Privacy Policy

Our Commitment to Your Privacy

Vetster UK Limited (“ Vetster ”, “ we ”, “ us ” or “ our ”) respects your privacy and is committed to protecting the privacy and security of your Personal Information (defined below).

Vetster is an online marketplace that allows licensed veterinary professionals (“ Vets ”) to provide veterinary telemedicine consultations to owners (“ Clients ”) of pets and other animals (referred to as “ Pets ”). Both Vets and Clients will be referred to as “ user ”, “ you ” or “ your ” throughout this Privacy Policy.

This privacy policy describes how Vetster collects and processes your Personal Information when you use of the Vetster’s website, application or other platform (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

This Privacy Policy is divided into following sections, which can be accessed by clicking on the ‎‎hyperlinks below‎.

Purpose of this Privacy Policy

This Privacy Policy applies to any Personal Information that is collected and processed by us, whether it is collected in person, over the telephone, in writing, electronically via email messages that link to this Privacy Policy, or via your use of our website, mobile applications or social media pages (each referred to as a “ Site ”) on which this Privacy Policy appears.

For the purpose of this Privacy Policy, “ Personal Information ” means any information about an individual from which that person can be identified, in accordance with applicable privacy and data protection laws. Anonymous information that does not identify an individual is not considered to be Personal Information.

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

We encourage you to read this Privacy Policy carefully, and to watch for and read any updates that might be made from time to time, as explained below under “ Changes to this Privacy Policy ”.

Controller

Vetster UK Limited is the controller responsible for processing your Personal Information under this Privacy Policy. Vetster is a subsidiary of Vetster Inc. (together with all other subsidiaries, “ Vetster Group ”).

We are registered with the Information Commissioner’s Office with number ZB288891.

We have appointed a Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out under “Contact Us” section below.

Personal Information You Provide

We collect, use, store and transfer Personal Information that you voluntarily provide to us in order to use our services. This Personal Information is collected for the purpose of providing you with the services you request or choose to interact with and responding to inquiries you make, as described below.

For Clients – we collect the following Personal Information when you register an account on our Site:

• first and last names
• residential address
• email address(es)
• mobile phone number(s)
• details about your Pet.

For Vets – we collect the following information when you subscribe to our service and post your listing on your Site (but note that to the extent this information does not enable us to identify any individual, it may not constitute “Personal Information” under applicable data protection laws):

• first and last names
• veterinary licence information
• veterinary clinic information
• business mailing address
• business website address
• business email address(es)
• business phone number(s)
• mobile phone number
• banking information, for deposit of patient consultation fees

In addition to the above, we may collect additional Personal Information in the following circumstances:

• Account and Profile Data: We will collect information in relation to your account when you make use our Sites or services, such as information about your bookings, orders or subscriptions, or payment information such as debit or credit card transaction details, via our secure third-party payment processor, Stripe. We may also collect information you provide when you participate in any interactive features on our site, such as when you participate in surveys or promotions.
• Customer Service: We will collect any Personal Information you choose to provide when engaging with us or our customer service for the purposes of responding to your inquiry, investigating or resolving your issue or otherwise addressing communication with you. This involves Personal Information you provide when speaking to us via phone or in writing via letters, emails, chat messages or texts, our social media pages, raising support tickets or otherwise providing feedback. The Personal Information you provide may include your name and contact details, the purpose and use of our services or your interactions with other users.
• Marketing & Communications: When you sign-up for marketing communications, we may ask for your contact information such as your name and email address. We may also collect information about your preferences in receiving marketing from us and our third parties and your communication preferences.

Note that we do not store any credit or debit card information. Payments are processed via our third-party payment provider that is fully compliant with Payment Card Industry (PCI) data security standards.

Technical Information

In addition to the above information provided to us directly by you, we may also collect, use and share the following information that is automatically generated by your use of the Site (“Technical Information”). Technical Information is not considered “Personal Information” under applicable data protection laws as it does not directly or indirectly reveal your identity. However, if we associate it with your Personal Information so that we can directly or indirectly identify you, we will treat it as Personal Information in accordance with this Privacy Policy.

