Privacy Policy

Last updated: 19 April 2026

Scope

This Privacy Policy applies to:

·       the Shop, where WagglyHub is the seller/trader of record for products offered through www.wagglyhub.com; and

·       the Services Marketplace, where independent service providers offer pet-related services to users through our platform.

This Policy applies to www.wagglyhub.com and related website pages, features, customer support channels, and services (together, the "Service").

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1. Who we are

WagglyHub SRL ("WagglyHub", "we", "us", "our") is the controller of the personal data described in this Policy, except where this Policy explains otherwise.

·       Registered office: Avenue du Globe 51, 1190 Forest (Brussels), Belgium

·       Belgian Company Number (BCE/KBO): 1028163475

·       VAT: BE1028163475

·       Contact: support@wagglyhub.com

Our lead supervisory authority is the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit). If you are located in the European Economic Area, you also have the right to lodge a complaint with the supervisory authority of your Member State of habitual residence, place of work, or place of the alleged infringement.

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2. How our platform works

WagglyHub operates:

·       an online Shop for products; and

·       a Services Marketplace where users may find, book, and interact with independent pet service providers.

In the Services Marketplace, service providers act as independent controllers for the personal data they receive and use to perform their services. WagglyHub remains controller for the personal data it processes to operate the platform itself, including account management, booking flows, support, trust and safety, fraud prevention, review systems, and related platform operations.

For certain limited activities (in particular, platform messaging and the operation of the public review system relating to a specific professional), WagglyHub and the relevant service provider may act as joint controllers within the meaning of Article 26 GDPR. Where that is the case, a summary of the essence of our joint-controller arrangement is available on request at support@wagglyhub.com.

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3. What data we collect

3.1 Account and contact data

·       name

·       email address

·       telephone number

·       postal address

·       account identifiers

·       user type or profile role (for example, customer, pet owner, or professional)

·       preferences and communication settings

3.2 Identity and access data

We use Microsoft Entra as part of our identity and access management setup. We may process authentication and related access-control data necessary to allow you to securely access and use the Service.

3.3 Shop order and transaction data

When you purchase products in the Shop, we may collect:

·       products ordered

·       cart and checkout information

·       billing and shipping details

·       order history

·       returns

·       refunds

·       customer service communications relating to orders

3.4 Services Marketplace data

When you use the Services Marketplace, we may collect and process:

·       service search and listing interaction data

·       booking and reservation details

·       information you provide to request or receive a service

·       communications between users and service providers through the platform

·       support and dispute-related information

·       review and rating data after a completed service

3.5 Professional profile data

For service providers, we may collect and display profile information such as:

·       personal or business name

·       trading name

·       profile photo

·       service location

·       profile description

·       qualifications or service-related information provided by the professional

·       availability or service information

·       public reviews and aggregated ratings

Certain elements of a professional profile may be made publicly visible by design of the marketplace or according to the professional's account settings and submitted profile content.

3.6 Pet-related information

Where relevant to a requested service, users may provide information relating to their pet, such as:

·       pet name, species, breed, age, weight

·       behavioural notes

·       special care requirements

·       medication or care instructions

We ask users to provide only the information reasonably necessary for the requested service and to avoid sharing unnecessary personal data in free-text fields or messages.

Special categories of personal data. WagglyHub does not seek and does not knowingly process special categories of personal data within the meaning of Article 9 GDPR (such as health data, biometric data or data concerning ethnic origin). If you choose to share information about your own health (for example, in pet care notes or messages), please limit it to what is strictly necessary for the requested service.

3.7 Payment data

We use third-party payment providers, including Stripe, to process payments and, where applicable, professional onboarding, verification, and payouts to service providers.

For Marketplace transactions, WagglyHub acts as the receiving merchant of record and therefore receives and processes payment-related data for the purpose of payment collection, settlement to service providers, fraud prevention, refunds, chargebacks and accounting. We do not store full payment card details on our own systems. The data we may receive includes: payment status, transaction identifiers, amount and currency, refund status, payout and transfer status, dispute and chargeback records, anti-fraud signals, and other information necessary to manage bookings, purchases, cancellations, refunds, fraud prevention, and support.

