Legal
Privacy Policy — Offleash Walker Portal
1.About this policy and who it applies to
This Privacy Policy applies to professional dog walkers who use the Offleash Walker Portal at pack.getoffleash.com.au (the "Portal"). The Portal is operated by CEDR Consulting Pty Ltd (ABN 90 670 532 377) of Malvern East VIC 3145 ("we", "us", "our", "Offleash").
This policy is separate from and supplements the Offleash Consumer Privacy Policy, which governs use of the Offleash consumer app at getoffleash.com.au. If you use both the Portal and the consumer app, both policies apply to their respective services.
This policy applies to you if you are:
- A registered walker on the Offleash Walker Portal
- A person applying to become a registered walker
- An employee or contractor of a registered walker business using the Portal on behalf of that business
This policy explains what personal information we collect about you and your clients in connection with the Portal, how we use and disclose that information, and your rights in relation to it. We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
If you have questions about this policy, contact us at pack@off-leash.app.
2.The nature of your relationship with Offleash
You are an independent contractor, not an employee of Offleash. Offleash provides the Portal as a software platform to help you run your dog walking business. Offleash does not direct, supervise, or control the services you provide to your clients.
This distinction is important for privacy purposes. When you collect personal information from your clients through the Portal (for example, their dog's health details or home address), you do so as an independent data controller in your own right. You are responsible for complying with your own privacy obligations to your clients under the Privacy Act 1988 (Cth) and the APPs.
Offleash processes client personal information on your behalf as a data processor, subject to our Walker Agreement and this policy. This does not relieve you of your own independent obligations as a data controller.
3.What personal information we collect about you (the walker)
Account and identity information
- Full legal name
- Email address and phone number
- Password (stored in hashed form — we never see your plain text password)
- Profile photo
- Authentication data if you sign in using Google OAuth
Business information
- Business name (if operating under a registered business name)
- Australian Business Number (ABN) — required for all walkers processing payments through the Portal
- GST registration status
- Business address and service area
- Professional bio and public profile content
Compliance and verification information
- Copy of government-issued photo ID (collected by Stripe as part of Stripe Connect onboarding — not stored by Offleash directly; see Section 8)
- Public liability insurance details — insurer name, policy number, coverage amount, and expiry date
- Any other professional certifications or accreditations you choose to add (e.g. dog training qualifications, first aid)
Financial and payment information
- Stripe Connect account ID (a reference identifier — not your bank account number)
- Transaction metadata for payments processed through the Portal (see Section 8 for full details)
- Subscription billing details for your Offleash Walker Portal subscription (managed by Stripe Billing)
Walk session and operational data
- Walk session records — scheduled sessions, actual start and end times, dogs walked, parks visited
- In-walk event logs — potty events, photos taken, 'all is well' notifications sent
- Walk report cards generated for clients
- Incident reports submitted during or after walks
- Park check-in records associated with your walk sessions
Communications
- Messages exchanged with clients through the Portal's messaging feature
- Support communications with Offleash
Usage and device data
- Pages and features accessed within the Portal
- Login times and session duration
- Device type and browser information
- IP address
4.What personal information we collect about your clients
When you use the Portal to manage your dog walking business, you and Offleash jointly handle personal information belonging to your clients (dog owners). The following client information is collected through the Portal:
Client account information
- Client's name and email address
- Phone number
- Home address and any alternative pick-up/drop-off addresses
Dog information
- Dog name, breed, date of birth, weight, and size
- Gender and desexed status
- Energy level and personality notes
- Vaccination status (self-reported by client)
- Microchip number
- Known health conditions, allergies, and medications (self-reported)
- Veterinary clinic name and contact details
- Authorised veterinary spend limit
- Emergency contact details
Walk and service records
- Walk history — dates, times, parks, duration
- Walk report cards and photos from each session
- Incident reports involving the client's dog
- Payment history for services rendered
Client payment data
- Transaction metadata for payments made by clients through the Portal (see Section 8)
- No raw card data is stored by Offleash — all payment credentials are handled by Stripe
You are responsible for obtaining appropriate consent from your clients to collect and use their personal information through the Portal. Offleash provides standard consent language in the client onboarding flow, but you remain the data controller for your client relationships.
