PRIVACY POLICY – PARTNER PROGRAMME Last Updated: January 2026

This Privacy Policy explains how Lorenzo Barichella ST trading as Training Dog® (“we”, “us”, “our”) collects, uses, and protects the personal data of participants in the DOG LICENCE™ Partner Programme (“Partners”).

CONTROLLER DETAILS Data Controller: Lorenzo Barichella ST trading as Training Dog® 180 Brompton Park Crescent London SW6 1SX United Kingdom

Contact Information: Email: [email protected] Phone: 07756212501 (UK +44)

Data Protection Enquiries: Email: [email protected]

1. INTRODUCTION 1.1 Scope This Privacy Policy applies to personal data we collect from Partners who participate in the DOG LICENCE™ Partner Programme, including:

• Registered dog breeders

• Dog groomers and grooming salons

• Pet shops and pet supply retailers

• Veterinary clinics and veterinary practices

• Dog trainers and training facilities

• Dog walkers and pet care professionals

• Dog daycare and boarding facilities

• Other dog-related professional services

1.2 Commitment to Privacy We are committed to protecting your privacy and complying with all applicable UK data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1.3 Updates to This Policy We may update this Privacy Policy from time to time. We will notify Partners of any material changes via email at least 30 days before the changes take effect. Continued participation in the Partner Programme after the notice period constitutes acceptance of the updated policy.

2. PERSONAL DATA WE COLLECT 2.1 Information You Provide When you apply to join or participate in the Partner Programme, we collect:

Contact Information:

• Full name

• Business name/trading name

• Email address

• Telephone number

• Business address

Business Information:

• Type of business (e.g., breeder, groomer, pet shop, veterinary clinic, trainer, etc.)

• Industry sector

• Professional credentials or registrations (if applicable)

• Approximate volume of dog owner interactions (to estimate card requirements)

Payment Information:

• Bank account details (for bank transfers) OR

• PayPal email address

• VAT registration number (if applicable)

Programme Participation Data:

• Unique referral code

• Commission earnings and payment history

• Sales generated through your referral code

• Communication preferences

• Correspondence with our support team

2.2 Information We Collect Automatically When you interact with our Partner portal or communications, we may collect:

• IP address

• Browser type and version

• Device information

• Access times and dates

• Pages viewed

• Referring website addresses

2.3 Information We Do NOT Collect We do not collect:

• Personal data of your customers (dog owners)

• Sensitive personal data about Partners (health, religion, political views, etc.) unless voluntarily provided

• Payment card details (processed securely by third-party payment processors)

3. HOW WE USE YOUR PERSONAL DATA 3.1 Legal Basis for Processing We process your personal data under the following legal bases:

Contract Performance (Article 6(1)(b) UK GDPR) To fulfil our obligations under the Partner Programme Terms & Conditions:

• Setting up and managing your Partner account

• Providing recommendation cards and materials

• Tracking referrals and calculating commissions

• Processing commission payments

• Communicating about programme participation

Legitimate Interests (Article 6(1)(f) UK GDPR) For our legitimate business interests:

• Preventing fraud and abuse of the Programme

• Maintaining accurate business records

• Improving the Partner Programme

• Analyzing programme performance

• Protecting our legal rights

Legal Obligation (Article 6(1)(c) UK GDPR) To comply with legal requirements:

• Maintaining financial records for HMRC (7 years)

• Providing tax documentation upon request

• Responding to lawful requests from authorities

Consent (Article 6(1)(a) UK GDPR) With your explicit consent:

• Sending marketing communications about Training Dog® products

• Featuring your business in case studies or testimonials

• Sharing your success stories (anonymized or attributed)

You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

3.2 Purposes of Processing We use your personal data to:

Programme Administration:

• Verify eligibility for the Partner Programme

• Create and manage Partner accounts

• Distribute recommendation cards and materials

• Track card inventory and restock requests

Commission Management:

• Track sales generated through unique referral codes

• Calculate commission earnings

• Process monthly commission payments

• Provide commission statements and reports

• Manage payment disputes or queries

Communication:

• Respond to enquiries and support requests

• Send programme updates and notifications

• Provide monthly commission statements

• Notify of policy changes

• Send newsletters and programme tips (with consent)

Compliance and Legal:

• Maintain records for tax and accounting purposes

• Comply with HMRC requirements

• Respond to legal requests or court orders

• Protect against fraud and unauthorized activity

Business Improvement:

• Analyze programme effectiveness

• Identify trends and opportunities

• Improve Partner experience

• Develop new features or materials

4. DATA SHARING AND DISCLOSURE 4.1 Third-Party Service Providers We may share your personal data with trusted third-party service providers who assist us in operating the Partner Programme:

Payment Processors:

• Banks (for UK bank transfers)

• PayPal (for PayPal payments)

• These providers process payment data securely under strict confidentiality agreements

IT and Communication Services:

• Email service providers (for programme communications)

• Cloud storage providers (for secure data storage)

• CRM systems (for Partner relationship management)

All third-party providers are:

• Carefully selected and vetted

• Contractually obligated to protect your data

• Required to comply with UK GDPR

• Prohibited from using your data for their own purposes

4.2 Legal Requirements We may disclose your personal data if required by law:

• To HMRC or other tax authorities

• To law enforcement or regulatory authorities

• In response to valid court orders or legal processes

• To protect our legal rights or prevent fraud

4.3 Business Transfers If Training Dog® is acquired, merged, or sells assets, your personal data may be transferred to the new owner as part of the transaction. You will be notified of any such change.

4.4 What We Do NOT Do We will NEVER:

• Sell your personal data to third parties

• Share your data with competitors

• Use your data for purposes unrelated to the Partner Programme without consent

• Send your data outside the UK without adequate safeguards

5. DATA SECURITY 5.1 Security Measures We implement appropriate technical and organizational measures to protect your personal data:

Technical Measures:

• Encryption of data in transit (SSL/TLS)

• Encryption of data at rest

• Secure servers with firewall protection

• Regular security updates and patches

• Access controls and authentication

• Regular security audits and vulnerability testing

Organizational Measures:

• Strict access controls (need-to-know basis)

• Employee training on data protection

• Confidentiality agreements with staff

• Clear data handling procedures

• Regular review of security policies

• Incident response procedures

5.2 Payment Security

• Bank details processed via secure banking protocols

• PayPal payments processed through PayPal’s secure platform

• We do not store complete payment card details

• Payment data encrypted during transmission and storage

• PCI-DSS compliance where applicable

5.3 Your Responsibility Partners are responsible for:

• Keeping login credentials confidential

• Using strong, unique passwords

• Not sharing account access with others

• Notifying us immediately of any suspected security breach

• Keeping contact information up to date

6. DATA RETENTION 6.1 Retention Periods We retain your personal data for the following periods:

Active Partnership:

• All data retained for the duration of your participation in the Programme

After Partnership Ends:

• Payment and commission records: 7 years (HMRC requirement)

• Contact details: 1 year (to facilitate potential re-enrollment)

• Correspondence and support tickets: 2 years

• Marketing consent records: Until consent withdrawn

Legal Holds:

• If data is subject to legal proceedings, we retain it until the matter is resolved

6.2 Deletion After Retention Period After retention periods expire:

• Data is securely deleted or anonymized

• Backups are overwritten according to our backup schedule

• Physical records are securely destroyed

6.3 Early Deletion Requests You may request earlier deletion of your data, subject to:

• Legal retention obligations (e.g., HMRC 7-year requirement)

• Ongoing disputes or legal matters

• Legitimate business needs (e.g., processing outstanding payments)

7. YOUR RIGHTS Under UK GDPR, you have the following rights regarding your personal data:

7.1 Right of Access (Article 15) You have the right to:

• Confirm whether we process your personal data

• Receive a copy of your personal data

• Receive information about how we use your data

How to exercise: Email [email protected] with “Data Access Request” in the subject line. We will respond within one month.

7.2 Right to Rectification (Article 16) You have the right to:

• Correct inaccurate personal data

• Complete incomplete personal data

How to exercise: Email [email protected] or update your Partner account directly. We will make corrections within one month.

