Privacy Policy

Last updated: 2020-08-21

FirstVet, Inc., a Delaware corporation (the “Corporation”) respects the privacy of others. This Privacy Policy (this “Privacy Policy”) explains the Corporation’s privacy practices for the Corporation website located at www.firstvet.com (together with its pages and features, “Site”) and mobile software application (together with its pages and features, “App”) by providing you and any person helping you visit, access, register with or use the Site and/or the App (collectively, “you” or “your”) with an overview of the following:

This Privacy Policy applies to information collected through the Site and/or the App. Please carefully read this Privacy Policy in its entirety.

When you create, register or log into an account through the Site or the App, you are automatically accepting and agreeing to the most recent version of this Privacy Policy, as well as the Site’s and the App’s Terms and Conditions.

Similarly, by visiting, accessing or using the Site or the App, you are automatically accepting and agreeing to the most recent version of this Privacy Policy, as well as the Site’s and the App’s Terms and Conditions, and your continuing visit, access or use of the Site or the App reaffirms your acceptance and agreement in each instance.

As used herein, the term “personal information” means information that relates to an identified or identifiable individual (e.g., your name, physical address, telephone number, email address, social security number); and the term “non-personal information” means any information other than personal information that the Corporation may collect from you, such as anonymized data.

1. A Special Note About Minors.

The Site is a general audience website intended for use by adults. Neither the Site nor the App is designed or intended to attract, and is not directed to, children under eighteen (18) years of age, let alone children under thirteen (13) years of age. The Corporation does not collect personal information through the Site or the App from any person it actually knows to be under thirteen (13) years of age. If the Corporation obtains actual knowledge that it has collected personal information through the Site or the App from a person under thirteen (13) years of age, then it will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under eighteen (18) years of age, then you (or your parent or legal guardian) may at any time request that the Corporation remove content or information about you that is posted on the Site or the App. Please submit any such request (a “Request for Removal of Minor Information”) to any one of the following:

By mail: FirstVet, Inc., [List Preferred Mailing Address], with a subject line of “Removal of Minor Information.”

By email: [List Designated Email Address], with a subject line of “Removal of Minor Information.”

For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body:

a. The nature of your request;

b. The identity of the content or information to be removed;

c. Whether such content or information is found on the Site or the App;

d. The location of content or information on the Site or the App (e.g., provide the URL for the specific web page the content or information is found on);

e. That the request is related to the “Removal of Minor Information;”

f. Your name, street address, city, state, zip code and email address; and

g. Whether you prefer to receive a response to your request by mail or email.

If you send a Request for Removal of Minor Information by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking. The Corporation will not accept any Request for Removal of Minor Information via telephone or facsimile. The Corporation is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site or the App.

Also, please note that the Corporation is not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires the Corporation to maintain the content or information; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when the Corporation anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of the Corporation’s voluntary practices concerning the collection of personal information through the Site from certain minors, and is not intended to be an admission that the Corporation is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

2. Categories of Information Collected.

The Corporation may collect personal and non-personal information about you through the Site, the App, and/or any electronic medical record platforms lawfully accessed and used by the Corporation Depending upon your use of the Site and/or the App, the following is a list of the various categories of information that may be collected about you:

    1. Categories of Information Collected Through the Site and/or the App. The categories of personal and non-personal information collected from you through the Site and/or the App might include your:
      1. Name (first, last and/or middle) and unique identifiers (e.g., username);
      2. Login information for the Site and/or the App (e.g., username, password, security questions and answers);
      3. Home contact information (e.g., mailing address, email address, telephone number, fax number);
      4. Gender;
      5. Date of birth;
      6. Electronic signature;
      7. Photographic or video image to the extent provided by you to the Corporation;
      8. Pet health information, including the results of any questionnaires, surveys, information requests, interviews, or other documentary, text, video, or audio interactions related to the provision of veterinarian health services;
      9. Billing, payment, insurance, and/or shipping information (e.g., payor or payee name, checking account number, credit card number, expiration date, verification code, accountholder name, cardholder name, billing address, mailing address, tax ID number, billing history, insurance identification and policy numbers);
      10. Business contact information (e.g., company, title, mailing address, email address, telephone number, facsimile number, tax ID number);
      11. Computer, mobile device, and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/existing web pages, web page requests, cookie information, hardware attributes, software attributes);
      12. Third-party website, network, platform, server and/or application information (e.g., Facebook, Twitter, Instagram);
      13. Usage activity concerning your interactions with the Site, the App and/or third-party websites, networks, platforms, servers or applications accessed through the Site and/or the App (e.g., number of clicks on a page or feature, amount of time spent on a page or feature, identity of third-party websites, networks, platforms, servers and applications being accessed through the Site and/or the App);
      14. Usage activity concerning products and services provided to or accessed by you on or through the Site and/or the App (e.g., viewing habits, viewing preferences, viewing history, title selections, favorites, streams, downloads, demographics and closed captioning selections);
      15. Transactional information (e.g., offers, orders, pricing, payments, purchaser, seller, item information, shipping terms, comments, ratings, feedback and instant messages and/or other communications made within or through the Site and/or the App);
      16. Information about third parties that you refer to the Corporation (e.g., name, email and/or other contact information, relationship);
      17. Information set forth in the Site’s and/or the App’s online account registration, subscriber profile, and/or subscriber directory forms completed by you; and/or
      18. Statements or content (e.g., comments, videos, photographs, images), and information about such statements or content, which you submit or publish on or through the Site and/or the App, or which are accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram).
    2. Categories of Other Information Collected From Your Mobile Device. If you use your mobile device to visit, access or use the Site or the App, then additional categories of personal and non-personal information collected from you through the Site and/or the App might include:
      1. Your name associated with your mobile device;
      2. Your telephone number associated with your mobile device;
      3. Your geolocation;
      4. Your mobile device ID information;
      5. With your express consent, your contacts and/or contact information (e.g., names, telephone numbers, physical addresses, email addresses, photos) stored on your mobile device; and/or
      6. With your express consent, information about third-party software applications on your mobile device (including, without limitation, general software apps, downloadable software apps, social media apps).

