Privacy Policy

Last updated: August 2026

Edward Marran trading as Progress Paws ("Progress Paws," "we," "us," or "our") respects your privacy. This Privacy Policy explains what personal information we collect through progresspaws.com and the Service, why we collect it, how we use and protect it, and the choices and rights you have.

This Policy is written to comply with South Africa's Protection of Personal Information Act 4 of 2013 ("POPIA"). It applies to visitors to our marketing site, to the dog training businesses ("Tenants") that subscribe to the Service, to the staff they invite, and to the pet owners ("Clients") who use the Service through a Tenant's account.

This Policy works alongside our Terms of Service. Where this Policy uses a capitalized term it doesn't define, that term has the meaning given in the Terms of Service.

1. Who We Are and What This Policy Covers

1.1 About us. Progress Paws is a cloud-based platform that helps dog training businesses manage classes, enrollment, vaccine compliance, and payments.

1.2 What this covers. This Policy covers personal information processed through progresspaws.com and the Service, including waitlist sign-ups, Tenant accounts, Authorized User accounts, and Client accounts.

1.3 What it doesn't cover. This Policy doesn't cover the practices of Tenants themselves, or of third parties like PayPal or Microsoft, each of whom has its own privacy notice — see Section 10.

2. Definitions

"Client"

means an individual pet owner who uses the Service to enroll a dog, upload records, or book and pay for a Tenant's classes.

"Operator"

has the meaning given in POPIA — broadly, a party that processes personal information on behalf of, and only on the instructions of, a responsible party.

"Personal Information"

means personal information as defined in POPIA — broadly, information that identifies or can identify a living, natural person, and, under POPIA, an identifiable, existing juristic person.

"Responsible Party"

has the meaning given in POPIA — broadly, the party that decides why and how personal information is processed.

"Service"

means the Progress Paws software-as-a-service platform.

"Tenant"

means the dog training business that has subscribed to the Service.

3. The Personal Information We Collect

3.1 From our marketing site. If you join our waitlist, subscribe to our newsletter, or use our contact form, we collect your name, email address, plus the UTM and referrer information that shows us which channel sent you.

3.2 From a Tenant. If you register a business, we collect the business name, contact details, business address, time zone, and billing information for the Subscription Plan you choose.

3.3 From Authorized Users. For staff a Tenant invites, we collect name, email address, and role, through Microsoft Entra ID.

3.4 From Clients. For pet owners using the Service, we collect name, contact details, emergency contact, communication preferences, and details about the dogs in their care, including vaccination records and any medical, behavioral, or safety notes a Tenant records.

3.5 Payment information. Payments are processed by PayPal. We receive confirmation that a payment succeeded or failed, but we don't receive or store full card numbers.

3.6 Technical information. Like most web services, we automatically collect IP address, browser and device information, and usage data through cookies and similar technologies — see Section 9.

4. How We Collect It

4.1 Directly from you. Most personal information comes from what you type into a form — registering, enrolling a dog, filling in a profile, or joining the waitlist.

4.2 Through your use of the Service. Some information is generated automatically as the Service runs, such as attendance records, progress notes, payment history, and system logs.

4.3 From third parties. We receive limited information from Microsoft (sign-in details), PayPal (payment confirmations), and analytics providers (aggregate usage patterns).

5. How We Use Personal Information

We use personal information to:

• provide the Service — running classes, tracking enrollment, flagging vaccine and age eligibility, processing payments, and sending confirmations and receipts;
• communicate with you — class reminders, vaccine expiry warnings, support responses, and service announcements;
• maintain and improve the Service — troubleshooting, security monitoring, and understanding how features are used;
• market to Tenants and waitlist sign-ups who haven't opted out — see Section 15; and
• meet our legal obligations, including tax, accounting, and responding to lawful requests from authorities.

6. Our Lawful Grounds for Processing

POPIA requires processing to rest on a lawful ground. Depending on the information and the purpose, we rely on: performing our contract with you or your Tenant; your consent, where we ask for it, for example for marketing emails or non-essential cookies; our legitimate interests in running and securing the Service, weighed against your rights; and complying with a legal obligation.

7. Our Role: Responsible Party or Operator

7.1 For Tenant and Authorized User information. When we process the personal information of a Tenant's business and staff — for account administration, billing, and support — we act as the "responsible party" under POPIA.

7.2 For Client information. When a Tenant uses the Service to process the personal information of its own Clients — enrollment, vaccine records, payments — the Tenant is the "responsible party" and we act only as an "operator," processing that information on the Tenant's instructions and for no other purpose.

7.3 What this means practically. If you're a Client, we still apply the security and confidentiality commitments in this Policy, but your Tenant is primarily responsible for telling you how your information is used and for responding to most requests about it — see Section 8.

8. If You're a Client of One of Our Tenants

8.1 Your trainer is your first point of contact. Because your dog training business is the responsible party for your information, please contact them first with a question or a request to access, correct, or delete your information.