7.3 Right to Erasure (Article 17) You have the right to request deletion of your personal data when:

• Data is no longer necessary for the purposes it was collected

• You withdraw consent (where processing is based on consent)

• You object to processing and there are no overriding legitimate grounds

• Data has been unlawfully processed

• Erasure is required to comply with legal obligations

Limitations: We may refuse erasure if retention is necessary for:

• Legal obligations (e.g., HMRC requirements)

• Establishment, exercise, or defense of legal claims

How to exercise: Email [email protected] with “Deletion Request” in the subject line.

7.4 Right to Restriction of Processing (Article 18) You have the right to restrict processing when:

• You contest the accuracy of the data

• Processing is unlawful but you prefer restriction to erasure

• We no longer need the data but you need it for legal claims

• You have objected to processing pending verification of legitimate grounds

How to exercise: Email [email protected] with “Restriction Request” in the subject line.

7.5 Right to Data Portability (Article 20) You have the right to:

• Receive your personal data in a structured, commonly used, machine-readable format

• Transmit that data to another controller

Applies to: Data you provided based on consent or contract performance, and processed by automated means.

How to exercise: Email [email protected] with “Data Portability Request” in the subject line.

7.6 Right to Object (Article 21) You have the right to object to processing based on:

• Legitimate interests (Article 6(1)(f))

• Direct marketing (absolute right)

How to exercise: Email [email protected] with “Objection” in the subject line. For marketing, you may also use the unsubscribe link in emails.

7.7 Rights Related to Automated Decision-Making (Article 22) We do not use automated decision-making or profiling that produces legal or similarly significant effects.

7.8 Right to Withdraw Consent Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

How to exercise: Email [email protected] or use the unsubscribe link in marketing emails.

7.9 Right to Complain You have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):

ICO Contact Details: Website: https://ico.org.uk Telephone: 0303 123 1113 Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

We encourage you to contact us first so we can try to resolve any concerns.

8. INTERNATIONAL DATA TRANSFERS 8.1 Data Location Your personal data is primarily stored and processed in the United Kingdom.

8.2 Transfers Outside the UK If we transfer data outside the UK, we ensure adequate protection through:

• UK GDPR adequacy decisions

• Standard Contractual Clauses approved by the UK ICO

• Other appropriate safeguards recognized under UK law

8.3 Third-Party Services Some service providers may store data on servers outside the UK. We ensure these providers:

• Comply with UK GDPR requirements

• Implement appropriate safeguards

• Have appropriate data transfer mechanisms in place

9. COOKIES AND TRACKING 9.1 Partner Portal If we provide an online Partner portal, we may use:

• Essential cookies (for login and session management)

• Analytics cookies (to improve portal performance)

• Preference cookies (to remember your settings)

9.2 Email Communications We may use tracking pixels in emails to:

• Monitor email delivery and open rates

• Improve communication effectiveness

• Ensure compliance with anti-spam laws

You can disable email tracking by adjusting your email client settings.

9.3 Your Choices You can control cookies through your browser settings. Note that disabling essential cookies may prevent you from accessing certain features.

10. CHILDREN’S PRIVACY The Partner Programme is intended for business professionals aged 18 and over. We do not knowingly collect personal data from children under 18. If we discover we have collected data from a child, we will delete it promptly.

11. DATA BREACH NOTIFICATION 11.1 Our Obligations If we discover a personal data breach that poses a risk to your rights and freedoms, we will:

• Notify the ICO within 72 hours of becoming aware

• Notify affected Partners without undue delay

• Provide information about the nature of the breach, likely consequences, and measures taken

11.2 Your Obligations If you become aware of any actual or suspected data breach involving your Partner account or data, you must notify us immediately at [email protected].

12. PARTNER RESPONSIBILITIES 12.1 Customer Data Partners must NOT:

• Collect personal data from dog owners on behalf of Training Dog®

• Share dog owner contact details with Training Dog®

• Process dog owner data as part of the Partner Programme

Partners’ role is limited to distributing recommendation cards. Dog owners interact directly with Training Dog® for all purchases and data processing.

