Anderson Abercromby Vet Referrals respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice covers the following content:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
This privacy notice aims to give you information on how we collect and process your personal data through your registration with any of practices and use of our website, including any data you may provide through our website when you sign up to our newsletter, or purchase a product or service.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
VetPartners Practices Limited t/a Anderson Abercromby Veterinary Referrals is the data controller and responsible for your personal data (collectively referred to as "Anderson Abercromby Veterinary Referrals ", "we", "us" or "our" in this privacy notice).
Our full details are: VetPartners Practices Limited t/a Anderson Abercromby Veterinary Referrals (registered in England and Wales under company number 10026837 VAT Registration No. GB 228 9288 65; Registered Office: Spitfire House, Aviator Court, York YO30 4UZ
Email address: firstname.lastname@example.org
Postal address: c/o Spitfire House, Aviator Court, Amy Johnson Way, York YO30 4UZ
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.
This version was last updated on 10 September 2019 and historic versions can be obtained by contacting us.
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.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual (the 'Data Subject') 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:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
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 products or veterinary 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.
We use different methods to collect data from and about you including through:
(a) analytics providers [such as Google based outside the EU];
(b) Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as PAYPAL based outside the EU]
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:
Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
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 or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. If you would like to know more about the specific legal ground we are relying on to process your personal data (where more than one ground has been set out), please contact us.
Type of data
Lawful basis for processing including basis of legitimate interest
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
To process payments for products and services we provide to you, including:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you of treatments that your pet is due, or which may be beneficial to your pet
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We may process your personal data in order to make suggestions and recommendations to you about products or services that may be of interest to you (‘direct marketing’). In these cases, the lawful basis we rely on is ‘consent’. Before we process your data for direct marketing purposes, we will require your consent to do so. Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to yourself.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need for your pet(s), 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).
You will only receive marketing communications from us if you have purchased products or services from us and specifically ‘opted in’ to receive such communications.
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time or adjust your marketing preferences or by following the opt-out or ‘unsubscribe’ links on any marketing message sent to you or by contacting us at any time.
We will only use your personal data for the purposes for which we collected it. However, we may sometimes find that our purposes for collecting and using data changes over time. If we originally collected and used your personal data on the lawful basis of consent, we will always ask you for ‘fresh’ consent for the processing of your personal data for any new purpose. If we did not originally collect your personal data on the basis of consent, we may only use your personal data for a new purpose if this new purpose is compatible with the original purpose. When assessing whether the original and new purpose are compatible, we will consider the differences between the original and the new purpose; the reasonable expectations that you would have with regards to our handling of your data; and the impact on the individuals whose data we are processing. 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, ‘incompatible’ purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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, set out in a Data Sharing Agreement.
We do not transfer your personal data outside the European Economic Area (EEA) without having appropriate safeguards in place to allow for restricted transfers of personal data.
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 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.
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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We keep basic information about our customers (including Contact, Identity, Pet, Financial and Transaction Data) for six years after they cease being customers for legal and tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us.
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.
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.
We are usually able to respond to all requests within one calendar month from confirming the validity of the request. In the rare occasions where a request is particularly complex or voluminous, we may need to extend this deadline by an additional two calendar months. If this is the case, we will notify you as soon as possible, and in any event within 30 days.
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 make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is 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 where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties