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Privacy Policy
Last updated: August 7, 2023
The Vets Holding Inc. (“TheVets”, “we”) respects the privacy of its users, customers and partners (“you”), and is committed to protecting the personal information shared with us in connection with your use of our Services and our Website, as those terms defined in our terms of service (“Terms”).
Your access to or use of the Website or Services involves collecting and processing of certain personal information by us, or on our behalf by our service providers or partners, as described in this privacy policy.
Unless otherwise explicitly required by you, and approved in writing by us, your use of the Website or Services, so as your active provision of personal information (such as by phone or in a form), constitutes your consent to the terms set forth in this privacy policy, including the collection and processing of your personal information.
1. Scope and applicability
1.1. Data subjects. This Privacy Policy (the “Policy”) applies when you (i) visit the Website, and/or (ii) use the Services and/or (iii) partner with us, and/or (iv) otherwise in contact with us. Therefore, the Policy applies to you if you are one or more of the following:
- Visitor of our Website (available at: www.thevets.com or any of its sub-domains), (“Website Visitor(s)”);
- A customer who uses our Services, whether by booking an appointment or enrolling in a membership program (“Customer”);
- Prospective or current partner of us, or service provider, whether by collaborating with us, by participating in a referral program or otherwise having a B2B relationship with us (“Partner”);
- Candidate for a job in our company (whether as an employee or a contractor) (“Candidate”);
- None of the above, however, made contact with us by phone, email, or any other avenue provided by us
1.2. Jurisdiction. Our Services are offered only within certain states in the United States of America. Therefore, this Policy is written with the applicable legislation and requirements of several US jurisdictions in mind. If you are a resident of any jurisdiction other than the USA, please do not access the Website or use the Services
1.3. Supplemental documents. This Policy supplements, incorporated by reference, and shall be read in conjunction with, our Terms of Service, available at Terms of Service (“TOS”). Additionally, if you are a resident of California, please refer to our CCPA and CPRA notice, in addition to this Policy.
2. Your choices, consent and control
2.1. Please read this Policy carefully before accessing the Website or using our Services, because in doing so, you agree to be bound by the terms and conditions set forth in this Policy, and to the collection and processing of your Personal Information (see definition below).
2.2 Please note: you are not obligated by law to provide us with any Personal Information. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purposes described in this Policy or in proximity to any data submission point, and that we may retain such information in accordance with this Policy and any applicable laws and regulations.
2.3. Certain information we collect, such as general Usage Information (as defined below), device information, analytics, statistics, or any other data that enables us to provide the Services and improve them, is collected as part of our legitimate interest. You can find a further explanation below, under the “Legal Basis” section.
2.4. Certain types of information, such as media files are optional (for instance, when you use our mobile application) and subject to your explicit consent.
3. Information we collect
3.1. General: We may collect certain categories of Personal Information from you or about you, from one or more sources, as we describe below. In this section, we describe the categories of information that we may collect and the applicable circumstances under which such collection is performed (also defined by applicable law as the “purpose” of collection).
3.2. Definition: What is Personal Information? The exact definition may be different, depending on your state of residence. Below is CPRA’s (California Privacy Right Act) definition, which is considered to be the most protective legislation regarding the privacy of internet users in the United States:
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household”.
Please note that Personal Information does not include information that has been aggregated or otherwise processed so it can no longer be used to identify or be associated with a specific natural person.
3.3. The Personal Information we collect and process, is derived from three different sources, as listed below:
- Submitted and actively provided by the User. This includes the following categories:
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- Identifiers: we collect data and information you submit to us via forms (such as account registration, membership enrollment, and contact page, as made available via the Services) and when you contact us, or when we contact you to provide the Services. This includes details such as your full name, phone number, email address and home/work address. The purpose of the collection and processing of this information is to provide you with the Services, to communicate with you about the Services, to coordinate meetings, and to charge for the Services. We also use your email address to notify you about your membership status.
This category also includes certain online identifiers, which do not personally identify you, however, associate certain online actions with your device or browser, as detailed below
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- Media files. When you use the Services via the mobile application, you may choose to submit or upload files or images to your pet’s file and records.
