Privacy Policy

1.Introduction

Red Catlog (“Red Catlog,” “we,” “our,” or “us”) is committed to protecting the privacy and personal information of everyone who accesses or uses our website, mobile applications, and related services (collectively, the “Platform”).

Red Catlog is a marketplace that enables users to discover, connect with, and book independent service providers referred to on the Platform as “Therapists.”

Therapists may offer eligible massage, relaxation, wellness, body-care, and related services available through Red Catlog.

This Privacy Policy explains how Red Catlog collects, uses, discloses, stores, protects, and otherwise processes personal information when you access or use the Platform.

By accessing or using Red Catlog, you acknowledge that you have read and understood this Privacy Policy.

Where applicable law requires consent for a specific processing activity, Red Catlog will seek appropriate consent separately.

2.Scope

This Privacy Policy applies to personal information processed in connection with Red Catlog, including information relating to:

• Visitors to the Platform
• Registered users
• Customers
• Therapists
• Verified users
• Agents and referral participants
• Subscribers
• Individuals making or receiving bookings
• Individuals communicating through Platform features
• Individuals who contact customer support
• Persons participating in promotions, surveys, or referral programmes
• Anyone else who interacts with Red Catlog through its official services.

This Privacy Policy does not govern independent third-party websites, applications, or services that Red Catlog does not control.

3.Categories of Users

Red Catlog users may include:

A. Customers

Individuals who use the Platform to discover, communicate with, and book eligible Therapists.

B. Therapists

Individuals or businesses that create profiles and offer eligible massage, relaxation, wellness, body-care, and related services through Red Catlog.

For purposes of Red Catlog and this Privacy Policy, the word “Therapist” is the Platform’s designation for approved service providers and does not, by itself, represent or guarantee that a person is a medical practitioner, clinical therapist, physiotherapist, psychologist, or other regulated healthcare professional unless that qualification is separately stated and appropriately verified.

C. Agents and Referral Participants

Individuals authorised to participate in Red Catlog’s Therapist-acquisition, referral, or other approved programmes.

D. Visitors

Individuals who browse or interact with Red Catlog without maintaining a registered account.

The information we collect depends on your relationship with Red Catlog and the features you use.

4.Information You Provide

Depending on how you use Red Catlog, we may collect:

• Full name
• Username or display name
• Email address
• Telephone number
• Date of birth
• Country
• State
• City
• Gender, where voluntarily provided
• Profile biography
• Profile photographs
• Language preferences
• Account preferences
• Government-issued identification where required
• Selfie or verification photographs
• Biometric or facial-verification information where implemented and lawfully permitted
• Payment or billing information
• Payout information
• Customer-support communications
• Complaints and safety reports
• Verification documents
• Other information you choose to provide.

Users should not provide personal information that is unnecessary for the use of the Platform.

5.Therapist Information

If you register as a Therapist, Red Catlog may collect additional information including:

• Therapist name or display name
• Profile biography
• Profile photographs
• Service categories
• Service descriptions
• Service prices
• Service location
• Service coverage area
• Availability
• Business or trading name, where applicable
• Years of experience, where provided
• Training, qualifications, certifications, or professional credentials where relevant
• Identity-verification information
• Bank or payout information
• Booking history
• Service-completion history
• Ratings and reviews
• Cancellation history
• Customer complaints
• Safety information
• Information required to determine whether services offered comply with Red Catlog’s policies.

Certain Therapist information is intended to be publicly visible or visible to prospective customers to enable customers to assess and book services.

Therapists are responsible for ensuring that information provided in their profiles is accurate, current, and not misleading.

6.Booking and Transaction Information

When a booking is initiated, accepted, paid for, cancelled, completed, refunded, or disputed, Red Catlog may process information including:

• Customer identity
• Therapist identity
• Service selected
• Booking date and time
• Booking location or service area
• Booking instructions
• Price
• Payment status
• Booking status
• Cancellation information
• Refund information
• Service-completion status
• Ratings and reviews
• Complaints or dispute information
• Communications reasonably necessary to manage the booking.

We use this information to operate the marketplace, facilitate transactions, resolve disputes, protect users, prevent fraud, administer commissions where applicable, and improve Platform performance.

7.Location Information

Location information may be necessary because customers use Red Catlog to discover Therapists within relevant geographic areas and because certain services may be delivered at agreed locations.

Depending on the features you use and permissions you provide, we may process:

• Country
• State
• City
• Neighbourhood
• Service area
• Approximate location derived from IP address
• Locations manually entered by you
• Precise device location where you expressly enable a feature that requires it.

