Site Privacy Policy (updated September 2020)

Welcome to our privacy notice. Vetonlines, (“we”, “us”, “our”, “the Company”) is committed to protecting and respecting your privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide directly through this website.

Through the Site, we operate an online service enabling members (“Members”) to receive health services from various petcare providers (the “Services”). We developed this privacy policy (“Privacy Policy”) to explain how we collect, use, and disclose information from and/or about you when you use the Site or the Services.

THE SITE WILL BE COLLECTING AND TRANSMITTING YOUR PERSONAL INFORMATION AS WELL AS MEDICAL AND HEALTH-RELATED INFORMATION ABOUT YOUR PET. BY USING THE SITE, YOU AGREE THAT WE CAN COLLECT AND USE YOUR PERSONAL, YOUR PET INFORMATION AND OTHER INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT USE THE SITE.

Please read the following carefully to understand our views and practices regarding your personal data and how we will use it.

By agreeing to our Terms and Conditions, you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 2018 (“the Act”), we are the data controller. We can be contacted at info@vetonlines.co.uk. Our registered address is 139 Wilbraham Road, Fallowfield, Manchester, M14 7DS.

Our ICO registration number is ZA751511.

You may contact us to find out more about the way we use personal data via email at info@vetonlines.co.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Our site is not intended for children and we do not knowingly allow individuals under the age 18 to create accounts that allow access to our site.

IF YOU DO NOT PROVIDE PERSONAL DATA

If we need to process the data you provide us with to fulfil our service, and you fail to provide that data when requested, we may not be able to perform the service, in which case, we may have to cancel a service you have with us. We will of course notify you if we need to cancel a service.

WHAT INFORMATION DO WE USE?

We will collect and process the following information about you.

1. Information you give us about you.

You give us this information by filling in forms on our website (www.vetonlines.co.uk) that you may access directly or through another website, or by corresponding with us by e-mail. It only includes basic personal data required for us to communicate with you if you become a customer, and for you to be able to use our site, subscribe to our service and report a problem with our website. The information you give us may include your name, email address, home address, telephone number, photographs of your pets, geographical location and financial and payment information.

2. Information we collect about you.

With regard to each of your visits to our website we will automatically collect the following information:

our communications with you or between you and other users on the website;

content statistics (e.g. your input on the website);

technical information, including device identifiers, device type, geo-location information, connection information, statistics on page views, traffic to and from the website, the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, ad data and platform; and information based on your activities on the website, including the mobile network information, full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

3. Information we receive from other sources.

This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (e.g. business partners, sub-contractors in technical, payment and delivery services, search information providers). We will notify you when we receive personal data about you from other sources and the purposes for which we intend to use that information.

4. Personal information

We collect or maintain personal information that may include:

– Your name, age, email address, username, password, location, telephone number and other registration information.

– Pet details that you provide, including name, species, breed, age, weight.

– Pet health information that you provide us, which may include information or records relating to your pet medical or health history, health status and other health related information.

– Health information about your pet prepared by the pet care provider(s) who provide the Services through the Site such as medical records, treatment and examination notes, and other health related information.

– Billing information that you provide us, such as name, surname, address.

– Information about the computer or mobile device you are using, such as what Internet browser you use, the kind of computer or mobile device you use, and other information about how you use the Site.

– Details of your existing vet of record, and any information pertaining to the recovery of the pet(s) medical records.

– Other information you input into the Site or related services.

– Usage of Personal Health Data.

5. We may use your Personal and your Pet Health Information for the following purposes (subject to applicable legal restrictions):

– To provide you with the Services.

– To improve the quality of healthcare through the performance of quality reviews and similar activities.

– To create De-identified Information such as aggregate statistics relating to the use of the Service.

– To notify you when Site updates are available.

– To market and promote the Site and the Services to you.

– To fulfil any other purpose for which you provide us Personal Information.

– For any other purpose for which you give us authorization.

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. This website uses a cookie control system which you accept on your first site visit. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

HOW DO WE USE THIS INFORMATION?

We will only use personal data when the law allows us to. You will not be subject to decisions based on automated data processing without your prior consent. Most commonly, we will use your personal data in the following circumstances:

– where we need to perform the contract, we are about to enter into or have entered into with you;

– to provide you with our email notifications, newsletters and marketing communications at either your request or with your consent when completing a registration form for the service;

– where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;

– to ensure that our service is delivered efficiently, including where we wish to notify you of any changes to the service, generate relevant content, tailor the website to your interests, and improve your visibility to potential collaborators;

– to provide customer service to you in relation to your use of the service, to deal with inquiries and complaints relating to the use of the service and to notify you about any changes to our service;

– to administer, support, improve, optimise and develop our service;

– to produce reports which may be used, sold, or published by us at our sole discretion provided that any data or reports will be anonymised and not refer to any individual user of the services;

– for internal record keeping and marketing and demographic studies to improve the services that we provide;

– for security purposes;

– where we need to comply with a legal or regulatory obligation; and

– to investigate potential breach of our terms and conditions.

– We will ask for your consent before using information for a purpose other than those that are set out in this privacy notice.

MARKETING

We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services through us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at info@vetonlines.co.uk.

