Privacy policy
FluentPet
Privacy Policy
CleverPet, Inc. dba FluentPet
Last Updated: May 14, 2026
Effective Date: May 14, 2026
1. Scope and Introduction
This Privacy Policy describes how CleverPet, Inc. dba FluentPet ('FluentPet,' 'we,' 'us,' or 'our') collects, uses, and discloses your personal information when you visit fluent.pet, use our mobile applications, purchase or use our products (including the FluentPet Connect device and associated hardware), participate in our research programs, or otherwise communicate with us (collectively, the 'Services').
For purposes of this Privacy Policy, 'you' and 'your' means you as the user of the Services, whether you are a customer, website visitor, research participant, or another individual whose information we have collected pursuant to this Privacy Policy.
2. Changes to This Privacy Policy
We may update this Privacy Policy from time to time, including to reflect changes to our practices, product features, or for legal or regulatory reasons. We will post the revised Privacy Policy on the Site and update the 'Last Updated' date. For material changes — including any changes to how we collect or use data from FluentPet Connect devices, or how we use data for research purposes — we will provide notice by email to registered users at least 30 days before the changes take effect, and will obtain fresh consent where required by applicable law.
3. How We Collect and Use Your Personal Information
We collect personal information from a variety of sources depending on how you interact with us. In addition to the specific uses set out below, we may use information we collect to communicate with you, provide or improve the Services, comply with legal obligations, enforce our terms of service, and to protect or defend our rights and the rights of our users.
3.1 Information You Provide Directly
- Contact details including your name, address, phone number, and email.
- Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.
- Account information including your username, password, security questions, and other information used for account security purposes.
- Shopping information including items you view, add to your cart, loyalty points, reviews, referrals, or gift cards.
- Customer support information including the content of communications you send us.
- Research participation information, including any consents, survey responses, or other information you voluntarily provide when participating in FluentPet-affiliated research programs.
3.2 Website and App Usage Data
Usage Data may include device information, browser type and settings, operating system, network connection details, IP address, approximate location derived from IP address, pages visited, full page URLs, referring URLs, timestamps, time spent on pages, clickstream data, cookie identifiers, pixel identifiers, session identifiers, advertising identifiers, and other information about your interactions with the Services.
3.3 FluentPet Connect Device Data
If you use a FluentPet Connect device (including Connect button hubs and associated hardware), we collect additional categories of data generated by the device:
- Button interaction data: records of which buttons are pressed, timestamps of each press, press duration, press sequences and patterns, and inter-press intervals.
- Device telemetry: device identifier, firmware version, connectivity status, battery level (if applicable), and error logs.
- Session data: frequency and duration of interaction sessions, time-of-day patterns, and inactivity periods.
- Configuration data: button labels you assign, board layout, and user-defined settings.
Audio: The FluentPet Connect device has no microphone or capability to capture audio.
Device data is transmitted to FluentPet's cloud infrastructure via encrypted connections (TLS 1.2 or higher). Device data is associated with your account and is subject to the retention schedule in Section 9.
3.4 Research Use of Device Data
FluentPet conducts and supports scientific research into animal cognition and communication. Device data — including button interaction patterns — may be used for research purposes, subject to the following conditions:
- De-identification: Before any device data is used for research analysis or shared with research collaborators, it is de-identified using industry-standard techniques to remove or hash direct identifiers. De-identified data is not re-linked to individual accounts.
- Opt-in and Opt-out: We share data with researchers on an opt-in basis. You may opt-in to having your de-identified device data shared with researchers by using the FluentPet App. You may opt out of research use of your device data at any time through your account settings or by contacting us at privacy@fluent.pet. Opting out of research use does not affect your ability to use the FluentPet Connect device or any other Services.
- Third-party research collaborators: De-identified device data may be shared with qualified academic research partners and collaborators.
- Machine learning and model training: Aggregated, de-identified device data may be used to train or improve machine learning models used in our Services. Raw, individually identifiable device data is not used for model training without separate explicit consent.