3. How Information Is Collected.

Depending upon your use of the Site and/or the App, the Corporation might collect personal and non-personal information from you when you visit, access or use the Site and/or the App; when you register with or subscribe to the Site and/or the App; when you register for or subscribe to the products and/or services of the Corporation online through the Site and/or the App; when you register for or subscribe to the products and/or services of the Corporation online through the Corporation Pages or, if applicable, other areas of the Site or the App; when you “sign in,” “log in,” or the like to the Site and/or the App; when you allow the Site and/or the App to access, upload, download, import or export content found on or through, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access or use the Site and/or the App) or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, your mobile device service provider); or whenever the Corporation asks you for such information, such as, for example, when you process a payment through the Site and/or the App, or when you answer an online survey or questionnaire.

In addition, if you or a third party sends the Corporation a comment, message or other communication (such as, by way of example only, email, letter, fax, phone call, or voice message) about you or your activities on or through the Site and/or the App, then the Corporation may collect any personal or non-personal information provided therein or therewith.

Finally, the Corporation might use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:

Please be advised that if you choose to block, reject, disable, delete or change the management settings for any or all of the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies, then certain areas of the Site and/or the App might not function properly.

By visiting, accessing or using the Site and/or the App, you acknowledge and agree in each instance that you are giving the Corporation permission to monitor or otherwise track your activities on the Site and/or the App, and that the Corporation may use the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies.

4. Use of Information Collected.

The Corporation may use the personal and/or non-personal information it collects from you through the Site and/or the App in a variety of ways, such as, for example, to:

The Corporation reserves the right to use your personal and non-personal information when:

5. Disclaimer of HIPAA Applicability.

The Corporation is not a “covered entity” as defined in the federal medical record privacy statute known as the Health Insurance Portability and Accountability Act of 1996, as amended, and the regulations issued under that law (“HIPAA”). Additionally, with respect to the personal information we will obtain about you, we are not a “business associate” under HIPAA. Therefore, even though your personal information contains medical information that is the type of information commonly protected under HIPAA, it is not subject to any of the protections available to you under HIPAA. HIPAA is inapplicable to our relationship with you.

6. Disclaimer of CCPA Applicability.

The Corporation is not subject to regulation under the California Consumer Privacy Act of 2018 (“CCPA”). Therefore, even if you are a California resident and we may have personal information about you that is the type of the information subject to the CCPA, the CCPA is not applicable to the Corporation or to our relationship with you.

7. Sharing of Information Collected.

The Corporation may share your personal information with the Corporation’s employees, agents, administrators, accountants, financial advisors and legal advisors; with the Corporation’s affiliates and their respective employees, agents, administrators, accountants, financial advisors and legal advisors; with the Corporation’s employed or contracted doctors, nurses and other providers, along with non-Corporation providers who might also provide you with health- or healthcare-related services; with pharmacies or other vendors that may fill your prescription drugs or other product orders; and with those third parties who help manage, administer distribute and/or operate the Site, the App, and/or their respective products, services and/or features (e.g., web hosting companies, website administrators, mobile app distribution platforms, support services companies, credit card or other payment processing companies), as needed in order for them to perform such services.

In certain cases, the Corporation may be required to disclose personal information to investigate, prevent, or take action concerning: (1) legal requests; (2) the enforcement of our Terms and Conditions; (3) the protection of our rights, property, or personal safety or the rights, property, or personal safety of our users and the public; (4) our exercise of legal rights; and (5) any other disclosure required by law.

