Date of publication: 21st of November, 2023.
Table of contents:
This policy sets out the basis on which any personal data we collect from you, or that you provide to us in relation to your use of our website, www.petlabco.uk, and during any other interactions with us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Title: Data Protection Officer
Email address: email@example.com
Postal address: 31-33 Prescot St, London E1 8BB
Petlab encourages you to review the privacy statements of any websites you choose to navigate to, from Petlab, so that you can understand how those websites collect, use and share your information. Petlab is not responsible for how those third parties use your personal data, or for their privacy statements or other content on websites outside of the Petlab websites.
Purpose of this Policy
Collection of your Personal Information
Petlab may collect and process personal data, such as your name and email address if you enter these on the contact form on our website or to fulfil our contractual obligations to provide our products or services, invoice and receive payment for products or services, send legal updates, and news and information about our products or services or when we deal with enquiries or complaints.
Depending on the nature of your interaction with us, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and social media accounts.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and to others and other details of products and/or services you have purchased from us.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device model and other technology on the devices you use to access this website or our software.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not expect to collect any Special Categories of Personal Data (such as details about 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) pursuant to the provision of our website or our products or services and Petlab requests that you do not share such data with us and shall not request this data from you unless it is required to deal with a specific issue and it complies with Applicable Data Protection Law.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your name, email address and contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
• purchase a product or service;
• access our website;
• meet with one of our employees or consultants;
• participate in an event which we have organised;
• complete a form on our website requesting us to contact you;
• subscribe to our publications or newsletter;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• make a complaint, raise a query or give us some feedback.
Automated technologies through the use of our website or services. In your use of our website or services (including receiving our newsletter), certain Usage Data is transmitted to us such as the device you are using, your IP address and other such data.
Third parties or publicly available sources. We may receive personal data about you from various third parties, such as Technical Data or Usage Data from analytics providers or search information providers.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of 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 enter into with you (for example, to provide you with our services). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
Purposes for which we will process your personal data and legal
Petlab collects and uses your personal information to operate its website(s) and deliver the products and services you have requested including processing your account application. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need it to perform the contract we have entered into with you or to enter into a contract at your request.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message (although we may also rely on legitimate interests where appropriate). You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of how we may 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver products and/or services including:
(a) Manage payments, fees and charges
(b) Make a decision regarding whether to provide you with products or services
(c) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers suitable for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business).
Petlab may use your personal information to inform you of products or services available from Petlab and our partners. Petlab may also contact you via surveys to conduct research about your opinion of our website and our products and services. Petlab does not sell, rent or lease or provide in any other way its customer lists to third parties.
Petlab may keep track of the websites and pages our users visit within Petlab and which products and services our users access. This data is used to deliver customised content to Petlab customers whose behaviour indicates that they are interested in a particular subject area.
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 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.
Disclosure and International Transfers of Personal Data
Petlab may share your personal data with trusted partners, contractors and other group companies to help provide our products and services, including to perform credit-checks, fraud prevention, analysis, provide you with products or services, send you email or postal mail, provide customer support and IT support, market research, or to securely store your data. All such third parties are required to maintain the confidentiality of your information.
We require all third parties we share personal data with 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 and applicable law.
Some of our service providers or partners may process your personal data in countries outside of the UK/EEA that do not have equivalent data protection laws to the UK/EEA. In addition, your personal data may be accessed by our group entities located overseas, such as Petlab Co. Inc in the US to enable them to provide intra-group services to Petlab. Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it as when it is within the UK/EEA by ensuring at least one of the following safeguards is implemented:
• Where the transfer of your personal data is to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government or other regulatory authority.
• Where we use specific contracts approved by the European Commission, the UK Government or other regulatory authority which give personal data the same protection it has in the UK/EU. For transfers of personal data from Petlab Group Limited to Petlab Co. Inc, we have entered into Standard Contractual Clauses to protect your data (a copy of which is available on request from our Data Protection Officer, using the contact details provided above).
• Where the personal data is protected by Binding Corporate Rules.
Petlab may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to:
(a) conform to the edicts of the law or regulation or comply with legal process served on Petlab or the site;
(b) protect and defend the rights or property of Petlab; and,
(c) act under exigent circumstances to protect the personal safety of customers of Petlab, or the public.
Additional Information regarding Third Party Tracking Services
Personal Data is collected for the following purposes and using the following services:
Interaction with external social networks and platforms
The website may incorporate links to social media platforms, such as a Facebook Like button, LinkedIn button, Twitter Tweet button and social widgets. This type of service allows interaction with social networks or other external platforms directly with our websites. The interaction and information obtained through our websites are always subject to your privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when users do not use it.
We have put in place and will maintain appropriate security measures to prevent your personal data from being accidentally lost, 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 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.
Petlab will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements. Data is reviewed regularly for relevance. Any data deemed no-longer relevant is deleted. Petlab shall keep personal data of customers seven years from the date of closing an account. If your account application is declined Petlab will keep this personal data for 5 years from the decision. If your account is subject to any dispute or complaint it will keep personal data relating to this issue for 6 years from the case being closed. Petlab shall keep emails of clients and prospective clients for as long as it has a lawful basis to do so.
If you have a question about our data retention periods please contact us at firstname.lastname@example.org.
Please see the following link for more information about how Google uses information from their sites or apps that use their service:Google’s Privacy & Terms site.
Children Under Thirteen
Petlab does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website or our services.
Opt-Out & Unsubscribe
We respect your privacy and will give you an opportunity to opt-out of receiving unsolicited direct marketing communications by email. You may opt-out of receiving any or all marketing communications from Petlab by contacting us or selecting the “Unsubscribe” option on our email.
Your Legal Rights
You have the 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.
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.
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 local law. 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.
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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the right to ask us to stop using your personal data for direct marketing purposes at any time.
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. Note that this right only applies to automated information which you initially provided and which you consented for us to use or where we used the information to enter into or perform a contract with you.
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 withdrew 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.
No fee usually required.
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 may 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.
Petlab Group Limited
31-33 Prescot St, London E1 8BB
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