3.8 Provider verification, payout and trader-traceability data

For service providers, we collect or receive data needed to operate the marketplace and to comply with legal, tax and payment-provider requirements. This includes data processed for trader traceability under Article 30 of the Digital Services Act (DSA) and for tax reporting under Council Directive (EU) 2021/514 (DAC7).

Typical categories collected and held by WagglyHub:

·       company or legal name

·       business address

·       VAT or business registration number

·       tax identification number (TIN) and Member State of residence

·       self-certification of compliance with applicable law

·       verification status received from our payment service provider (for example, confirmation that the provider has been verified and is enabled to receive payouts)

·       payout-related summary information (such as payout status and transaction identifiers)

·       supporting business information where required

Identity documents and payment account details (such as IBAN) required for KYC verification, anti-money-laundering checks and payouts are collected and held directly by our payment service provider, which acts as a separate controller for that processing under its own privacy notice. WagglyHub does not store these documents or full payment account details on its own systems and only receives the verification outcome and limited payout-related metadata.

3.9 Device, usage, and log data

·       IP address

·       device identifiers

·       browser type

·       pages viewed

·       timestamps

·       error reports

·       diagnostics and security logs

3.10 Communications and support data

·       emails

·       support tickets

·       messages sent through platform messaging tools

·       records relevant to complaint handling, dispute resolution, moderation, trust and safety, or abuse prevention

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4. How we collect data

We collect personal data:

·       directly from you, when you create an account, place an order, request a service, contact us, or use features of the Service;

·       automatically, when you use the Service (through cookies and similar technologies, subject to your choices, and through server and application logs);

·       from other users and service providers, in the context of bookings, disputes, reviews, messages or support interactions;

·       from third-party providers that support the Service, including payment (Stripe), identity (Microsoft Entra), Shop infrastructure (Shopify), and other security, analytics, communications, hosting and support providers;

·       from public or regulatory sources, where necessary for verification, anti-fraud, or legal compliance purposes.

Where required by Article 14 GDPR, we will provide the relevant information through this Policy and/or by additional notice.

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5. Why we use your data and our legal bases

We use personal data for the purposes listed below. For each purpose we identify the legal basis under Article 6 GDPR on which we rely.

Purpose	Legal basis
Create and manage user accounts; authenticate access	Performance of a contract (Art. 6(1)(b))
Provide the Shop, process orders, deliveries, returns and refunds	Performance of a contract (Art. 6(1)(b))
Provide the Services Marketplace, operate bookings, cancellations and refunds	Performance of a contract (Art. 6(1)(b))
Operate public professional profiles and review systems	Performance of a contract with the professional (Art. 6(1)(b)); legitimate interests of users and of WagglyHub in a transparent marketplace (Art. 6(1)(f))
Provide customer support and handle complaints	Performance of a contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f))
Prevent, detect and investigate fraud, abuse and security incidents; enforce our terms	Legitimate interests in protecting users, professionals and the platform (Art. 6(1)(f)); legal obligation where applicable (Art. 6(1)(c))
Trader traceability under Article 30 DSA	Legal obligation (Art. 6(1)(c))
Tax reporting under DAC7 and other accounting / tax obligations	Legal obligation (Art. 6(1)(c))
Comply with consumer-protection, marketplace and other applicable legal obligations	Legal obligation (Art. 6(1)(c))
Improve the performance, quality and user experience of the Service	Legitimate interests in improving the Service (Art. 6(1)(f))
Send service-related communications	Performance of a contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f))
Send marketing communications	Consent (Art. 6(1)(a)) or, where permitted, legitimate interests in marketing our own similar products or services to existing customers (Art. 6(1)(f)), subject to an easy opt-out
Set non-essential cookies and similar technologies	Consent
Establish, exercise or defend legal claims	Legitimate interests (Art. 6(1)(f)); legal obligation where applicable

Where we rely on legitimate interests, we balance those interests against your rights and freedoms. You have the right to object at any time in the circumstances provided by law (see Section 15).