The Corporation does not limit the ways in which it may use or share non-personal information because non-personal information does not identify you. For example, the Corporation may freely share non-personal information with its affiliates, suppliers and representatives, as well as with other individuals, businesses, and government entities.

You may choose to share certain information and/or follow other users on the Site and/or the App. You may choose to share your contact information with other users or provide it publicly.

8. Data Retention.

The Corporation may retain your personal information and non-personal information for as long as it believes necessary; as long as necessary to comply with its legal obligations, resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with the products and/or services of the Site, the App, and/or the Corporation The Corporation may dispose of or delete any such personal information or non-personal information at any time, except as set forth in any other agreement or document executed by the Corporation or as required by law. Notwithstanding the foregoing and for the avoidance of doubt, the Corporation may not retain your personal information and non-personal information for any periods of time longer than is permitted by applicable law (including, without limitation, in consideration of any requirements to destroy personal information and/or non-personal information after a reasonable period following the time that any such information is no longer needed for a business purpose under the SHIELD Act or any other applicable federal or state law).

9. Transactions.

In connection with any transaction that you conduct through the Site and/or the App (e.g., the payment of any subscription fees, the purchase or sale of any products on or through the Site and/or the App), you may be asked to supply certain information relevant to the transaction, including, without limitation, your credit card number and expiration date, your billing address, your shipping address, your phone number and/or your email address. By submitting such information, you consent to the Corporation providing such information to third parties (e.g., payment processing companies, buyers on the Site and/or the App, sellers on the Site and/or the App) for the purpose of facilitating the transaction.

All credit card, debit card and other monetary transactions on or through the Site and/or the App occur through an online payment processing application(s) accessible through the Site and/or the App. This online payment processing application(s) is provided by the Corporation’s third-party online payment processing vendor, Stripe (“Stripe”). Additional information about Stripe, its privacy policy and its information security measures (collectively, the Stripe Policies”) should be available on the Stripe website located at https://stripe.com/privacy or by contacting Stripe directly. Reference is made to the Stripe Policies for informational purposes only and they are in no way incorporated into or made a part of this Privacy Policy.

10. Third Party Applications and Networks.

The Site, the App, and/or any communications sent through or as a function of the Site and/or the App may contain links to third-party websites, networks, platforms, servers and/or applications.

You may have the opportunity to access the Site and/or the App using your online user accounts with certain third-party websites, networks, platforms, servers or applications, which may be subject to separate privacy policies pertaining to those third-party websites, networks, platforms, servers or applications. The Corporation may also collect information from those third-party websites, networks, platforms, servers or applications (such as, for example, your name, gender, date of birth and personal interests, when you “like” or click links provided by or through those third-party websites, networks, platforms, servers, or applications and other information available through your online account or page with those third-party websites, networks, platforms, servers or applications). You should carefully review the relevant terms of use and privacy policies associated with third party websites, networks, platforms, servers, and applications.

11. Security.

The Corporation implements security measures to help protect the personal information it collects through the Site and the App. To the extent applicable, the Corporation may also encrypt the transmission of information through the Site by using secure socket layer (SSL) technology.

To help maintain the security of your personal information, the Corporation asks that you please notify it immediately of any unauthorized visit, access or use of the Site and/or the App, or the loss or unauthorized use of your user access information for the Site and/or the App (e.g., username or password).

12. Retention, Review, and Change of Information Collected.

You may request at any time that the Corporation provide you with an opportunity to review and change your personal information collected through the Site or the App or to no longer use your personal information to provide you with any products or services. Please submit any such request (a “Request Concerning Personal Information”) to any one of the following:

By mail: FirstVet, Inc., 900 3rd Ave 29th floor, New York, NY 10022, with a subject line of “Your Personal Information.”

By email: support-us@firstvet.com, with a subject line of “Your Personal Information.”

For each Request Concerning Personal Information, please state “Your Personal Information” in the email or letter subject line, and clearly state the following in the body:

a. The nature of your request;

b. That the request is related to “Your Personal Information;”

c. Your name, street address, city, state, zip code and email address; and

d. Whether you prefer to receive a response to your request by mail or email.

If you send a Request Concerning Personal Information by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking. The Corporation will not accept a Request Concerning Personal Information via telephone or facsimile. The Corporation is not responsible for any Request Concerning Personal Information that is incomplete, incorrectly labeled, or incorrectly sent.

You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

13. Your California Privacy Rights.

If you are a resident of the State of California and the Corporation has an established business relationship with you, then, pursuant to Section 1798.83 of the California Civil Code, you have the right to request the following at any time: (a) information from the Corporation, free of charge, regarding the manner in which the Corporation shares certain personal information collected through the Site and/or the App with third parties who use such information for direct marketing purposes; and (b) the discontinuation (or opt-out) of the Corporation’s sharing of such information with such third parties. Please submit any such request (a “California Privacy Rights Request”) to any one of the following:

By mail: FirstVet, Inc., 900 3rd Ave 29th floor, New York, NY 10022, with a subject line of “Your California Privacy Rights.”