Where a Therapist must travel to a customer or a booking takes place at a specific location, relevant location information may be shared with the parties as necessary to fulfil the booking.

Red Catlog will seek to avoid publicly displaying precise residential or real-time location information where such disclosure is unnecessary.

8.Payment and Payout Information

When customers make payments or Therapists, Agents, or other eligible participants receive payouts, Red Catlog may process:

• Transaction amounts
• Payment method
• Payment status
• Billing information
• Refund information
• Bank or payout details
• Payout status
• Transaction references
• Information relevant to preventing payment fraud.

Payments may be processed by authorised third-party payment service providers.

Where a payment provider processes financial information directly, that provider may process such information under its own privacy terms and applicable law.

9.Agent and Referral Information

Where Red Catlog operates an authorised referral or acquisition programme, we may process:

• Agent ID
• Referral code
• Referral link
• Identity of the referring participant
• Identity of the referred participant
• Referral relationship
• Therapists attributed to an Agent
• Qualifying bookings and transactions
• Commission calculations
• Pending commissions
• Paid commissions
• Refunded or reversed transactions
• Information relating to suspected referral or transaction fraud.

Referral records may be retained for as long as reasonably necessary to administer the programme, calculate payments, resolve disputes, prevent abuse, meet legal obligations, and maintain accurate financial records.

10.Information Collected Automatically

When you use Red Catlog, we may automatically collect:

• IP address
• Device type
• Device identifiers
• Operating system
• Browser information
• App version
• Login history
• Session information
• Time zone
• Language settings
• Network information
• Approximate location
• Crash reports
• Diagnostic information
• Performance analytics.

This information may be used to operate, secure, troubleshoot, analyse, and improve the Platform.

11.Usage Information

We may collect information about how you use Red Catlog, including:

• Pages or screens viewed
• Searches conducted
• Therapist profiles viewed
• Service categories viewed
• Bookings initiated
• Bookings completed
• Features used
• Profile interactions
• Message metadata, such as sender, recipient, date, and time
• Ratings and reviews
• Referral activity
• Subscription history
• Advertising or promotional interactions
• Safety reports
• Complaints
• Login frequency.

Where Red Catlog provides in-app messaging, processing of message content will depend on the technical design of that service and applicable law.

12.Cookies and Similar Technologies

We may use cookies, pixels, local storage, software-development kits, and similar technologies to:

• Keep users signed in
• Remember preferences
• Improve security
• Detect fraud
• Measure Platform performance
• Analyse traffic
• Personalise features where appropriate
• Troubleshoot technical problems
• Measure marketing performance where permitted.

Where applicable law requires consent for non-essential cookies or tracking technologies, Red Catlog will seek appropriate consent.

Disabling certain technologies may affect Platform functionality.

13.Why We Process Personal Information

Red Catlog may process personal information to:

Operate the Platform

• Create and manage accounts
• Display Therapist profiles
• Enable Therapist searches
• Facilitate bookings
• Process payments and payouts
• Manage Therapist availability
• Enable ratings and reviews
• Administer subscriptions where applicable
• Operate referral programmes.

Protect Users and the Platform

• Verify age and identity
• Verify Therapist eligibility where required
• Prevent fake accounts
• Prevent impersonation
• Investigate misconduct
• Detect fraudulent bookings
• Detect referral fraud
• Enforce Platform rules
• Investigate complaints
• Protect customers and Therapists
• Maintain Platform security.

Improve the Platform

• Analyse usage
• Improve search and matching
• Improve user experience
• Identify technical problems
• Develop new features
• Understand customer preferences
• Analyse marketplace performance.

Communicate With Users

• Provide booking updates
• Send payment or payout notifications
• Send verification notices
• Provide customer support
• Issue security alerts
• Communicate important service changes
• Send promotional communications where permitted.

Meet Legal and Compliance Requirements

• Maintain required records
• Comply with applicable law
• Respond to lawful government or court requests
• Establish or defend legal claims
• Investigate fraud
• Enforce Red Catlog’s agreements and policies.

14.Legal Bases for Processing

Where applicable law requires Red Catlog to establish a lawful basis for processing personal information, that basis may include:

• Your consent
• Performance of a contract with you
• Steps taken at your request before entering into a contract
• Compliance with a legal obligation
• Legitimate interests pursued by Red Catlog or another person where not overridden by your rights
• Protection of vital interests
• Performance of a task in the public interest where applicable
• Another lawful basis recognised by applicable law.