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

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6. Who receives your data

Depending on how you use the Service, we may share personal data with:

·       Shopify, for Shop infrastructure and order-related operations, including checkout, order processing, and related Shop functionality;

·       Microsoft Entra, for identity and access management;

·       Stripe, for payments, professional onboarding, verification and payouts;

·       independent service providers in the Services Marketplace, where data sharing is necessary to deliver the requested service;

·       other processors supporting the Service, such as hosting, email delivery, analytics, customer-support, security, and logistics partners;

·       professional advisers, auditors and insurers, where necessary to protect our legal position;

·       tax authorities, in particular the Belgian tax administration (SPF Finances / FOD Financiën), in the context of DAC7 reporting and other tax obligations;

·       public authorities, regulators and courts, where required by law or necessary to comply with legal obligations or to establish, exercise or defend legal claims;

·       a buyer, seller, investor or successor entity, in connection with a corporate transaction, subject to appropriate safeguards.

We maintain an up-to-date list of our main sub-processors, which is available on request from support@wagglyhub.com.

Where recipients process personal data on our behalf, they do so under appropriate contractual and data-protection safeguards. Where recipients act as independent controllers or joint controllers, their own privacy notices and arrangements apply to their subsequent processing.

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7. International transfers

WagglyHub operates from the European Union and seeks, where reasonably feasible, to use providers and configurations that support storage and primary processing of personal data within the European Union or European Economic Area (EU/EEA).

However, some of our service providers may, depending on the service, support model, or technical configuration, access or transfer certain personal data outside the EU/EEA. Where this occurs, WagglyHub will ensure that an appropriate transfer mechanism under Chapter V GDPR is in place, such as:

·       an adequacy decision of the European Commission;

·       the EU-U.S. Data Privacy Framework, where the recipient is certified; or

·       Standard Contractual Clauses, together with supplementary measures where necessary.

You can obtain more information about the safeguards applied to relevant transfers by contacting support@wagglyhub.com.

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8. Retention

We keep personal data only for as long as necessary for the purposes described in this Policy, including to provide the Service, comply with legal obligations, resolve disputes, enforce agreements and protect our legal position. The table below sets out our indicative retention periods. Actual retention may be longer where required or permitted by law.

Category	Indicative retention
Active account data	For the duration of the account
Inactive accounts	Deleted or anonymised after 24 months of inactivity, subject to legal retention obligations
Shop order, invoice, accounting and VAT records	7 years from the end of the relevant financial year (Belgian accounting and VAT law)
Contracts and related commercial records	Up to 10 years after the end of the contractual relationship, where required or justified by applicable law or limitation periods
Booking and service-related records	Duration of the service plus up to 5 years for dispute and claims purposes
Trust and safety, fraud prevention and moderation records	Up to 5 years after the last relevant event
Provider verification documentation	For the duration of the professional relationship and, where required by law, for an additional retention period
DAC7 tax-reporting data	10 years, in line with applicable Belgian law
DSA Article 30 trader-identification data	For the duration of the contractual relationship and for any further period required under Article 30 DSA and applicable law
Platform messages	Up to 24 months after the related booking or last message, unless longer retention is needed for dispute or safety purposes
Reviews and ratings	While the professional profile remains active, or longer where necessary to ensure the integrity of the review system
Technical logs and security events	Up to 12 months, except where a longer period is necessary for security investigations
Analytics and cookie-based data	According to the retention periods set out in our Cookie Policy
Marketing consents and opt-outs	Until consent is withdrawn, then retained as a suppression record

We may delete or irreversibly anonymise personal data when it is no longer needed.

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9. Marketplace-specific privacy roles

9.1 WagglyHub

WagglyHub is controller for the personal data it uses to:

·       operate the platform and manage user accounts

·       manage bookings and orders

·       provide platform messaging and support

·       operate review systems

·       prevent fraud and abuse

·       enforce platform rules and terms

·       comply with legal obligations

·       improve and secure the Service

9.2 Service providers

Service providers are independent controllers for the personal data they receive and process to perform their services. This may include contact details, address data where home services are provided, booking details, pet-related service information, communications and other information needed to perform the requested service.

Service providers are responsible for complying with their own data-protection obligations and for providing any privacy information required under applicable law.

9.3 Joint controllership

For certain limited activities (notably platform messaging and the operation of the public review system in relation to a specific professional), WagglyHub and the relevant service provider may act as joint controllers under Article 26 GDPR. A summary of the essence of our joint-controller arrangement is available on request at support@wagglyhub.com.

Regardless of how responsibilities are allocated between joint controllers, you may exercise your rights under the GDPR in respect of, and against, each of the joint controllers.

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10. Messages, reviews, and public content

Messages

Where messaging functionality is available, WagglyHub may access, review and process messages exchanged through the platform where reasonably necessary for:

·       customer support

·       dispute resolution

·       fraud or abuse prevention

·       trust and safety

·       enforcement of our terms and policies

·       legal compliance

Users should avoid sharing unnecessary personal data or unrelated sensitive information in messages and should limit shared information to what is relevant for the requested service.

Reviews

Users may be invited to submit reviews only in relation to eligible completed services. In line with Directive (EU) 2019/2161 (Omnibus Directive) and applicable national consumer-protection rules, we take reasonable and proportionate steps to verify that published reviews originate from users who have actually booked or purchased the relevant service.

Reviews may be published in anonymous form and may contribute to an aggregated rating visible on professional profiles. We may moderate, remove or restrict reviews where necessary to enforce our terms, prevent abuse or comply with legal obligations.

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11. Automated decision-making and profiling

We may use automated tools to support fraud detection, abuse prevention, security monitoring, trust and verification processes, and the efficient operation of the Service.

These tools are intended to support operational decision-making. WagglyHub does not take decisions producing legal effects or similarly significantly affecting individuals solely by automated means within the meaning of Article 22 GDPR. If this changes, we will update this Policy and provide any additional information required by applicable law.

Information on how our search and ranking systems work, including the main parameters that determine whether and how a professional's listings appear in search results, is set out in our Terms of Service, in line with Article 27 of the Digital Services Act.

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12. Digital Services Act disclosures

WagglyHub operates an online platform that allows consumers to conclude distance contracts with traders (our service providers) and processes personal data to comply with applicable obligations under Regulation (EU) 2022/2065 (Digital Services Act, DSA).

In particular, under Article 30 DSA (traceability of traders), before allowing a service provider to offer services through the Services Marketplace, we collect and, where required, verify identification and contact information about the trader, such as legal name, trading name, address, telephone number, email address, business-register entry where applicable, VAT or tax identification number, and a self-certification that the provider will offer only products or services complying with applicable EU law.

Identity-document verification and payment-account identification required for these purposes are carried out by our payment service provider, which acts as a separate controller for that processing under its own privacy notice. WagglyHub relies on the verification outcome confirmed to it by that provider.

Data collected for DSA-compliance purposes is processed on the basis of a legal obligation (Article 6(1)(c) GDPR).

Further operational information, including our notice-and-action mechanism, statements of reasons and internal complaint-handling system, is set out in our Terms of Service.

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13. Tax reporting under DAC7

WagglyHub is an operator of a digital platform facilitating the provision of relevant services for consideration and is therefore subject to Council Directive (EU) 2021/514 (DAC7), as implemented into Belgian law.

This means that, in relation to service providers that qualify as reportable sellers:

·       we collect and verify identification data required by law, including name or business name, address, TIN and Member State of residence, VAT or business-registration number, and other information specified by law;

·       we report to the Belgian tax administration (SPF Finances / FOD Financiën) the required information about reportable sellers and the consideration they have received through the platform, on an annual basis;

·       the Belgian tax administration may share that information with tax authorities of other EU Member States, and with competent authorities of certain non-EU jurisdictions that have entered into equivalent arrangements;

·       we retain DAC7 data for the period required by applicable Belgian law (currently 10 years);

·       where required by law, we provide reportable sellers with a copy of the information reported about them.

The legal basis for this processing is compliance with a legal obligation (Article 6(1)(c) GDPR).

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14. Security

We implement appropriate technical and organisational measures designed to protect personal data and to help prevent unauthorised access, misuse, loss or disclosure. These measures include, depending on the nature of the processing:

·       encryption of data in transit and, where appropriate, at rest;

·       access controls, authentication and role-based permissions;

·       logging, monitoring and alerting on security events;

·       separation of environments and segregation of duties;

·       vendor due diligence and contractual security commitments with sub-processors;

·       regular review of our security practices, incident-response procedures and backups.

We continuously review and improve our security practices in line with the nature of the Service and the risks involved. The implementation of these measures is proportionate to the nature, scale and risks of the Service, and to WagglyHub's size and resources at any given time, in accordance with Article 32 GDPR.

Personal data breaches

In the event of a personal data breach, we will comply with our obligations under Articles 33 and 34 GDPR. Where required, we will notify the Belgian Data Protection Authority without undue delay and, where the breach is likely to result in a high risk to your rights and freedoms, we will inform affected individuals without undue delay in a clear and intelligible manner.

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15. Your rights

Subject to applicable law, you have the right to:

·       access your personal data and obtain a copy;

·       request rectification of inaccurate or incomplete data;

·       request erasure ("right to be forgotten") in certain circumstances;

·       request restriction of processing;

·       object to processing based on legitimate interests, on grounds relating to your particular situation;

·       object at any time and absolutely to the processing of your personal data for direct marketing purposes, including any related profiling (Article 21(2) GDPR);

·       receive your data in a structured, commonly used and machine-readable format and, where technically feasible, have it transmitted to another controller (data portability);

·       withdraw consent at any time where processing is based on consent;

·       lodge a complaint with a supervisory authority, including in the Member State of your habitual residence, place of work or place of the alleged infringement, and in Belgium with the Belgian Data Protection Authority.

To exercise your rights, contact us at support@wagglyhub.com. We may need to verify your identity before responding. We will handle your request in accordance with applicable data-protection law and, in any event, within one month of receipt. That period may be extended by two further months where necessary, taking into account the complexity and number of requests, in which case we will inform you.

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16. Service Audience

The Service is intended exclusively for adults. We do not direct the Service to minors, do not knowingly create accounts for minors, and do not knowingly process personal data of minors.

If we become aware that personal data of a minor has been provided to us, we will delete that data without undue delay and may suspend or terminate the related account.

If you believe that a minor has provided personal data to us, please contact support@wagglyhub.com.

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17. Cookies and similar technologies

We use cookies and similar technologies to:

·       make the Service work properly;

·       maintain security and session integrity;

·       remember preferences;

·       measure performance and usage;

·       support marketing and advertising, where you consent.

Strictly necessary cookies and similar technologies are used where required for the operation, security and core functionality of the Service. Analytics, advertising and other non-essential technologies are used only where you have given prior consent, which you can refuse or withdraw at any time as easily as you can give it.

We use a consent-management mechanism to collect and manage your choices. You can change your cookie preferences at any time through the cookie settings link available on the website.

For more detailed information, please see our Cookie Policy.

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18. Marketing communications

We may send you service-related communications where necessary to provide the Service.

We may also send marketing communications about products, services, updates or offers where you have consented or where otherwise permitted by applicable law.

You can unsubscribe from marketing communications at any time, free of charge, by using the unsubscribe link in the message or by contacting us at support@wagglyhub.com. You also have an absolute right to object to processing for direct-marketing purposes under Article 21(2) GDPR.

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19. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version and revise the "Last updated" date. Where the changes are material, we will provide additional notice, for example by email or through the Service.

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20. Contact us

·       Contact: support@wagglyhub.com

·       Postal address: WagglyHub SRL, Avenue du Globe 51, 1190 Forest (Brussels), Belgium