By email: support-us@firstvet.com, with a subject line of “Your California Privacy Rights.”

For each California Privacy Rights Request, please state “Your California Privacy Rights” in the email or letter subject line, and clearly state the following in the body:

a. The nature of your request;

b. That the request is related to “Your California Privacy Rights;”

c. Your name, street address, city, state, zip code and email address; and

d. Whether you prefer to receive a response to your request by mail or email.

If you send a California Privacy Rights Request by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking. The Corporation will not accept a California Privacy Rights Request via telephone or fax; and is not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled or incorrectly sent.

You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

Further, the Corporation does not respond to “do not track” (DNT) signals.

Finally, as explained further above, the Corporation does not authorize third parties to collect your personal information when you use the Site or the App, except as expressly stated in this Privacy Policy. To the fullest extent permitted by law, the Corporation is not responsible for, and you hereby release the Corporation from any and all liability which may arise from, such third parties’ unauthorized collection of your personal information.

14. Users in the EU, EEA, UK, and Switzerland.

Data Controller

The Corporation is the data controller of the personal information collected and processed through your use of the Site and/or the App.

You may contact us by mail, by email, or by telephone.

By mail: FirstVet, Inc., 900 3rd Ave 29th floor, New York, NY 10022, with a subject line of “Your GDPR Rights.”

By email: support-us@firstvet.com, with a subject line of “Your GDPR Rights.”

By telephone:

Purposes of Processing and Legal Basis for Processing

As explained above, we process personal information in various ways depending upon your use of our Site and/or App. We process personal information on the following bases: (1) with your consent; (2) as necessary to perform a contract when you request services; and (3) as necessary for our legitimate interests in providing you with our products and services, enhancing our web services, conducting analytics, and delivering relevant advertising.

Your Rights Regarding Personal Information

a. Access and Confirmation. You have the right to ask us if we process personal information about you, and in some circumstances, to obtain a copy of your personal information.

b. Deletion and Blocking. Under certain circumstances, you may have the right to have your personal information deleted or blocked without undue delay.

c. Direct Marketing. You have the right to object to our processing of your personal information for direct marketing purposes.

d. Consent. To the extent we are processing personal information on the basis of your consent, you have the right to withdraw consent at any time.

e. Data Portability. Under certain circumstances, to the extent we are processing your personal information on the basis of consent, or that it is necessary to perform a contract with you, and the processing is carried out by automated means, you have the right to receive the personal information in a structured, commonly used and machine-readable format.

To exercise the rights set forth above in subsections a-e, please contact us at support-us@firstvet.com.

f. Right to Lodge a Complaint. You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority in your country.


Transfers

We are headquartered in the United States of America. Personal information may be accessed by us or transferred to us in the United States. The European Commission has not determined that the United States ensures an adequate level of protection for personal information.

By providing us with personal information, you consent to the storage or processing of your personal information in the United States and acknowledge that the personal information will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your personal information.

We will protect the privacy and security of personal information according to this Privacy Policy, regardless of where it is processed or stored.

15. Modifications of this Privacy Policy.

We regularly review and revise our Privacy Policy. We make changes to the Privacy Policy available on this page and note that the policy has been updated. If we make material changes to how we treat your personal information, we will notify you by email to the primary email address specified in your account and through a notice on our home page.

16. Mergers, Acquisitions, and Other Business Transactions

The Corporation may decide to sell, buy, merge, or otherwise reorganize its business. If that occurs, you will be notified via email or a prominent notice on our website of any ownership change and any changes in the use of your personal information. These types of transactions may involve the disclosure of personal information to prospective or actual purchasers, or receiving it from sellers. We seek appropriate protection for personal information in these types of transactions.

17. Severability.

If any term or condition of this Privacy Policy is deemed invalid or unenforceable by a court of law with binding authority, then the remaining terms and conditions shall not be affected, and the court shall reform the invalidated or unenforceable term or condition to the maximum extent permitted under the law and consistent with the intent of this Privacy Policy.

18. Contact Us.

Please direct any questions you may have about this Privacy Policy, the Site or the App to any one of the following:

By mail: FirstVet, Inc., 900 3rd Ave 29th floor, New York, NY 10022, with a subject line of “Privacy Policy.”

By email: support-us@firstvet.com, with a subject line of “Privacy Policy.”

The foregoing contact information may change from time-to-time by supplementation, amendment, or modification of this Privacy Policy.

Modification Date.

This Privacy Policy was last modified on 8/21, 2020.