Where My Paws At Portal and its affiliates (collectively, the “Where My Paws At Portal”, “Company,” “we,” “us,” or “our”) acknowledge the importance of protecting the privacy of all consumers (“you” or “user”), whether as a guest or a registered user to our website or mobile application that run on smart phones, tablets and other devices which provide dedicated non-browser-based interaction between you and our sites (all of which are collectively called our “Sites”).

This Privacy Policy details how your personal data may be used when you visit this and all of our Sites (regardless of where you visit it from) and tell you about your privacy rights.

We collect and process your personal data through your use of any of our Sites, including any data you provide through our Sites when you register or sign in on any of our Sites, purchase a product or service or take part in a giveaway.

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

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.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set below:

Email address: [email protected]

DATA WE COLLECT

Data, or personal information, means any information about an individual from which that person or pet can be identified. We collect different kinds of information from or about you or your pet. We may collect, use, store and transfer different kinds of personal data about you or your pet as below:

Contact Data – including but not limited to billing address, delivery address, location, email address and/or telephone numbers.

Identity Data – includes but not limited to first name, last name, address, username or similar identifier, date of birth and gender, pet name, pet age, pet date of birth, registered vet, microchip number, DM number, location

Financial Data includes bank account and payment card details, payment history.

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 IP address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings and other technology identification on the devices used to access our Sites, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our Sites, products and services including redemption of our offers, how you use your devices to access our Sites, including the screens you visit and searches you make.

Other Data includes:

• photos or other data uploaded onto any of our Sites by you or shared with other users of our Sites by you via our Sites.
• communications with us via social media platforms, email, electronic messages, and other electronic and non-electronic communications.
• third party partner information related to how you use our third-party partners, such as your reviews of our merchant partners or other service providers.
• your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices’ address book contacts, and other social media such as Facebook, Instagram and Twitter.
• Marketing and Communications Data includes 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. 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.

We do not collect on your philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

FAILURE TO PROVIDE PERSONAL DATA

We may not be able to perform the contract we have or are trying to enter with you. 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.

HOW IS YOUR PERSONAL DATA COLLECTED?

Different methods are used to collect data from and about you and your pet including but not limited through:

• registration forms
• purchasing our products or services
• creating an account or registering on our Sites
• registering to our services or products
• entering a competition, giveaway, or survey
• corresponding with us
• posting material on our Sites or social media platforms
• giving feedback or leaving comments

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our Sites or transmitted to other users of our Sites or third parties (collectively, “User Information”). Your User Information is posted and transmitted to others at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile. Please be aware we cannot control the actions of other users of our Sites with whom you may choose to share your User Information with. Therefore, we cannot and do not guarantee that your User Information will not be viewed by unauthorised persons.

We may automatically collect Technical Data about your browsing actions, equipment and patterns. We collect this by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies.

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 our Sites may become inaccessible or not function properly.

We automatically capture information through the use of cookies examples below.

• Strictly necessary cookies. These cookies are essential for enabling our Sites to provide certain of your requested services such as retaining your shopping bag items.
• Performance cookies. Performance cookies collect anonymous information on the users of our Sites to enable us to improve the operation of our Sites.
• Functionality cookies. These cookies retain choices you make such as member ID, email ID and other preferences in order to help you avoid having to re-enter the information as you navigate through our Sites, including the shopping cart.
• Targeting or advertising cookies. These cookies collect information about your browsing habits to allow us to provide advertising relevant to you and your interests.
• Web beacons: Pages of our Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and collect other related website and app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
• Log files: We may use log files to capture your activities on our apps as they interact with our Sites. Information captured in such log files may include the types of content you view or engage with and the frequency or duration of your activities.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources, or you provide to us.

HOW DO 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 or have entered into with you.
• Where we need to perform a contract, we have with a third party to provide you a product or service.
• 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, text message or other means. You have the right to withdraw consent to marketing at any time.

Marketing: If you do not wish to have your personal data used by the Company to promote our own or third parties’ products or services, you can opt-out by contacting us.

Targeted Advertising: If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by contacting us.

PROMOTIONAL OFFERS

You may receive promotional communications from us if you have requested information or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion.

THIRD-PARTY LINKS

The Sites may include links to third-party websites, applications and plug-ins. Accessing those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements.

We do not control third parties’ collection or use of your data. However, third parties may provide you with ways to choose not to have your information collected or used in this way.

OPTING OUT: You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking 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 at 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, warranty registration, product/service experience or other transactions.

UNDERAGE PERSONS

The Sites are not intended for children, and we do not knowingly collect data relating to children. Our Sites are not intended for use by persons under 13 years of age without legal parental or guardian consent. If you are under 13, do not use or provide any information on our Sites, or on or through any of their features register on the Sites, make any purchases through our Sites, use any of the interactive or public comment features of our Sites or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use without legal parental or guardian consent.

LOCATION INFORMATION

You can choose whether to allow our Sites to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of our Sites may then be inaccessible or not function properly.

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. 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.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

• Internal Third Parties
• External Third Parties
• 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 Policy.
• To a third party you nominate to fulfil the purpose for which you provide it. For example, if you give us an e-mail address to use the “e-mail a friend” feature of our Sites or you nominate another person to become a secondary member in family account, we will transmit the contents of that e-mail and your e-mail address to the recipients.

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.

DATA SECURITY

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.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for.

LAWFUL BASIS

Performance of Contract means processing your data where 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 necessary for compliance with a legal or regulatory obligation that we are subject to.

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 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).

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the following

• 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.

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