PRIVACY POLICY Customers

Last updated: 2022-01-05

1. INTRODUCTION

FirstVet recognizes the importance of protecting the privacy of your personal data. We have instituted strict policies and security measures to protect the information you provide us.

The purpose of this privacy policy is for you, as a customer, to learn how FirstVet handles your personal data and for you to be able to feel secure that the processing is being carried out in accordance with the General Data Protection Regulation and other applicable data protection law. The privacy policy also describes your rights vis-à-vis us and how you can enforce those rights. By purchasing or receiving our products/services, you confirm that you have read and understood the content of this privacy policy.

This privacy policy is aimed towards you as a customer belonging to one or more of the following categories;

(a) Service Customers (users of our online veterinarian services)

(b) E-commerce Customers (customers that shop online)

(c) Website Users

(d) Newsletter Recipients

all jointly or any of the above are referred to as Customers.

For the purpose of this policy, User Data means (i) technical information, including IP address, login information, type and version of operating system and unit, time settings, language settings, screen settings, etc.; and (ii) information about your use of any of our services, including which functions you have used and when, etc.

2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

The Swedish company FirstVet AB, reg. no. 559047-9894 (“FirstVet”, "We", "Us"), is the controller of your personal data. FirstVet’s affiliated companies (including other companies within the FirstVet group, joint ventures, franchisees and licensees) and selected suppliers may process your personal data on FirstVet’s behalf and in accordance with FirstVets’ instructions as stated below and are thereby processors of your personal data.

You may contact FirstVet at any time, please find our contact details below.

Address: Strandvägen 47, 5th floor, 114 56 Stockholm

Phone: +46 10 206 70 66

E-mail: support@firstvet.com

3. CATEGORIES OF DATA PROCESSED, PURPOSE AND LEGAL BASIS FOR PROCESSING

3.1 General

Below is a summary of the categories of data that we process, the purposes of processing the data and on what legal basis we are processing your data.

3.2 Service Customers

FirstVet may collect and process your name, e-mail address, and phone number for the purpose of identifying and administrating the user, setting up an account, providing the Service, customer support and for sending your pets’ journal. In addition, personal data may be collected during your use of our service. The data is also processed so that FirstVet can process any complaints or claims and to communicate with you regarding your use of the service. The legal basis for processing such data is that the processing is necessary in order for FirstVet to fulfill its contractual obligation towards you as a Customer.

In some cases, FirstVet may collect and process your personal identity number or similar for the purpose of securely validating its Customers age, active coverage with FirstVet’s partners and to enable secure access to FirstVet’s services via electrical identification login methods or similar. Such number may also be processed in relation to the prescription of medicine. The legal basis for processing such data is a balancing of interest, where FirstVet’s legitimate interest is to provide a secure service and to ensure that any prescription of medicine is provided to the correct recipient.

FirstVet may also process your name, personal identity number or similar, e-mail address, address, phone number and information regarding your online consultation in order to send follow-up information regarding the consultation, e.g. to schedule another appointment, send prescriptions for medicine and other relevant information in relation to the consultation. The legal basis for processing such data is that the processing is necessary in order for FirstVet to fulfill its contractual obligations towards the Customer.

Photos and videos, which may contain personal data, and your pet’s journal are collected and processed for the purpose of carrying out FirstVet’s services and enabling a veterinarian to establish a veterinary diagnosis. The legal basis for processing such data is that the processing is necessary in order for FirstVet to fulfill its contractual obligation towards the Customer.

Payments made for purchases of FirstVet’s services are processed by a third-party payment service and such third party is the controller of the credit card information and other information relating to the payment. FirstVet does not collect or store any payment information.

If you take part in any contest or special event of FirstVet we may process your name, address, e-mail address, images and any information required by the contest or special event for the purpose of validating and administering your participation in the contest or special event. If you take part in a survey or questionnaire issued by FirstVet, we may collect and process your name, phone number, e-mail address and any information provided in a survey or questionnaire for the purpose of evaluating the answers provided in a survey or questionnaire in order to enhance FirstVet’s business operations. The legal basis for the processing is a balancing of interests, where FirstVet’s legitimate interest is to advertise its business by providing its Customers with special events and contests and for us to evaluate FirstVet’s business via Customer inputs through evaluations and questionnaires.