THIRD-PARTY MARKETING

We will obtain your express opt-in consent before we share your personal data with any external company for marketing purposes.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to know how the processing for the new purpose is compatible with the original purpose, please email us at info@vetonlines.co.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

HOW DO WE SHARE YOUR INFORMATION?

Upon registration, your username and user ID will be linked to your activity on the website and displayed with the information provided on your profile (including your profile picture) and any of your communications on the website (e.g. personal messages and comments).

We do not share your data with any of our service partners, unless you are also users of their services.

Our service provider partners send us lists of eligible users. This ensures that we only give access to our services to eligible users. We identify such users either by their access code, such as a customer number or policy number, or by their email address.

You acknowledge and agree that from time to time we have the right to share your personal information with:

– Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

– Selected third parties and business partners, suppliers and sub-contractors for the performance of any contract we enter into with you:

– Rocket Science Group, LLC for use of their service, Mailchimp (“Mailchimp”) based in the US, to send you our newsletter, if you consent;

– Paypal Inc. (“Paypal”) based in the US, for processing payments;

Tsohost, Inc. (“Tsohost”), for our IT hosting on their servers based in UK;

– Other than as expressly set out in this Privacy Notice or as otherwise required or permitted by law, we will not share, sell, or distribute any of the information you provide us without your consent.

DISCLOSURE OF PERSONAL INFORMATION

We will disclose your personal information in the following circumstances:

– To our subsidiaries and affiliates;

– To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

– to any third party to whom disclosure is necessary to enable us to fulfil your orders and provide you with any service which you have subscribed to;

– where required to do so by law or court order; and

– to any person to whom disclosure is necessary to enable us to enforce our rights under this privacy notice or under our Terms and Conditions.

– When we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to protect our rights, to investigate fraud, or to respond to a government request;

– To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Vetonline’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information maintained by the Site is among the assets transferred;

– For any other purpose disclosed by us when you provide the information.

This includes when:

– We sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

– The company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

– If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of the company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE DO WE STORE YOUR INFORMATION?

– All personal data we process is processed by our staff in the UK.

– For the purposes of IT hosting and maintenance this information is located on servers in the UK.

– Our external third parties Mailchimp, Paypal, are based outside the European Economic Area (EEA), so their processing of your personal data will involve transferring your data outside the EEA.

– Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

– Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

– Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

– Appropriate security measures will be adopted to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

– Please contact us at info@vetonlines.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

– Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.

– We do not store your personal health data on your computer or mobile device. We store all your personal data on secure servers located in the UK. Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

– We do not store any credit or debit card information. Payments are processed via a third-party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.

– We encrypt data transmitted to and from the Website. However, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

– Other data may be processed or stored via destinations outside the European Economic Area (“EEA”)

– We employ reasonable physical, electronic and managerial security methods to help protect against unauthorised access to Personal Information, such as encryption. But please be aware that no data transmission over the Internet or data storage facility can be guaranteed to be perfectly secure. As a result, while we try to protect your Personal Information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.

HOW LONG DO WE KEEP YOUR DATA FOR?

– We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, however, individual users are not identifiable in these reports.

– We generally retain your data for up to six (6) years after your last use of our service, cancellation of any ongoing contract (such as subscription-based access) or termination of access (such as free memberships by virtue of contract with a third party partner (such as a value-added policy benefit offered by a pet insurance company).

– To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

– We are required under UK tax law to keep basic personal data about our customers (name, address, contact details) for a minimum of six (6) years after which time it will be destroyed.

– In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

– You can ask us to delete your data in some circumstances. See below for further information.

WHAT ARE YOUR RIGHTS?

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

– Request access to your personal data.

– Request correction of your personal data.

– Request erasure of your personal data.

– Object to processing of your personal data.

– Request restriction of processing your personal data.

– Request transfer of your personal data.

– Right to withdraw consent.

EXERCISING YOUR RIGHTS

If you wish to exercise any of your rights set out above, please email us at info@vetonlines.co.uk.

– We aim to respond to all legitimate requests within one month from the date of receipt. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

– You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

– You may request deletion of your Personal Information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information, it will be deleted from the active database, but may remain in our archives and we may also retain Anonymous Information about your use of our Service. Once we disclose some of your Personal Information to third parties, we may not be able to access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. After we delete Personal Information, we will retain De-Identified Data and will continue to use De-Identified Data as permitted under this Privacy Policy.

THIRD-PARTY LINKS

Our website may contain links to websites or access to plug-ins and applications. We do not control and accept any liability or responsibility for third-party websites. This privacy notice is not applicable to other websites. Please consult the terms and conditions and privacy policies of third-party websites to find out how they collect and use your personal data.

SOCIAL MEDIA PLATFORM

All communications and actions carried out on third-party social media platforms will be subject to the terms and conditions and privacy policies of those websites. Please note that we will never ask for your personal or sensitive information through social media platforms. Please only discuss sensitive information through email.

This website may use social sharing buttons which allow you to share web content quickly on a social media platform. Please use such buttons at your discretion as the third-party platform may track and save your request.

CHANGES TO OUR PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this page and notified to you by e-mail. By continuing to use this website, you are agreeing to the changes that have been made, and any future changes, to the policy.