT - not legal advice - review before publishing
Last updated: 16 October 2026 (DRAFT)
Square brackets mark details still to be confirmed before publication.
11. Who we are
Toodles is run by ExHale Labs (ABN 84 525 889 101), an Australian business. We are responsible for the personal information described in this policy. You can contact us at help@toodles.dog about anything in this policy.
22. The short version
- Camera mode measures sound level and movement on the camera device itself. It does not record audio or video by default.
- Peek snapshots are optional, low-resolution still images. They are uploaded only during an active session and deleted when that session ends.
- We do not sell your personal information.
- Meta measurement runs only on our website, and only if you consent.
- You can delete your account in the app, on the website or by emailing us.
33. What we collect
| Information | What it is | Why we have it |
|---|---|---|
| Anonymous user ID | A random ID created on your device when you first open the app. On the web, we create a guest ID stored in your browser. | To keep your data together without needing your name. It also identifies your purchases across the app stores and the website. |
| Onboarding answers about your dog | For example your dog's name, age and the behaviours you see when left alone, plus your goal and the timing of your training. | To build your plan and starting point. |
| Training sessions | Planned absences, start and end times, outcomes, milestones and any short reflection you write. | To show your progress and adjust future sessions. |
| Camera signal levels | Numbers for sound level and movement during a session. These are not audio or video. | To show live status and send "Come back now" alerts. |
| Peek snapshots (optional) | Low-resolution still images, sent only during an active session. See section 4. | To let you check on your dog during a session. |
| Email address | Only if you give it to us to link an account or sign in on the website, or as part of a website sign-up. | To sign you in, save your progress and send service emails. |
| Support messages | Messages you send us, with the category you chose, the platform you use and any account details needed to answer. | To help you. |
| Purchase records | Subscription status, product, price, dates and the store or payment channel, from Apple, Google and our payment providers. | To unlock Premium, answer billing questions and keep tax and accounting records. |
| Notification token | A device token used to send you notifications, when you allow them. | To deliver alerts and reminders. |
| Usage and device data | App version, platform, device type and events such as screens viewed, sessions started, alerts shown and milestones reached. | To understand how the app and website are used and to fix problems. See section 6. |
| Web storage | Your guest ID and quiz answers saved in your browser's local storage. | To keep your place in the web quiz and checkout. |
44. The camera feature
- You set up camera mode on a spare phone (Toodles in camera mode) or in a laptop browser at toodles.dog/cam, using a 6-digit code.
- During a session, the camera device measures sound level and movement on the device. It sends us signal levels so that your phone can show a live status and alert you.
- No audio or video is recorded or uploaded by default. The camera device does not upload a video or audio stream.
- Peek snapshots are optional. When you turn them on, the camera device uploads a low-resolution still image during an active session. We keep only the latest snapshot, and we delete it when the session ends.
- During a session, we keep only the most recent 60 seconds of signal readings for the live view. Session summaries, such as how calm the session was, stay in your training history until you delete them.
- Other people: you are responsible for telling people in your home and visitors that a camera is in use, and for following recording laws where you live. See the Terms of Use, section 6.
- You can remove a camera device at any time in the app.
55. How we use your information and our legal basis
| Purpose | Information used | Legal basis (EU and UK users) |
|---|---|---|
| Provide the app and website: plans, sessions, camera mode, alerts, progress | Anonymous ID, dog profile, sessions, signal levels, snapshots if you turn them on | Performing our contract with you |
| Health-related training logs and camera readings | Training logs, signal levels and reflections, which can include health-related information about your dog and household | Your consent (see section 6) |
| Unlock Premium and handle billing | Purchase records, store and payment channel | Performing our contract; legal obligation for tax and accounting records |
| Respond to support requests | Support messages and account details | Performing our contract; our legitimate interests in providing support |
| Sign-in, security, fraud prevention and abuse limits | Anonymous ID, email, device and request data | Our legitimate interests in keeping the Service secure |
| Understand how the app and website are used, and improve them | Usage and device data | Our legitimate interests in improving the Service (see section 6) |
| Measure website advertising | Website events, only with consent | Your consent |
| Service emails, such as sign-in codes and purchase confirmations | Email address | Performing our contract |
We do not send marketing emails unless you opt in. We do not send marketing push notifications.
66. Analytics, advertising and consent
Analytics. We use PostHog to see how the app and website are used. Analytics events are linked to your anonymous ID and include things such as when a session starts, when an alert is shown and which milestones are reached. Some of these events relate to your dog's training, and those events are sent to our analytics provider.
Meta measurement (website only). If you accept the consent choice on our website, we send website events to Meta through the Meta Pixel and the Meta Conversions API so that Meta can measure and optimise our advertising. These events may include details of the pages you view and the steps you complete in our web quiz, such as starting or finishing a step. If you decline, these events are not sent to Meta. We do not use Meta measurement in the app.
Health-related information consent. When you start Toodles, the first screen says:
By tapping Get started, you agree to our Terms and consent to Toodles keeping your training logs and camera readings, which can include health-related information about your dog and your household.
You can withdraw this consent at any time by deleting your account, or by emailing help@toodles.dog. Withdrawing consent may mean we can no longer provide the Service.
77. Who we share information with
We do not sell your personal information.