3.3 E-commerce Customers (only applicable in markets where e-commerce is available)

Your name, e-mail address, phone number and shipping- and billing address (including street name, zip code, city and country) are collected and used to process your order. The data is also processed so that FirstVet can process any returns, exchanges and complaints as well as communicating with you regarding the order and to answer and administer any questions or comments you may have regarding the products. The phone number is collected for the purpose of sending you a text message when the package has arrived at your pick-up place. The legal basis for processing such data is that the processing is necessary in order for FirstVet to fulfil its contractual obligation towards the Customer.

FirstVet also stores your purchase history for the purpose of facilitating the return process, exchanges and complaints and to communicate with you regarding the purchase. The legal basis for processing such data is that the processing is necessary in order for FirstVet to fulfill its contractual obligation towards you as a Customer.

FirstVet also stores information regarding returns for accounting purposes. Storing data on returns for this purpose is based on FirstVet’s legal obligations.

FirstVet also stores and processes your purchase history for the purpose of reminding you to refill and buy more consumable products, such as pet food and cat sand, when we estimate that the product from your last purchase is starting to run low. The legal basis for the processing is a balance of interests where our legitimate interest is to market our e-commerce and products to our Customers.

Payments made for purchases on FirstVet’s website are processed by a third-party payment service and such third party is the controller of the credit card information and other information relating to the payment. FirstVet does not collect or store any payment information.

3.4 Website Users

If you visit the website www.firstvet.com and consent to the placing of cookies, we may process your IP-address to locate from where in the world you are visiting from. The purpose of the processing is to gather data for statistical purposes and to enable security. The legal basis for the processing is a balance of interests where our legitimate interest is to improve our services through the use of statistics over visitors of the website and to facilitate the security of the website and its visitors.

Please note that your IP-address does not directly identify you as an individual. However, by cross-referencing your IP-address with additional available information, your identity may be revealed. FirstVet will not seek to identify you as a Website User.

FirstVet may also process your activity on the website provided that you have given your consent to the placing of cookies. The purpose of the processing is to measure and analyze your use of FirstVet’s website, targeting ad campaigns, deliver commercial and transactional messages and to improve FirstVet’s website, services and marketing. This processing is based on the legal basis of balancing of interests, where FirstVet’s legitimate interest is to be able to advertise its services and products and to improve its website and services.

3.5 Newsletter recipients

If you register an account with FirstVet you will automatically receive our newsletter. We will process your e-mail address for the purpose of providing you with the newsletter. The processing is based on the legal basis balancing of interests, where FirstVet’s legitimate interest is to advertise its services and products via the send-outs of its newsletter.

If you no longer wish to receive FirstVet’s newsletter, you may unsubscribe at any time for any reason whatsoever.

3.6 Anonymized data

It can be noted that we may also use anonymized data for statistical purposes. The processing is based on a balancing of interests, where FirstVet’s legitimate interest is to anonymise your personal data for product development purposes and to analyse customer behaviour in order to improve our services and the customer experience. By anonymising data relating to you, we also ensure that we use personal data as little as possible.

3.7 Direct marketing and profiling

We conduct direct marketing to our Customers to market our services and products. Direct marketing may be in the form of mail, e-mail, text message, social media or other similar electronic channels of communication. The data that may be processed mainly includes name, e-mail address, telephone number and User Data.