- Scientific Integrity Review Board (SIRB): All research use of data is subject to oversight by FluentPet's independent SIRB, whose composition and conflict-of-interest policies are described at fluent.pet/scientific-integrity.
3.5 Information from Third Parties
We may obtain information about you from third parties, including vendors and service providers who collect information on our behalf, such as:
- Shopify, which powers our e-commerce platform and payment processing.
- Payment processors, who collect payment information to fulfill your orders.
- Analytics providers, advertising partners, and other service providers described in Section 6 (Cookies) and Section 7 (Disclosure of Personal Information).
Any information we obtain from third parties will be treated in accordance with this Privacy Policy.
4. How We Use Your Personal Information
4.1 Providing Products and Services
We use your personal information to provide the Services, including to process payments, fulfill orders, send account-related notifications, manage your account, arrange shipping, facilitate returns and exchanges, and maintain account security. We may enable Shopify to match your account with other Shopify services you choose to use, in which case Shopify processes your information per its own Privacy Policy.
4.2 Marketing and Advertising
We may use your personal information to send marketing and promotional communications by email, text message, or postal mail, and to show you advertisements. This may include audience matching, ad personalization, frequency capping, conversion measurement, attribution, analytics, suppression lists, retargeting, and measuring the effectiveness of advertising campaigns on third-party platforms.
Legal basis (EEA/UK): Legitimate interest in promoting our products (Art. 6(1)(f) GDPR), or consent where required by applicable law.
4.3 Security and Fraud Prevention
We use your personal information to detect, investigate, and respond to fraudulent, illegal, or malicious activity.
Legal basis (EEA/UK): Legitimate interest in maintaining platform security (Art. 6(1)(f) GDPR).
4.4 Service Improvement and Communications
We use your personal information to provide customer support and improve our Services.
Legal basis (EEA/UK): Legitimate interest in maintaining and improving our business (Art. 6(1)(f) GDPR).
4.5 Research and Development
As described in Section 3.4, de-identified device data may be used for scientific research into animal cognition and communication, and for training and improving machine learning models used in our Services.
Legal basis (EEA/UK): Legitimate interest in conducting research aligned with our scientific mission (Art. 6(1)(f) GDPR); where research falls within Art. 89 GDPR, we apply appropriate safeguards including de-identification and SIRB oversight. Consent is obtained for participation in named research studies.
5. GDPR Lawful Basis Summary
| Processing Activity | Lawful Basis | Notes |
|---|---|---|
| Order fulfillment and account management | Contract performance (Art. 6(1)(b)) | Necessary to deliver the Services |
| Marketing communications (EEA/UK) | Legitimate interest (Art. 6(1)(f)) or consent | Opt-out available at any time |
| Security and fraud prevention | Legitimate interest (Art. 6(1)(f)) | |
| Connect device data collection | Contract performance (Art. 6(1)(b)) and legitimate interest (Art. 6(1)(f)) | Necessary to operate connected product |
| Research use of de-identified device data | Legitimate interest (Art. 6(1)(f)); Art. 89 safeguards applied | Opt-out available; SIRB oversight |
| Named research study participation | Consent (Art. 6(1)(a)) | Separate consent form required; withdrawable |
| ML model training on aggregated data | Legitimate interest (Art. 6(1)(f)) | Aggregated and de-identified only |
| Legal compliance | Legal obligation (Art. 6(1)(c)) |
6. Cookies and Tracking Technologies
Like many websites, we use cookies, pixels, web beacons, software developer kits, and similar technologies on our Site and in our mobile applications.
- Operational cookies: necessary for core Site functionality, including session management and shopping cart.
- Analytics cookies: used to understand how users interact with the Site, including via third-party analytics providers.
- Advertising cookies: used to personalize advertising on our Site and third-party platforms, including via Shopify Audiences and other marketing partners.
For information about Shopify-specific cookies, see shopify.com/legal/cookies.
