Effective Date: March 2020
MANAGING YOUR INFORMATION PREFERENCES
INFORMATION WE COLLECT
We collect information that personally identifies you, such as your name, address, email address and other personally identifiable information when you sign up for the Sites or Services (“Personal Information”). The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or Services. In connection with your order to purchase Services, we collect credit card or other financial account information. We also collect Personal Information from you when you access the Services and/or other parts of the Sites and elect to provide Personal Information. For example, when you use the Services, we will collect data that you upload to the Sites and/or information or content that you input or otherwise submit into your account. This includes financial information and other information such as a client’s or an animal’s name, the name of the clinic or veterinary practice that you or other users are associated with, feeding information, registration papers, photos and any animal health or treatment information. It may also include video and audio footage that you record and upload to our Sites when you choose to share your stories or product reviews along with photos of your animals.
We may also offer the opportunity to participate in studies. If you participate in a study, we may provide a sampling kit for you to obtain a sample from your animal and return it to us. The sample will be anonymized and analyzed to determine health correlations across the sample population. This information may be shared with partners. If we received a specimen from your horse, we will receive your submission of a pea-size fecal sample from your horse, and will either send it to our service provider contract lab (your horse’s name, barcode, and fecal sample data are the only information shared with the lab), or process it in our in-house lab. We will compare your horse’s results to other samples, distance matrices and clustering based on various methodologies, aggregate and individual analyses of demographic and health-associated data. Residual material may be stored at our facility indefinitely. Information you share with us may become part of your horse’s medical record and through that route may be accessible to other veterinarians, and/or staff in the future.
We automatically collect information regarding the actions you take on the Sites and Services. For example, each time you use the Sites we may automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Sites. This information may be associated with your account. We may store such information itself and/or such information may be included in databases owned and maintained by Company affiliates, agents or Service Providers (as defined below). We may use such information and pool it with other information to track, for example, the total number of visitors to our Sites, or visitors to each page of our Sites. We use this information to help us understand how people use the Sites and Services, and to enhance the Sites and Services.
COOKIES, WEB BEACONS AND TRACKING CODE
We and our Service Providers may use the information that we collect about you (whether directly from you from our Sites, through your device(s), or from a third party) to help us and our Service Providers identify other devices that you use (e.g., a mobile phone, tablet, other computer). We, and our Service Providers also may use the cross-device and browser tracking and other information we learn about you to serve targeted advertising on your devices and to send you emails. To opt-out of cross-device and browser advertising, you may follow the instructions set forth in the Advertising section below. Please note: if you opt out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt out of each browser or device that you use.
HOW WE USE INFORMATION AND WHEN WE MAY SHARE AND DISCLOSE INFORMATION GENERALLY
We may use your information, including your Personal Information for the purpose for which it was provided or in the ways that you authorize, including without limitation for the purposes described further below:
Provision and Monitoring of the Services: We will use your Personal Information to provide you with access to and to support your use of the Services, to maintain or service your account, verify your information and to monitor your use of the Services. We will also give you the opportunity to store, review and edit Personal Information and other information on the Sites.
Order Fulfillment: We may use your Personal Information that you provide to fulfill any orders you may place for Services offered by Company.
Service Improvement: We may use your Personal Information, aggregated Personal Information and other non-personally-identifiable information collected through the Sites and Services to help us improve the content and functionality of the Sites, to better understand our users and to improve the Services. Provision of Information to Others: The Services allow you to grant others access to your information. We will grant access to whoever you authorize, so carefully consider your decision before choosing to allow someone access to any sensitive information.
Advertising and Marketing: We may use your Personal Information for marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also use the information that we learn about you to assist us in advertising our Services on other websites and to assist us in evaluating the success of our advertising campaigns in various platforms. In addition, with your permission, we may use the reviews you provide and photos of your animal in our advertising campaigns.
Studies: If you participate in a study, we may share information collected for purposes of the study. Unless the study invitation indicates otherwise, the information will be anonymized prior to sharing the information so that only aggregated anonymized data will be studied. For the microbiome study and Platinum Health® platform, we may invite researchers to access your horse’s information for the purpose of scientific research.
Surveys, Contests and Other Special Offers: From time to time, we may offer our users the opportunity to participate in loyalty programs, surveys, contests and other special offers. If you elect to participate in these services, you will need to provide certain Personal Information.
Questions and Requests: If you contact us by e-mail or otherwise, we will use the Personal Information you provide to answer your question or resolve your problem.
Contacting You About Other Products, Services and Events: If you opt-in, Company, our Service Providers and/or third parties may use your Personal Information to contact you in the future to tell you about products, services and events that may be of interest to you.
Research and Data Analysis: In an ongoing effort to better understand and serve the users of the Sites and the Services, Company may conduct research on and audit its customers’ demographics, interests and behavior based on usage data and other information provided to us. This data may be compiled and analyzed on an aggregate basis, and Company may share this data with researchers, advertisers, business partners, publications, and other third parties. This information will not identify you personally.
