Privacy Notice
Last Updated: May 11, 2023
This Privacy Notice ("Policy") pertains to the websites, mobile applications, software downloaded and installed on a mobile device, related social media, and/or other services provided, including email messages that we may send to you ("Site"), controlled or operated by PetReflex, a company registered under the laws of the jurisdiction in which it operates, and/or its owners, agents, employees, representatives, or affiliates and assigns ("PetReflex"). This Policy sets out the basis on which we collect any personal information relating to you, or that you provide to us in relation to us providing pet health monitoring services.
PetReflex gathers and uses (i) personal information submitted to the Site and (ii) aggregated information collected from the services provided through the Site. This Policy applies to the Site, and any domains, services, applications, and applicable products ("Services"). From time to time we may update this Policy, at our sole discretion. Your use of the Site after an updated Policy becomes effective will indicate your acceptance; therefore, we encourage you to periodically review this Policy and the Site in order to keep apprised of our current privacy practices.
Who are we?
As used herein "we", "our" or "us" means PetReflex.
We may be the controller of your personal information. This means that we are responsible for deciding how we collect, store, and use your personal information.If you have any questions about this privacy notice, please contact us by email at support@petreflex.com.
Who does this Policy apply to?
This privacy notice applies to all users of the Site.
When you use the Site or Services, we may collect and use personal information about you that directly or indirectly identifies you or another individual ("Personal Information"), which may also include your name, email address, phone number, address, browser and device information, and information collected through cookies and other similar technologies (such as IP address).
We may also collect and use non-personal information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been anonymized, de-identified, or aggregated ("Other Information"). Other Information that we may include a unique identifier from Apple and Google in order to link your use of the app for billing through iTunes and Google Play and for advertising purposes. We use Other Information to facilitate our operation of our Site and for other purposes as described below.
You hereby declare and agree that any and all information you provide to us and/or update and/or share with PetReflex on the Site is correct, reliable, and accurate, and that you registered and/or provided the information in your own name and on your own behalf, and not in the name and/or on the behalf of any third party and that you permit us to use the information in accordance with this Policy.
INFORMATION WE USE OR COLLECT
Personal Information you provide us directly
We collect certain personal information that you provide to us, including without limitation, names, email addresses, usernames, contact preferences, pet information, pet health preferences, geolocation, and other similar information. We use such Personal Information to provide the Services and administer your inquiries. For instance, when you register on the PetReflex app, if you express an interest in obtaining information about us or our products and Services, when you participate in activities on the PetReflex app, or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the PetReflex app, the choices you make, and the Services you use.
Other Information automatically collected
In order to provide relevant marketing, offers, and Services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, including without limitation Facebook, as well as from other third parties. This information may include your name and profile picture.
We also collect certain information when you visit, use or navigate the PetReflex app. This information may not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, geolocation, information about how and when you use the PetReflex app, and other technical information.
Third-Party Collection
We may collaborate with third parties to either display advertising on our App or to manage or operate our App or features therein. Our third-party partners may use technologies such as cookies or emails to gather information about your activities on other apps or sites to provide you with advertising based on your browsing activities and interests. Please be aware that when you are using the PetReflex app, or when you receive an email message from us through the Services, you could be directed to other sites or apps that are beyond our control. There may be links to other sites or apps from PetReflex or from the email messages we send to you that take you outside our App. These other sites or apps may send their own cookies to visitors, collect data, or solicit personal information and are regulated by their own privacy policies, which we encourage you to review. The privacy policies of these other sites or apps may significantly differ from this Policy. We are not responsible for the privacy practices of these other sites or apps and cannot guarantee the security of any of your personal information collected therein. Note that when you link to a third-party site or app from PetReflex, you may see pre-populated data fields with your personal information; however, that information is not available to the third party unless you take certain actions on the third party's site or app, such as submitting a form. To see how they use this information please refer to their privacy policies.
These third parties include, but are not limited to:
Analytics & Tracking providers
Google LLC (Firebase / BigQuery): We use Google's Firebase and BigQuery for analyzing and tracking usage data. Privacy policy: https://policies.google.com/privacy More about Firebase privacy: https://firebase.google.com/support/privacy
Google LLC (Google Play Market): Our app is distributed via the Google Play Market, which collects certain user data. Privacy policy: https://policies.google.com/privacy
Apple Inc. (Apple iTunes Connect): Our app is also distributed via Apple's iTunes Connect, which collects certain user data. Privacy policy: https://www.apple.com/legal/privacy
Please note that these third-party service providers may have their own privacy policies, and we strongly advise you to read them.
For additional information on application personalized advertising opt-out, please consult the following privacy settings:
iOS: On your device, navigate to Settings > Privacy > Apple Advertising. Toggle off Personalized Ads.
Android: On your device, proceed to your Google Account. In the navigation panel, select Data & privacy. Scroll to "Things you've done and places you've been." Under "Ad settings," select Ad personalization. Toggle off the switch next to "Ad Personalization is ON."
