PRIVACY POLICY

TraksPet Application

Version 1.2 — Last updated: 27 August 2026

We understand how important your personal information and privacy are to you, and we will do everything possible to keep them secure and under your control. Please read and fully understand this Policy before using our products or services, especially the clauses highlighted in bold, which may contain sensitive information, important rights and interests, or relevant obligations.

We will collect and use your personal information only for the purposes described in this Policy, and only to the extent necessary to provide and improve our products and services, comply with legal obligations, and protect you, other users, and the public against fraud, abuse, and security risks.

This Policy primarily explains what personal information we collect, how we collect and use it, how we share and protect it, what rights you have, and how you may exercise them. If you do not agree with any part of this Policy, we recommend that you stop using our products and services.

When you sign in with an account, we may associate your information across different devices or services under that same account so that you can have a unified service experience and manage your account more conveniently.

You may also choose to use certain product features without creating or signing in to an account. In that case, we will collect only the minimum information necessary to provide certain basic features, based on your specific use. However, some features that require account data, such as backup and synchronization, may not be available without an account.

Table of Contents

1. How we collect and use your personal information
2. How we use cookies and application permissions
3. How we share, transfer, and publicly disclose your personal information
4. How we store your personal information
5. How we protect your personal information
6. Minors
7. Changes to this Privacy Policy
8. How you can manage your personal information
9. Account deletion process
10. How to contact us

1. How we collect and use your personal information

We may collect and use your personal information in the following circumstances and in the following ways. If we collect or use your information for additional purposes not described in this Policy, we will separately explain the purpose, scope, and method, and will obtain your consent again when required by law.

1.1 Registration, authentication, and device linking

(1) When you register an account or sign in using a third-party account, we may collect your mobile phone number, sign-in credentials, and basic profile information, such as nickname, avatar, and region, in order to create and manage your account.

(2) When you add a pet profile, we may collect information such as your pet's name, type, breed, sex, neutering status, date of birth, weight, body condition, and photo in order to provide pet-related features, such as health suggestions and behavior analysis.

(3) When you link, activate, or manage a device, we may collect device information such as the model, ID, serial number, activation code, ICCID, firmware version, status (online, offline, or battery level), and its linking relationship with a pet or family account. This information is used to associate the device with your account, provide software updates, and ensure normal use of the device.

1.2 Information generated while using the products or services

To provide basic features such as location tracking, activity statistics, pet trip records, and notifications, we may collect and process information generated while you use our products and services, including:

(1) Location information. When you activate location features, such as real-time location, route history, Lost Mode, geofencing, “Near Me,” or navigation, we may collect the device's GPS coordinates and, if permitted, the location of your mobile phone. This may be based on GPS, base stations, mobile networks, and other positioning technologies.

You can enable or disable location permissions in the system settings at any time. If you disable them, certain location and map services may not function properly.

(2) Activity and usage data. This includes step count, activity duration, distance, estimated calorie consumption, rest time, and other movement-related statistics generated through the sensors built into the device and our algorithms. We use this information to present activity summaries and provide suggestions concerning your pet's health. These values are estimates and are provided for reference only; they do not constitute medical or veterinary diagnoses.

(3) Log information. This includes operations performed in the application, such as tapping buttons or changing pages, device connection status, error codes, failure logs, and other system logs. We use these logs to analyze operating status, troubleshoot problems, improve service quality, and maintain security.

(4) Audio and video during calls. When the user initiates or receives a voice call or video call, the device may capture audio and, in the case of video calls, images and video of the pet's immediate surroundings. This content is transmitted between the device and the application of an authorized user linked to the account, solely to enable the communication requested by the user.

Audio and video are transmitted only live during the call. TraksPet does not record or store the content of voice calls or video calls. Only authorized users linked to the account can initiate and receive these communications.

The device automatically accepts the call five (5) seconds after it is received. This function is automatic and cannot be enabled, disabled, or configured by the user.

1.3 Ensuring security and complying with laws

To protect the security of your account, devices, and system services, and to comply with legal and regulatory requirements, we may collect and process information such as device identifiers, network information, and diagnostic and security logs, within the scope permitted by law. This is intended to prevent fraud, abuse, attacks, viruses, and other security risks, and to comply with our network and data security obligations.

1.4 Situations in which consent is not required by law

In accordance with applicable laws, we may process your personal information without separately obtaining your consent in the following situations:

(1) When necessary to enter into or perform a contract to which you are a party.

(2) When necessary to comply with legal duties or obligations.

(3) When necessary to protect the life, health, integrity, or safety of persons or their property in an emergency.