We share information only with:
- Apple and Google, which distribute the app and process purchases made through the App Store and Google Play;
- Meta, for the website measurement described in section 6, and only if you consent;
- our service providers, who act on our instructions to run the Service. These are providers of:
- hosting and database services;
- payment and subscription management, including the provider that processes website payments;
- sign-in services for the website;
- analytics;
- email delivery;
- push notification delivery;
- authorities or others, when the law requires it, or to protect people's safety or our legal rights.
A named list of our service providers is available on request. Email help@toodles.dog to ask for it.
If we ever sell or transfer all or part of Toodles, your information may be transferred as part of that deal. We will tell you if this happens.
88. Where your information is stored
We and our service providers store and process information in Australia and in other countries, including the United States [TO CONFIRM locations]. Those countries may have different privacy laws.
- For Australian users, when we disclose personal information to overseas recipients, we take reasonable steps to make sure they handle it in line with the Australian Privacy Principles, as the Privacy Act requires.
- For users in the EU or UK, where information is transferred outside the EEA or UK, we use the safeguards the law requires, such as adequacy decisions or standard contractual clauses.
99. How long we keep information
| Information | How long we keep it |
|---|---|
| Account, dog profile, training sessions and milestones | Until you delete your account |
| Peek snapshots | Deleted when the session ends |
| Live signal readings | Only the most recent 60 seconds of a session |
| Support messages | While your account exists. Messages from people without an account are kept for [12] months. |
| Email addresses for web leads | Until you unsubscribe or ask us to delete them |
| Analytics events in our own store | 180 days, then deleted |
| Analytics events in our analytics provider | [TO CONFIRM retention setting] |
| Purchase records | [5] years after the transaction, for tax and accounting, anonymised where possible |
| Notification tokens | Until you turn off notifications or delete your account |
| Backups | Deleted within [90] days after the source data is deleted |
When we no longer need information for the purposes in this policy, we delete it or make it anonymous.
1010. Deleting your information
You can delete your account in any of these ways:
- In the app: Settings, then Delete account.
- On the web: sign in and go to toodles.dog/account/delete.
- By email: write to help@toodles.dog from the email address on your account. We may need to check it is you.
When you delete your account, we delete your dog profile, training sessions, camera devices, support messages, web leads and the analytics events linked to your anonymous ID. We keep purchase records only in anonymous form, where the law requires us to keep them. Data in backups is deleted as described in section 9.
Deleting your account does not cancel a store subscription. See the Subscription Terms.
1111. Your rights
You can ask us for access to, or correction of, your personal information, and you can ask us to delete it. How we handle your request depends on where you live.
Australia. Under the Privacy Act 1988 and the Australian Privacy Principles, you can request access to (APP 12) and correction of (APP 13) your personal information. If you are not happy with how we handle a complaint, you can contact the Office of the Australian Information Commissioner at oaic.gov.au.
EU and UK. Under the GDPR and the UK GDPR, you can ask us for access to your information, correction, deletion, restriction of processing, a copy of your information in a portable format, and you can object to processing based on our legitimate interests. You can withdraw consent at any time. We will respond within one month, and we may extend this by two months for complex requests. You can also complain to the data protection authority in your country, or to the UK Information Commissioner's Office.
United States. Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and similar state privacy laws, you can ask us to tell you what personal information we hold, to delete or correct it, and to opt out of the sharing of your personal information for targeted advertising. We do not sell personal information. Meta measurement on our website only happens with your consent, and you can opt out by declining the consent choice or by using a Global Privacy Control signal in your browser, which we honour on our website. We will not discriminate against you for using these rights.
To make a request, use the in-app or web deletion options, or email help@toodles.dog. We may need to verify your identity before we act on a request. You can also use an authorised agent, and we may ask them to show they have your permission.
1212. Children
- Toodles is for people aged 13 or older. See the Terms of Use, section 2.
- We do not knowingly collect personal information from children under 13. If we learn that an account belongs to a child under 13, we will delete it.
- If you think a child under 13 has given us personal information, please email help@toodles.dog.
1313. Security
- Information is sent to and from our servers over encrypted connections.
- Our database can only be accessed by our servers. The apps and the website cannot read it directly.
- Access to personal information is limited to people who need it to run the Service, and our admin tools require secure sign-in.
- Camera mode keeps audio and video on the camera device.
- No system is completely secure. If a data breach is likely to cause serious harm, we will notify you and the Office of the Australian Information Commissioner as the Notifiable Data Breaches scheme requires, and we will meet any equivalent obligations in the EU or UK.
1414. Your choices
- Notifications: turn them off in your phone settings. Session reminders, alerts and the trial reminder can be managed there.
- Camera access: you can revoke camera permission in your device settings at any time, which stops camera mode. You can also remove a camera device in the app.
- Peek snapshots: you can keep them off. They are off unless you turn them on.
- Email: you do not have to give us an email address to use the app.
- Website measurement: you can accept or decline Meta measurement with the consent choice on our website.
1515. Changes to this policy
We may update this policy. If a change is material, we will tell you in the app or by email before it takes effect. The "Last updated" date at the top shows when it last changed.
1616. Contact
ExHale Labs (ABN 84 525 889 101) Email: help@toodles.dog Postal address: [TO CONFIRM]