5.How we collect personal information
We collect personal information:
- Directly from you when you register on the Portal, set up your walker profile, schedule walks, log walk events, and otherwise use the Portal
- From Stripe, when you complete Stripe Connect onboarding and when you process payments — Stripe shares transaction metadata with us (see Section 8)
- From your clients, when they complete their onboarding through your walker booking link or when they provide information about their dogs
- Automatically through the Portal's usage logging and analytics systems
6.Why we collect personal information — our purposes
We use personal information to:
For walker account management
- Create and manage your walker account and business profile
- Verify your identity and professional credentials
- Process your monthly subscription payment
- Provide you with the Portal's scheduling, client management, invoicing, and analytics features
- Display your public walker profile to dog owners on the Offleash consumer app
- Send transactional communications including account confirmations, walk reminders, and payment receipts
- Provide customer support
For payment processing
- Facilitate payments from your clients to your Stripe Connect account
- Collect Offleash's service fee via Stripe's platform fee mechanism
- Generate invoices and transaction records
- Comply with our obligations under the ATO Sharing Economy Reporting Regime (SERR) — see Section 9
For client management
- Enable you to manage your client roster and dog profiles
- Store walk records, report cards, and incident reports on your behalf
- Send automated notifications to your clients on your behalf (park check-ins, 'all is well' updates, walk report delivery)
For safety and compliance
- Maintain incident records as evidentiary documents
- Monitor for unusual transaction patterns as a good governance measure
- Comply with our legal obligations under Australian law
For service improvement
- Conduct analytics on Portal usage to improve the product
- Produce aggregated, anonymised data about dog walking patterns and park usage (see Section 7)
We do not use your personal information or your clients' personal information for targeted advertising. We do not sell personal information to third parties.
7.Aggregated and anonymised data
Walk session data — including parks visited, times, and dog characteristics — contributes to Offleash's park intelligence features on the consumer app (breed mix, energy levels, real-time activity). This data is aggregated and anonymised before being displayed publicly. Individual walkers and their clients are never identified in park intelligence displays.
We may also produce aggregated, anonymised reports about dog walking patterns for internal analytics purposes and, in future, for councils and research partners. This data will not identify any individual walker or client.
You may opt out of your walk session data contributing to third-party aggregated data products at any time in Portal Settings → Privacy → Data sharing. Note that opting out does not affect core Portal functionality.
8.Payment data and Stripe Connect
How payments work
The Offleash Walker Portal uses Stripe Connect to facilitate payments between your clients and your business. When a client pays for a walk through the Portal:
- The client's payment goes directly to your Stripe Express account
- Offleash collects a 1.5% service fee on the transaction via Stripe's platform fee mechanism
- Offleash's bank account never receives or holds your client's funds
- Stripe's own processing fees (approximately 1.75% + $0.30 AUD per transaction) are deducted from your Stripe account by Stripe directly
What Offleash stores
Offleash stores only the following transaction metadata in its database (hosted in AWS ap-southeast-2, Sydney):
- Stripe transaction ID
- Total transaction amount
- Offleash service fee amount
- Your Stripe Connect account ID
- Transaction status and timestamp
- Last 4 digits of the card used (for reference only)
Offleash does not store your card number, CVV, expiry date, your clients' full card details, or your bank account BSB and account number.
Stripe Connect onboarding
As part of the Stripe Express onboarding process, Stripe will collect and verify your identity directly. This includes your full name, date of birth, residential address, and a copy of a government-issued photo ID. This information is held by Stripe under Stripe's own Privacy Policy (stripe.com/au/privacy) and is not stored by Offleash.
You must accept the Stripe Connected Account Agreement as part of the onboarding process. By doing so, you establish a direct contractual relationship with Stripe Payments Australia Pty Ltd.
ABN requirement
All walkers processing payments through the Portal are required to provide a valid ABN. If you are unable to provide an ABN, you must provide a completed ATO Statement by a Supplier form before your payment processing access will be activated. This requirement exists to protect you from the "no ABN withholding" rules under Australian tax law, which could otherwise require 47% of payments to be withheld.
GST
If you are registered for GST, the Portal's invoicing system will apply 10% GST to your service amounts. If you are not registered for GST (annual turnover below $75,000), invoices will state "GST not applicable — supplier not registered for GST." It is your responsibility to notify Offleash if your GST registration status changes.