8.2 We'll help. We give Tenants the tools to fulfil those requests directly in the Service, and we assist a Tenant on request to locate or remove information we hold on their behalf.

8.3 You can still contact us. If you're not able to reach your Tenant, or you have a concern about how we, rather than your Tenant, have handled your information, contact us using the details in Section 21.

9. Cookies and Similar Technologies

9.1 What we use. Our marketing site can use Google Analytics 4 and the Meta (Facebook) Pixel to understand traffic and measure ad performance, alongside cookies that keep the site itself working. These analytics and advertising cookies are only loaded after you accept them (see 9.2); until then, only strictly necessary cookies are used.

9.2 Your choices. Before any non-essential cookie is set, we ask for your consent through a cookie banner. Nothing analytics- or advertising-related loads until you choose "Accept." You can decline, and you can change your choice at any time through the "Cookie Preferences" link in our footer or through your browser settings.

9.3 Do Not Track. The Service doesn't currently respond to browser "Do Not Track" signals.

10. How We Share Personal Information

10.1 Service providers. We share personal information with providers who help us run the Service: PayPal (payments), Microsoft (Entra ID sign-in), our cloud hosting provider, our transactional email provider, and analytics providers. Each processes information only as needed to provide their service to us.

10.2 Tenants. If you're a Client, the Tenant you enroll with can see the information you and your dog's profile contain, because the Service is how they run their classes.

10.3 Legal reasons. We may share personal information if required by law, to protect rights, safety, or property, or in connection with a merger, acquisition, or sale of assets, in which case this Policy would continue to apply to the transferred information.

10.4 We don't sell personal information. We don't sell personal information to third parties, and we don't share it for third parties' own independent marketing purposes.

11. Cross-Border Transfers

Our service providers, including our cloud hosting infrastructure, may process personal information outside South Africa. Where that happens, we take steps intended to meet POPIA's conditions for cross-border transfer, such as confirming the recipient is subject to a comparable level of data protection, or is bound by contractual terms that provide one.

12. Data Retention

We keep personal information for as long as your account is active, and for a reasonable period after that to allow data export, resolve disputes, and meet legal, accounting, or tax retention requirements. When information is no longer needed for these purposes, we delete or anonymize it.

13. How We Protect Personal Information

We maintain reasonable technical and organizational security measures designed to protect personal information against loss, misuse, and unauthorized access, including access controls that keep each Tenant's data separate from every other Tenant's. No system is completely secure, and we can't guarantee absolute security.

14. Your Rights Under POPIA

Subject to some conditions and exceptions, POPIA gives you the right to:

• be told what personal information we hold about you and why — this Policy is part of that;
• access the personal information we hold about you;
• ask us to correct or update personal information that's inaccurate, outdated, or incomplete;
• ask us to delete or destroy personal information we no longer have a lawful reason to hold;
• object to our processing of your personal information on reasonable grounds, and to processing for direct marketing;
• not be subject to a decision based solely on automated processing that significantly affects you, without a chance for it to be reviewed; and
• complain to the Information Regulator — see Section 19.

If you're a Client, please see Section 8 first — your Tenant is usually the right place to start.

15. Direct Marketing

We'll only send you direct marketing by email if you've consented, or, where POPIA allows it, if you're an existing customer and the marketing is about similar products or services, and every marketing email includes a way to opt out. Opting out of marketing won't stop service-related messages, like receipts, class reminders, or security notices, which aren't marketing.

16. Children's Privacy

The Service is for use by adults running or working with, or enrolling a dog in, a dog training business. We don't knowingly collect personal information directly from children. A dog's profile may reference a household that includes children, but accounts should only be created and managed by an adult.

17. Data Breach Notification

If we become aware of a security compromise that has led, or may lead, to unauthorized access to or acquisition of personal information, we'll notify the Information Regulator and the affected data subjects as POPIA requires, and take reasonable steps to help affected Tenants meet their own notification obligations.

18. Our Information Officer

Edward Marran, as our Information Officer, oversees our compliance with POPIA and is registered with the Information Regulator as POPIA requires. You can contact our Information Officer using the details in Section 21.

19. Complaints to the Information Regulator

If you're unhappy with how we've handled your personal information, we'd appreciate the chance to resolve it directly first — contact us using Section 21. You also have the right to complain to South Africa's Information Regulator:

Information Regulator (South Africa)
JD House, Stiemens Street, Braamfontein, Johannesburg, 2001
inforegulator.org.za

(Please confirm current postal, email, and complaints-form details on their website before relying on them, since these can change.)

20. Changes to This Policy

We may update this Policy from time to time. If a change is material, we'll give notice — by email or an in-app notice, for example — before it takes effect. The version and date at the top of this Policy always reflect the current version.

21. Contact Us

Questions about this Policy, or requests about your personal information, can go to:

Progress Paws
Privacy questions: info@progresspaws.com