Privacy Notice
PET RECORDS LIMITED (ALSO TRADING AS BOOP™)
Updated 12/12/24
INTRODUCTION
Welcome to our privacy notice!
We respect your privacy and are committed to protecting your personal data. This privacy notice tells you about how we collect, use and look after your personal data when you download and use our Boop™ application, or when you visit our website at www.booppet.app. It also tells you about your privacy rights and how the law protects you.
Our website, products and services are not intended for children, and we do not knowingly collect data relating to individuals under 18 years old.
We keep this privacy notice under regular review. This version was last updated on 12 – Dec – 2024.
You can easily navigate your way through this privacy notice using the following headings:
1. Important information and who we are
2. The PERSONAL data we collect about you
3. How WE COLLECT your personal data
4. SHARING YOUR DATA WITH THIRD PARTIES
5. TRANSFERRING YOUR DATA INTERNATIONALLY
1. Important information and who we are
Controller
Pet Records Limited (company number 15678740) is the so-called controller of your personal data and is therefore responsible for it under the law (referred to as "we", "us" or "our" in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your privacy rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy notice or our privacy practices, or if you wish to exercise your privacy rights, please contact us in the following ways:
Email address: dpo@petrecords.co.uk
Postal address: 85 Great Portland Street, First Floor, London, England, W1W 7LT
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance so that we can help to address your concerns.
Your duty to tell us about any changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our Boop™ application and website may include links to third-party websites, plug-ins and applications.
Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy notices. When you leave our application or website, we encourage you to read the privacy notice of every website you visit.
2. The PERSONAL data we collect about you
Personal data, or personal information, means any data/information about an individual that directly or indirectly identifies them. It does not include data/information where the identity has been removed (i.e., anonymous data).
We may collect, use, store and transfer distinct kinds of personal data about you which we have grouped together as follows:
· Identity Data - first name, last name, previous names, username or similar identifier, marital status and title (for employees of veterinary practices using our Boop™ application, also job title).
· Contact Data - home address, email addresses and mobile telephone number (for employees of veterinary practices using our Boop™ application, also work addresses).
· Technical Data - internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our Boop™ application and website.
· Profile Data - your username and password, purchases, feedback, and survey responses.
· Usage Data - information about how you use our Boop™ application and website and other products and services.
· Marketing and Communications Data - your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not, directly or indirectly, reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing our Boop™ application and website or using our products and services. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
If we need to collect personal data to fulfil a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to agree with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. How WE COLLECT your personal data
We use different methods to collect personal data from and about you including through:
· Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
§ download and use our Boop™ application;
§ create an account on our Boop™ application;
§ subscribe to our services or publications;
§ request marketing to be sent to you (including completing web forms);
§ enter a competition, promotion, or survey; or
§ give us feedback or contact us.
· Automated technologies or interactions. As you interact with our Boop™ application and website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://booppet.app/cookies for further details.
· Third parties or publicly available sources. We will collect or receive personal data about you from various third parties and public sources as set out below:
§ Identity and Contact Data about veterinarians and veterinary nurses from the registers of the Royal College of Veterinary Surgeons.
§ Technical Data from analytics providers such as Google and PostHog.
4. How we use your personal data
We will only use your personal data when the law allows us to.
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Performance of a contract with you: Where we need to carry out the contract we are about to enter into, or have entered into, with you, or where we need to otherwise provide you with a service, offer, promotion or product that you have requested. This may include where we need to take certain steps, at your request, before we enter into a contract.
· Legitimate interests: Where it is necessary to conduct our business and pursue our legitimate interests, which is generally where we use your personal data in ways you would reasonably expect us to. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Examples of where using your personal data would be in our legitimate interests include:
§ Preventing, investigating, and detecting crime, fraud, bullying, harassment, discriminatory or other anti-social behaviour and taking action against perpetrators, including working with law enforcement agencies
§ Protecting us, our customers, product users and partners, by taking appropriate legal action against third parties who have committed criminal acts, or breach their legal obligations to us.
· Legal obligation: Where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis. For example, keeping recordings and providing information to tax authorities.
· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example, if you subscribe to an email newsletter.
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing (including basis of legitimate interest, where relevant)
To register you as a new user/customer and provide you access to our products and services
(a) Identity
(b) Contact
(a) Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(c) Dealing with your requests, complaints and queries
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, to manage our relationship with you, and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business)
To administer and protect our business, our Boop™ application and website, and our products and services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud)
(b) Necessary to comply with a legal obligation
To deliver content to you (including marketing or content sponsored by our third-party partners offering products and services that may be of interest to you) via our Boop™ application and website, and to measure or understand the effectiveness of such content
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers/users use our products and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Boop™ application and website and our products and services, marketing, customer relationships and experiences and to measure the effectiveness of our communications and marketing
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Boop™ application and website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about products or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products and services and grow our business)
(b) Consent, where you have provided your consent to receiving direct marketing communications
Direct marketing
When you download and register to use our Boop™ application, we will ask you to tell us your preferences for receiving direct marketing communications from us via e-mail, text message, telephone and post.
We may also use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
Third-party marketing
Please rest assured that we will get your express opt-in consent before we share your personal data with any third-party for their own direct marketing purposes.
Opting out of direct marketing
You can ask us or third parties acting on our behalf to stop sending you direct marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing support@booppet.app
Where you opt out of receiving these direct marketing messages, you may still receive service-related communications that are essential for administrative or customer service purposes, for example, relating to products and services that you have purchased, appointment reminders, updates to our terms and conditions, checking that your contact details are correct.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Boop™ application and website may become inaccessible or not function properly. For more information about the cookies we use, please see https://booppet.app/cookies
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. SHARING YOUR DATA WITH THIRD PARTIES
Do you share my personal data with third parties?
When you download and register to use our Boop™ application, you will have the option to provide your pet’s veterinary practice details. Where you do this, certain of your personal data, for example Identity Data and Contact Data, will be shared with, and visible to, your veterinary practice via our Boop™ application.
We may also share your personal data with the parties set out below for the purposes set out in the table above [Purposes for which we will use your personal data].
· External third parties, such as:.
§ Service providers acting as processors who provide IT and system administration services.
§ Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. TRANSFERRING YOUR DATA INTERNATIONALLY
Do you transfer my personal data outside of the UK?
We may transfer your personal data to countries outside the UK, including to Google servers located in the European Union.
Please rest assured that whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. LOOKING AFTER YOUR DATA
How do you protect my personal data?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, or used, accessed, altered or disclosed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place policies and procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
8. KEEPING YOUR DATA
How long will you use my personal data for?
We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for distinct aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Right to request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
· If you want us to establish the data's accuracy.
· Where our use of the data is unlawful, but you do not want us to erase it.
· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
· You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to personal information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.