Privacy Policy

1. Who this policy applies to

This policy applies to visitors, registered users, buyers, sellers, breeders, rehomers, Dog Services businesses and other people who use or interact with ePuP.

For the purposes of UK data protection law, the organisation operating ePuP is responsible for determining how personal information collected through the marketplace is processed, except where another organisation independently determines its own purposes and means of processing.

2. Information we may collect

Depending on how you use ePuP, we may collect or process the following categories of information:

• Account information, including your name, email address, password credentials, account identifiers and account status.
• Contact information, including telephone numbers and communication preferences.
• Profile and marketplace information, including seller profiles, business profiles, adverts, descriptions, photographs, videos, pricing and other content you choose to provide.
• Verification information, including email verification, telephone verification, identity verification, address verification, breeder or business verification and related verification outcomes.
• Transaction and payment information, including information relating to listing packages, promotions, payment status, refunds or chargebacks. Payment card information may be handled directly by our payment service providers rather than stored by ePuP.
• Messages and communications, including marketplace messages between users, support requests, reports, seller replies and communications with ePuP.
• Safety and moderation information, including reports, moderation decisions, fraud indicators, scam-risk information, Trust Score information, verification signals and enforcement records.
• Technical information, including IP addresses, device and browser information, login activity, timestamps, approximate location derived from technical data, security signals and similar diagnostic information.
• Usage information, including pages visited, searches, favourites, saved searches, interactions with adverts and use of marketplace features.
• Information supplied to us by third parties, where permitted by law, such as payment, identity, communications, fraud-prevention or security providers.

3. How we use personal information

We may use personal information where reasonably necessary to:

• create, authenticate and administer user accounts;
• publish and manage adverts and marketplace profiles;
• enable messaging and other marketplace communications;
• process payments, promotions, refunds and billing records;
• verify email addresses, telephone numbers, identities, addresses, businesses or other trust information;
• moderate adverts, photographs, videos, messages, reviews and other user-generated content;
• detect, investigate and prevent fraud, scams, misuse, suspicious activity and security incidents;
• calculate and display appropriate marketplace trust and verification signals;
• respond to support requests and complaints;
• investigate reports concerning animal welfare, unlawful behaviour or marketplace safety;
• enforce our Terms, Marketplace Rules, Seller Standards and other policies;
• maintain, secure, troubleshoot and improve the ePuP service;
• comply with legal, regulatory, law-enforcement, court or governmental requirements where applicable;
• establish, exercise or defend legal claims and protect the rights, property and safety of ePuP, its users, animals and others.

4. Our lawful bases for processing

Under UK data protection law, the lawful basis we rely on will depend on why particular information is being processed.

These lawful bases may include:

• Contract — where processing is necessary to provide an ePuP service you have requested or to take steps before entering into a contract.
• Legitimate interests — where processing is reasonably necessary to operate, secure and improve the marketplace, prevent fraud, protect users and animals, enforce marketplace rules or defend legal rights, provided those interests are not overridden by your rights.
• Legal obligation — where processing is necessary to comply with a legal requirement.
• Consent — where applicable law requires us to obtain your consent, for example for certain optional cookies or communications.

5. Identity, telephone and other verification

ePuP may use verification services to help establish trust between marketplace users. Depending on the verification method, information may be processed by specialist third-party providers.

Verification indicators are designed to provide additional trust signals. They do not guarantee a person's identity, honesty, legal status, the quality of an advert or the suitability of an animal.

Where a verified telephone number is changed or removed, its verified status may be withdrawn until the replacement number has been verified again.

6. Automated moderation, fraud detection and Trust Scores

ePuP uses automated systems to assist with marketplace safety, moderation, fraud detection and trust assessment.

These systems may analyse information such as advert content, images, videos, verification status, account history, IP and technical signals, moderation history and other relevant risk indicators.

Automated checks may contribute to decisions about whether content can be published automatically, should be referred for human moderation, or requires further verification.

ePuP may also calculate marketplace Trust Scores and display verification signals to users. These signals are intended to support marketplace safety and are not warranties, guarantees or professional assessments of a user.

7. Messages and communications

Messages sent using ePuP may be stored and processed so that we can operate the messaging service, investigate abuse or fraud, respond to reports, enforce marketplace rules and protect users.

Users should avoid sharing unnecessary sensitive personal information in marketplace messages.

8. Who we may share information with

We may share personal information where necessary with service providers that help us operate and protect ePuP, including providers of:

• hosting and infrastructure;
• payment processing;
• identity or account verification;
• telephone verification and communications;
• fraud prevention and security;
• email delivery;
• content moderation and artificial intelligence services;
• analytics and technical support.

We may also disclose information where reasonably necessary to courts, regulators, law-enforcement agencies, local authorities, animal-welfare bodies or other competent authorities where we are legally required or permitted to do so.

We do not sell personal information in the ordinary meaning of selling personal data for money.

9. International transfers

Some service providers may process information outside the United Kingdom.

Where UK data protection law requires safeguards for an international transfer, we will seek to use an appropriate lawful transfer mechanism, such as an adequacy regulation, approved contractual safeguards or another permitted mechanism.

10. How long we keep information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including operating accounts, maintaining marketplace records, preventing fraud, resolving disputes, complying with legal obligations and enforcing our agreements.

Different categories of information may be retained for different periods. Fraud, security, moderation, transaction and legal records may need to be retained after an account or advert has been deleted where there is a legitimate or legal reason to do so.

11. Security

ePuP uses technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

No internet service can guarantee absolute security. Users are responsible for protecting their login credentials and should notify ePuP promptly if they believe their account has been compromised.

12. Cookies and similar technologies

ePuP may use cookies and similar technologies for essential functions such as authentication, security, session management and preferences.

Where required by law, optional cookies or similar technologies will be subject to appropriate consent controls.

Further information is available in our Cookie Policy.

13. Your data protection rights

Depending on the circumstances, UK data protection law may give you rights including:

• the right to be informed about processing;
• the right to access personal information;
• the right to correct inaccurate information;
• the right to request erasure in certain circumstances;
• the right to request restriction of processing;
• the right to object to certain processing;
• the right to data portability where applicable;
• rights relating to certain decisions made solely by automated means where applicable.

These rights are not absolute and may be subject to exemptions or other legal requirements.

14. Account closure and deletion requests

Closing an account does not necessarily mean every record will be immediately erased. We may retain information where necessary for fraud prevention, marketplace integrity, dispute resolution, legal compliance, accounting, enforcement or the establishment, exercise or defence of legal claims.

15. Children

ePuP is not intended to enable children to independently enter into marketplace transactions where they do not have legal capacity to do so.

Users must comply with the age and eligibility requirements set out in the ePuP Terms & Conditions.

16. Law-enforcement and safeguarding requests

Where appropriate and legally permitted, ePuP may preserve or disclose relevant account, advert, messaging, transaction, verification or technical information in response to lawful requests from competent authorities.

Additional information is available on our Law Enforcement page .

17. Complaints about data protection

If you have a privacy concern, please contact ePuP first so that we have an opportunity to investigate and respond.

You may also have the right to complain to the UK Information Commissioner's Office (ICO), the UK's independent data protection regulator.

18. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to the ePuP service, technology, legal requirements or marketplace practices.

Where appropriate, material changes may be communicated through the website, account notices or other reasonable means.

19. Contacting ePuP

Privacy enquiries, rights requests and other data-protection correspondence can be submitted through the ePuP Contact page.

We may ask for reasonable information to confirm your identity before responding to certain privacy requests.