12.2 Data Protection Compliance Partners are responsible for their own compliance with UK GDPR in their business operations, including:

• Customer data from their own business activities

• Employee data (if applicable)

• Their own privacy policies and procedures

13. CHANGES TO THIS PRIVACY POLICY 13.1 Notification of Changes We will notify Partners of material changes to this Privacy Policy by:

• Emailing registered Partner email addresses

• Providing at least 30 days’ notice before changes take effect

• Updating the “Last Updated” date at the top of this document

13.2 Acceptance of Changes Continued participation in the Partner Programme after the notice period constitutes acceptance of the updated Privacy Policy.

13.3 Right to Terminate If you do not accept changes to this Privacy Policy, you may terminate your participation in the Partner Programme immediately.

14. CONTACT INFORMATION For any questions, concerns, or requests regarding this Privacy Policy or your personal data:

General Enquiries: Training Dog® Email: [email protected] Phone: 07756212501 (UK +44)

Data Protection Enquiries: Email: [email protected]

Postal Address: Lorenzo Barichella ST trading as Training Dog® 180 Brompton Park Crescent London SW6 1SX United Kingdom

Regulatory Authority: Information Commissioner’s Office (ICO) Website: https://ico.org.uk Telephone: 0303 123 1113

15. ACCEPTANCE By joining the DOG LICENCE™ Partner Programme, you acknowledge that you have read, understood, and agree to this Privacy Policy.

Last Updated: January 2026

© 2026 Training Dog®. All rights reserved.

ONLY BREEDERS
PRIVACY POLICY – PARTNER PROGRAMME

Last Updated: January 2026

1. INTRODUCTION

Training Dog® (“we,” “us,” “our”) is committed to protecting the privacy and security of personal data belonging to Partners in our DOG LICENCE™ Partner Programme.

This Privacy Policy explains how we collect, use, store, and protect your personal information in accordance with UK data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Controller:
Training Dog®
[Your registered address]
Email: [email protected]
ICO Registration Number: [Your ICO number if applicable]

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

When you register for the Partner Programme, we collect:

Identity Information:

• Full name

• Kennel name (if applicable)

• Breed specialisations

Contact Information:

• Postal address

• Email address

• Phone number

Financial Information:

• Bank account details (account name, sort code, account number) OR

• PayPal email address

• VAT registration number (if applicable)

Business Information:

• Approximate number of puppies placed annually

• Preference for display stand

• How you heard about the programme

Marketing Preferences:

• Consent for operational emails (required)

• Consent for marketing emails (optional)

2.2 Information We Generate

Programme Data:

• Unique referral code assigned to you

• Date of registration

• Commission records and payment history

• Number of successful referrals

• Sales data linked to your referral code

2.3 Information We Collect Automatically

Technical Information:

• IP address when submitting registration form

• Browser type and version

• Device information

• Time zone settings

Usage Data:

• Pages viewed

• Time spent on pages

• Links clicked

3. HOW WE USE YOUR INFORMATION

3.1 Legal Basis for Processing

We process your personal data under the following legal bases:

Contract Performance (Art. 6(1)(b) UK GDPR):

• To register you in the Partner Programme

• To generate and provide your unique referral code

• To send you personalised recommendation cards

• To calculate commissions owed to you

• To process monthly commission payments

• To communicate about programme matters

Legitimate Interest (Art. 6(1)(f) UK GDPR):

• To prevent fraud and abuse of the programme

• To maintain accurate business records

• To improve the Partner Programme

• To analyse programme performance

• To ensure programme integrity

Legal Obligation (Art. 6(1)(c) UK GDPR):

• To comply with financial record-keeping requirements (7 years for HMRC)

• To comply with tax reporting obligations

• To respond to lawful requests from authorities

Consent (Art. 6(1)(a) UK GDPR):

• To send marketing communications (only if you opt in)

• You may withdraw consent at any time

3.2 Specific Purposes

We use your information to:

Programme Administration:

• Process your application to join the programme

• Create and send personalised recommendation cards

• Provide optional display stands if requested

• Assign and manage your unique referral code

• Track referrals and sales attributed to your code

Payment Processing:

