Welcome to the Animal Trust Vets CIC (“Animal Trust”) privacy notice.

Animal Trust respects your privacy and is committed to protecting your personal data. 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.

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how Animal Trust collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to marketing or register as a new client.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1.2 Controller Animal Trust Vets CIC, a not-for-profit company registered in England and Wales is the controller and responsible for your personal data (collectively referred to as “Animal Trust”, “we”, “us” or “our” in this privacy notice).

We have appointed a Compliance Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Compliance Manager using the details set out below.

1.2.1 Contact Details

Our full details are:

Full name of legal entity: Animal Trust Vets CIC

Company registration number: 07938025

Name or title of data privacy manager: Jayne Hamlin

Email address: [email protected]

Postal address: Animal Trust Administration Centre, Cedab Road, Ellesmere Port, CH65 4FE

Phone Number: 0151 203 0943

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.

1.3 Changes to the Privacy Notice and Your Duty to Inform us of Changes

This version was last updated on 12/10/2021 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes residential address, billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account, direct debit and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (“IP”) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your username or plan number and password, membership plan options, purchases or orders made by you, your interests, preferences, feedback and names or details of pets. 

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about

2.1 If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with membership or goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial and Profile Data by filling in forms or by corresponding with us by post, phone, email, online or otherwise. This includes the personal data you provide when you:

• apply for our products or services;
• create an account on our website (including membership of our Animal Plan);
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details].

Third parties or publicly available sources.  We may receive personal data about you from various third parties and public sources as set out below: Technical and Usage Data from the following parties: analytics providers such as Google based outside the EU; advertising networks; and search information providers. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as banks or credit reference agencies based inside or outside the EU. Identity and Contact Data from data brokers or aggregators. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU. Registering through the website as a new client. Signing up to Mail Chimp for marketing purposes.

How We Use Your Personal Data We will only use your personal data when the law allows us to. 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. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

1. Purpose/Use To register you as a new customer

Type of data (a) Identity (b) Contact

Legal basis and retention period Performance of a contract with you In order to register you and your pet and to provide veterinary services,
We will retain this data in accordance with clause 8.1 below.

2. Purpose/Use To process fees due to us (a) Manage payments, fees and charges (b) Collect and recover money owed to us

Type of data (a) Identity (b) Contact (c) Financial (d) Transaction

Legal basis and retention period (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) in respect of treatment provided. We will retain this data in accordance with clause 8.1 below.

3. Purpose/Use To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries (c ) To deal with your Pet Insurance Provider.

Type of data (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

Legal basis and retention period (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you. (d) Necessary for your legitimate interest OR with your Consent in order to process any Insurance claim in respect of your pet. We will retain this data in accordance with clause 8.1 below.

4. Purpose/Use To enable you to partake in a prize draw, competition or complete a survey

Type of data (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

Legal basis and retention period (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) We will retain this data in accordance with clause 8.1 below.

5. Purpose/Use To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data (a) Identity (b) Contact (c) Technical

Legal basis and retention period (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation We will retain this data in accordance with clause 8.1 below.

6. Purpose/Use To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

Legal basis and retention period Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) We will retain this data in accordance with clause 8.1 below.

7. Purpose/Use To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

Type of data (a) Technical (b) Usage

Legal basis and retention period Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) We will retain this data in accordance with clause 8.1 below.

8. Purpose/Use To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data.

Type of data (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

Legal basis and retention period Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications We will retain this data in accordance with clause 8.1 below.

9. Purpose/Use To carry out market research through your voluntary participation in surveys **Legal basis and retention period ** Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). We will retain this data for in accordance with clause 8.1 below.

4.2 Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.3 Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data 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 from us and, in each case, you have not opted out of receiving that marketing.

4.4 Third-party marketing We will get your express opt-in consent before we share your personal data with any third- party company or business.

4.5 Opting out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing messages sent to you or by logging into the website and checking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us using the contact details provided in clause 1.2.1 any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions. You will still receive service-related communications that are essential for administrative or customer service purposes.

4.6 Cookies You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

4.7 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties as set out in the Glossary.

Specific third parties such as the Royal College of Veterinary Surgeons.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, New Zealand:. OR

We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at [email protected]: OR

The service provider is certified under the EU-US Data Privacy Framework.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. These measures include, but are not limited to, password protection of files, ensuring staff are trained in data protection and cybersecurity, and maintaining secure IT systems. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.1 How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please go to https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/to find out more about these rights:

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.

The right to object at any time to the processing of your personal data for direct marketing purposes.

If you wish to exercise any of the rights set out above, please contact us.

9.1 No Fee Usually Required 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.

9.2 What We May Need from You We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.3 Time Limit to Respond We try to respond to all legitimate requests within one month. 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.

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected].

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

External Third Parties Service providers acting as processors based in the United Kingdom and who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, accountants, auditors, and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Examples of external third parties who we may share your information with include, but are not limited to:

• EzyVet
• IDEXX and other laboratories
• Intercom
• Smartflow
• Smart.Vet
• MailChimp
• Wind Cave
• ChargeBee

Your Legal Rights You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time  where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.