For a more customized and relevant marketing, FirstVet does a profiling of its Customers. "Profiling" means the automated processing and analysis of your personal data to assess certain personal characteristics of you for marketing purposes, for example to analyse or predict your personal preferences and interests, such as purchasing interests. At the same time, we compare your data with the content preferences of our other Customers with similar use of our services. The profiling for these purposes does not have a significant impact on you as a Customer. We use profiling to;

● deliver our services with tailored content based on what we think will be of most interest to you (this includes, for example, the FirstVet app and its various features and remembering information from your previous interactions to give an improved customer experience); and

● deliver tailored marketing to you, including ensuring that the information and marketing provided is relevant to you (for example, you will not receive any cat-related marketing if you do not have a cat registered on your account and have not purchased cat products from us). Tailored marketing can help to improve your access to new products, services and features that are most relevant to you, which in turn could help to improve your and your pet’s life and social experiences.

Marketing activities where you as a Customer have actively chosen to use one of our services or have otherwise contacted us to find out more about our services do not constitute direct marketing, including but not limited to, confirmation of a booked consultation, reminders of forgotten/abandoned digital shopping baskets and the like directed to you specifically as a result of your interaction with us, general newsletters, product recommendations, other features and offers or similar activities that simplify things for you as a Customer.

The processing is based on a balancing of interests where FirstVet’s interest is to determine what marketing we will provide to you. It shall further be noted that marketing is mentioned as an example of a legitimate interest in the GDPR.

If you have any questions about the profiling process, please contact us. Contact details can be found at the top of this policy. You can object to our profiling for direct marketing at any time by contacting us (and we will then stop profiling for marketing). You can also stop our profiling for our services by terminating your account with us.

3.8 FIRSTVET’S USE OF YOUR MATERIAL ON SOCIAL MEDIA

FirstVet is engaged on several social media platforms, including Facebook [LINK] and Instagram [LINK]. We love to see our Customers share their stories of their experiences from our services and see their pets with new products from our e-commerce on social media. This gives us an additional opportunity to receive feedback and improve our services and products, as well as use Customer’s material for marketing purposes. If you tag us in a post, story or similar, or use one of our hashtags provided from time to time (for example in connection to contests, campaigns or similar), we may want to repost, share and/or otherwise use such material for marketing purposes in our own channels and we may ask for permission to use these images. If you want to give your consent for such use, reply with the hashtag #boopFirstVet.

By tagging us in your post with @firstvet and replying with #boopFirstVet, or just use the hashtag, hereinafter referred to as "images", you give FirstVet a non-exclusive, royalty-free, worldwide license to use such images in its marketing and/or advertising, including social media channels, on the website, newsletters, email, other customer communications and other marketing purposes. We will strive to always tag and/or mention your account or other information about you (as applicable) as the source.

By replying with #boopFirstVet, you consent to our use of your images as described above and confirm that you have read and understood these terms. You also warrant that (1) you own all rights to the images, (2) you have obtained permission from any persons appearing in the images to assign the rights thereto, and (3) FirstVet’s use of the images will not infringe the rights of any third party or violate any law.

You hereby release FirstVet from any and all obligations to pay you for the use of your images and for the intellectual property rights in them in connection with the uses described above, and you hereby release and agree to indemnify FirstVet and all persons acting on FirstVet's behalf from any and all claims, demands and liabilities, of whatever nature, in connection with the use of the images as described above.

If you have any question, or wish to withdraw your consent to this, you can email us at ciara.richards@firstvet.com. We will not be able to withdraw the use of images made before your consent is withdrawn, but we will not make any new use of the images.

4. DOES FIRSTVET SHARE YOUR INFORMATION WITH OTHERS?

FirstVet does not sell or rent our Customers’ personal data to any other entity.

We may share your data with affiliated companies including other companies within the FirstVet group, joint ventures, franchisees and licensees. FirstVet may also share your data with selected suppliers who perform functions on our behalf such as providing technical measures for our online services, delivery of orders, processing payments, carrying out promotional services or data management, to maintain our website, to distribute e-mails, to send out our newsletter, to provide client communications and to manage our customer database. Furthermore, FirstVet may share your personal data with veterinary clinics and veterinary hospitals when transferring you to a clinic or a hospital. FirstVet may also share your personal data with insurance companies and partners in order to ensure that FirstVet’s services are covered in their offer to you and/or the functionality of our services. As necessary, the personal data you provide to us may be processed by these third parties, solely on FirstVet’s behalf and in accordance with FirstVet’s instructions to the data processor. We do not authorize any of our suppliers to make any other use of your personal data.