(4) When personal information that you have disclosed yourself, or that has been lawfully disclosed, is processed within a reasonable scope and in accordance with the law.

(5) Other circumstances established by applicable laws and regulations.

If we need to process your personal information for purposes other than those specified in this Policy, or use information already collected for a new purpose, we will notify you again and obtain your consent before such use when required by law.

2. How we use cookies and application permissions

2.1 Cookies and similar technologies

We may use cookies and similar technologies, such as local storage and SDK tracking technologies, to remember your settings and preferences, keep you signed in, and analyze how you use our products and services in order to improve your user experience.

You can manage or delete cookies through your browser or device settings. If you delete or disable cookies, you may need to reconfigure your preferences each time you use our services, and some features may not function properly.

2.2 Application permissions

Some application features require certain system permissions to function properly. We will request permissions only when they are necessary for specific features, and we will not enable them by default. Common permissions and their purposes include the following, depending on your device's operating system:

(1) Location. Used to display maps, real-time and historical routes, geofences, the “Near Me” feature, and navigation to your pet. If you deny this permission, location-related features may not be available.

(2) Bluetooth. Used when pairing or communicating with certain devices via Bluetooth, where applicable. If you deny this permission, some Bluetooth features may not be available.

(3) Camera. Used to scan QR codes to link devices or read tags, take photographs, and, during video calls, capture and transmit video of the pet's immediate surroundings to the authorized user linked to the account.

(4) Photos, media, and files. Used to save or select photos, such as pet avatars, screenshots, and comment attachments, and to cache necessary resources.

(5) Microphone. Used to capture and transmit audio during voice calls, video calls, or voice messages when those features are available.

(6) Notifications. Used to send you messages such as low-battery alerts, SOS alerts, Lost Mode reminders, trip updates, marketing information where permitted, and system notifications.

You can manage these permissions at any time in your device settings. After you revoke a permission, we will stop collecting the corresponding information and certain related features may not function properly, but this will not affect the use of other features.

2.3 Third-party SDKs we use

To support features such as one-click sign-in, message delivery, statistics and analytics, maps and navigation, and audio and video communication, some application functions are provided by third-party SDKs. These third parties may collect information such as device identifiers, network information, operation logs, and location data as necessary to provide their services.

We carefully select our external partners and require them to protect your personal information in accordance with the law and this Policy. They are permitted to process your information only for agreed specific purposes and within the scope necessary to provide their services.

An up-to-date list of the third-party SDKs used and the information each one collects is available in the application's “Privacy” section.

3. How we share, transfer, and publicly disclose your personal information

3.1 Sharing

We will not share your personal information with any company, organization, or individual except in the following circumstances:

(1) With your explicit consent. We may share your personal information with other parties after separately obtaining your consent.

(2) Sharing with processors. We may entrust the processing of your personal information to authorized partners acting on our behalf, such as cloud service providers, SMS service providers, map and navigation providers, push-notification service providers, data analytics service providers, and customer service providers. These third parties may process your information only within the scope of the authorization granted and for the purposes established in this Policy, and must apply confidentiality and security measures that are at least as strict as ours.

(3) Sharing required by law or competent authorities. We may share your personal information when required by applicable laws and regulations, legal proceedings, litigation, governmental authorities, or law-enforcement agencies.

When we share information, we will adopt necessary measures, such as anonymization and encryption, to protect your personal information to the greatest extent possible.

3.2 Transfer

We will not transfer your personal information to any company, organization, or person except in the following circumstances:

(1) With your express consent.

(2) In the event of a merger, division, dissolution, acquisition, asset transfer, or similar transaction involving us, your personal information may be transferred as part of that transaction. In such a case, we will require the new entity receiving your personal information to remain subject to this Privacy Policy. If the purposes or manner of processing the information change, we will request your consent again when required by applicable law.

3.3 Public disclosure

We will not publicly disclose your personal information except in the following circumstances:

(1) With your express consent.

(2) When public disclosure is required by law, legal proceedings, litigation, or governmental authorities.

If we make a public disclosure, we will use methods consistent with industry standards and legal requirements to protect your information to the greatest extent possible.

4. How we store your personal information

4.1 Storage location

Personal information collected and generated through the Application will be stored on Amazon Web Services (AWS) servers located in Germany. To optimize performance and availability and reduce service latency for users, the Application uses AWS Global Accelerator infrastructure, which incorporates acceleration nodes distributed across different regions, including South America. These nodes facilitate secure data transmission without changing the location where the information is permanently stored.

If business needs require transferring your personal information abroad, we will comply with applicable laws and regulations, inform you of the purpose, scope, and destination of the transfer and, where required by law, separately obtain your consent and adopt the safeguards established by the applicable rules for international data transfers.

4.2 Storage period

We will retain your personal information only for the minimum period necessary to fulfill the purposes described in this Policy and for the time required by law or contracts, or to protect your and other users' legitimate rights and interests. For reference:

• Account and profile data: while the account remains active and for up to 30 calendar days after its deletion.
• Location and route history: 180 calendar days, unless you delete it earlier from the application.
• Pet activity data: 12 months.
• Technical and security logs: 12 months.

Once the retention period has ended, or if you actively delete your information or cancel your account, we will delete or anonymize your personal information in accordance with applicable law.

5. How we protect your personal information

We attach great importance to the security of your personal information and have adopted reasonable, practical, industry-recognized measures to protect it against unauthorized access, disclosure, use, modification, damage, or loss.

These measures include, among others:

• Using encryption technologies, such as HTTPS and encryption of stored data, to protect information during transmission and storage.
• Establishing strict access-control and permission-management mechanisms so that only authorized personnel can access personal information, and only when necessary.
• Training employees and partners in security and privacy protection to strengthen the culture of data protection.
• Establishing incident-response mechanisms and emergency plans for security incidents involving personal information.

Please note that, although we have implemented reasonable security measures, no transmission or storage method can guarantee 100% security.

If a security incident occurs, such as a data breach, we will notify you promptly and without undue delay, in accordance with applicable law, about:

• The nature of the incident and its potential impact.
• The measures we have adopted or will adopt.
• Recommendations to prevent or reduce risks.
• Available remedial actions.

We will also notify the competent authorities within the time limits and in the manner established by applicable law.

6. Minors

Our products and services are primarily intended for adults.

If you are a minor under the laws of your country or region, you must first obtain the consent of your parents or legal representative before using our products and services.

The device is designed for use with companion animals and is not intended or certified for tracking people.

If we discover that we have collected personal information from a minor without the verifiable consent of their legal representative, we will attempt to delete that information as soon as possible.

Legal representatives may request the deletion or correction of a minor's personal information using the contact details provided in section 10.

7. Changes to this Privacy Policy

We may update this Policy periodically due to changes in legislation, business adjustments, or improvements to our services.

When the Policy is updated, we will notify you through reasonable means, such as push notifications, pop-up windows, in-application messages, or posts on our website, so that you can review the latest version.

In the event of significant changes, such as changes to the purpose, scope, or type of processing of personal information, we will request your express consent again. If you do not accept the updated version, you may stop using the service and delete your account at no cost.

8. How you can manage your personal information

Within the application, we provide various tools that allow you to manage your personal information. For example, you can:

• Access and edit your basic profile and pet information under “My Account” → “Account Management” and “Pet Management.”
• View and manage your devices under “Device Management,” including linking and unlinking devices and changing their settings.
• Manage permissions in your mobile phone settings, including location, camera, microphone, photos, notifications, Bluetooth, and others.
• Modify or delete content you have uploaded, such as pet photographs, notes, images, or comments.
• View and delete the location and route history recorded by the device.

In addition, you may request access to, rectification, deletion, blocking, or portability of your personal information, object to certain processing, and withdraw consent you have given by writing to the contact address indicated in section 10. We will respond to your request within the period established by applicable law and, in all cases, within a maximum of thirty (30) calendar days.

9. Account deletion process

You may choose to delete your account at any time.

Once the account has been deleted, we will stop providing services to you and, in principle, delete or anonymize your personal information in accordance with applicable law.

The deletion process may be irreversible, and certain information may be retained for a specified period to comply with legal obligations, resolve disputes, or ensure security.

You can delete your account from the application under “My Account” → “Account Management” → “Delete Account,” or through an equivalent option.

We recommend that you carefully read the warnings displayed before confirming deletion.

10. How to contact us

If you have questions, comments, or complaints about this Privacy Policy, or wish to exercise any of the rights described in section 8, you may contact us through the following channels:

• Data controller: Inversiones e Inmobiliaria Jiménez, Sanhueza & Mujica SpA
• RUT: 76.323.754-0
• Address: O'Higgins No. 241, office 810, Concepción, Chile
• Email for privacy matters: contacto@mallconnection.com
• Data protection officer or person in charge: Enith González, egonzalez@mallconnection.com
• Technical support for the application and device: contacto@mallconnection.com
• Website: Not currently available

We will respond to your request within the applicable legal period. If you are not satisfied with our response, you may apply to the competent personal-data-protection or consumer-protection authority in your country of residence.

This Privacy Policy forms part of the User Agreement. If there is any discrepancy with another version in another language, to the extent permitted by law, the version that provides users with greater protection will prevail.