1. IMPORTANT INFORMATION AND WHO WE ARE
We do collect details of children solely for the purpose of recording the environment in which a pet is living and in order to assess the pet’s behaviour treatment.
2. THE DATA WE COLLECT ABOUT YOU
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 follows:
- Identity Data includes first name, last name and pet’s name.
- Profile Data includes general information about your pet, information about your household in relation to your pet, your responses to our pet behaviour questionnaire, feedback from you following our consultations and your pet’s veterinary clinical history.
- Contact Data includes billing address, postal address, email addresses and telephone numbers.
- Financial Data includes bank account and payment card details using the payment method of your choice, such as by cheque, BACS transfer, direct debit (via GoCardless), online payment (via Paypal or Stripe), or over the phone (via Square). For recurrent services and with your permission, we store your bank details and contact information with GoCardless to collect payment via direct debit, or we sometimes collect and store your debit or credit card details for future transactions via our payment card authorisation form, which are passed to our payment provider, Square.
- Transaction Data includes details about payments to and from you and other details of 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.
- Usage Data includes information about how you use our website and services.
- Communications Data includes your preferences in receiving future correspondence from us after the service has come to an end and your general communication preferences.
During diagnosis and treatment of your pet’s behaviour problem, we sometimes may collect Special Categories of Personal Data about you, your household and the people close to you (this could include details about your ethnicity, philosophical beliefs, relationships and information about your health). Similarly, we may collect information about criminal convictions and offences. However, all of this data is only collected and used with your express permission.
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 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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise, such as when you:
- subscribe to our services (including through our online calendar provided by SmoothBook, based inside the UK);
- request information about us to be sent to you;
- fill out a questionnaire about your pet (including online through our online form provider, JotForm based inside the EU); or
- give us some feedback.
- Third parties. We may receive personal data about you when you are referred to us from your vet or another animal care professional, and/or a local authority (e.g. fostering agency or county council) whom you are already in contact with about your pet.
4. 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.
Personal data relevant only to the services requested is collected. This data allows us to carry out consultancy services relating to animal behaviour and training for animal owners and keepers, referring veterinary staff, local authorities and child adoption/fostering agencies.
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 that 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
Your personal data is protected from loss, misuse, unauthorised access and disclosure. We may have to share your personal data with the parties set out below for the legitimate purposes referred to in paragraph 4 above:
- External Third Parties, such as your vet practice, other animal care professionals. your pet insurance company, the payment provider we use to collect any transaction costs or any other individuals outside your household that have come into contact with your pet, who you have given us express permission to contact;
- Local authorities (e.g. council, police, law courts, fostering agencies) who have a specific and authorised interest in the service we are providing;
- Service providers who provide IT and system administration services to us (e.g. Fruux);
- Professional advisers, such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us;
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
We do not share your personal data with third parties for marketing purposes.
Your personal data will remain confidential and will only be shared with individuals and/or organisations with your permission in order to carry out the services requested as indicated above, or if required to do so in 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.
6. INTERNATIONAL TRANSFERS
Some of our external third parties (such as Dropbox or A2Hosting) are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.
7. 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. 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 require all third parties to respect the security of your personal data and to treat it in accordance with the law.
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. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Personal data will be stored for seven years from last contact. In the event of death, this period will be seven years from the date of death. For example, sometimes behaviour problems continue to some degree for the lifetime of a pet, so your data is retained for at least that length of time.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are as follows:
- 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.
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.
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.
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.
10. OUR CONTACT DETAILS
If you have any questions about the data we collect, store or process, then please contact us at:
Email address: firstname.lastname@example.org
Postal address: Unit 55, 51 Pinfold Street, Birmingham, B2 4AY
Telephone number: (+44) (0) 121 299 0188
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.