If FirstVet and/or its subsidiaries are subject to an actual or potential merger or acquisition or similar transaction, we may share your data with potential and actual buyer(s) and their financial and legal advisers, subject to such third parties undertaking appropriate confidentiality.

FirstVet may also disclose your personal data to a public authority where FirstVet is obligated to do so by law. In the event all or part of FirstVet’s operations are sold, FirstVet may transfer your personal data to a potential purchaser of the business.

5. TRANSFER OUTSIDE OF THE EU/EES

We may share your data with our selected suppliers, who may process your data in countries both inside and outside of the EU/EES when performing functions on our behalf as set out in section 4 above.

Please note that countries outside of the EU/EEA may not provide an adequate level of protection for your personal data. FirstVet has however taken appropriate safeguards to ensure that the receiving parties of your data in countries outside of the EU/EEA shall provide an adequate protection of your data. Such safeguards may be that the receiving party has signed so called standard data protection clauses adopted by the EU Commission together with an assessment of whether the safeguards in the applicable standard contractual clause, in relation to the recipient’s country’s applicable law, grants the data subject its rights in accordance with GDPR.

Please contact us at support@firstvet.com if you want further information on what safeguards have been taken and if you want a copy of such safeguards.

6. HOW LONG DO WE KEEP YOUR DATA?

6.1 General

Notwithstanding anything to the contrary herein, FirstVet reserves the right to keep and process your personal data in accordance with this policy to the extent necessary to perform our contractual obligations to you, and to the extent we are required to process your data by law or in order to defend ourselves in a dispute, to prevent fraud or abuse, or to enforce our Terms and Conditions.

6.2 Service Customers

Your data may be saved for up to 18 months from your last activity with the service or on the website for direct marketing purposes, subject to your ongoing right to opt-out. Thereafter it shall be deleted, or be anonymized in order to be used for statistical purposes.

If you make a complaint FirstVet may save your data to the extent necessary to handle the complaint. FirstVet may also save the complaint information as such for the remaining period under which the Customer is entitled to make a complaint in order to prevent a Customer from filing two complaints and being compensated twice for the same defect.

6.3 E-commerce Customer

Your data may be saved for up to 18 months from your last activity with our e-commerce for direct marketing purposes, subject to your ongoing right to opt-out. Thereafter it shall be deleted, or be anonymized in order to be used for statistical purposes.

Your purchase history, i.e. your name, contact information and purchase data, will be stored during the return and exchange period for the purpose of administering returns and exchanges (i.e. not the complaint period).

If you have made a complaint, FirstVet may save your data to the extent necessary to handle the complaint. FirstVet may also save the complaint information as such for the remaining period under which you are entitled to make a complaint (i.e. three years after the purchase), in order to be able to avoid having you file two complaints and being compensated twice for the same defect.

6.4 Website Users

Your IP-address will be deleted no later than two weeks after your last visit on our website, or be anonymized in order to be used for statistical purposes. It is necessary for FirstVet to store the information for two weeks in order to produce event-logs in the event of security incidents.

6.5 Newsletter recipient

Your e-mail address will be deleted, or anonymized in order to be used for statistical purposes, when you chose not to receive FirstVet’s newsletter by enforcing your right to opt-out by clicking the link provided in each send out or by contacting FirstVet to inform us about your wish to stop receiving our newsletter.

7. YOUR DATA SUBJECT RIGHTS

In this section 7, we have summarized your data subject rights to request access, portability, rectification, erasure of your personal data, to restrict the processing of your personal data, to object to processing, and your right to lodge a complaint with the supervisory authority.

If you want to exercise your rights, please send us an e-mail to support@firstvet.com. Please note however that if you want to lodge a complaint with the supervisory authority, you need to contact the authority directly.