Marketing
We may use your Personal Information, such as your name, email address, telephone number, etc., either directly or through our third-party subcontractors, for the purpose of supplying you with promotional materials related to our services, PetReflex, which we think may pique your interest. By unsubscribing from such content, we will remove your email address or telephone number from our marketing distribution lists.
Please be aware that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of significant email communications without giving you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
USE OF PERSONAL INFORMATION
We collect and use your Personal Information to manage and enhance your use of the PetReflex app or the Services. The type of information we collect can vary depending on how you access, visit, use, or otherwise take advantage of the PetReflex app or the Services.
We use your Personal Information as follows:
Where we have stated that your Personal Information is used in order to carry out a contract with you, or to provide the PetReflex Services to you, and you do not provide that information, we may not be able to respond to your request for PetReflex Services or enter into a contract with you.
We will only use your Personal Information for the purposes set out above or for other reasons compatible with those original purposes. If we change the purpose for which we use your Personal Information within PetReflex, we will do so with your consent.
REASONS FOR USE OF PERSONAL INFORMATION
We may process your Personal Information if you have given us specific consent to use it for a specific purpose.
When necessary to perform PetReflex Services.
If it is necessary for our legitimate interest, for example: (i) to keep our records updated; (ii) to explore how customers use our PetReflex Services; (iii) to offer additional features to our customers; (iv) to prevent fraud or monitor for security vulnerabilities; (v) to keep our PetReflex Site updated and relevant; (vi) to develop our business; and (vii) to inform our marketing strategy (by delivering PetReflex Site content and advertising to you).
For our business or commercial purpose, including without limitation, data analysis, audits, fraud and abuse monitoring and prevention, detecting security vulnerabilities, identifying technical errors, for testing products and services, enhancing, improving or modifying our PetReflex Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities, to provide you, or permit selected third parties to provide you with information about products and services we offer. In some circumstances, and subject to consent, to disclose information to a third party that offers goods or services complementary to our own PetReflex Services.
As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to enforce our terms and conditions; (iv) to protect our operations; (v) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (vi) to allow us to pursue available remedies or limit the damages that we may sustain.
How long do we keep your personal information?
At PetReflex, we will only retain your Personal Information for as long as it is necessary for the purposes outlined in this Policy, unless a longer retention period is mandated or permitted by law.
Acting in our capacity as a data controller of Personal Information, we maintain the Personal Information we collect as long as we have an ongoing legitimate business need to do so (such as complying with applicable legal, tax, or accounting requirements). When we no longer have an ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it. If deletion or anonymization is not feasible (for example, because your Personal Information has been stored in backup archives), we will securely store your Personal Information and isolate it from any further processing, in accordance with applicable laws, until deletion is feasible. However, we will make good faith efforts to delete your personal information if you contact us by following the Opt-out mechanism in this Policy, provided we are not legally obliged to retain it or if it is not necessary for legitimate business purposes. We reserve the right to decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
At PetReflex, we contract with vendors, consultants, agents, and other service providers(collectively, "Service Providers") to perform certain tasks on our behalf. We may need to share your Personal Information with some of these Service Providers to deliver our services to you or to communicate with you, for instance, to provide marketing assistance or offers on our behalf. When we share your Personal Information, we require the Service Provider to maintain the privacy, confidentiality, and security of your Personal Information.
You may disclose Personal Information through our platform, on message boards, chat, profile pages, blogs, and other services where you can post information and materials. This information can appear in public ways, such as through search engines or other publicly available platforms, and can be "crawled" or searched by third parties. Please do not post any information that you do not wish to reveal to the public at large.
We may also provide your Personal Information to (i) our professional advisors who need to access such information for the purpose of advising us; (ii) any law enforcement body that may have a reasonable requirement to access your personal information; (iii) any potential third party in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
We do not share information that could personally identify you with our third-party advertising partners for the purposes of advertising, remarketing, and behavioral advertising based on your use of the PetReflex platform.
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We and our Service Providers may collect and store your usage information in log files as well as through the use of cookies, web beacons, pixel tags, embedded scripts, and other tracking technologies now and hereafter developed ("Tracking Technologies"). We may use Tracking Technologies to, among other things, better serve you with more tailored information for our Services, and for those of third parties, facilitate your ongoing access to and use of PetReflex, and collect and store information about your use of the app. These technologies are used in analyzing trends, administering the app, tracking users' movements around the app, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
"Cookies" include commonly used pieces of information in the form of small files that are placed on an individual's device to enable the individual to more easily communicate and interact with the app. When you use our app, we may send one or more cookies to your device. They enable us to store information about your device which helps us, among other things, to provide you with a good experience when you use our app and enhance the level of services and functions provided. We also may use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our app and other websites. To do so, these companies may place or recognize a unique cookie or similar on your browser. We use cookies to remember users' settings (i.e., language preference), tracking for marketing purposes, and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our app, but your ability to use some features or areas of our app may be limited.
Most mobile operating systems and mobile applications include a Do-Not-Track ("DNT")feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to
DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We will continue to process such data in accordance with this Policy. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.
DO WE TRANSFER YOUR PERSONAL INFORMATION INTERNATIONALLY?
Your Personal Information may be transferred outside of France to the European Economic Area ("EEA") and outside of France and/or the EEA to other countries, potentially including the United States ("US"). We will implement adequate measures to ensure that your Personal Information is kept secure. These adequate measures shall include: (i) transferring to a jurisdiction which France and/or the European Commission recognizes as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of Personal Information; (ii) transferring in accordance to the EU General Data Protection Regulation ("GDPR"); and (iii) transferring pursuant to Standard Contractual Clauses ("Model Clauses") in accordance with French law and/or EEA decisions on transferring personal information.
However, if you are accessing our Site from outside France, your personal information may be stored and processed in any country where we have facilities or engage service providers. By using the Site or disclosing information to us, you consent to the transfer of information to countries outside of your country of residence, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. We ensure that the Service Providers receiving your Personal Information offer an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the GDPR or other applicable regulators or legislators.
Where we act as a processor on your behalf as a controller, we operate under our Data Processing Agreement ("DPA") (link to DPA). This DPA outlines our commitment to privacy and security when processing personal information in connection with the provision of the Services for the transfer of personal information outside the EEA or France.
How do we keep your personal data secure?
At PetReflex, we have implemented appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. Additionally, we limit access to your Personal Information to those employees or Service Providers who have a business need-to-know. We have established procedures to handle any suspected data security breach, and we will notify you and any applicable regulator of a suspected breach where it may pose a risk to you, in accordance with French law.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, while we strive to protect your Personal Information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Information, the transmission of Personal Information to and from our site is at your own risk. You should only access the Site within a secure environment.
Additionally, please be aware that our security procedures mean that we may occasionally request proof of identity before we are able to disclose the personal information we have collected from you.
What rights do you have over your personal data?
As a user of PetReflex, you possess certain rights under applicable data protection laws in various regions. These rights may include the ability (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Personal Information. Please make such requests using the contact information provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
EEA, UK, Switzerland
If you are a resident in the European Economic Area (EEA), Switzerland, or the UK, your rights under GDPR include: (i) request access to and obtain a copy of your personal data; (ii) request rectification (or correction) of inaccurate personal data you have provided; (iii) request erasure (or deletion) of personal data that is no longer necessary to fulfill the purposes for which it was collected, or does not need to be retained for other legitimate purposes; (iv) restrict or object to the processing of your personal data; and (v) if applicable, request your personal data be ported (transferred) to another company.
If you are a resident in the EEA, Switzerland, or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm ; https://ico.org.uk/.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
As PetReflex is based in France, French users can contact the Commission Nationale de l'Informatique et des Libertés (CNIL), the French data protection authority, for any complaints. You can find their contact details here: https://www.cnil.fr/.
California
If you are a California resident, you can make certain requests regarding your personal information, including:(i) you may request access to a copy of the personal Information we have about you, including a list of categories of your personal information that we have shared with another company for a business purpose; (ii) you may request that we delete your personal information; (iii) you may request that we stop sharing your personal information; or (iv) you may request the right not to be discriminated against. You can find pertinent authority here: https://oag.ca.gov/privacy.
CCPA Privacy Notice
California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. ("CCPA"), defines a"resident" as: (i) every individual who is in the State of California for other than a temporary or transitory purpose and (ii) every individual whois domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
For the purposes of this notice to residents, please check our CCPA Privacy Notice (link to CCPA Notice).
For additional information as to how to exercise your rights, or if you are unsure about your rights or are concerned about how your personal information may be processed, please contact us at support@petreflex.com .
WHAT IS THE OPT-OUT MECHANISM?
Depending on the laws applicable in your country, you may have the right to request access to the personal information we collect from you, modify that information, or delete it under certain circumstances. To request to review, update, or delete your personal information, please submit your request to support@petreflex.com.
WHAT ABOUT CHILDREN?
We are committed to protecting the privacy rights of children. PetReflex is not designed or intended for children, and we do not intentionally or knowingly collect information about children under the age of 18. If you believe that we may have collected personal information from someone under the age of 18, please notify us at support@petreflex.com, and we will take the necessary steps to delete such information and/or the account. If we begin to offer services that are directed towards or likely to be used by children, we will only collect personal information from a child under the age of 18 with the express consent of an adult, parent, guardian, or caretaker.
DO WE MAKE UPDATES TOTHIS POLICY?
We may periodically update this Policy. The updated version will be indicated by a revised date, and the updated version will become effective as soon as it is accessible. Your continued use of PetReflex after an updated privacy policy becomes effective constitutes your acceptance of the revised policy. Therefore, we encourage you to periodically review this Policy to stay informed about our current privacy practices.