• Calculate monthly commission amounts

• Process payments via bank transfer or PayPal

• Send payment confirmation emails

• Maintain payment records for accounting purposes

• Provide annual commission statements for tax purposes

Communications:

• Send operational emails (payment confirmations, card restocks, programme updates)

• Respond to your enquiries and support requests

• Send marketing emails if you’ve opted in (you can unsubscribe anytime)

• Notify you of changes to Terms & Conditions or this Privacy Policy

Compliance and Legal:

• Maintain records required by UK financial regulations

• Respond to legal requests or comply with legal obligations

• Protect against fraud and abuse

• Enforce our Terms & Conditions

Business Improvement:

• Analyse programme performance and effectiveness

• Understand referral patterns and sales data

• Improve Partner experience and materials

• Develop new features or benefits for Partners

4. HOW WE SHARE YOUR INFORMATION

4.1 Third-Party Service Providers

We share your data with trusted third-party service providers who process data on our behalf:

Payment Processors:

• Your bank details shared with our payment service provider to process bank transfers

• Your PayPal email shared with PayPal to process payments

• These providers are PCI-DSS compliant and bound by strict confidentiality agreements

Email Service Providers:

• Your email address and name shared with our email service provider to send programme communications

• Providers comply with UK GDPR and have appropriate security measures

Postal Services:

• Your name and postal address shared with Royal Mail or courier services to deliver recommendation cards

• Only used for programme-related deliveries

Website Hosting:

• Technical data processed by our hosting provider

• Servers located in the UK or EU with adequate data protection

All third-party processors:

• Are carefully selected and vetted

• Process data only on our instructions

• Have appropriate technical and organisational security measures

• Are bound by data processing agreements

• Comply with UK GDPR requirements

4.2 Legal Requirements

We may disclose your information if required to:

• Comply with legal obligations or court orders

• Respond to lawful requests from HMRC, police, or other authorities

• Protect our rights, property, or safety

• Prevent fraud or criminal activity

• Enforce our Terms & Conditions

4.3 Business Transfers

If Training Dog® is sold, merged, or transferred to another entity, your data may be transferred to the successor organisation. You will be notified of any such change.

4.4 What We Do NOT Share

We will never:

• Sell your personal data to third parties

• Share your data with puppy families or customers (they will never know you receive commission)

• Share your financial information except as necessary for payment processing

• Use your data for purposes other than those stated in this policy without your consent

5. DATA SECURITY

5.1 Security Measures

We implement appropriate technical and organisational measures to protect your data:

Technical Measures:

• Industry-standard encryption for data in transit (TLS/SSL)

• Encryption for sensitive data at rest

• Secure, password-protected databases

• Regular security updates and patches

• Firewall protection

• Intrusion detection systems

Organisational Measures:

• Access to personal data restricted to authorised personnel only

• Staff trained on data protection and confidentiality

• Confidentiality agreements with all staff and contractors

• Regular security audits and assessments

• Incident response procedures

Payment Security:

• Financial data processed via PCI-DSS compliant providers

• We do not store full bank account or credit card details on our systems

• Payments transmitted via secure, encrypted connections

5.2 Data Breach Procedures

In the event of a data breach affecting your personal data:

• We will notify you within 72 hours if the breach poses a high risk to your rights

• We will report to the Information Commissioner’s Office (ICO) as required by law

• We will take immediate steps to contain and remedy the breach

• We will provide advice on steps you can take to protect yourself

6. DATA RETENTION

We retain your personal data for different periods depending on the type of data and legal requirements:

During Active Partnership:

• All data retained for the duration of your participation in the programme

After Termination:

Early Deletion:

• You may request deletion of contact details 1 year after termination

• Financial records must be retained for 7 years regardless of deletion requests (legal obligation)

• We will delete data earlier where legally permissible and upon request

Secure Deletion: When data is deleted, we use secure deletion methods to ensure it cannot be recovered.