• Log Files: Log files make a record of each visit to our Site and log a number of details, including: your operating system; the date, time and duration of the visit; the pages and documents accessed; and the previous site accessed by you (such as, the search engine that referred you to our Site). Such information is collected for aggregated statistical purposes only, such as to track the number of visits to our Site, the number of views to particular pages, time-based traffic patterns, and the proportion of visitors using certain devices. Vetster will not make any attempt to identify users according to their browsing activity through such records.
• Device Identifiers: A device identifier, such as an IP address, is a distinctive number associated with a device. We may use your device identifier to identify you when you visit our Site to determine repeat visitors and detect and prevent fraudulent activity. By using device identifiers to approximate geographic location (to a city level), we can determine your approximate time zone, and better understand the locations of our customer base.
• Cookies: Cookies are small text files stored on your computer that identify your IP address to our computers each time you visit our Site. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them). We may use cookies to collect and store certain information that details your preferences, in order to facilitate a more personalized browsing experience. We may also use cookies to collect aggregated statistical information, similar to that collected through log files. You can choose to disable or block cookies on your browser, as described below under the heading “Your Privacy Preferences”. For more information about the cookies we use, please see Cookie Policy .
• Web Beacons: We may use web beacons, also known as pixel tags, clear GIFs or other similar technologies in connection with some of our Site pages, social media pages and HTML-formatted email messages to, among other things, track the actions of users and email recipients, measure the success of our marketing campaigns, and compile statistics about our Site and social media usage and email response rates. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can disable or block cookies as noted below under the heading “Your Privacy Preferences”. If you turn off cookies, web beacons (or similar technologies) will still detect visits to these pages, but the notices they generate cannot be associated with other cookie information and are disregarded.
• Analytics: Vetster uses Google Analytics to provide statistics about the visitors to our Site. Google Analytics tracks and analyzes non-personally identifiable statistical information, including, without limitation, search engines, display advertising, pay-per-click networks, email marketing and digital collateral such as links within PDF documents. More information about Google Analytics is available here .
• Geo-location: If you have activated the GPS location feature on your mobile device when using one of our apps or permit us to identify your location when using our website, we will have access to your location in order to match Clients with eligible Vets in the closest eligible locale.

Information we receive from third-party sources

We may receive Personal Information about you from various third parties, such as:

• As mentioned above, analytics providers such Google and other technical service providers and sub-contractors;

Sensitive Data

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 criminal convictions and offences.

Personal Information of Children

Our Sites are not intended for children and we do not knowingly collect Personal Information of children; however, we cannot always determine the age of persons who access and use our Site. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or legal guardian to contact us to have this information removed from our records.

If You Fail To Provide Personal Information

Where we need to collect personal information 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 our services or otherwise permit you using some features of the Sites). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We will only use your Personal Information where we have a reason and where that reason is permitted under data protection laws. We set out the reasons (legal bases) for using your Personal Information and for what purposes we do so below.

Performance of a Contract With You

We collect and use your Personal Information where we need to in order to enter into a contract with you and/or to provide the service you have requested. This includes information we collect and process for the following purposes:

• to register and set-up your account on our Site, to enable access to the relevant parts of the Sites and services you have asked for;
• to match Clients with Vets in order to provide veterinary telemedicine consultations and other services for their Pets;
• to collect payment of fees owing to us for our services from Clients;
• to deposit payments to Vets for patient consultations;
• to contact you or respond to your inquiries concerning our services and provide you with customer support at your request;
• to contact you about changes to the terms of any contract we have with you.

Legitimate Interests

We also process your Personal Information where we have a legitimate interest in doing so, such as to personalise or improve our service, to promote responsible relationships between users, or to protect our interests or interest of others. This includes processing of your Personal Information for the following purposes:

• to monitor and analyze usage of our Site or our services in order to improve our Site or the quality or effectiveness of the services we offer;
• to tailor content on the Site to you, for example display content that is most relevant to you or show you Vet listings that meet Clients’ search criteria and location;
• to enable us to help you with any inquiries, complaints or issues in the most efficient way and provide a good customer experience;
• to prevent, detect, investigate and, where appropriate, report any prohibited or illegal activities or fraud or to respond to any requests from regulators;
• to enforce the terms of any contract we have with you, including to recover any debts owed to us and exercise or defend legal claims and to protect our rights or the rights of others;
• to send you marketing communications about our products, services and initiatives as permitted by applicable law (you can opt-out at any time, please follow the steps in the section below titled “Your Privacy Preferences”)

Compliance with our Legal Obligation

We may also use your Personal Information to comply with any legal obligation or regulatory requirement to which we are subject. This may involve disclosing your Personal Information to law enforcement agencies or regulators.

Consent

We may also process your Personal Information for other purposes with your consent. If we need to seek your consent to process your Personal Information, we will make the relevant purposes for which your information will be used clear to you at the time.

Generally, we do not rely on consent as a legal basis for processing your Personal Information although we will get your consent before sending third party direct marketing communications to you. To opt-out of receiving marketing communications, please follow the steps in the section below titled “Your Privacy Preferences”.

Direct and Third Party Marketing; Opt-Out

We can use your Personal Information to send you marketing information where you have given your consent or where we have a legitimate interest in doing so (and we are permitted to do so by law).

We may use Personal Information (such as your name and contact details, Account and Profile Data and Technical Information as well as Marketing & Communications 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).

We may use your Personal Information to send you marketing information about our other products or services, features or initiatives if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by updating your preferences as set out the section below titled “Your Privacy Preferences”.

Change of Purpose

We will only use your Personal Information 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 Information 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 Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Vetster does not trade or sell Personal Information to others. Vetster may disclose Personal Information to certain third parties as further described below. Such information will be disclosed in accordance with applicable law.

Other Users of the Site:

Name, photograph, veterinary license (Vet), location (Vet), areas of interest (Vet), capabilities (Vet) you provide to us when a Client registers for an account on the Site or when a Vet subscribes to our service and posts a listing on your Site will be displayed to other users of the Site, for example when a Client searches for a licensed veterinarian, or when a Client joins an appointment with a veterinarian.

Vetster Group:

Vetster may share your Personal information with other Vetster Group companies where necessary for the purposes set out in “How We Use Your Information” section above, for example where we share resources such as customer services and technology across the Vetster Group.

Third Party Service Providers:

Vetster may from time to time disclose Personal Information about users to third parties who provide services to Vetster (“Third Party Service Providers”). We will limit this disclosure to only the Personal Information that is reasonably necessary for the purpose or service for which the Third Party Service Provider is engaged. The types of Third Party Service Providers with whom we may share your Personal information will include, for example:

• Payment processing providers, such as Stripe and Hyperwallet;
• Software development and design partners;
• Customer relation management and customer support providers such as HubSpot and Intercom;

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

Sale or Business Transaction:

Subject to applicable law, we may share or transfer your Personal Information where reasonably required in the event of a prospective or completed sale, merger, amalgamation, restructuring, reorganisation or other business transaction involving all or part of our business. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is concluded, assignees or successors of Vetster or our business or assets may use and disclose Personal Information only for the purposes as set out this Privacy Policy, unless further consent is obtained from you or otherwise permitted by applicable law

Technical Information:

As described above, we share your Technical Information with the Google Analytics analytical platform, to help us understand how you use our Site so that we can enhance your user experience.

We may also share your Personal Information:

• if we are required (or we believe we are required) to disclose or share your Personal Information to comply with the law, any regulatory requirement or a court order, or any request from any regulatory authority or government;
• with such third parties we reasonably consider necessary or desirable to protect your safety or the safety of others or to prevent or detect fraud or other crimes, for example, with law enforcement agencies;
• to protect the rights of Vetster and Vetster Group, its partners and other users of the Site;
• to enforce our rights under any contract we have with you, or this Privacy Policy;
• for any other purpose disclosed by us when you provide the information.

Third Party Platforms

The Site may contain links to other third party platforms, such as websites, plug-ins and applications. While we try to link only to platforms that share our high standards and respect for privacy, clicking on those links or enabling those connections may allow third parties to collect or share data about you and we are not responsible for the content of the privacy statements, or the privacy practices employed by other platforms. We encourage you to review the privacy policies of each platform you visit.

In some cases, the personal data we collect from you may processed by us and our third party service providers outside of the UK, for example, in the European Economic Area (“EEA”), Canada, or the United States. These countries or territories may not have the same protection as the UK has. However, whenever we transfer your Personal Information outside of the UK, we are obliged to ensure that your Personal Information is processed by us, any other Vetster Group companies and our suppliers outside the UK is afforded a similar degree of protection if it were processed within the UK, by implementing certain safeguards.

We share your Personal Information within the Vetster Group. This will involve transferring your data outside the UK. For the purposes of IT hosting, the Personal Information we collect about you will be stored on servers located in Canada & The United States.

Many of our external third party providers are based outside the UK so their processing of your Personal Information will involve a transfer of data outside the UK. You can obtain more information about our policies and practices with respect to the use of Third Party Service Providers outside of the UK by contacting us as described below, under “Contact Us”.

Whenever we transfer your Personal Information out of the UK, we ensure a similar degree of protection is afforded to it by ensuring safeguards, such as the following, are implemented:

• we will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information; and
• where we use certain service providers, we may use specific contracts approved for use in the UK which give Personal Information the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the UK.

We will retain your Personal Information for only so long as is necessary to fulfill the purposes for which it was collected, and for such periods of time as may be required to comply with applicable legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We generally retain your data for up to 6 years after your last use of our service, cancellation of any ongoing contract with you (such as subscription-based access) or termination of access on our Sites.

In some circumstances we will anonymise your Personal Information (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.

When your Personal Information is no longer required, we will make all reasonable efforts to ensure all electronic and hard copies of such information are securely destroyed or anonymised. However, where your information has been provided to third parties for certain purposes, such as payment processing, those third parties, such as payment processors and financial institutions, may in certain circumstances (for example, where they are the controllers of such information) retain the information according to their own retention and privacy policies.

We take all reasonable measures designed to safeguard your Personal Information against unauthorized access, use, disclosure, copying or modification. Such measures, which may necessarily evolve over time as the availability and effectiveness of methods vary, include physical, organizational and technological safeguards, such as:

• restricting access to Personal Information to employees and Third Party Service Providers who need such information for a legitimate business purpose, and who are required to abide by this Privacy Policy, Vetster’s internal privacy and security practices and are subject to a duty of confidentiality;
• restricting access to our systems, accounts and electronic databases or other electronic formats that may contain Personal Information through password protection and internal security policies; and
• implementing technical security measures such as firewall technology, anti-malware screening and data encryption technology.

While Vetster employs advanced data encryption technology when interfacing with our users, Third Party Service Providers and other partners, you should be aware that there is a residual risk in transmitting any data electronically. Despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. This risk is inherent in all Internet dealings. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Under certain circumstances, you have rights under data protection laws in relation to your Personal Information as set out below. If you wish to exercise any of those rights, please contact us as described below, under “Contact Us” section.

• Request access. This is commonly known as a ‘data subject access request’. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
• Request correction. 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. This is also known as ‘the right to be forgotten’. 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. This enables you to 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. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • 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. If you request personal data we hold about you to be transferred 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, you can withdraw your consent at any time. 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.
• Right to complain. You have the right to lodge a complaint about the way we handle or process your information with a competent data protection authority. See “Contact Us” section below.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

You will not have to pay a fee to access your Personal Information (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 could refuse to comply with your request in these circumstances.

In order to verify your identity, we may also request that you provide certain Personal Information to us to match against our records. This is a security measure to ensure that Personal Information 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.

If you are receiving our marketing communications, you may unsubscribe at any time by clicking on the “unsubscribe” option in any marketing email or text you receive or by contacting us as set out below under the “Contact Us” heading. Please note that if you unsubscribe from marketing communications, we may still send you transactional emails or emails about your use of our Site.

You can disable or block cookies by following the instructions on your web browser. While you do not need to enable cookies to visit our Site, certain features of our Site depend on the use of cookies. Accordingly, if you choose to block cookies you may not be able to use those features or may lose preferences based on those cookies. For more information about the cookies we use, please see Cookie Policy .

We keep this Privacy Policy under regular review and can amend it from time to time. This version has been last updated on the “Last Updated” date at the top of the policy. You should check back here periodically to find out if any changes have been made to this Privacy Policy. If we make any material changes, we will notify you of those changes as appropriate, for example, by in-Site notification or email.

If you disagree with any change to the Privacy Policy, please refrain from using our Site or otherwise providing us with your Personal Information.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

If you would like to exercise your privacy rights or preferences or if you have any questions or complaints about this Privacy Policy, or the manner in which your Personal Information has been collected or handled by Vetster, please contact our Privacy Manager using the following details:

• Email address: data-requests@vetster.com
• Postal address: 15 Glenforest Rd, Toronto, ON Canada M4N 1Z7
• Telephone number: +1-844-619-0123.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.