Privacy Policy of www.vetpal.ie

Vetpal Limited, a company incorporated under the laws of Ireland, (“Vetpal” or "We") are committed to protecting and respecting your privacy.

For the purpose of the Data Protection Act 2018 and the EU General Data Protection Regulation (2016/679) (GDPR) (together “Data Protection Law”), we are the data controller. All definitions in this policy in respect of personal data and processing are as described in the GDPR. 

Our website www.vetpal.ie (“our site” or “the site”) and the VETPAL application (“our app” or “the app”) are both operated by Vetpal.

This privacy policy sets out the basis on which we process any personal data we collect from you through your use of the site or the app.

Our app and website are used by animal owners, veterinarians and pharmacists/licensed merchants (the “Animal Remedy Stores”), to facilitate (i) making of appointments and communicating directly with veterinary practices via a messaging service on the app, (ii) requesting prescriptions for collection at either the veterinary practice or from Animal Remedy Stores (iii) selecting one or more veterinary practices to a allow an appropriate Client-Practice-Patient-Relationship (“CPPR”) to exist.

As part of this process we collect personal data in relation to the following:

“Animal Owners”:                     the individuals availing of services from the veterinarians and collecting prescriptions from the Animal Remedy Stores,

“Veterinarians”:                        the veterinarians providing the prescriptions to the Animal Owners,

“Animal Remedy Stores”:         the individual pharmacists or licensed merchants dispensing the prescriptions to the Animal Owners.

On our site or app, the personal data of Animal Owners, Veterinarians and Animal Remedy Stores will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

· Information that you provide by filling in forms on our site www.vetpal.ie (“our site”). This includes information provided at the time of registering to use our site, becoming a member of our site or posting material. We may also ask you for information when you report a problem with our site or app.

· If you contact us, we may keep a record of that correspondence.

· We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

· Details of transactions you carry out through our site and of the fulfilment of your orders.

· Statistical information about browsing actions including, but not limited to:

· traffic data;

· location data: we gather location data to track the nearest veterinary clinic and Animal Remedy Store to each Animal Owner.

PURPOSE OF PROCESSING

The purpose of the processing of your personal data is to fulfil our contractual obligations with the Animal Owners, Veterinarians and Animal Remedy Stores.

The specific purposes are set out below:

· Animal Owners’ personal data:

• Registration details: email, name, address, phone number, and, if the Animal Owner is a farmer, their heard/equine/flock number. These details are collected in order to provide access to our service.
• We process personal data of Animal Owners in order to connect the Animal Owners with Veterinarians and Animal Remedy Stores to enable them to avail of the services.
• The lawful basis for the processing of this personal data is based on your consent. By clicking “I agree” in the relevant box situated on the form on which we collect your data (the registration form) when creating an account on our site, you are consenting to the processing your personal data in accordance with this policy. You have the right to withdraw your consent regarding the processing of sensitive data at any time.
• The Animal Owners will also be required to provide certain information relating to their animals
• You will also be asked to tick a box if you are an organic farmer when creating an account. This information may be provided to the Department of Agriculture if requested.

· Veterinarian’s personal data:

• Registration details: email, name, qualifications, Veterinary Council of Ireland registration number. 
• We will also collect data about the clinic where they veterinarian practices; such as the phone number and address.
• We process personal data of veterinarians in order to set up their profiles and allow them to use the app to connect with Animal Owners. We also process their data to enable the veterinarians to liaise with Animal Remedy Stores and manage the prescription process through the app and website in order track their activity as required by the Animal Owners. The lawful basis for processing this personal data is the provision of the services offered by the app and website to the Animal Owners.

· Animal Remedy Store personal data:

• Registration details: email, name, Pharmaceutical Society of Ireland number (if the individual is a pharmacist), QQI Level 6 Certificate number/Responsible Person Certificate Number.
• We will also collect data about the store where the pharmacist or licensed merchant operates; such as the phone number and address.
• We process personal data of pharmacists or licensed merchants in order to set up their profiles on the site and allow them to manage the prescription process through the app and website and in order track their activity as required by the Animal Owners. The lawful basis for processing this personal data is the provision of the services offered by the app and website to the Animal Owners.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

· To enable Animal Owners to receive prescriptions for their animals from veterinarians and Animal Remedy Stores.

· To facilitate Animal Owners making appointments and communicating directly with veterinary practices via a messaging service on the app,

· To provide Animal Owners, veterinarians and Animal Remedy Stores with copies of the animal’s prescriptions when requested.

· To ensure that content from our site is presented in the most effective manner for you and for your computer or device.

· To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

· To allow you to participate in interactive features of our service, when you choose to do so.

· To notify you about changes to our service.

We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post, telephone or e-mail.

If you are an existing customer, we will only contact you by electronic means (e-mail or SMS or smart-phone alert) with information about goods and services similar to those which were the subject of a previous sale to you.

If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form).

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

RETENTION OF YOUR DATA

We shall retain personal data for strictly no longer than is necessary for:

(a) the purposes for which it was collected;

a. for as long you maintain an active profile on the site or app; and

b. for 5 year following the date on which the Animal Owner and/or veterinarian and/or Animal Remedy Store ceases to maintain a profile to allow us to respond to follow up queries; and

(b) as required to fulfil our obligations in law.

STORAGE OF YOUR DATA

Our site and app or certain information in relation to either them may also be hosted by our cloud services based in Ireland. We have a contract in place with the cloud services and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All transfers of data outside of the European Economic Area (the “EEA”) are made in accordance with the requirements of Regulation (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and are based on either an adequacy decision being made by the European Commission or the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA. 

By using our site or app or by interacting with us in the ways described in this Privacy Policy, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Policy. Please contact us if you do not want your information to be transferred outside the EEA in the manner set out in this Privacy Policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot absolutely guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

SECURITY OF YOUR DATA

In order to ensure the security of your personal data, we shall ensure the security of the information we collect and shall store it in a safe manner. We have the following measures in place (although we cannot always guarantee the security of data that is collected and stored by us):

a) where our employees or contractors process personal data, we will ensure that they are trained in the handling and care of personal data and that such employees or contractors are only permitted access to personal data on a “need to know” basis;

b) ensure that all inquiries from data subjects relating to processing of their personal data by Vetpal are dealt with promptly and properly;

c) only retain personal or sensitive data on our files for the duration of provision of the services to you, unless the longer retention of such personal data is required for legal and auditing purposes;

d) not transfer personal data outside the EEA except where necessary for the provision of the services, or you have consented, and appropriate measures to safeguard the security of your personal data are adopted;

e) we maintain appropriate technical, security and organisational security measures against any unauthorised access to or alteration, disclosure, destruction, or accidental loss or destruction of or damage to personal data. We will carry out regular testing of the effectiveness of our security measures to minimise risk;

f) process personal data in accordance with the duration, nature and purpose of processing as required to carry out services;

g) demonstrate compliance by keeping an auditable record of:

(i) the categories of all Personal Data we process,

(ii) details of any sub-contractors appointed to process data on Vetpal’s behalf;

(iii) categories of processing carried out by Vetpal;

(iv) details of any transfers of Personal Data to third countries; and

(v) current maintained and accurate descriptions of the technical and organisational security measures in place for each category of Personal Data, which demonstrate how such measures are implemented for the Services provided under this Agreement;

SUB PROCESSING

We maintain a list of sub-processors available on request.

DATA PROTECTION INCIDENT

Upon becoming aware of a breach of personal data we will notify affected data subjects within 72 hours in writing, detailing the circumstances and particulars thereof; report the breach to the Data Protection Commissioner of Ireland (the “Supervisory Authority”); and take such reasonable corrective and mitigating measures as required under Data Protection Law and that are customary under the circumstances.

IP ADDRESSES, COOKIES AND GOOGLE ANALYTICS

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. Aggregate information is statistical data about your browsing activities and patterns and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

· To estimate our audience size and usage pattern.

· To store information about your preferences, and to allow us to customise our site according to your individual interests.

· To speed up your searches.

· To recognise you when you return to our site.

You may refuse to accept cookies when you open our site. Please note that our advertisers may also use cookies, over which we have no control. For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org

We also use Google Analytics on our site. Google Analytics transmits website traffic data to Google servers in the United States, but it does not identify individual users or associated IP addresses with any data held by Google. We use reports provided by Google Analytics to better understand traffic and usage of our website.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Companies Act 2014.

We may disclose your personal information to third parties:

· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

· If Vetpal or substantially all of its assets are acquired by a third party, personal data held by it about Animal Owners or veterinarians will be one of the transferred assets.

· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or EU regulation, or in order to enforce or apply our terms of use as set out in our general terms and conditions and other agreements; or to protect the rights, property, or safety of Vetpal, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. This also includes providing the Department of Agriculture with details of the prescriptions ordered through our site in compliance with EU Regulation on Veterinary Medicinal Products (EU2019/6) if requested.

YOUR RIGHTS

You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:

• right to access your personal data: you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data;
• right to rectification: you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete;
• right to erasure: you have the right to request that we delete personal data that we hold about you;
• right to restriction of processing or to object to processing: you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes;

· right to data portability: you have the right to request that we provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format;

· Consent: you have the right to withdraw your consent at any time.

To exercise these rights please email support@vetpal.ie. Any request should be put in writing and will be responded to, by us within 30 days. Please contact us either by email at support@vetpal.ie or by post at our registered address from time to time. All correspondence should be marked for the attention of our GDPR team. 

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@vetpal.ie.