Privacy Policy
Last Updated: 2026-06-01
Introduction
Cutu! and/or Cutu.app (“the App”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services.
Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use the App.
- Company Name: SC Astra Invent Tech SRL
- Contact Email: contact@astrainvent.com
- Address: Str. Albastrelelor nr. 15 birou 2Z, Brasov, Brasov, Romania, 500381
- Authentication credentials from social login providers (Google and Apple)
- Google ID and Apple ID linked to your account
- Email address associated with your social login
1.2 User-Generated Content
- Dog Profiles: Images, name, breed, and other text attributes describing your dog(s)
- Spots: Images, GPS coordinates of the spot location, name, and descriptive text
- Playdates: Date, time, name, description, associated spot reference, and text attributes
- Check-ins: Date and time of check-in, associated spot reference
1.3 Location Data
Precise GPS location is collected but stays on your device:
- To display distances from your location to spots
- To help you find the nearest spots
Precise GPS location is collected and sent to the server, then immediately discarded:
- To validate that you are within the required radius when checking in to a spot
- To enable background passive perimeter-based check-ins
Precise GPS location is collected and stored on the server indefinitely:
- When you create a new spot, we store the GPS coordinates you provide
- Messaging/push notification tokens (stored on server when notifications are enabled)
- Device type (iOS or Android)
- App version
1.5 Communications
- Messages and interactions through the App
- Reports of inappropriate content
We use the information we collect for the following purposes:
- Authenticating your account and maintaining your session
- Creating, storing, and retrieving your dog profiles, spots, playdates, and check-ins
- Displaying content from other users relevant to your interests
- Calculating distances and geographic information
- Validating check-ins and enabling passive check-in functionality
- Sending push notifications (based on your preferences)
- Providing and improving the App’s functionality
- Enforcing our terms and conditions
- Preventing fraud and ensuring security
- Complying with legal obligations
3. Data Sharing & Third Parties
3.1 Third-Party Service Providers
We share your data with the following third parties only to the extent necessary to provide the App:
- Hosting Provider: Hetzner (servers in Finland) - stores all user data and database
- Apple APNS & Google Firebase FCM - to deliver push notifications (messaging tokens only)
- Google Maps - to provide in-app map display and location services
- Cloudflare CDN - to deliver images securely
3.2 Data Sharing Practices
- Personal data is not sold to third parties
- Personal data is not shared for marketing purposes
- Shared information is limited to what is functionally necessary to provide the service
4. Public Nature of Social Content
4.1 What Is Public by Default
Dog Profiles:
- Only the first letter of your dog’s name and profile image are visible to all users by default
- You can adjust privacy settings to make your full profile visible to:
Spots:
- All user-contributed information (images, name, GPS coordinates, descriptions) is public by default
- Any user can view spots and associated information
Check-ins:
- All check-ins are public by default
- This means other users can see that you checked in at a particular spot at a particular time
- The exact check-in time and spot location are disclosed
Playdates:
- Public Playdates: Fully visible to all users, including location, time, attendees, and details
- Private Playdates: Only visible to invited users
Friend Connections:
- Your friend list and connections are visible to other users
Leaderboards:
- Rankings are visible by default
- May indirectly expose location and time information through activity patterns
Achievements:
- Achievements are visible by default
- May indirectly expose location and time information
4.2 Timestamps and Location Visibility
- Spots: Exact GPS location is publicly visible
- Playdates: Exact time is publicly visible; location can be inferred from the associated spot
- Check-ins: Time and location are not explicitly displayed but can be inferred from the check-in timestamp and associated spot
- Leaderboards: Can be used to infer location and time patterns
- Achievements: Can be used to infer location and time patterns
5. Location Services & Tracking
5.1 When Location Tracking Is Enabled
Foreground Location Tracking:
- Enabled when you manually start the tracking function with the App in the foreground
- Used to verify your eligibility to check in to a spot
- Used to display your location on maps and show distances to spots
Background Location Tracking:
- Enabled only when you specifically choose to enable background location tracking for passive check-ins
- Allows the App to automatically check you in to a spot if you enter the perimeter while the App is running in the background
- Requires your explicit permission
5.2 Precise Location Data Handling
- Precise location data collected for check-in validation is not stored after validation completes
- Precise location data for passive check-ins is not stored after validation completes
- Precise location data is stored indefinitely only for spots you create
6. Push Notifications & Device Data
6.1 Notification Tokens
- If you enable notifications, your device’s messaging token is stored on our servers
- Tokens are stored only for the duration you have notifications enabled
6.2 Notification Preferences
You can choose which types of notifications you receive (or disable all notifications) through the Notifications section of the App:
- News
- Promotional
- Playdates notifications
- Leaderboard updates
- Passive check-in notifications
7. Accounts & Authentication
7.1 Social Login
All accounts are created using social login only:
Your account is tied to the identity provider you choose.
7.2 Account Linking
The server stores the following information to maintain your account:
- Google ID or Apple ID (depending on which provider you use)
- Email address associated with your social login account
8. Your Privacy Rights & Controls
8.1 Access & Download
- You can download your data from within the App at any time
- Your download includes all your personal information and user-generated content
8.2 Editing & Deletion
- You can edit your dog profiles and playdates at any time
- You cannot edit spots once created
- You can delete your account from within the App
8.3 Account Deletion
When you delete your account:
- Server data: Deleted immediately
- Logs: Deleted after 30 days
- Backups: Deleted after 30 days
- Note: Spots you created remain on the system, but associated images and account-specific data are removed
9. Data Retention
- Account Data: Retained for 2 years since your last login. After 2 years, your account and associated data are automatically deleted
- Spots: Remain on the system even if your account is deleted; only account-contributed extras (like images) are removed
- Backups: Automatically deleted 30 days after creation
- Logs: Automatically deleted 30 days after creation
10. Data Security
We implement the following security measures to protect your information:
- Encryption in Transit: All data transmitted to and from the App is encrypted using TLS (Transport Layer Security)
- Encryption at Rest: All stored data is encrypted
- Content Moderation: All images must be approved by staff before being visible to other users
- Reporting System: Users can report inappropriate content, which is reviewed and actioned accordingly
- Staff Review: Images and reported content are reviewed by our moderation team
11. Children & Age Restrictions
- Minimum age to use the App is 18 years old
- By using the App, you represent and warrant that you are at least 18 years old
- Users are expected to be fully responsible for their safety and the safety of their dogs
- Users should be cautious when interacting with other users and respect privacy boundaries
12. Analytics
- The App does not collect analytics data
- The App does not track users across third-party apps or websites
- We do not use analytics services
13. International Data Transfers
Your data is transferred to and stored in the following jurisdictions:
- Primary Data Storage: Hetzner servers in Finland (all user data and database)
- Image Delivery: Cloudflare CDN (globally distributed)
- Notifications: Apple APNS (Apple’s infrastructure) and Google Firebase FCM (Google’s infrastructure)
- Maps: Google Maps infrastructure
By using the App, you consent to the transfer of your personal data to these jurisdictions, which may have different data protection laws than your country of residence.
14. Third-Party Services & Links
14.1 External Services
The App integrates with the following third-party services:
- Google: For authentication and map services
- Apple: For authentication and push notifications
- Firebase (Google): For push notification delivery
- Cloudflare: For image content delivery
14.2 Third-Party Privacy
These third parties have their own privacy policies. We encourage you to review their privacy policies:
We are not responsible for the practices of third-party services.
15. User-Generated Content & Moderation
15.1 Content Guidelines
- Users are responsible for the content they post
- Content must comply with applicable laws and our terms of service
- Inappropriate or illegal content will be actioned
15.2 Reporting & Enforcement
- Users can report dog profiles, spots, and playdates for moderation
- Staff will review reported content and take appropriate action
- Reports may be retained for safety and fraud prevention purposes
15.3 Image Approval
All images uploaded by users must be approved by staff before they are visible to other users. This review process may take time.
16. Legal Basis for Processing (GDPR)
We process your personal data under the following legal bases:
16.1 Contractual Necessity
- Account creation and maintenance
- Providing the App’s core features and services
- Processing check-ins, spots, and playdates
16.2 Consent
- Location data collection (with your explicit permission for background location)
- Push notifications
- Marketing communications
16.3 Legitimate Interests
- Security and fraud prevention
- Abuse prevention and content moderation
- App improvement and bug fixes
- Legal and regulatory compliance
16.4 Legal Compliance
- Compliance with court orders or legal requests
- Compliance with applicable laws and regulations
16.5 Your Consent Rights
For processing based on consent, you may withdraw your consent at any time by:
- Disabling location services in your device settings or App settings
- Disabling push notifications in the App’s Notifications section
- Deleting your account
17. Data Subject Rights (for EU Residents)
If you are a resident of the European Union, you have the following rights under the General Data Protection Regulation (GDPR):
- Right of Access: You can request a copy of your personal data
- Right of Rectification: You can correct inaccurate personal data
- Right of Erasure: You can request deletion of your personal data
- Right to Restrict Processing: You can request restriction of data processing
- Right to Data Portability: You can request your data in a portable format
- Right to Object: You can object to processing of your personal data
- Right to Lodge a Complaint: You can file a complaint with your supervisory authority
To exercise these rights, contact us at contact@astrainvent.com.
18. Permissions Used
The App requests the following device permissions:
18.1 Location Permissions
- Foreground Location: Required to verify check-in eligibility, create spots at specific locations, display your location on maps, and calculate distances
- Background Location: Optional; enables passive check-ins when you visit a spot but forget to open the App
18.2 Camera and Photos
- Camera/Photo Library: Allows users to add photos to dog profiles and create new spots
18.3 Notifications
- Push Notifications: Allows the App to send you notifications for events you’ve opted into
- Contacts: Not used by the App
19. US State Privacy Notices
19.1 CCPA/CPRA Disclosures (for California Residents)
- We do not sell personal information to third parties
- We do not share personal information for targeted advertising
- Personal information shared with third parties is limited to what is functionally necessary to provide the App (notifications, maps)
- You have the right to opt-out of any sale or sharing (which we do not engage in)
If you have questions about this Privacy Policy or our privacy practices, please contact us at:
20.2 Policy Changes
We may update this Privacy Policy from time to time. We will notify you of significant changes by:
- Posting the updated policy in the App
- Updating the “Last Updated” date at the top of this policy
Your continued use of the App following notice of changes constitutes your acceptance of the updated Privacy Policy.