Privacy

Who we are

Locus Dog Club is the trading name of Alisa Groen, who provides dog training and behaviour coaching on the Costa del Sol, Spain (Estepona and Marbella) and is the data controller for everything described here. Registered address: Urb. La Alberdina, Los Rosalejos 4, 29680 Estepona, Málaga, Spain. Tax identifier: Y9109985K.

What we collect

• What you send via the assessment or contact form: your name, your dog's name, breed and age, what you are working on, plus email, phone and location.
• What you send through the feedback form: how the book and the Workspace are working for you, your dog’s name and age, and the follow-ups you agree to, such as a call back on the number you give.
• Messages you send us by email, through the site chat, or on Instagram, including comments on our posts that ask for a link and the direct messages that follow, with your public profile name and picture.
• Basic source data (which page or campaign brought you), to improve our marketing.
• When you buy: your name, email address, billing country and address as entered at checkout, what you bought, the amount and the date. Card details go to our payment provider only.
• If you are a founding reader: your personal share link, how many times it has been opened (a count per day, with no data about the people who opened it) and how many purchases came through it. When someone buys through your link, we record that on their customer record and on yours.

Why we use it (lawful basis)

• To answer your enquiry and run Where to start and any training (your request, our service).
• To send follow-ups where you have agreed (consent), withdrawable any time.
• To measure our own marketing (legitimate interests).
• To deliver what you bought, give you access and handle refunds (our contract with you).
• To keep purchase, VAT and accounting records, including the country used to apply VAT (a legal obligation under Spanish tax law).

Public social media profiles of clients

When you book or buy from Locus Dog Club, we may look at the public parts of your social media profiles, such as your name, profile picture, bio, public posts, highlights and stories, and your public follower and following lists, through third party data services. We do this to understand who our clients are and to improve our service and our marketing. Our legal basis is our legitimate interest. We only use information that is public, we never see private accounts beyond their public profile, we keep it for as long as you are a client and up to 12 months after, and you can object at any time by writing to info@locusdogclub.com, after which we stop and delete it.

Cookies & tracking

Tracking stays minimal. Cookies fall into three categories: necessary, which always run; analytics, which show us how the site is used; and marketing, which measure our adverts and run the live chat. Analytics and marketing load only if you switch that category on, and you can accept all, reject all or choose per category. You can change your choice at any time from Cookie settings at the foot of every page. We respect "Do Not Track" and Global Privacy Control signals, and never put personal data in web addresses. Every cookie, its provider and how long it lasts is listed in our Cookie policy.

Who we share it with

We do not sell your data. We share it with the providers who help us run Locus, each under a written data processing agreement that limits them to acting on our instructions. One recipient also uses data for its own purposes, and only with your marketing consent: our web agency, Orevida, described in the next section. By category, our providers are:

• Website hosting and security, which processes your IP address and request data to serve the site and block abuse.
• Our customer relationship and scheduling system, which holds your enquiry, your booking and your correspondence with us.
• Email delivery, so we can reply to you and send what you asked for.
• Payment processing, which handles your card details directly. We never receive or store your full card number.
• Analytics and advertising measurement, each only where you switched that category on. See our Cookie policy.

We may also disclose data where the law requires it, or to establish or defend a legal claim. If the business is ever sold or reorganised, your data may transfer with it, and your rights over it do not change.

Our web agency’s tracking pixel (Orevida)

This website is built and run by our web agency, Orevida LLC (Orevida Media, orevida.com). Only if you switch on the Marketing category in the cookie banner, the site loads Orevida’s tracking pixel. It sends its data through our own domain (the /px path) to Orevida’s servers, which passes on your IP address and browser identifier (user agent).