The lawful basis used depends on the information involved and the purpose for which it is processed.

Where processing is based on consent, you may withdraw your consent subject to applicable law.

Withdrawal of consent does not necessarily affect processing lawfully conducted before withdrawal.

15.Identity, Age, and Therapist Verification

Red Catlog may require users and Therapists to complete identity, age, eligibility, or other verification procedures.

Verification may include:

• Government-issued identification
• Selfie verification
• Facial matching where implemented and lawfully permitted
• Proof of address
• Business information
• Training or qualification documentation where appropriate
• Service-related documentation
• Additional information reasonably necessary to confirm identity or prevent fraud.

Where a Therapist claims a regulated professional qualification, professional title, licence, or certification, Red Catlog may require appropriate documentary verification before allowing the claim to appear on the Platform.

Verification information may be processed by Red Catlog or authorised verification providers.

Access to verification information should be limited to persons with a legitimate need for access.

16.Customer and Therapist Information Sharing

Red Catlog operates a marketplace in which certain information must be exchanged between customers and Therapists to facilitate bookings.

When a customer makes a booking, Red Catlog may provide the Therapist with information reasonably necessary to perform the booked service, including:

• Customer name or Platform identity
• Service booked
• Booking date and time
• Booking instructions
• Service location where applicable
• Information reasonably necessary for booking-related communication.

Customers may be able to see information contained in a Therapist’s public profile, including:

• Name or display name
• Profile photograph
• Service categories
• Service descriptions
• Pricing
• Service area
• Availability
• Ratings
• Reviews
• Other information the Therapist makes available through the Platform.

Information obtained through Red Catlog must not be misused for harassment, stalking, discrimination, fraud, unsolicited marketing, or activities unrelated to legitimate Platform use.

17.Information Not Required for Ordinary Services

Red Catlog primarily facilitates massage, relaxation, wellness, body-care, and related services.

Unless a particular feature or service lawfully requires otherwise, Red Catlog does not ordinarily require customers to submit:

• Medical diagnoses
• Hospital records
• Clinical treatment records
• Prescriptions
• Detailed medical histories
• Unnecessary health information

simply to make an ordinary booking through the Platform.

Users should avoid submitting unnecessary medical, financial, identification, or other sensitive information through profiles, reviews, messages, or booking instructions.

18.Communications

Red Catlog may send you:

• Account notifications
• Booking confirmations
• Booking reminders
• Booking changes
• Payment notifications
• Payout notifications
• Security alerts
• Verification updates
• Customer-support responses
• Subscription notices
• Referral-programme updates
• Product announcements
• Service updates
• Promotional communications where permitted.

You may opt out of promotional communications through available preference or unsubscribe mechanisms.

You may not be able to opt out of essential account, booking, payment, legal, or security communications while maintaining an active account.

19.Sharing Personal Information With Service Providers

Red Catlog does not sell personal information as part of its ordinary business model.

We may share personal information with trusted third parties that help us operate the Platform, including:

• Payment processors
• Payout providers
• Cloud-hosting providers
• Identity-verification providers
• Communications providers
• Analytics providers
• Fraud-detection and security partners
• Customer-support providers
• Technology providers
• Marketing providers where lawfully permitted
• Auditors
• Insurers
• Accountants
• Lawyers
• Other professional advisers.

Such organisations may process information only as permitted by their lawful role, applicable agreements, and applicable data-protection requirements.

20.Legal, Regulatory, and Safety Disclosures

Red Catlog may disclose personal information where we reasonably believe disclosure is necessary or permitted to:

• Comply with applicable law
• Comply with a valid legal process
• Respond to lawful requests from courts, regulators, or government authorities
• Investigate suspected fraud
• Investigate serious violations of Platform rules
• Protect the rights, property, or security of Red Catlog
• Protect customers, Therapists, Agents, or other persons
• Prevent or address serious harm
• Investigate suspected criminal conduct
• Establish, exercise, or defend legal claims.

Red Catlog will seek to assess requests for user information in accordance with applicable law.

21.Business Transfers

If Red Catlog or part of its business becomes involved in a merger, acquisition, restructuring, financing, sale of assets, insolvency, or similar corporate transaction, personal information may be disclosed or transferred as part of that transaction where permitted by law.

Appropriate safeguards will be applied where required.

22.International Data Transfers

Your personal information may be processed or stored outside the country in which you reside.

This may occur where Red Catlog uses international:

• Cloud infrastructure
• Payment providers
• Identity-verification services
• Analytics providers
• Communications systems
• Other technology providers.