7.1 Right of access

You have the right to obtain confirmation of whether personal data concerning yourself is being processed and, where that is the case, access to the personal data and information regarding, inter alia, the purpose of processing, the categories of personal data concerned, the categories of recipients to whom your data have been or will be disclosed, and the envisaged period of time for which personal data will be stored (or the criteria for determining this).

7.2 Right of rectification

You have the right to request rectification of inaccurate personal data concerning yourself, and to complete incomplete data.

7.3 Right of erasure

Under certain circumstances you are entitled to request that we erase your personal data or restrict our processing of your data, namely in the following events.

(a) When it is no longer necessary for us to process your data taking into consideration the purposes for which it was collected.

(b) When our processing is based on your consent and you have withdrawn your consent, and there is no other legal basis for the processing of your data.

(c) When our processing of your data is based on a legitimate interest legal basis and you object to such processing, and there is no overriding legitimate ground for our processing.

(d) When you have objected to our processing of your data for direct marketing purposes.

(e) When your personal data has been unlawfully processed.

(f) When the personal data must be erased for compliance with a legal obligation that applies to us.

(g) When the personal data collected concerns a child (under 13 years of age) in relation to the offer of information society services.

7.4 Right to objection - direct marketing and profiling

You have the right to object at any time to our processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing. If you object to our processing of your personal data for direct marketing purposes, including profiling, we will cease such processing of your data.

7.5 Data portability

If our processing is based on your consent or if the processing is necessary for our performance of a contract with you, you have the right to request that the data which you have provided to us shall be provided to you in a structured, commonly used and machine-readable format and you also have the right to transmit such data to another controller.

7.6 Right to lodge a complaint with supervisory authority

Please note that if you consider the processing of your data to be in violation of applicable data protection laws, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or the place of the alleged infringement (see EU’s supervising authorities here).

8. HOW DO I UNSUBSCRIBE FROM FIRSTVET’S NEWSLETTERS AND E-MAILS?

If you no longer wish to receive our newsletters or other e-mails, you can unsubscribe as indicated in the particular communication, i.e. by using the unsubscribe link which is included in all newsletters and other e-mails. You may also contact us at support@firstvet.com.

9. IS IT MANDATORY TO PROVIDE PERSONAL DATA?

Certain personal data is required to provide in order for you to access certain services when, for example, you purchase an item online or use our services. In such cases provision of mandatory data is necessary for FirstVet to be able to fulfil our contractual obligation to you in accordance with applicable terms and conditions.

10. CHILDREN'S PRIVACY AND LEGAL PURCHASE AGE

FirstVet does not wish to collect personal information from anyone under the age of sixteen (16). If you are under eighteen (18), we require that you inform and get your parents’ or guardians’ consent before purchasing anything or provide any personal data to us at www.firstvet.com or any other website related to FirstVet.

11. COOKIES AND SIMILAR TECHNIQUES

We may use, apply and integrate different tools, beacons, pixels and similar components from third-party vendors for remarketing, re-engagement and similar audience features to reach Customers with ads on sites across the internet and measuring and analyzing User Data. This allows us to measure and analyze your use of FirstVet’s website, targeting ad campaigns, deliver commercial and transactional messages and to improve FirstVet’s website and marketing. We further use widgets and similar tools to support the service and its functions and/or communicate with you on our website and our app. Such tools and components may for example include Facebook Custom Audiences, Facebook Pixel, Google Analytics, Google AdWords, Google AdSense, Google+, Firebase, Hotjar and Instagram.

The third-party vendors, such as Facebook and Google, may include cookies and/or device identifiers to serve ads based on your visit to our website or use of our app. You can opt-out of these vendors’ use of cookies by visiting their respective website, the Network Advertising Initiative opt-put page or control the use of cookies in your device settings. Please read more about our use of cookies in our cookies policy, which can be found on our website.

12. CHANGES TO THIS POLICY

FirstVet reserves the right to occasionally make changes to our privacy policy or practices. We will post the updated policy on our website, and thus we encourage you to review this page from time to time.

Version 2022.1, last date for modification: 4 January 2022

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