- Audio: Please note that the contents of your interaction with our customer support or coordination teams may include audio recordings and transcripts of such communications. The purpose of the collection and processing of this category of Personal Information is to perform quality control checks on our service representatives and improve our services.
- Membership Information. If you choose to enroll in a membership program with us, we will collect your Identifiers, and Billing information, and will also retain information related to your membership activity, to track, monitor and protect your activity and provide you with your membership’s services.
- Billing and Payment Information. When you book an appointment via the Services or, when enrolling for our membership program, you will be requested to submit your billing information. This information includes your credit card details and billing address and is collected and processed by third-party processing vendors on our behalf (for example Stripe, which their privacy policy can be found here: https://stripe.com/privacy) .
- Support Information. We process information related to your support request, in order to provide you with the support services you requested, track the request resolution and keep it in your Customer card for better, more improved Services. This information includes the request metadata (such as time, date, category, and status) and your Customer information, including Membership information. We also process the content of your request in order to provide you with the relevant Services.
- Account information. When you choose to enroll in our membership program or to manage an account with us, you will be requested to create authentication credentials (consisting of your email address and password). Alternatively, you may be requested to submit a username or a zipcode and use a “one-time-password” (OTP) to sign in to the Services.
- Automatically processed when you use Online Services. This information includes the local storage of your device (see below for more details under cookies and web technologies). Please keep in mind that most devices and browsers allow you to control or disable the use of certain collectible information including location services, in your device’s or browser’s settings menu. This type of processing includes the following categories of data.
- Online Identifiers: Online identifiers do not personally identify you, however, associate certain online actions with your device or browser, and include the Internet protocol address (IP) which may also provide us with general location information, cookie IDs and our own internal random identifier of a user in the system.
- Cookies: Cookies are files downloaded to your device, for example, when you visit the Website. They are useful because they allow us to recognize a user’s device and support the continuity of your experience. Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and improving your user experience. They can also help to ensure that ads you see online are more relevant to you and your interests.
- Apple or Android ID. When you use the Services via the mobile application, we may access and use the ID that your mobile operator provides to you, in order to extract analytics, usage, and to [complete]
- Usage Information and Analytics: Usage information and analytics about your interaction with our services, which may include, for example, the URLs of our website that you have visited and sent you to our Website, and, data extracted by analytics services via tags and cookies, as mentioned above, interactions with elements and content on our Website, pages you viewed, clicks you made on the Website, platform type, and browser type, version and language from which you access the Services. The purpose of the collection and processing of this category of data is to help us analyze the usage type and level of engagement on the Website, in order to improve our Services and make them better customized and relevant to our Customers’ and Users’ needs.
- Device and Technical Information: this category includes certain data about the device type, language and version from which you access it, for the main purpose of visibility, compatibility, functionality and availability of the Services. This category includes the type of device from which you access the Services, browser type and version, time zone setting, and operating system type and version.
- Personal Information we collect from third parties:
We may get certain information about you from third parties, as follows:
- Vets: When you get a Service from one of our vets, these vets are providing the Services on our behalf, even if they are not directly employed by us but working under a contract. Vets will share the Service rendering information with us, such as a summary of the visit, length and billing amount, the visit duration and location.
- Media channels: certain media channels that may have sent you to our Website, such as Facebook, Google and LinkedIn may provide us with metadata about you, in an anonymized and minimized form for purposes of measurement and calculation of payment to them. This data sharing is subject to and disclosed in their own individual privacy policies which you are required to confirm before you use their services.
- Call center services: In certain cases (for example to accommodate an overload or when outside of normal working hours), we may use third-party phone services for that purpose. Those third-party services are considered our Service Providers (as described below), and will process certain information from you for the purpose of providing us with such purposes and providing you the Services on our behalf. Our legal basis for the use of your information.
- Referral. A portion of the Services may offer – from time to time – programs, promotions and benefits to Customers. In cases where such programs include “bring-a-friend” features, we may receive the personal information of a third-party data subject, submitted by their friend or a family member. This information includes a name or a nickname and an email address, used to contact such person with the gift and/or discount assigned to them by our Customers.
