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 in August 2021.
1.1. We, PetsApp Ltd, are the data controller. We can be contacted on +44 7422 942065 or firstname.lastname@example.org.
1.2. Our Data Protection Officer, Thom Jenkins, can be contacted at Office 406 Exmouth House, London, England, EC1R 0JH, +44 7422 942065 or email@example.com.
1.3. We will always comply (and be able to demonstrate our compliance) with relevant data protection legislation, including the Data Protection Act 2018 ("DPA") and the UK General Data Protection Regulation ("GDPR") as applicable, when processing your personal data. Further details on the DPA and UK GDPR can be found at the Information Commissioner's Office website (www.ico.gov.uk).
2. Your use of the Site
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:
a) to book you in for a demo and/or sign you up as a client; and
b) to analyse 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.
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:
a) If you are a veterinary clinic client of ours, a contact name and e-mail address, the address of your veterinary clinic and telephone number of such clinic.
b) If you are a veterinary clinic employee/contractor i.e., a veterinary clinic end user actually using the App, we will collect from you your name, e-mail address, job role and affiliated clinic name (whether given to us by the vet clinic itself or by you inputting such details directly or signing-up via Google, Facebook or Apple). We will then verify these details (including e.g., via an appropriate RCVS registration entry) and, once verified, allow you to access and use the App.
c) 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 veterinary clinic in order for your veterinary clinic or us, on the instructions of your veterinary clinic, 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), post code, 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 veterinary clinic but we would advise you to carefully check and edit these as needed.
d) If you are a veterinary clinic end user 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. 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 veterinary clinic, where you have provided such consent to your clinic; (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.
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:
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 veterinary appointment services electronically;
b) to, if you consent and/or have provided your veterinary clinic 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;
c) to tweak, tune and facilitate the improvement of the App;
d) to provide technical support in relation to your use of the App and troubleshooting;
e) to prevent fraud or illegal activities;
f) to use such information in anonymised form for our own research and marketing purposes; and
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:
a) various external service providers that we engage to provide services for us, including AWS, Twilio, Stripe, Elastic Cloud, Practice Management System providers and Auth0;
b) Google, Facebook and/or Apple if you are a pet owner or veterinary clinic end user and choose to sign-up with us via those services;
c) 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;
d) in anonymised 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 reorganisation. 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 unauthorised 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 veterinary clinic or veterinary clinic user), your clinic is engaged by us (if you are a pet owner that signed-up via a vet clinic invite) or you have an account with us (if you are a pet owner that signed-up directly yourself). The exception to this is in relation to the appointment related data which we store for 7 years in accordance with applicable regulatory obligations. Our other third party partners may store data outside the EEA and we have appropriate contracts in place to ensure the adequacy of such transfer. You can ask for your information to be removed at any time by e-mailing us at firstname.lastname@example.org.
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.