You can control cookies through your browser settings. Blocking cookies may impair some functionality. Our website recognizes the Global Privacy Control (GPC) signal; if you enable GPC, we treat it as a valid opt-out of sharing/targeted advertising for that browser and, where linkable, for your associated account. We do not recognize other 'Do Not Track' signals.
To opt out of personalized advertising through Shopify Audiences, visit privacy.shopify.com/en.
7. Disclosure of Personal Information
We may disclose your personal information in the following circumstances:
- Service providers: vendors who perform services on our behalf, such as IT management, payment processing, data analytics, customer support, cloud storage (see Section 8 for detail), fulfillment, and shipping.
- Business and marketing partners: including Shopify, advertising platforms, and analytics providers, to provide services and advertising. Some vendors process information on our behalf as service providers or contractors. Other business and marketing partners may process information as independent businesses under their own privacy notices, including for advertising measurement, attribution, audience creation, and cross-context behavioral advertising.
- Research collaborators: de-identified device data only, as described in Section 3.4. .
- With your direction or consent: for example, to ship products, through social media integrations you activate, or for other purposes you explicitly authorize.
- Corporate affiliates: within our corporate group, in our legitimate interest to operate our business.
- Business transactions: in connection with a merger, acquisition, or bankruptcy, subject to confidentiality obligations.
- Legal compliance and rights protection: to respond to subpoenas, court orders, or other lawful requests, or to protect the rights of FluentPet, our users, or the public.
7.1 Data Sold or Shared for Advertising (Past 12 Months)
We do not sell personal information for monetary consideration. We do share certain personal information for cross-context behavioral advertising, as described below.
FluentPet shares certain personal information with third parties for cross-context behavioral advertising, as defined under the California Privacy Rights Act and similar state laws. FluentPet shares certain personal information with business and marketing partners, including advertising platforms (including, without limitation, Meta, TikTok, and Google), email marketing providers (such as Klaviyo), and e-commerce and analytics services (such as Shopify).
The following table describes that sharing:
| Category of Personal Information | Categories of Recipients |
|---|---|
| Identifiers (name, email, phone number) | Business and marketing partners |
| Commercial information (purchase records) | Business and marketing partners |
| Website/app Usage Data | Business and marketing partners |
We do not sell or share FluentPet Connect device data, button interaction data, or de-identified research data for advertising or marketing purposes.
You may opt out of this sharing at any time by:
- Enabling the Global Privacy Control (GPC) signal in your browser
- Visiting our Privacy Choices page
- Contacting us at privacy@fluent.pet
7.2 Full Disclosure Table (Past 12 Months)
| Category | Categories of Recipients |
|---|---|
| Identifiers (contact details, account info) | Service providers, business/marketing partners, affiliates |
| California Customer Records (contact, order info) | Service providers, business/marketing partners, affiliates |
| Commercial information (orders, shopping) | Service providers, business/marketing partners, affiliates |
| Internet/network activity (Usage Data) | Service providers, business/marketing partners |
| Geolocation (IP-derived) | Service providers |
| Device data (Connect device, de-identified) | Research collaborators only (de-identified) |
8. Cloud Infrastructure and Key Subprocessors
FluentPet Connect device data is transmitted to and stored in cloud infrastructure operated on our behalf. Key subprocessors include:
| Subprocessor | Purpose | Location |
|---|---|---|
| Shopify | E-commerce, order management, payment processing | US / Canada |
| Amazon Web Services (AWS) | Cloud infrastructure, device data storage and transmission | US |
| Meta | iOS/Android analytics, advertising attribution | US |
| Google (Firebase) | iOS/Android crash reporting, analytics, push notifications | US |
| Klaviyo | Email marketing and customer communications | US |
| Apple (APNs) | iOS app distribution and push notifications | US |
| Google Play | Android app distribution and push notifications | US |
| Sentry | Error and crash logging | US |
| Datadog | Infrastructure monitoring and logging | US |
| Amplitude | Product analytics | US |
| Expo | React Native build tooling | US |
9. Security and Retention of Your Information
9.1 Security
We implement industry-standard technical and organizational measures to protect your personal information, including TLS encryption for data in transit and encryption at rest for device data stored in our cloud infrastructure. No security measures are perfect; we cannot guarantee absolute security. We recommend against communicating sensitive or confidential information over insecure channels.
9.2 Retention Schedule
| Data Category | Retention Period |
|---|---|
| Account and contact information | Duration of account, plus 3 years after account closure or last transaction |
| Order and transaction records | 7 years (tax and legal compliance) |
| Connect device interaction data (identified) | Duration of account, plus 2 years after account closure |
| Connect device interaction data (de-identified, research) | Indefinite (no longer linked to individual accounts) |
| Website Usage Data / cookies | Up to 13 months from collection |
| Customer support records | 3 years from close of support ticket |
| Marketing preferences and opt-out records | 5 years or as required by applicable law |
| Legal hold data | Duration of legal hold |
10. Children's Data
The Services are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you are the parent or guardian of a child who has provided us personal information, please contact us at privacy@fluent.pet to request its deletion.
As of the Effective Date, we do not knowingly sell or share personal information of individuals under 16 years of age.
11. User-Generated Content
If you submit product reviews, community posts, or other user-generated content to public areas of the Services, that content will be publicly accessible. We are not responsible for how others access or use information you choose to make public. You should not include personal information in public posts that you do not wish to be widely accessible.
12. Third-Party Websites and Links
Our Site may link to websites or platforms operated by third parties. We are not responsible for their privacy or security practices. Information you provide on third-party platforms is governed by those platforms' privacy policies.
13. Your Rights
Depending on where you live, you may have the following rights regarding your personal information. These rights are not absolute and may be subject to exceptions permitted by applicable law.
- Right to Access / Know: request access to the personal information we hold about you and how we use and share it.
- Right to Delete: request deletion of personal information we hold about you.
- Right to Correct: request correction of inaccurate personal information.
- Right of Portability: receive a copy of your personal information in a portable format.
- Right to Opt Out of Sale or Sharing / Targeted Advertising: direct us not to sell or share your personal information or use it for targeted advertising. GPC signals are honored as described in Section 6.
- Right to Opt Out of Research Use of Device Data: direct us not to use your identifiable device data for research purposes. This can be done through account settings or by contacting privacy@fluent.pet. This right is independent of the right to opt out of sale/sharing.
- Restriction of Processing: request that we stop or restrict processing of your personal information.
- Withdrawal of Consent: where processing is based on consent, withdraw that consent at any time.
- Appeal: appeal our decision if we decline your request.
- Lodge a Complaint: if you are not satisfied with our response, you may lodge a complaint with your local data protection authority. EEA supervisory authorities are listed at edpb.europa.eu/about-edpb/board/members_en.
To exercise any of these rights, contact us at privacy@fluent.pet. We will not discriminate against you for exercising your rights. We may need to verify your identity before processing your request. You may designate an authorized agent to make requests on your behalf with appropriate documentation.
14. International Users and Data Transfers
Your personal information may be transferred, stored, and processed outside the country in which you reside. For transfers from the European Economic Area (EEA) or the UK, we rely on recognized transfer mechanisms, including the European Commission's Standard Contractual Clauses or the UK International Data Transfer Agreement (IDTA), unless the destination country provides an adequate level of protection as determined by the relevant authority.
For transfers of FluentPet Connect device data outside the EEA or UK specifically, we rely on Standard Contractual Clauses with our cloud infrastructure provider. A copy of the applicable transfer mechanism can be obtained by contacting privacy@fluent.pet.
15. Complaints
If you have complaints about how we process your personal information, please contact us using the information below. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.
16. Contact
For questions about this Privacy Policy, to exercise your rights, or to contact our privacy team:
- Email: privacy@fluent.pet
- Mailing address: CleverPet, Inc. dba FluentPet, 302 Washington St #150-3668, San Diego, CA 92103, US
For the purpose of applicable data protection laws, CleverPet, Inc. dba FluentPet is the data controller of your personal information, unless explicitly stated otherwise.