4. The legal basis for the processing of your information
We collect, process and use your information for the purposes described in this Policy, based on at least one of the following legal grounds:
- With your consent upon using our services, and in certain cases, when you submit such information, for example, when you complete a form, contact our support services or talk with one of our representatives.
- Certain types of data or access to data will require explicit (opt-in) consent from you.
- Our legitimate interest in functional and services provisional: We collect and process your Personal Information in order to provide you with the services, following your acceptance of the TOS and this Policy; to maintain and improve our services; to develop new services and features for our Users; and to personalize the Services in order to ensure a better user experience.
- Legitimate interests: We process certain information such as cookies and other online necessities for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for the sake of detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services, protecting against harm to the rights, property or safety of our online properties, our Users, or the public, as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Policy; and in order to comply and/or fulfill our obligations under applicable laws, regulations, guidelines, industry standards, contractual requirements, legal process, subpoena or governmental request, as well as our TOS.
- Contract: In case we engage in a direct contract, whether with a User, business partners, peers or service providers, in addition to the Terms and this Privacy Policy.
5. The purpose for processing Personal Information
In addition to the purposes described next to each category of data above, we may use information that we collect about you, in its raw format, or aggregated and processed format, for the following purposes:
- To provide, operate and improve our services and manage our operation;
- To generate analysis and insights for our Users and to better understand how they use our services;
- To send You updates, notices, notifications, announcements, and additional information related to our Services;
- In cases where you provided your separate consent to so, and so long as you did not opt-out, to share with you promotional offers related to the services and the context of pets;
- To be able to manage Your account, when this feature will be made available, and provide You with customer support;
- To create cumulative statistical data and other cumulative information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our services;
- To perform functions or services as otherwise described to you at the time of collection;
- To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities;
- To comply with any applicable rule or regulation and/or respond to or defend against legal proceedings brought against us or our affiliates.
6. Sharing information with third parties
We keep the information processed by us in strict confidence and only share your information with third parties in very limited circumstances and for very specific purposes, as per the categories described in this Policy. We hereby commit that WE DO NOT SELL YOUR PERSONAL INFORMATION TO ANY SOURCE AND UNDER NO CIRCUMSTANCES.
- We share some of your Personal Information with the veterinarians collaborating with our Services, in order for them to be able to provide you with their medical services.
- Third-Party Services: We are partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include customer support services, payment and processing, media services that advertise our Services and send prospective customers to us, data hosting, database and server co-location services (e.g., Amazon (AWS)), data analytics services (e.g. Google Analytics) and session replay records for analytic purposes such as crashes, functionality and usability (e.g. MixPanel, Hotjar, UXCam) and our business, legal and financial advisors, and communication partners such as “Referral Factory” (collectively, “Third Party Service Providers”).
- Law enforcement, legal proceedings, and as authorized by law: We may disclose or otherwise allow access to Personal Information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, in cases of emergency or if we believe in good faith that this will help protect the rights, property or personal safety of our company, any of our Users, or any members of the general public.
- Change of control: In the event that we will be acquired by or merged with a third-party entity, we reserve the right to transfer or assign the information we collected as part of such merger, acquisition, sale, or other change of control.
Such Third Party Service Providers may receive or otherwise have access to some of your Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing our services, and may only use your Personal Information for such purposes. Disclosures of Personal Information is subject to the respective third party’s undertaking of confidentiality obligations, and the prevention of any independent right to use this data except as required to help us provide you with our services.
For the avoidance of doubt, we may share your Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use Non-personal (including anonymized, statistical or aggregated) Information in our sole discretion and without the need for further approval.
7. Where we store your personal information
Your information will be maintained, processed and stored by us and our authorized affiliates (as applicable) in secure cloud storage, provided by our Third Party Service Providers based in the United States.
While the data protection laws in jurisdictions where the information is physically stored may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your Personal Information on our behalf, are each committed to keeping it protected and secured, pursuant to this Policy and best industry standards, regardless of any lesser legal requirements that may apply in a particular jurisdiction. You hereby accept the place of storage and the transfer of information as described in this Policy.
8. Your Rights under the Policy
Depending on your country of residency, certain rights concerning your Personal Information may be available to you. The rights described below are available to our consumers in the United States and are based on the CCPA legislation.
