LEGAL

Privacy Policy

Last updated on October 18th, 2023

Welcome to Vetcove! We are excited to have you here, and we hope that you are equally as excited to learn about how we protect personal information shared with us from our business partners. Just like how our furry friends depend on their trusted veterinarians to keep them healthy and happy, we want you to trust us with any personal information or business information you may supply to us. We are committed to being trans-paw-rent about our privacy practices and to giving you control over how your information is collected, used, and shared.

This Privacy Policy and Notice ("Privacy Policy") covers all uses of our business-to-business procurement platform and corresponding mobile application (collectively, "Procurement Platform"), along with the use of a veterinary customer’s home delivery platform powered by us ("HD Platform") by individuals in the veterinary industry who have a business relationship with us and more specifically:

  • Our veterinary customers such as veterinary clinics and animal hospitals ("Veterinary Customers") who use our Procurement Platform and related services;
  • Product manufacturers, compounders or other vendors and suppliers ("Vendors") who use our Procurement Platform and related services; and
  • Our Veterinary Customers who use the HD Platform and related services in order to sell veterinary products to their pet parent clients.

As used in this Privacy Policy, "Platforms" refers to the Procurement Platform and HD Platform. "Services" refers to the aforementioned services related to the Platforms.

Please read this Privacy Policy carefully to understand the personal information we collect, how we use it, and the choices available to you. If you do not agree to this Privacy Policy, please do not use the Platforms or Services.

1. Scope

1.1. Jurisdiction and Applicable Laws

Vetcove does not have any locations outside of the United States ("U.S"), nor do we offer products or services, including purchase of any products through the Platforms, outside of the U.S. As our products and services are intended for U.S. businesses and U.S. residents only, please do not attempt to use the Platforms or Services if you are located outside of the U.S.

"Privacy Laws" as used in this Privacy Policy refers to the U.S. privacy laws currently in force, and that are binding upon us and applicable to you, which may include the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) where you are a California resident. If you are a California resident, please review the California Supplement included below.

“Personal Information” as used in this Privacy Policy means information which identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, as defined under the Privacy Laws as ‘personal information,’ ‘personal data,’ ‘personally identifiable information,’ or the like; however, it does not apply to: (a) publicly available information from government records; and (b) de-identified and aggregated information.

As used herein, the term “End Users” refers to those employees, agents, contractors or other authorized users of a Veterinary Customer or Vendor who use the Platforms or Services and who have an established business relationship with us. The term “Consumer” as used in this Privacy Policy means a natural person, and includes End Users.

1.2. Out-of-Scope

Please note that information collected and used outside of what is stated in the above paragraphs is considered outside the scope of this Privacy Policy. For example, this Privacy Policy does not cover the following:

  • Information from individuals who use the HD Platform directly as an individual Consumer for browsing and purchasing from their clinic. The consumer privacy policy posted on the applicable HD Platform governs the collection and use of Consumer’s information when using such HD Platform.
  • Your information collected directly from Vendors or other third parties, even where the information collected is in connection with your use of the Platforms or Services. The applicable Vendor’s or other third party’s privacy policy covers the collection and use of information submitted by you to the Vendor, on or through the Vendor’s platform, or to the respective third party.
  • Business information that may be considered confidential or sensitive, but that is not Personal Information; for example, the credit card number for a veterinary practice. Handling of such confidential and sensitive business information may be covered under a separate services agreement that we have with our Veterinary Customer or the entity that represents them (such as corporate hospital groups).

1.3. Minors

The Platforms and Services are not intended for children under eighteen (18) years of age. No one under the age of 18 may provide any information to, on, or through the Platforms or Services. We do not knowingly collect Personal Information from children under 18. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us using any of the contact methods in the Contact Us section

2. Information We Collect

The information we collect about you depends on the Platforms and Services you use, how you use them, and the information you provide to us. Depending on which Platform(s) and Services you use, we collect different types of information about your business, company, clinic, group, or other entity you represent, as well as information about you, our End User.

We collect information in three main ways: (1) information you provide directly to us; (2) information we collect automatically through technology when you use the Platforms and Services; and (3) information we collect from other sources.

2.1. Information You Provide Directly to Us

When you use our Services, you may provide certain information to us. For example, we collect information directly from you when you create or use a Vetcove account, participate in Vetcove surveys or research, purchase products and interact with the Services, engage with us through our sales and marketing efforts, or communicate and interact with us.