Where international transfers occur, Red Catlog will take steps required by applicable law to establish an appropriate lawful basis and safeguards.

23.Data Security

Red Catlog implements reasonable administrative, organisational, and technical safeguards designed to protect personal information.

These may include:

• Encryption in transit
• Encryption of appropriate sensitive information at rest
• Secure authentication
• Role-based access controls
• Data-access restrictions
• Security monitoring
• Fraud-detection systems
• Secure software-development practices
• Vulnerability management
• Backup procedures
• Incident-response procedures
• Disaster-recovery measures.

Access to personal information should be limited to employees, contractors, and service providers who have a legitimate business need for access.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

24.Security Incidents and Data Breaches

Where Red Catlog becomes aware of a suspected personal-data breach or security incident, we may investigate the incident and take reasonable steps to contain, remediate, and document it.

Where required by applicable law, Red Catlog may notify:

• Affected individuals
• Relevant authorities
• Regulators
• Other appropriate parties.

25.Data Minimisation

Red Catlog seeks to collect only personal information that is reasonably necessary for specified Platform, transaction, safety, security, fraud-prevention, compliance, and business purposes.

Users should not upload unnecessary:

• Identification documents
• Financial information
• Confidential information
• Medical information
• Other sensitive personal information

to public profiles, reviews, booking notes, or ordinary Platform communications.

26.Data Retention

We retain personal information for no longer than reasonably necessary for the purposes for which it was collected or as otherwise permitted or required by applicable law.

Retention periods may depend on:

• Whether your account remains active
• Booking or transaction history
• Unresolved complaints
• Safety investigations
• Fraud-prevention requirements
• Referral attribution
• Commission records
• Legal limitation periods
• Tax or accounting obligations
• Regulatory requirements
• Security requirements.

When personal information is no longer reasonably required, Red Catlog may securely delete, anonymise, aggregate, or otherwise dispose of it.

27.Your Privacy Rights

Subject to applicable law and relevant exemptions, you may have rights to:

• Obtain information about how your personal information is processed
• Access your personal information
• Correct inaccurate or incomplete information
• Request deletion of eligible personal information
• Request restriction of certain processing
• Object to certain processing
• Withdraw consent where processing relies on consent
• Receive eligible personal information in a portable form
• Object to certain automated decision-making where applicable
• Lodge a complaint with an appropriate data-protection authority
• Exercise other rights provided by applicable law.

Red Catlog may request reasonable information to verify your identity before fulfilling certain requests.

Certain requests may be limited where applicable law permits or requires Red Catlog to retain or continue processing relevant information.

28.Marketing Preferences

Where permitted, Red Catlog may communicate with users about:

• Platform features
• Promotions
• Discounts
• New service categories
• Referral programmes
• New products or services
• Other relevant Red Catlog offerings.

Where consent is legally required for direct marketing, Red Catlog will seek such consent.

Opting out of marketing does not prevent us from sending essential booking, transaction, security, or account communications.

29.Reviews and Public Content

Users may be able to publish:

• Ratings
• Reviews
• Profile photographs
• Therapist descriptions
• Comments
• Other public-facing information.

Information deliberately posted publicly may be visible to other users.

Users should avoid posting unnecessary confidential, financial, medical, identification, or other sensitive personal information.

Red Catlog may moderate, restrict, remove, or retain public content in accordance with its Terms of Use, Platform policies, and applicable law.

30.Safety Reports, Complaints, and Investigations

Users may report concerns including:

• Misconduct
• Harassment
• Unsafe behaviour
• Fraud
• Impersonation
• Inappropriate services
• Suspicious booking behaviour
• Payment disputes
• Booking disputes
• Policy violations
• Other safety concerns.

Red Catlog may process information reasonably necessary to investigate such matters and protect users and the Platform.

Relevant information may be shared with affected users, professional advisers, insurers, payment providers, regulators, law-enforcement authorities, or other appropriate persons where permitted or required by law.

31.Children and Age Restrictions

Red Catlog is intended for adults aged eighteen (18) years or older.

Persons under eighteen must not independently create or maintain standard Red Catlog accounts.

If Red Catlog becomes aware that a person under the required age has created an unauthorised account, we may suspend or close the account and take appropriate steps regarding the associated information, subject to applicable legal and record-retention obligations.

32.Third-Party Services

The Platform may contain integrations or links to third-party services.

Third parties may process information under their own privacy policies and legal obligations.