9.Sharing Economy Reporting Regime (SERR)
Offleash is an electronic distribution platform (EDP) for the purposes of the ATO's Sharing Economy Reporting Regime, which has been in effect since 1 July 2024.
Under this regime, Offleash is legally required to report the following information about payments made to you through the Portal to the Australian Taxation Office (ATO), on a biannual basis:
- Your full name, ABN, date of birth, and address
- Total gross amount paid to you through the Portal during the reporting period
- Total GST amount (where applicable)
- Total Offleash service fees charged to your transactions
- Total net amount received by you
Reporting periods and lodgement dates:
| Period | Lodgement deadline |
|---|---|
| 1 January – 30 June | 31 July |
| 1 July – 31 December | 31 January |
You will be notified via the Portal prior to each reporting period. By accepting the Walker Agreement, you acknowledge and consent to Offleash collecting and reporting this information to the ATO as required by law. SERR reporting cannot be opted out of while you continue to process payments through the Portal.
The ATO may use this information to cross-check against your own tax returns. It is your responsibility to ensure your tax returns accurately reflect your income from the Portal. Offleash recommends consulting a registered tax agent or using an integrated accounting tool (Xero, available in the Portal) to manage your tax obligations.
10.Who we share personal information with
Your clients
Walk records, report cards, incident reports, and notifications are shared with the relevant dog owner as part of the core service.
Service providers
We share personal information with the following third-party providers who assist us in operating the Portal. Each is bound by contractual obligations to handle personal information securely and only for the purposes we specify:
| Provider | Purpose | Location |
|---|---|---|
| Supabase (via AWS ap-southeast-2) | Database, authentication, and file storage | Australia (Sydney region) |
| Vercel | Application hosting and deployment | United States and global CDN |
| Stripe Payments Australia Pty Ltd | Payment processing, Stripe Connect account management, identity verification | United States / Australia |
| Resend | Transactional email delivery | United States |
| PostHog | Product analytics and usage tracking | United States / EU |
| Anthropic | AI language model for walk report card summary generation | United States |
| Xero (if enabled) | Accounting integration — transaction data only | Australia / New Zealand |
| Sign-in via Google OAuth (if used) | United States |
The ATO
As described in Section 9, we are required by law to report walker income data to the ATO biannually under the SERR.
Regulatory and law enforcement authorities
We may disclose personal information where required by law, court order, or to cooperate with law enforcement or regulatory authorities. We will notify you of such disclosure where we are legally permitted to do so.
Business transfers
If CEDR Consulting Pty Ltd or the Offleash business is acquired, merged, or undergoes a change of ownership, personal information held by us may be transferred to the acquiring entity. We will notify affected walkers before any such transfer.
Overseas disclosure
Personal information may be stored or processed in the United States and other countries where our service providers operate. We take reasonable steps to ensure overseas recipients handle personal information consistently with the Australian Privacy Principles, including through Data Processing Agreements with each provider.
11.Data Processing Agreements
Offleash has entered into Data Processing Agreements (DPAs) with its key service providers, including Supabase, Stripe, Resend, and PostHog. These agreements ensure that personal information processed on our behalf is handled in accordance with the APPs.
12.Your clients' rights — your responsibilities
As the data controller for your client relationships, you are responsible for:
- Informing your clients about how their personal information is collected and used through the Portal
- Obtaining appropriate consent from clients before collecting sensitive information (such as health conditions)
- Responding to client requests to access, correct, or delete their personal information held within your walker account
- Complying with all applicable Australian privacy laws in your dealings with clients
Offleash provides standard privacy disclosure language in the client onboarding flow to assist you. However, this does not constitute legal advice, and you should seek independent advice if you are uncertain about your obligations.
To assist with client data requests, you may export client data from the Portal at any time via Settings → Data → Export client records.
