Privacy & Cookie Policy

VetSOS Ltd Privacy Policy

VetSOS Ltd is committed to protecting and respecting the privacy of our employees, our clients and third parties such as, but not limited to, poorly pet (“Patient”) owners and second opinion vets. This policy explains when and why we collect data about your practice, personal information about your staff and your clients both from our website and through various communication channels such as, but not limited to, – telephone, email, WhatsApp, social media platforms etc.  Our privacy policy explains how we use your data, the conditions under which we may disclose it to other parties and how we keep it secure.

We may update this policy from time to time so it is important that you check policy (via our website www.vetsos.co.uk  regularly to ensure you are happy with any changes.  If you have any questions about our privacy policy please contact us by email to [email protected] . We may notify you by email of any changes to this policy.

Who are we?

VetSOS Ltd is a private limited company registered in England and Wales under company number 09152815. Registered Address: Column House, London Road, Shrewsbury, Shropshire, SY2 6NN. UK. We are registered for VAT purposes with registration number 200171675.

Lawful basis allowing VetSOS Ltd to process data

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the UK General Data Protection Regulations (UK GDPR) which means all legislationand regulatory requirements in force from time to time relating to the use of personal data and the privacy of electronic communications, including, without limitation (i) any data protection legislation from time to time in force in the UK including the Data Protection Act 2018 or any successor legislation, as well as (ii) the General Data Protection Regulation ((EU) 2016/679) , (iii) the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (DPPEC Regulations), SI 2019/419, (iv) the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020, SI 2020/1586 and any other directly applicable European Union regulation relating to data protection and privacy as amended by UK law (for so long as and to the extent that the law of the European Union has legal effect in the UK). Where used in this policy the terms data controller, personal data and data subject shall have the meaning ascribed to them by GDPR or the Data Protection Act 2018, whichever is in effect from time to time.

Organisations, companies and individuals are permitted to gather, securely store and process data if they have a legal basis for doing so.  We have a legitimate interest in processing data in order to fulfil the contract we have entered into with you and in fulfilling our duty of care to you and your clients and providing you with the best service we can offer. Collecting data enables us to provide veterinary services to the host practice clients, with whom we have entered into a contract.  Collection of data allows us to enhance and personalise the services we offer for the benefit of the host practice and their Patient owners.

Our collection and use of your personal information

We collect personal information about you when you access our website, register with us, contact us, send us feedback, purchase products or services, post material to our website and complete customer surveys.

We collect this personal information from you either directly, such as when you register with us, contact us or purchase products or services or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).

The personal information we collect about you depends on the activities carried out. This information includes information relating to you as well as third parties including but limited to a Patient and a Patient owner:

  • your name, address and contact details
  • date of birth
  • gender
  • employment details
  • bank account and payment details
  • details of any feedback you give us by phone, email, post or via social media
  • information relating to the services we provide to you including Patients’ relevant medical and health data
  • information, emails and records of telephone conversations and other interactions relating to our transactions with you
  • your account details, such as username, login details
  • records of use of and movements through any online portal, passwords, personal identification numbers, IP addresses and other IT system information  (subject to your consent to our cookie policy in certain cases), geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use
  • your marketing preferences

We use this personal information to:

  • create and manage your account with us
  • verify your identity
  • provide goods and services to you and Patients’ owners
  • customise our website and its content to your particular preferences
  • notify you of any changes to our website or to our services that may affect you
  • improve our services

We do not knowingly collect or use personal information relating to children and any children accessing our site must be supervised by an appropriate adult such as a parent or guardian.

Our legal basis for processing your personal information

We are a data controller and data processor.

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

consent: where you have given us clear consent for us to process your personal information for a specific purpose (including career opportunities). Also, for us to send you direct marketing, news and information about us and our products and services in accordance with the preferences you select when you sign up to receive updates or purchase products or services. You may withdraw this consent by emailing us at [email protected]

contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract. This includes dealing with your purchase of products or services from us including delivery, management of our business, reminders for appointments, follow up consultations, treatments and record keeping

legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)

legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests). This may include sending communications to you which are relate to the type of product or service supplied to you and also to better direct marketing relating to other things (subject to you having consented to this) in order to ensure any communications are relevant to you. Also, Patient care advice and news about us which may affect you, request feedback or completion of a survey regarding our services.