With your marketing consent, Orevida receives:

• Usage data: pages viewed, referrer, time, scroll depth, clicks on buttons and links, and your cookie choice.
• Campaign data: campaign parameters and advertising click IDs in the page address (for example utm_*, gclid, fbclid) and the source of your first and latest visit.
• A device fingerprint: a value calculated on each page view from an invisibly drawn canvas image and device features (language, screen, time zone, processor cores, memory, operating system, connection type). It is not stored on your device. It lets Orevida recognise your device without a cookie and link visits across devices.
• Identifiers of other cookies: the Google Analytics and Meta identifiers, where those are also allowed.
• Your email address, after you send an enquiry or make a purchase.

Enquiries. When you send an enquiry, book a session or finish the assessment with Marketing switched on, our server also sends Orevida a record of that enquiry (your email address, the campaign data above and the reference number of your record in our customer system), so an enquiry is counted even when a browser blocks the pixel. In the same case we store the pixel’s visitor ID and any Orevida short-link ID with your enquiry in our customer system, and your browser keeps that reference number (_ud) so the customer system can link your later page views to your enquiry. With Marketing off, none of this happens.

Purposes. We use this to measure which source or advert led to an enquiry or a purchase. Orevida also uses the data for its own purposes and decides on that processing itself: to recognise visitors across sessions and devices, for its own analysis across the websites of all brands that use the Orevida pixel (first and last touch attribution), to enrich customer records in CRM and email marketing systems, and for future sending of conversions to advertising platforms such as Google Ads and Meta.

Storage. The pixel stores a pseudonymous visitor ID and the source of your first and latest visit on your device (_ore_uid, _ore_ft, _ore_lt, and ore_sid for the session). Orevida keeps the data it receives until you withdraw your consent or ask for deletion, which you can request from us or from Orevida.

Legal basis. Your consent, under Article 6(1)(a) GDPR and, for storing and reading information on your device including the fingerprint, Article 22(2) of the Spanish LSSI. You can withdraw it at any time under Cookie settings in the footer of every page; the entries on your device are then deleted.

Outside the EU. Orevida LLC is based in the United Arab Emirates, outside the EU and EEA, so this data is transferred to a third country. Orevida’s privacy policy: orevida.com/privacy.

Sending data outside the EEA

Some providers operate outside the European Economic Area, including in the United States. Where data leaves the EEA we rely on the safeguards the GDPR allows, which in practice means the European Commission’s Standard Contractual Clauses, an adequacy decision where one covers the provider, or both. Ask us which applies to a particular provider and we will tell you.

How long we keep it

We keep data only as long as we have a reason to, then delete or anonymise it.

• Enquiries that do not become bookings: up to 24 months, so we can pick up a conversation you restart, then deleted.
• Client records, including session notes: for the working relationship and up to 6 years afterwards, which is the window in which a claim could still arise.
• Purchase and accounting records: as long as Spanish tax and accounting law requires, currently up to 6 years.
• Public social media profile data of clients: while you are a client and up to 12 months after, or until you object.
• Your reading and Workspace records: for as long as your access is live, and removed when you ask us to close it.
• Consent records: kept while the consent stands and for a period afterwards, because we have to be able to show what you agreed to.
• Analytics data: the retention period of the tool concerned, and only where you consented.

Your reading and the Locus CODE™ Workspace

If you buy a guide, the reader and the Workspace store what they need to work: which books your link opens, roughly where you are in one, and what you enter yourself, such as your dog’s name and the notes you write.

Two things are worth stating plainly, because they are choices rather than defaults. Your notes, your scores and the moments you write are yours: we do not copy them into our customer records and we do not read them to market to you. What does reach our customer records is your dog’s name, breed and age, so that Alisa can see who she is working with, and it is attached to your customer record under your name and email. If you fill them in, the same record also carries your dog’s sex and whether they are neutered or spayed, their date of birth and whether it is an estimate, their weight, where they came from, the main concerns you tick, and your answer to one question: whether your dog has bitten or guarded something seriously (yes, no or not sure). That answer helps Alisa plan a safe first session, and it is the only thing from the Workspace’s safety questions that leaves it. Each dog has its own record, linked to yours by a one-way reference that cannot reveal your access key. The Workspace does not ask about your dog’s health, medication or vet, or about the people in your home. Your Workspace records are held against your access key.