Red Catlog is not responsible for independent third-party privacy practices merely because their service or link is accessible through Red Catlog.

Users should review applicable third-party privacy policies before submitting information directly to those services.

33.Account Closure

If you close your account:

• Your public profile may cease to be visible
• Active bookings or transactions may need to be resolved
• Certain information may remain for legal, accounting, fraud-prevention, safety, dispute-resolution, referral, or record-keeping purposes
• Information relating to serious policy violations may be retained where lawfully justified
• Anonymised or aggregated information may be retained for analytical purposes.

Closing an account therefore does not necessarily result in the immediate deletion of every record associated with the account.

34.Automated Systems and Fraud Detection

Red Catlog may use automated or semi-automated systems to help:

• Detect suspicious accounts
• Identify unusual transactions
• Detect fake bookings
• Detect duplicate accounts
• Identify possible fraud
• Protect customers and Therapists
• Improve search or matching
• Maintain Platform security.

Where automated decision-making creates legal or similarly significant effects and applicable law imposes additional requirements, Red Catlog will provide the required safeguards.

35.Changes to This Privacy Policy

Red Catlog may update this Privacy Policy from time to time to reflect:

• Changes to the Platform
• New features
• New service categories
• Changes in technology
• Changes in data practices
• Changes in business operations
• Legal or regulatory developments.

Where changes are material, Red Catlog will provide reasonable notice through the Platform, email, or another appropriate method.

Where applicable law requires additional consent for a new processing activity, Red Catlog will seek that consent rather than relying solely on continued Platform use.

36.Nigeria Data Protection

Where Nigerian data-protection law applies, Red Catlog intends to process personal information in accordance with applicable Nigerian data-protection requirements.

Red Catlog seeks to apply principles including:

• Lawfulness
• Fairness
• Transparency
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Confidentiality
• Security
• Accountability.

Red Catlog will also seek to respond appropriately to valid privacy requests and applicable regulatory obligations.

37.Prohibited Sexual Content and Commercial Sex

Red Catlog is a legitimate marketplace for eligible massage, relaxation, wellness, body-care, and related services.

Red Catlog is not a pornography, prostitution, escort, commercial-sex, or sexual-services Platform.

Users, Therapists, Agents, and other participants must not use Red Catlog to:

• Advertise, request, arrange, offer, promote, or facilitate commercial sexual services
• Offer or request prostitution or escort services
• Solicit sexual activity in exchange for money, gifts, benefits, services, accommodation, or other consideration
• Upload, distribute, promote, request, or exchange pornographic or sexually explicit content
• Offer massage, relaxation, wellness, or body-care services as a disguise for sexual activity
• Use profiles, photographs, messages, booking notes, reviews, or other Platform features to solicit sexual activity
• Redirect Red Catlog users to another platform or communication channel for the purpose of arranging commercial sex
• Facilitate sexual exploitation or trafficking
• Otherwise use Red Catlog primarily for sexual activity or sexual commerce.

Massage or other body-related services available through Red Catlog do not include or authorise sexual services.

Where Red Catlog reasonably suspects prohibited activity, we may process relevant account, identity, booking, transaction, location, communication, complaint, or safety information as reasonably necessary to investigate the matter, enforce our policies, protect users, and comply with applicable law.

Accounts involved in prohibited activity may be restricted, suspended, or permanently terminated.

Where required or permitted by applicable law, relevant information may also be preserved or disclosed to appropriate authorities.

38.Protection Against Sexual Exploitation

Red Catlog has zero tolerance for sexual exploitation, coercion, trafficking, child sexual exploitation, or abuse.

The Platform must not be used to:

• Exploit another person sexually
• Facilitate trafficking
• Groom or exploit minors
• Distribute unlawful sexual material
• Threaten or coerce users into sexual activity
• Facilitate any other unlawful sexual exploitation.

Suspected serious violations may result in immediate account restrictions, investigation, preservation of relevant records, and reporting to appropriate authorities where required or permitted by law.

39.Your Acknowledgement

By accessing or using Red Catlog, you acknowledge that:

• You have been provided with this Privacy Policy
• You have had an opportunity to understand how Red Catlog processes personal information
• Your use of the Platform remains subject to Red Catlog’s applicable Terms of Use, Safety Standards, Prohibited Services Policy, Therapist Rules, and other Platform policies.

Your use of Red Catlog does not replace any separate consent that applicable law requires for a specific processing activity.

Where consent is the appropriate lawful basis, Red Catlog will seek consent in accordance with applicable law.