7. YOUR RIGHTS

Under UK GDPR, you have the following rights regarding your personal data:

7.1 Right of Access (Art. 15)

• Request a copy of all personal data we hold about you

• Receive information about how we process your data

• Free of charge (unless request is manifestly unfounded or excessive)

7.2 Right to Rectification (Art. 16)

• Request correction of inaccurate or incomplete data

• We will update your data promptly upon request

7.3 Right to Erasure / “Right to be Forgotten” (Art. 17)

• Request deletion of your personal data

• Subject to legal retention requirements (we must keep financial records for 7 years)

• We will delete all other data where legally possible

7.4 Right to Restrict Processing (Art. 18)

• Request that we limit how we use your data in certain circumstances

• We will comply except where we have compelling legitimate grounds

7.5 Right to Data Portability (Art. 20)

• Request your data in a structured, commonly used, machine-readable format

• Request transfer of your data to another organisation where technically feasible

7.6 Right to Object (Art. 21)

• Object to processing based on legitimate interests

• Object to direct marketing at any time (we will stop immediately)

7.7 Rights Related to Automated Decision Making (Art. 22)

• We do not use automated decision-making or profiling in the Partner Programme

• All decisions made by human review

7.8 Right to Withdraw Consent

• Withdraw consent for marketing communications at any time

• Does not affect lawfulness of processing before withdrawal

• Does not affect processing based on other legal bases (contract, legal obligation)

7.9 How to Exercise Your Rights

To exercise any of these rights:

Email: [email protected]
Subject Line: “Data Subject Request – Partner Programme”
Include: Your name, kennel name, and email address used for registration

Response Time:

• We will respond within 30 days (may be extended to 60 days for complex requests)

• We will inform you of any extension and the reasons

Verification:

• We may request additional information to verify your identity before fulfilling requests

• This protects your data from unauthorised access

Free of Charge:

• All requests are free unless manifestly unfounded or excessive

• We may charge a reasonable fee for repetitive requests

8. INTERNATIONAL DATA TRANSFERS

UK-Based Processing:

• All data primarily processed and stored within the United Kingdom

• Hosting servers located in UK or EU with adequate data protection

Third-Party Processors:

• Some service providers (e.g., PayPal, email services) may process data outside the UK

• All international transfers comply with UK GDPR requirements

• Adequate safeguards in place (Standard Contractual Clauses, adequacy decisions)

Your Rights:

• You have the right to request information about international transfers

• You may request copies of safeguards in place

9. COOKIES AND TRACKING

Registration Form:

• We may use strictly necessary cookies to enable form submission

• Session cookies deleted when you close your browser

Analytics:

• We may use analytics cookies to understand how Partners interact with our website

• You can disable cookies in your browser settings

• Disabling cookies may affect website functionality

For full details on cookie usage, see our separate Cookie Policy.

10. CHILDREN’S PRIVACY

The Partner Programme is intended for adults only (18+ years of age).

We do not knowingly collect personal data from individuals under 18.

If we become aware that we have collected data from a minor, we will delete it immediately.

11. CHANGES TO THIS PRIVACY POLICY

Updates:

• We may update this Privacy Policy from time to time

• Material changes will be notified via email at least 30 days in advance

• Continued participation after notice period constitutes acceptance

• Previous versions available upon request

Review:

• We recommend reviewing this policy periodically

• Last updated date shown at top of policy

12. YOUR RIGHT TO COMPLAIN

Internal Complaint: If you have concerns about how we handle your data:

1. Contact us first: [email protected]

2. We will investigate and respond within 30 days

External Complaint: You have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: www.ico.org.uk
Live Chat: Available on ICO website

You may also complain to the ICO if you are dissatisfied with our response to your concerns.

13. CONTACT US

For Privacy-Related Questions:

Email: [email protected]
Subject Line: “Privacy Enquiry – Partner Programme”

For General Programme Questions:

Email: [email protected]
Phone: [Your phone number]

Postal Address:

Training Dog®
[Your registered address]

Data Protection Officer: If we appoint a Data Protection Officer in the future, their contact details will be listed here.

14. LEGAL BASIS SUMMARY

For quick reference, here is how we process your data:

By registering for the Partner Programme, you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your personal data as described.

Last Updated: January 2026

© 2026 Training Dog® – Lorenzo Barichella. All rights reserved.