The Pet Guardian: Privacy Policy

This Privacy Policy (the "Policy") describes the ways in which we, The Pet Guardians Ltd ("we", "us", or "our") with company number /………../ and registered office at ……………………………………………… collect and use personal data from you in the course of our business, including via the website: “…………………” (the "Site"), and via our (For example: IOS and Apple) app, The Pet Guardians App (the "App").

We may change this Policy at any time in which case we shall notify you of any changes to this Policy. The changes will apply to your use of the Site and/or App (as applicable) after we have given notice. If you do not wish to accept the new Policy you should not continue to use the Site and/or App (as applicable). If you continue to use the Site and/or App (as applicable) after the date on which the change comes into effect, your use of the Site and/or App (as applicable) indicates your agreement to be bound by the new Policy.

This Policy was last changed on ……………. (we can add the date once we modify the policy)

  1. Background

1.1. We, The Pet Guardians Ltd, are the data controller. We can be contacted on (Add land line or mobile number of the Company) or e-mail address of the Company.

1.2. Our Data Protection Officer, can be contacted at [email protected]

1.3. We will always comply (and be able to demonstrate our compliance) with relevant data protection legislation.

  1. Your use of the App

2.1. Information which is collected when you use the App: We may collect the following information from you via the App if you choose to contact us via the APP to book a demo or sign-up to use our App, namely your name, e-mail address, company name, job title together with any other contact details that you may provide to us such as your phone number. We also collect information via our use of cookies as described in our cookies policy.

 

2.2. Processing ground: We rely on the contractual necessity processing ground to collect the items of information listed in 2.1. above in relation to you contacting us, as this information is required in order for us to sign you up as a client. In relation to our use of cookies and any location data that you choose to provide to us, we rely on consent because we ask if you consent to our use of cookies when you first visit the Site and we ask you to consent to providing us with your location before you do so.

2.3. How the information about you on the Site is used: The information about you described in paragraph 2.1. is used by us:

  1. a) to sign you up as a client; and
  2. b) to analyze and improve the performance of our Site, for example in relation to using Google Analytics in order to track who visits our Site and how they navigate around the pages and to improve the experience while using the APP.
  3. Your use of the App

3.1. Information which is collected by our App: We may collect the following information when you use our App:

  1. a) If you are a pet guardian of ours, a contact name and e-mail address, your home address and mobile number.

(b) If you are a pet owner: (i) your name and e-mail address as provided to us directly by you if you choose to sign-up to the App (whether by inputting such details directly or signing-up via Google, Facebook or Apple); or (ii) your name and telephone number as provided to us indirectly via your pet Guardian in order for your Pet Guardian or us, on the instructions of your Pet Guardians, to invite you to sign-up to the App. Upon sign-up, in addition to the details provided to us directly or indirectly as above, we will then collect further details from you including your e-mail address or phone number (as applicable), and details about your pet (such as their type, gender, breed, date of birth, weight and whether they are neutered or not). If you sign-up indirectly under c(ii) some of these details may already be pre-populated by your Pet Guardian but we would advise you to carefully check and edit these as needed.

  1. d) If you are a Pet Guardian or pet owner using the App we will also, if you carry out any appointment via the App, record the appointment and, if you choose to submit such a review at the end of the appointment or via the Site, the review of your appointment. And if you choose to purchase any product using the App, the purchase history shall be saved in the App. The nature of what is recorded obviously depends on the nature of the appointment itself and the nature of such review obviously depends on what you choose to submit via the review.

 

3.2. Processing ground: We rely on contractual necessity to process the items of personal data set out in paragraph 3.1. above because such information is required for us to license the App to you. The exceptions to this are: (a) the data collected under c(i) if we use such data for the purposes of sending electronic marketing messages to you, in which case we will only do so if we have your consent or, where we are instructed to send such electronic marketing messages on behalf of your Pet Guardian, where you have provided such consent to your Pet Guardian; (b) the data collected under c(ii) as we are a data processor in relation to such data and hence reliant on whatever data processing ground your veterinary clinic is relying on to permit us to process your data on their instructions; and (c) the data collected under (d) where we rely on: (i) legitimate interests in the case of the appointment records because we require such data for our own professional liability and regulatory purposes, and to further our business purpose and the collection and retention of such data by us does not outweigh your rights and freedoms as an individual given that the App is a virtual appointment based application and you are informed that we record such data before you take part in the applicable appointment and the nature of such data collected and retained by us merely relates to the particular appointment in question and is hence not particularly sensitive personal data; and (ii) consent in the case of the review as you choose whether to provide such a review and what to provide in such review yourself. In addition, payments shall be recorded and invoices related to each purchase or transaction executed via the app shall be sent to the client (The payments shall be recorded for consumer experience, to track expenses on app and guardian to track income from app as well as the merchant to track sale via the App).

3.3. How the information about you on the App is used: The information about you described in paragraph 3.1. may be used by us as follows:

  1. a) to enable us to undertake administration tasks in relation to the management of the App and to provide the services that we provide via the App to you, namely to permit you to attend and access Pet Guardians appointment services electronically;
  2. b) to, if you consent and/or have provided your Pet Guardian with such consent (or where otherwise permitted under electronic marketing legislation), send electronic marketing messages to you in relation to goods or services that we consider you may be interested in;
  3. c) to tweak, tune and facilitate the improvement of the App;
  4. d) to provide technical support in relation to your use of the App and troubleshooting;
  5. e) to prevent fraud or illegal activities;
  6. f) to use such information in anonymized form for our own research and marketing purposes; and
  7. g) to share with third parties as described in paragraph 3.4 below.

3.4. Sharing information with third parties: We shall not pass your information to any third party (other than as described in this paragraph). Your information may, subject to our obligations to comply with applicable data protection legislation, be shared with the following third parties:

  1. a) Google, Facebook and/or Apple if you are a pet owner or Pet Guardian end user and choose to sign-up with us via those services;
  2. b) having taken precautions to maintain the security of such information, we may share this information with our regulator together with certain professional advisors of ours such as lawyers and accountants;
  3. c) in anonymized form, we may share the information with: (i) any third party, in relation to the sale of some or all of our business, or its assets, or as part of any business restructuring or reorganization. We will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this paragraph; or (ii) law enforcement agencies in compliance with law enforcement.

3.5. Links to third party websites and third-party adverts: We are not responsible for the privacy policies and practices of other sites even if you access them using links from the Site or App. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the Site or App from a third-party site or via a social network (e.g. Twitter), we are not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

3.6. Security: We have implemented technology and policies to safeguard your privacy from unauthorized access and improper use.

3.7. Storage and Data Retention: Your information is stored by us, via our third-party storage provider (AWS), in the EEA for so long as we consider it necessary to store it in order to be able to provide our services to you. Generally speaking, this is therefore the period of time for which you are engaged by us (if you are a Pet Guardian), you are engaged by us (if you are a pet owner that signed-up via a vet Pet Guardian invite) or you have an account with us (if you are a pet owner that signed-up directly yourself).

 

3.8. Your Rights: You can contact us using the details set out above if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data. You may also contact the ICO at any time.