Throughout the performance of the services we may work with host clinics and other third parties. These other third parties may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party, please consult their privacy policies as appropriate. Where we are supplied with data by a third party we will comply with their privacy policies as appropriate.

Marketing

We would like to send you further information aboutproducts and services and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

—contacting us at [email protected]

—using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

—updating your marketing preferences in your account with us.

It may take up to 7 days for this to take place.

For more information on your rights in relation to marketing, see ‘Your rights’ below.

Correspondence data


We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website may generate the metadata associated with communications made using the website contact forms.  Correspondence data may be processed for the purposes of communicating with you and record-keeping.


The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

Payment data


We may process payment information relating to goods and services that you purchase from us (“payment data”). The payment data may include your contact details, your card details, details pertaining to your accounting systems, your invoices and the transaction details. The payment data may be processed for the purposes of administering the payment, for the supply of the purchased goods and services, and keeping proper legally required records of those payments. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

Employment data

We may process information that you provide to us in connection with job vacancies and opportunities (“employment data”). This employment data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, employment history, immigration status, salary, curriculum vitae, job preferences and employment details.


We may also process your employment data in relation to job vacancies that you have applied for, generally processing any job applications, and facilitating the recruitment process. The legal basis for this processing is our legitimate interests in finding an appropriate person for a particular role.
Employment data we might collect may include payment details, medical and health information, and other information that may be generated during the course of your employment such as flexible working requests and appraisals. The legal basis for this processing is for the performance of our employment contract with you.


We may also collect and process information regarding your criminal record. We may only use information relating to criminal convictions where the law allows us to do so (this will usually be where such processing is necessary to carry out our obligations, for instance where we are required to carry out criminal record checks for particular roles), or where you have consented for us to do so.


Other processing activities


In addition to the specific purposes for which we may process your data, we may also process any of your personal data or data you have provided to us regarding your client, pet owner or Patient where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
When we receive data from third parties we shall only accept and retain such data if we have good, sensible , practical reasons for processing personal data which is in our interests. We shall only collect and retain personal data supplied by third parties such as host clinics for the required period and if you are a supplier of data we will not accept personal data unless we have specifically requested it.

Providing your personal data to others

We may disclose your personal data to referral hospitals and laboratories insofar as reasonably necessary to ensure the health welfare of animals committed to our care. We may disclose your personal data, including bank details, to bacs approved direct debit collection bureaus.

Our insurers/professional advisers


We may disclose your personal data to our insurers, professional advisers and the debt collection agency we instruct insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

For administrative services or staff benefits


We may disclose employee personal data to third parties such as those administering our payroll system or staff benefits (this will include the providers of pension schemes).

Where we provide your personal data to any third party we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party.

To comply with legal obligations


In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.

Transfer of your information out of the UK and EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, eg:

with your and our service providers located outside the UK/EEA;

if you are based outside the UK/EEA;

where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:

the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);

there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or

a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using approved standard contract clauses.

To obtain a copy of any standard contract clauses which we currently use (if any) and further information about relevant safeguards please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg:

you have explicitly consented to the proposed transfer after having been informed of the possible risks;

the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;

the transfer is necessary for a contract in your interests, between us and another person; or

the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

If you would like further information please contact our Data Protection Officer (see ‘How to contact us’ below).

We will not otherwise transfer your personal data outside of the area comprising the UK and EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

How long do we store your data?

We regularly review our data retention periods for personal information.  Any personal data that we process for any purpose or purposes is not kept for longer than is necessary for that purpose or those purposes. As far as possible, we will always minimise the data that is held about you.

Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:

  • Contact data for each of your Patients and their owners will be retained for 7 years following the date of our last contact or dealing with them, at the end of which period it will be deleted from our systems. We are required to retain this data for at least 5 years for regulatory reasons. In our experience, retaining this data for longer allows us to provide better care of the Patient over the course of its lifetime. We will retain data supplied by host clinics in so far as it is relevant and reasonably required for supplying services and for a period of 7 years after the last service provided by us. This is both for regulatory reasons and in order to provide a seamless and better service.
  • Where enquiry data includes information relating to the Patient’s health or clinical treatment, it will be retained for 7 years following the date of our last contact or dealing with the Patient, at the end of which period it will be deleted from our systems. We are required to retain this data for at least 5 years for regulatory reasons. In our experience, retaining this data for longer allows us to provide better care to your pet over the course of its lifetime. Otherwise, enquiry data will be retained for 2 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
  • Where correspondence data includes information relating to the Patient’s health or clinical treatment, it will be retained for 7 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems. We are required to retain this data for at least 5 years for regulatory reasons. In our experience, retaining this data for longer allows us to provide better care to the Patient over the course of its lifetime. Otherwise, correspondence data will be retained for 2 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.  We will also hold correspondence data of your client (the pet owner) for a period of 7 years in order to help with better, follow up care for the Patient.
  • For regulatory purposes, payment data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
  • Website data will be retained for 2 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
  • Employment data will be retained for 2 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

How do we use your information and the information of your client?

We may use your information to:

  • Process requests that you have submitted
  • Contact you or your client about the Patient’s treatment
  • Contact you about promotions or offers, although we will not contact your client with such offers or promotions
  • Carry out our obligations arising from any contracts entered between you and us
  • Seek your views or comments on the services we provide
  • Notify you of changes to our services
  • Send you communications, which you have requested, and that may be of interest
  • Process a cv application
  • To carry out analysis, improve the quality of our services and ensure that content from our site is presented in the most effective manner for you and for your computer
  • Training and security purposes
  • To track use of web pages

Disclosure of your information


We will not sell or rent your or your client’s information to third parties.
We will not share your or your client’s information with third parties for marketing purposes.

With your consent we may use your information for:

  • Reminders, surveys, notifications and other information that may be of interest to you via email, text or mail.
  • Receipt of marketing information via email, text or mail.
  • Electronic appointment reminders, recommendations and recalls.

When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. These include delivery companies, suppliers of materials and clinics. We will not release your information to third parties unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Personal data will not be used or retained for any purposes other than those which are relevant to the Patient’s pre operative care and post operative follow up care. We will not release personal data to third parties unless we are required to do so in order to perform the services or by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Where do we store your data?

Our servers are maintained in London by our hosting company 20i LTD. You understand that data stored on their servers may be subject to lawful requests by the courts or law enforcement authorities in the United Kingdom. You can read 20i LTD’s privacy policy here: https://www.20i.com/legal/20i-ltd-privacy-policy

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Your rights

Under the UK GDPR you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information.
  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address.
  • require us to correct any mistakes in your information which we hold.
  • require the erasure of personal information concerning you in certain situations.
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations.
  • object at any time to processing of personal information concerning you for direct marketing.
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
  • object in certain other situations to our continued processing of your personal information.
  • otherwise restrict our processing of your personal information in certain circumstances.
  • claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the UK GDPR.

If you would like to exercise any of those rights, please:

email, call or write to our data protection officer

let us have enough information to identify you (eg account number, user name, registration details),

let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill) if we believe it is necessary to identify you, and

let us know the information to which your request relates including any account or reference numbers, if you have them

Our details

VetSOS Ltd:  Column House, London Road, Shrewsbury, Shropshire, SY2 6NN. UK

Email: [email protected]

The website www.vetsos.co.uk remains the property of VetSOS Ltd 09152815

Links to other websites


Our website may contain links to other websites run by other organisations. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.
If you linked to our website from a third-party site, we cannot be responsible for the privacy practices of the operators of that third-party site and recommend that you check their policy.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies, web beacons, action tags, single pixel gifs on our website. These help us to recognise you and your device and store some information about your preferences or past actions.

For further information on our use of cookies, web beacons, action tags, single pixel gifs or similar technologies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].

How to contact us

Please contact our Data Protection Officer, if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact our Data Protection Officer, please send an email to [email protected] or write to VetSOS Ltd, C/O Azets Column House, London Road, Shrewsbury, Shropshire, SY2 6NN, UK.

Do you need extra help?

If you would like this website privacy policy in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).

Links:

www.vetsos.co.uk contains links to other web sites. Please note that when you click on one of these links, you are moving to another web site. We encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours.