DraftThis wording is pending owner review and may still change.
Last updated: 25 September 2026 (draft)
The short version
CuppaPug is a membership for adults who love our pugs. We keep the personal data we hold about you small, we never see your card details, we do not sell your data, and marketing is off unless you switch it on. You can ask for a copy of your data or ask us to delete your account from your profile page at any time, and a real person will handle it within a month.
Who we are
CuppaPug runs pug cafes in the United Kingdom and the United States, and this membership app for our members in both countries. If anything in this policy is unclear, or you want to use any of your rights, email hello@cuppapug.com and a person will help.
CuppaPug is the controller responsible for the personal data described here:
- Legal entity: [OWNER: legal entity name]
- Company number:[OWNER: company number or “not applicable”]
- Registered office: [OWNER: registered office address]
- ICO registration: [OWNER: ICO registration number or confirmed exemption]
- UK representative:[OWNER: UK representative, or “not applicable” if the controller is a UK company]
What we collect
- Your account and membership. Your name, email address, region (UK or USA), home cafe, membership tier and status, and the name and short bio you choose for your profile. Sign-in is handled by Clerk, our login provider: we never see or store your password.
- Your 18+ confirmation. The date you confirmed you are 18 or over, and which wording you saw. We never ask for your date of birth.
- Billing status, not billing details.Payments happen with Square. We receive messages like “payment succeeded” or “membership cancelled” and reference numbers, so the app knows what you can access. We never receive or store card numbers.
- What you share in the app. Community posts, comments, reactions, reports, photos you upload, cafe visits you log, and questions you send for livestreams.
- Notification choices and devices.Your notification preferences, and only if you switch it on, the browser push subscription that lets us reach your device, with your browser’s name.
- Support and usage traces. Short records of what happened in the app, linked to your member number: for example that you opened a pug profile, played a video, followed a pug, or sent a privacy request. We use them to fix problems and keep the app safe. They never contain your message text, card details or passwords, and they expire automatically.
Where your data comes from
Most of it comes from you. When you join on our website (run on Wix) and pay with Square, they pass us your email, your choices at checkout (terms, marketing, and your 18+ tick) and your billing status. Square keeps telling us when a payment succeeds or fails. Photos and short videos from customer reviews on our booking partner Beyonk may be shown in the app, only after our team has checked each one.
Why we use it, and our legal basis
UK data protection law asks us to name a legal reason (“lawful basis”) for each use. Where we rely on legitimate interests, we have checked that our reason is fair and does not override your rights, and you can object at any time.
- Running your membership: sign-in, access for your tier and region, perks
- Data: Account, membership and billing status, region and cafe
- Basis: Contract (we need it to provide the membership you signed up for)
- Membership emails and in-app notices (activation, payment problems, your requests)
- Data: Email address, notification records
- Basis: Contract
- Push notifications on your device
- Data: Push subscription for your browser
- Basis: Consent (you switch it on, and can switch it off any time)
- Cafe news and offers
- Data: Email address, marketing choice
- Basis: Consent (off unless you tick the box; withdraw any time)
- Checking members are 18 or over
- Data: Your 18+ confirmation and when you gave it (never your date of birth)
- Basis: Legitimate interests (keeping the service for adults) and legal obligation
- Keeping the community safe: screening, reports, moderation, warnings
- Data: Posts, comments, reports, moderation and safety records
- Basis: Legitimate interests (a kind, safe community) and legal obligation (UK Online Safety Act)
- Support, security and fixing problems: audit records and usage traces
- Data: Short records of actions in the app, with member IDs, never message text
- Basis: Legitimate interests (keeping the app working and secure)
- Sorting out billing and payment problems
- Data: Square customer and subscription references, payment status events
- Basis: Contract, and legal obligation for tax and accounting records
- Photos, videos and livestreams from our cafes
- Data: Images of the cafe, which can include visitors
- Basis: Legitimate interests (sharing cafe life with members). Consent where we feature you prominently, and always for children
- Answering your privacy requests and keeping a record of them
- Data: The request, its dates and what we did
- Basis: Legal obligation
Giving us your email and billing details is needed to have a membership. Everything else is up to you. We do not sell your personal data, and we do not share it for advertising.
Automatic checks in the community
New comments are checked automatically for links and some words that need a closer look, and a member’s first three comments wait for review. If three different members report the same comment, it is hidden automatically until our team looks at it. These checks only decide whether something waits for a person; a person makes every final decision. Nothing about you is decided automatically in a way that has legal or similarly serious effects. See our community guidelines.
Who helps us run CuppaPug
A small set of providers process data for us, each doing one job:
- Clerk: sign-in and account security.
- Square: membership payments and billing.
- Wix: our public website, where new memberships are set up.
- Cloudflare: storing and delivering the photos, videos and livestreams in the app.
- Railway: hosting the app and its database.
- Resend: sending membership emails such as activation links, access notices and privacy request confirmations.
- Marketing email: if you opt in, cafe news is sent with [OWNER: marketing email sender, for example Wix Email Marketing or Square Marketing].
- Browser push services (Apple, Google or Mozilla, depending on your browser): if you switch on push, they carry the notification to your device. The message content is encrypted.