13.Retention of personal information
We retain personal information for as long as necessary to provide the Portal and fulfil the purposes described in this policy, unless a longer retention period is required by law.
| Data type | Retention period |
|---|---|
| Walker account and profile data | Retained while your account is active, plus 90 days after closure |
| Walk session records | 3 years from date of walk |
| Walk report cards | 3 years from date of delivery |
| Incident reports | 7 years from date of incident (evidentiary requirement) |
| Transaction metadata | 5 years from transaction date (ATO requirement) |
| SERR reports lodged with ATO | 5 years from date of lodgement |
| Walker business information (ABN, insurance) | Duration of account plus 5 years |
| Client personal information | 3 years from last active walk, or until you delete the client record |
| Client dog health information | 3 years from last active walk, or until you delete the record |
| Communications (messages, support) | 2 years from date of communication |
| Backup data | Purged within 90 days of the deletion event |
Incident reports are retained for 7 years because they may be required as evidence in insurance claims, legal proceedings, or regulatory investigations. Incident records are immutable — they cannot be edited after submission, though addenda may be added.
14.Data security
We use industry-standard security practices to protect personal information held in the Portal, including:
- Encryption of data in transit (TLS)
- Encryption of data at rest
- Row-level security (RLS) on all database tables — your data is accessible only to you and authorised Offleash personnel
- Role-based access controls within the Offleash team
- Regular review of security practices
Stripe maintains its own security standards for payment data, including PCI DSS compliance. Offleash is out of scope for PCI DSS because we do not store, process, or transmit raw card data.
In the event of a data breach that is likely to result in serious harm, we will notify affected walkers and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).
15.Automated decision-making
Offleash uses automated processes in certain circumstances, including:
- Walker account verification — automated checks on ABN validity and insurance expiry dates
- Transaction monitoring — automated flagging of unusual transaction patterns as a good governance measure
- Walk report summaries — AI-generated draft summaries using Anthropic Claude, which are reviewed and approved by you before being sent to clients
Where an automated process may materially affect your access to the Portal or payment processing, you may request human review by contacting pack@off-leash.app. This is consistent with our obligations under APP 1 and the forthcoming automated decision-making transparency requirements (effective 10 December 2026).
16.Your rights
Access
You may request access to the personal information we hold about you. We will respond within 30 days.
Correction
If you believe personal information we hold is inaccurate, incomplete, or out of date, you may request a correction via the Portal or by emailing pack@off-leash.app.
Deletion
You may close your walker account at any time from Portal Settings → Account → Close Account. Personal information will be retained for the periods set out in Section 13 where required by law or for legitimate business purposes (such as incident records and ATO compliance). You may also request deletion by emailing pack@off-leash.app.
Data export
You may export your walk records, client data, and transaction history at any time from Portal Settings → Data → Export. We will also provide a full data export on request within 30 days. Email pack@off-leash.app with the subject line Data export request.
Opt out of analytics
You may opt out of PostHog analytics tracking at any time in Portal Settings → Privacy.
Opt out of aggregated data sharing
You may opt out of your walk data contributing to third-party aggregated data products in Portal Settings → Privacy → Data sharing.
SERR reporting
SERR reporting to the ATO is a legal obligation and cannot be opted out of while you process payments through the Portal. If you close your account, SERR reporting will continue for any periods during which you processed payments while your account was active.
To exercise any of these rights, contact us at pack@off-leash.app.
17.Minimum age
The Offleash Walker Portal is intended for users aged 18 and over. You must be at least 18 years old to hold a Stripe Connect account and to register as a professional walker on the Portal. We do not knowingly collect personal information from anyone under 18 in connection with the Portal.
18.Changes to this policy
We may update this policy from time to time. If we make material changes, we will notify you via email and via an in-app banner in the Portal, with at least 14 days notice before the changes take effect.
If you do not accept the updated policy, you may close your account before the changes take effect. Continued use of the Portal after the effective date constitutes your acceptance of the updated policy.
The version history of this policy is available on request.
19.Complaints
If you believe we have not handled your personal information in accordance with this policy or the Australian Privacy Principles, you have the right to make a complaint.
Step 1
Contact us directly at pack@off-leash.app. Please describe your concern in as much detail as possible. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.
Step 2
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by calling 1300 363 992.
From June 2025, individuals may also bring a direct court action for serious invasions of privacy under the statutory tort introduced by the Privacy and Other Legislation Amendment Act 2024 (Cth).
20.Contact
CEDR Consulting Pty Ltd
ABN: 90 670 532 377
Malvern East VIC 3145
Email: pack@off-leash.app
Website: pack.getoffleash.com.au