You can add photos of your dog to the Workspace: one profile photo and dated progress photos. They are stored privately against your access key, and the Workspace removes the camera’s hidden details (such as where a photo was taken) before it saves one. Your trainer sees them to coach you: your customer record holds one private, read-only link per dog that opens that dog’s photos and nothing else. We use your photos on the website or on social media only if you switch on “Locus may share my dog photos on the website and socials” in the Workspace. It is off until you turn it on, and you can turn it off at any time. You can delete any photo yourself in the Workspace, and we delete all of them when you ask us to.

We also note a few milestones on your customer record. Two are about reading: when you are half way through a book and when you reach its end. The others are about the Workspace: that you are a Workspace member, the day you first open it, and when you have logged your first, fourth, eighth and twelfth week. That is all: never which page, how long you read, what you read twice, or what you score or write. We use them to send you the next useful step, such as how to start the Workspace once you have finished Foundation, and to ask how the book is working for you. You can ask us to stop at any time.

If you turn on reminders in the Workspace, your browser gives us a notification address for that device, and we store it against your access key with the day, the hour and the time zone you chose. We use it for a reminder on your training day, a note when a week you scored has not been saved, a short line at your fourth, eighth and twelfth saved week, and now and then a note from your trainer. Nothing else, and never anything for marketing. The message passes through your browser’s own notification service, encrypted so that service cannot read it; it carries your dog’s name and nothing about you. To switch them off, untick the reminders in Your dog, or block notifications for this site in your browser or phone settings. An address that stops working is deleted the next time we try it, and all of it is deleted with your Workspace when you ask us to close it.

Automated processing

Where to start produces a suggested starting point automatically from the answers you give. It is a suggestion and a prompt for us, not a decision affecting your legal rights. It is shown to you straight away, from a fixed set of rules rather than a model, and Alisa reads your answers herself before she replies to you. We do not carry out automated decision-making that produces legal effects, and we do not profile you for advertising beyond the consented measurement described in our Cookie policy.

How we protect it

• The whole site is served over HTTPS and sets a strict content security policy.
• Access to client records is limited to the people who need it, protected by individual accounts.
• Access to a purchased guide is held by a personal key we can revoke, so a leaked link can be shut off without affecting anyone else.
• Payment card details never reach our systems.

No system is perfectly secure. If a breach ever affects your rights and freedoms, we will notify the supervisory authority within 72 hours as the GDPR requires, and we will tell you directly where the risk to you is high.

Children

Our services and this site are intended for adults. We do not knowingly collect data from children under 14, the age at which a child can consent in their own right in Spain. Children are welcome at sessions and events with a responsible adult, and any details we hold about a household come from the adult who booked. If you believe we hold a child’s data, tell us and we will delete it.

Your rights

Under the GDPR you can ask us to:

• give you a copy of the data we hold about you, and tell you what we do with it;
• correct anything inaccurate or incomplete;
• delete it, where we have no overriding reason to keep it;
• restrict what we do with it while a question about it is resolved;
• send it to you, or to someone else, in a portable format;
• stop processing based on our legitimate interests, including any direct marketing, which you can stop at any time without giving a reason.

Where we rely on your consent you can withdraw it at any time, and that does not affect anything done before you withdrew it. Email info@locusdogclub.com and we will respond within one month. We will not charge you, and we will not treat you differently for asking.

If you are unhappy with how we have handled it you can complain to the Spanish data protection authority, the Agencia Española de Protección de Datos, at aepd.es, or to the authority in your own EU country. We would rather you told us first so we can put it right.

Contact

Questions about your data, or want it removed? Email info@locusdogclub.com or call +34 644 404 754.

Ready to start with your dog? See where to start.