- AI writing tools used by our staff (Claude by Anthropic or ChatGPT by OpenAI): staff can use them to draft posts. The connection only shares counts and draft text, never member records, and staff must not paste member details into them.
Beyonk, our booking partner, is a separate company responsible for your bookings and reviews under its own privacy policy. We only show review photos and videos that its terms allow and that our team has approved.
Some providers are based in the USA, so your data may be processed there or elsewhere outside the UK. The transfer safeguard is [OWNER: counsel-confirmed UK/US transfer mechanism]. Our internal processor register tracks each provider’s contract and transfer review.
Livestreams and recordings
We livestream from our cafes to Premium members. Anyone in view of the camera, including visitors, can appear. There are signs at the cafe where and when we film, and you can ask staff to keep you out of shot. Shows are recorded by Cloudflare. We may keep one recording as a replay in the app; other recordings are deleted 30 days after the show. If you appear in a replay and want it removed or edited, email hello@cuppapug.com. Questions you send during a show are seen by the host (with your display name, never your email) and are deleted if you ask us to erase your data.
Photos and videos of people
Our staff take photos and videos of the pugs and cafe life for the app and our social channels. Visitors may appear in the background. If a photo would feature you recognisably and prominently, we ask you first. We never feature a child without a parent or carer agreeing. You can tell staff at the cafe that you would rather not appear, and you can ask us to take down any photo of you at any time by emailing hello@cuppapug.com.
Review photos and clips from Beyonk are only shown after a member of our team checks them, and never with the reviewer’s name. Photos you share in the app yourself are covered by the membership terms. We remove location details (EXIF/GPS) from photos you upload before anyone else sees them.
How long we keep things
We keep data only as long as we need it. These periods are enforced by automatic clean-up jobs in the app:
- Your account and everything you added
- While your membership is active. When it ends (cancelled or closed) and nothing changes for 2 years, we erase it. Or sooner if you ask.
- Posts and comments you delete
- Deleted straight away, with their photos. If someone had reported it, we keep it hidden, only for the report, for up to 1 year, then delete it.
- Community warnings and posting timeouts
- While your account exists. If your account is erased, for up to 2 years from when it was given, with no name or email attached.
- In-app notifications
- 90 days after you read them, 365 days if unread.
- Email and push delivery records
- 180 days.
- Push notification devices you switched off
- 90 days.
- Support and usage traces
- 180 days, or up to 370 days for privacy requests.
- Staff action records (audit log)
- 2 years.
- Payment status messages from Square
- Personal details removed after 90 days; deleted after 2 years. Square keeps its own billing records.
- Signup choices passed from our website
- 90 days if never matched to a membership; 2 years once matched.
- Billing problem records
- 2 years after the problem is resolved.
- Records of your privacy requests
- 2 years after the request is closed.
- Your consent, age and policy choices
- While your account exists, as proof of what you agreed to.
- Email addresses that bounced or complained
- Kept so we never email them again, unless you ask us to erase your data.
- Livestream recordings
- Recordings we do not use are deleted 30 days after the show. A chosen replay stays in the app until we remove it.
- Database backups
- [OWNER: Railway backup retention period]
Age
CuppaPug membership is for people aged 18 and over. You confirm this when you join and again when you activate your membership. We do not knowingly collect personal data from anyone under 18 through the app, and we close any account we find belongs to someone younger. Younger pug fans are always welcome at the cafe with a grown-up.
Your rights
If you are in the UK, you have the right to:
- get a copy of your data (access), and receive it in a reusable format;
- have wrong data corrected;
- have your data deleted;
- ask us to pause using your data while something is checked (restriction);
- object to uses based on legitimate interests;
- withdraw consent at any time, for example switching off marketing or push in notification preferences; and
- complain to us, and to the Information Commissioner’s Office (ico.org.uk) if you are not happy with our answer.
If you are in the USA, you may have similar rights under your state’s privacy law. We give every member the same rights and the same route, wherever you live:
- Use the privacy requests form on your profile page to ask for a copy of your data or to delete your account. We confirm by email straight away.
- Or email hello@cuppapug.com for anything else, including if you are not a member.
A person on our team handles every request, and we reply within one month. We may ask you to confirm it is really you. Deletion is never instant: we confirm with you, make sure billing with Square has stopped, then delete your data. We keep only what the table above says, for example reported content or billing records.
Cookies and storage on your device
We use only what the app needs to work, so we do not ask for cookie consent. There are no advertising, analytics or cross-site tracking cookies. What we use:
- sign-in cookies from Clerk, so you stay logged in;
- security cookies Cloudflare may set to protect the app from attacks;
- storage in your browser for things you do: unsent drafts, where you stopped in a replay, banners you closed, and when we last suggested adding the app to your home screen;
- an offline copy of app pages so the app loads quickly; and
- a push subscription, only if you switch on notifications.
Do Not Track: we do not track you across other websites, so we do not change anything when your browser sends a Do Not Track or Global Privacy Control signal.
Changes to this policy
If we change this policy in a way that matters, we will tell you in the app before the change takes effect. The date at the top shows when it last changed.