8.1. Access to Certain Information and Data Portability Rights
You have the right to request us to disclose certain information to you about our collection and use of your personal information over the past 12 months. In any other case, and if applicable, you can make a request to us as described below. Once we receive and confirm your verifiable consumer request, we will disclose the information you have requested, which could be one of the following types:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose.
8.2. Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (see below). The function of deleting your information when it is associated with an account, or cookies, is given directly to you, via your admin or browser’s settings, respectively.
When applicable, once we receive and confirm your verifiable consumer request, we will delete (and direct our Third Party Service Providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you or a third party.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act (Cal OPPA) or with any applicable legislation.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
8.3. Rectification
Customers of our Services (whether part of our membership program or not), can choose to edit their information. This option will be made available directly via your account, or, by reaching out to us with a rectification request to support@thevets.com.
8.4. Opt-out and consent withdrawal
We are happy to offer transparency and access controls to help Users and Customers take advantage of their right to opt-out and/or withdraw their previously given consent.
Users and Customers have the right to give and withdraw their previously given consent to the collection and processing of their Personal Information. This includes the right to withdraw or modify consent to the use of cookies at any time and the possibility to opt-out (unsubscribe) from our mailing list via mailing communication we send to you (subject to exemptions).
8.5. Exercising your rights and choices
- To exercise the rights described above, please submit a verifiable consumer request to us by email to support@thevets.com
- Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information.
- You may only make such a request for access or data portability twice within a 12-month period. The request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
- Making a request does not require you to create an account with us if you do not already have one. We will only use Personal Information provided in a verifiable consumer request to verify the identity or authority to make the request.
8.6. Response Timing and Format
- We strive to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
- If you do not have an account with us, we will deliver our response by email or any other format allowed by law. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request if that is the case.
- For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
- We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
9. Non-Discrimination
We will not discriminate against you for exercising any of your rights. Moreover, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
10. Do not Track Signals
Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature”); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. The Vets does not currently respond or recognize DNT Feature signals.
11. Data retention
We retain the Personal Information we collect or receive from you for as long as we need them in order to provide you with our Services and as otherwise necessary to comply with applicable laws and regulations. If you withdraw your consent to us processing your Personal Information, including by deleting your account, we will delete your Personal Information from our systems, except to the extent such data in whole or in part is required to comply with any applicable rule or regulation and/or to respond to or defend against legal proceeding brought against us or our affiliates.
12. Using cookies and other tracking technologies
We may use cookies and similar web technologies to help us with a better understanding of how you use our services, including those offered by Third Party Service Providers. These technologies are used in order to maintain, provide and improve our services on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of and “remember” our Users’ preferences and authenticated sessions, (ii) secure our services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our services, (iv) and create and monitor analytics.
13. Minors
To access or use our services, you must be over the age of sixteen(16), and in any case, not underage according to the legislation in your country of residence. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of 16 are not using our services.
In the event that it comes to our attention that a person under the age of 16 is using our services, we may prohibit and block such User from using our Services, and will make all efforts to promptly delete any Personal Information with respect to them.
14. Data security
We take great care in implementing and maintaining the security of our services and of your Personal Information. We employ industry standard procedures and policies to ensure the safety of your information, reduce the risks stemming from loss of information and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorized access will never occur and reiterate that no measure can provide absolute information security.
15. Changes to the Privacy Policy
The terms of this Policy will govern the use of our services and any information collected therein. We reserve the right to change this Policy at any time, so please revisit this page frequently. We will provide notice of substantial changes to this Policy on the homepage of the Website and/or we will send you an e-mail regarding such changes to the e-mail address you may have provided. Such substantial changes will take effect seven (7) days after such notice was provided on our Website or sent by email. Otherwise, all other changes to this Policy are effective as of the stated “Last Revised” date and your continued use of the Website after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.
16. General
This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Delaware, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in the City of Wilmington, County of New Castle Delaware, USA.
17. Any questions?
If you have any questions (or comments) concerning this Policy, you are welcome to send us an email at support@thevets.com and we will make an effort to reply within a reasonable timeframe.