Security: We may use your Personal Information to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
From time to time, we may establish a business relationship with other businesses that we believe to be trustworthy and have privacy practices consistent with our requirements (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as development, bioinformatics, research analyses, hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use or disclosure.
Users in the United States may opt out of many Advertiser networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Sites or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info and the NAI’s website at www.networkadvertising.org.
We may share information with businesses controlling, controlled by, or under common control with Company. If Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets or equity, we may disclose or transfer your information in connection with such transaction.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
Company will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other content and information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property or rights of Company or of any other entity, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
BE CAREFUL WHEN YOU SHARE INFORMATION WITH OTHERS
Please be aware that whenever you share information on a publicly available page or any other public forum on the Sites or Services, others may access that information. In addition, please remember that when you share information in any other communications with other entities, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of Personal Information and other information transmitted to us. We attempt to keep our Sites and Services optimized for current browsers and you should always keep your browsers updated. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Sites or Services, we cannot and do not guarantee the security of any information you transmit on or through the Sites or Services, and you agree that you do so at your own risk.
We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.
PROCESSING IN THE UNITED STATES
Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that the laws in the United States may not be as protective of your privacy as those in your location. By using our Sites or Services, you agree that the applicable laws in the United States will govern the collection, use, transfer, and disclosure of your Personal Information and communications.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at 512-401-8458 or email us at firstname.lastname@example.org
COLLECTION, USE, DISCLOSURE AND SALE OF PERSONAL INFORMATION
Our collection, use and disclosure of personal information will vary depending upon the circumstances and nature of our interactions or relationship with you. Below we identify the categories of personal information we collected about consumers, as well as how we have sold or disclosed for a business purpose such information in the prior 12 months. For more information about the business and commercial purposes for which we collect.
|PERSONAL INFORMATION COLLECTEDCATEGORIESDESCRIPTION||DO WE DISCLOSE THIS INFORMATION?||CATEGORIES OF OTHER ENTITIES TO WHOM WE MAY DISCLOSE THIS INFORMATION|
|Identifiers||Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers.||YES||service providersadvisors and agentsadvertising networksdata analytics providersoperating systems and platforms|
|Customer Records||Includes personal information, such as name, account name, user ID, contact information, education and employment information, tax ID, and financial or payment information), that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services.||YES||service providersadvisors and agentsoperating systems and platforms|
|Commercial Information||Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers.||YES||service providersadvisors and agentsaffiliates and subsidiariesdata analytics providerssocial networksoperating systems and platformsbusiness customer/client|
|Usage Data||Includes browser and operating system data, browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, and other services, and our marketing emails and online ads.||YES||service providersadvisors and agentsadvertising networksdata analytics providerssocial networksoperating systems and platformsbusiness customer/client|
|Audio, Video and Electronic Data||Includes audio, electronic, visual, similar information such as, photographs, videos and images (e.g., that you provide us or post to your profile).||YES||service providersadvisors and agentsadvertising networksdata analytics providerssocial networksoperating systems and platformsbusiness customer/client|
|Professional information||Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).||YES||service providersadvisors and agentsadvertising networksdata analytics providerssocial networksoperating systems and platformsbusiness customer/client|
|Education Information||Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).||YES||service providersadvisors and agentsdata analytics providersoperating systems and platformsbusiness customer/client|
|Inferences||Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.||YES|
- Identifiers such as name, alias user ID, username, unique personal identifier; address and other contact information; IP address and other online identifiers; and other similar identifiers to third party advertising networks and data analytics providers.
- Usage Data such as browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, , and our marketing emails and online ads to third party advertising networks and data analytics providers.
We do not sell personal information about consumers who we know are younger than 16 years old.
SOURCES OF PERSONAL INFORMATION
As further described in the Information We Collect section above, we may collect personal information from the following sources:
- directly from the individual
- advertising networks
- data analytics providers
- social networks
- operating systems and platforms
- business customers
TEXAS – SECTORAL PRIVACY OVERVIEW
Requests to Know and to Delete
If you reside in Texas, subject to certain exceptions and conditions, you have the following rights:
- Right of deletion: to request deletion of your personal information that we have collected about you and to have such personal information deleted (without charge).
- Right to know: with respect to the personal information we have collected about you in the prior 12 months, to require that we disclose the following to you (up to twice per year).
- Specific pieces of personal information that we have collected about you;
- Categories of personal information we have collected about you;
- Categories of sources from which the personal information is collected;
- Categories of personal information that we sold or disclosed for a business purpose about you;
- Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling personal information.
You can read the detailed Texas Sectoral Privacy laws here.
You can submit the requests above by emailing us at email@example.com or by calling our 512-401-8458. When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information that you provide with the information we have in our records, including your phone number, email address, city and state. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. We will respond to you within the timeframe required by law. If you are an agent submitting the request on behalf of a Texas consumer, please call our toll-free number at 512-401-8458 or email us at firstname.lastname@example.org. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
RIGHT TO OPT-OUT OF SALES
Texas consumers have the right to opt-out of the sale of their personal information. To exercise your opt-out rights, please call our toll-free number at 512-401-8458 or email us at email@example.com