Some of the most common categories of Personal Information we collect directly from End Users include:

  • Contact and account information, such as your name, email address, login credentials, and your business contact information and title/role. For veterinarians submitting prescriptions via the HD Platform, we may also collect certain identifying information, including for example your veterinary license number, your signature, and/or a unique PIN number.
  • Customer service interaction information, such as messages submitted to us through online forms or email, and summaries, transcriptions or voice recordings of interactions with our customer service personnel. For End Users associated with Veterinary Customers that use the HD Platform, we may also collect communications and conversations with clients to or through the HD Platform and related Services. For End Users associated with Veterinary Customers on our Procurement Platform, we may also collect information from you when you submit forms, provide information or responses in discussion forums, or otherwise communicate or interact with us.
  • Information related to loyalty programs, redemption campaigns, sweepstakes, including information needed for you to participate in, and for us to fulfill, your prize or participation incentives (if any).

2.2. Information Collected Automatically

The information we automatically collect when you use the Platforms and Services includes information about your access to and use of the websites and emails, such as your IP address, browser language, the state from which you accessed the Platforms or Services based on the location of your device, software and hardware attributes (including device IDs, operating system, and browser type), referring and exit URLs, the links you click and the files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our website, the date and time you accessed our websites or opened our emails, and other similar information

To collect this information, we and our service providers also use technologies, including cookies, to automatically collect certain types of usage and device information when you use the Platforms or Services. The Platforms utilize cookies to enhance overall shopping experience by retaining information about which items have been added to carts and collecting general data on traffic and interactions on the websites. This data is used to improve the Platforms’ functionality, and to ensure that we are offering the best experience and tools to our End Users (including you!). For information on how to disable cookies, please see Section 6 (Your Rights and Choices), below.

We use third-party analytics services on the Procurement Platform and related Services to better understand End User online activity. These service providers collect information about End User’s use of our Procurement Platform and related Services and other websites and online services over time through cookies, device identifiers, pixel tags, or other tracking technologies. We and our third-party providers use this information to, among other things, analyze and track data, determine the popularity of particular content, and deliver advertisements based on your interests on our Procurement Platform, as well as to provide services to us, such as reporting, analytics, and market research.

2.3. Information We Collect from Other Sources

We may collect information about our Veterinary Customers at the clinic-level from other sources to supplement the information we collect directly from you. For additional information regarding our collection and use of business information related to Veterinary Customers, please see Section 9 (Additional Notes on Business Information).

3. How We Use Your Information

Vetcove may use Personal Information we collect in the following ways:

  • To provide the services you have requested, such as to verify a purchase, offer customer support, facilitate cash-back and redemption offers in which you chose to participate, investigate and respond to your inquiries.
  • To communicate with you, for example, keeping you posted on purchases, shipments, and changes to our terms, conditions and policies.
  • For marketing and advertising purposes, including providing Veterinary Customers with the latest and most relevant product announcements and promotions. For example, we may utilize information provided to us to ensure that we’re showing our Veterinary Customers relevant ads on the Procurement Platform, and to measure the effectiveness and reach of those ads. We may also utilize Personal Information associated with End Users of a Veterinary Customer to administer loyalty programs and cashback campaigns on behalf of our Vendors.
  • To improve our Services and Platforms, including bug detection and error reporting, to understand how End Users interact with the Services and Platforms, to improve usability and effectiveness of our products, perform research and analytics, and to test and create new products, features and services.
  • For security and other general business operations, such as to maintain the safety, security, and integrity of the Platforms, detecting security incidents, investigating and protecting against malicious, deceptive, fraudulent, or illegal activity. Please note that if, due to personnel changes or otherwise, your Vetcove account needs to be transferred to a new authorized representative at your business, some account information may be shared with the new representative at the discretion of Vetcove to preserve the integrity of the account.
  • To facilitate mergers and acquisitions, such as to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information is held by us about users of the Platforms and Services is among the assets transferred.
  • For legal and compliance, such as to comply with applicable laws including Privacy Laws, including to verify age, DEA, and/or veterinary license numbers when veterinary products are ordered requiring such verification; facilitating any required reporting for substances designated as controlled at either the state or federal level; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements; enforcing our terms and conditions applicable to you (“Terms of Use"); protecting our operations; protecting the rights, privacy, safety, or property of Vetcove and users of the Platforms and Services and other relevant individuals; and allowing us to pursue available legal remedies and limiting the damages that Vetcove may sustain.
  • In accordance with your consent. We may also use your Personal Information for a specific purpose that we communicate to you. We will ask for your consent to process your Personal Information for such purpose in accordance with applicable legal requirements. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

For the purposes discussed in this Privacy Policy, we may combine the Personal Information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

4. How We Disclose Your Information

Vetcove may disclose Personal Information for a business purpose in the following ways:

  • Authorized third-party service providers. We use select third-party service providers to help us provide the Services and to operate our business. They provide a variety of services to us, including fulfillment, shipping and delivery, customer service, web hosting and design, payment processing, sales and marketing, data storage, analytics and related services, security, fraud prevention, research and legal, advising or consulting services. We share information with Vendors and our fulfillment partners for the purpose of ensuring the delivery of the purchased product or requested services. For the HD Platform, this includes, but is not limited to, sharing Personal Information of the prescribing veterinarian with our pharmacy partners for fulfilling orders to Consumers.
  • Vendors and other suppliers. We may disclose the information we collect about you to Vendors that have a business relationship with us, and whose products you purchase through the Platforms and Services. For example, for orders with Vendors through the Procurement Platform, we may share your account information, including, for example your veterinary license number, to the respective Vendor to process and ship the order, as well as to communicate directly with you for troubleshooting, order issues, errors or other investigations. For free samples, we may share your Personal Information with the Vendor providing those samples, so that the Vendor can communicate with you regarding your experience with their product(s).
  • Veterinary Customers. For End Users associated with a Veterinary Customer, this includes providing the owner or manager of the associated Veterinary Customer with information regarding redemption rewards or cashback redeemed by End Users; account information for modifying user access and permissions; clarifying or removing duplicate accounts; confirming the account information associated with a purchaser for certain orders placed on the Procurement Platform or prescriptions and orders generated through the HD Platform and related Services.
  • Legal purposes. We may disclose information we collect about you if required to do so by law or applicable regulations, or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order); (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of us or others.
  • Regulatory purposes. At times, we may be required to share certain information with third parties in order to fulfill our regulatory obligations. This may include, but is not limited to, providing information to manufacturers for reporting adverse events, or to assist any of our manufacturer or vendor partners in the event that a product is recalled from the market. In addition, this may include providing information concerning the prescribing veterinarian with pharmacy partners for purposes of reporting orders of certain medications into state databases.
  • Business transfers. As we continue to develop our business, we may engage in transactions with other companies regarding the purchase or sale of a business. We may disclose your information to the extent necessary and under confidentiality obligations as part of, or in contemplation of, such transactions.

5. Security and Retention of Your Information

5.1. Security of Your Information

We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information.

When creating an account on the Platforms, it is important that you select a strong and unique password and do not disclose it to others. Alert us immediately if you have any concerns about unauthorized use of your account.

5.2. Retention of Your Information

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. The criteria we use to determine our retention periods include the following:

  • The length of time we have an ongoing relationship with you and provide the Platform and Services to you (for example, for as long as you have an account with us or continue using the Services).
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations).

Subject to the foregoing, when you delete your account, we may delete or anonymize content you have posted on the Platforms, such as your reviews or Q&A activity

6. Your Rights and Choices

We provide you with the ability to exercise certain controls and choices regarding our collection, use, and disclosure of your information. Your legal rights to exercise such controls and choices vary based on the applicable Privacy Laws, such as the laws of your jurisdiction.

You may adjust the following controls:

  • Account ProfileYou may update certain account profile information by logging into your account. For example, you may modify your personal information, position, password, address, payment information, and any stored veterinary licenses through the Account tab of the Procurement Platform. To deactivate your account, you may email support@vetcove.com. You may also modify or manage user accounts or permissions for other End Users within your veterinary organization.
  • Communication preferences You may modify or update your communication methods via your account for both Platforms. You may also delete certain communication methods within your account.
  • Limit the information you provide to us. When you interact with us, you can choose to limit certain information you provide. However, if you choose to do so, you may not be able to take full advantage of the Platforms and Services, and we may not be able to fulfill your requests.
  • Cookie controls Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject those technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.

For questions regarding your Personal Information, or if you would like to change or update your Personal Information, please contact us at privacy@vetcove.com. In some cases, we may be required to keep certain information for legal or business reasons (like prescription records).

7. Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy and/or the California Supplement of this Privacy Policy at our discretion and at any time. When we make changes, we will post the updated version on the Platform and update the Privacy Policy’s revision or effective date on the top of the Privacy Policy. Your continued use of the Platform and Services following the posting of changes constitutes your acceptance of such changes.

8. Contact us

If you have any questions or comments about this Privacy Policy, including the California Supplement, the way in which Vetcove collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights in relation to your Personal Information, please do not hesitate to contact us using any of the methods below:

Email: privacy@vetcove.com

Postal Address:
Vetcove Inc.
Attn: Legal Department
382 NE 191st Street, PMB 46115
Miami, Florida 33179-3899

If you need to access this Privacy Policy in an alternative format due to having a disability, please contact us using any of the methods listed in this section.

9. Additional Notes on Business Information

De-Identified Information. We may de-identify information we collect so the information cannot reasonably identify you, your device or your affiliated Veterinary Customer, or we may collect information that is already in a de-identified form. For example, we share data analytics, based on de-identified information, with our industry partners. This includes data such as total sales of a medication in a particular territory or region, or overall compliance or lapse with particular medications. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.

Business-to-Business Information. Vetcove may obtain business information directly from you, or from other third-party sources. For example, when a Veterinary Customer connects with a Vendor through the Procurement Platform, Vetcove may receive from the Vendor, or retrieve on the Veterinary Customer’s behalf and as the Veterinary Customer’s authorized agent, information about the Veterinary Customer’s prior purchases (including products, quantities, and frequency of prior orders at the clinic-level). Vetcove may also collect information regarding your affiliated Veterinary Clinic’s purchasing and purchasing trends at the clinic-level by virtue of End User’s use of the Procurement Platform. Vetcove may use or disclose such business information in the following ways:

  • Linked Vendors: Vetcove may use and disclose information that pertains to Veterinary Customers to facilitate supplier integrations on the Procurement Platform, including by sharing which items are added to or removed from carts, or changing desired quantities in shopping carts. Additionally, for products purchased from a particular Vendor, we may share with that Vendor clinic purchasing volume or sales volume for that Vendor’s products, in order to comply with contractual obligations or for marketing purposes. This may include sharing enrollment and participation in any cashback or loyalty programs, and the total amount of rewards or redemptions claimed on a per-clinic basis; sharing information for the purposes of determining eligibility for particular cashback or loyalty offers; providing reports to Vendors regarding order data for the Vendor’s products; and sharing information regarding past purchases and pricing of particular products with the manufacturing Vendor of those products in order to confirm pricing accuracy. Beyond confirming pricing for select products with the Vendor that manufactured those products, we will not share pricing information with any third parties (even if aggregated or de-identified). For non-direct checkout orders on our Procurement Platform, we may share the shipping and payment information associated with the Veterinary Customer with the applicable Vendor (and any third party service providers, including UPS or FedEx) in order to fulfill the order. For orders by Veterinary Customers through the HD Platform and related Services, we may also share information pertaining to the Veterinary Customer for fulfillment purposes.
  • Data Analytics: Vetcove may share data analytics, based on de-identified Veterinary Customer information, with Vendors and other industry partners. This information may include data such as total medication sales in a particular region, or rate of lapse for particular medications. The purpose of sharing this aggregated information is to identify market trends and to improve overall care provided to pets. In addition, we may share the fact that your affiliated Veterinary Customers conducts purchasing through the Procurement Platform, or otherwise uses the Platform and Services with (a) Vendors; or (b) in the event that your affiliated Veterinary Customer is associated with a larger corporate hospital group, with your associated corporate hospital group.

For business-to-business information that does not constitute Personal Information as defined herein, nothing in this Privacy Policy shall be deemed to limit Vetcove’s use or disclosure of such information, subject to the terms of any services or other agreement between Vetcove and the applicable third-party business

California Supplement

This California Supplement: (a) is in addition to the information contained above; (b) is made part of the Privacy Policy; and (c) applies to the Personal Information we collect from California residents. We have adopted this California Supplement to comply with the CCPA and other related Privacy Laws. If there is any conflict between the information contained in this California Supplement with the information contained above, the information in this California Supplement will govern in relation to our handling of Personal Information of California residents.

A. Information We Collect

Table A below details the categories of Personal Information we collect from Consumers in the state of California, including those we collected within the last twelve (12) months:


Table A: Categories of Personal Information Collected

Category Examples Collected
A. Identifiers. A real name, alias, job title, unique personal identifier including veterinarian license number and DEA license number, online identifier or account name including Platform username, Internet Protocol address, business email address, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, employment information such as current job title. (Some personal information included in this category may overlap with other categories.) YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Log-in credentials, including passwords, Veterinary Customer’s credit card information. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on an End User’s interaction with the Platforms and Services, including any advertisements therein. YES
G. Geolocation data. Physical location, including location data during use of our Platforms and Services. YES
H. Sensory data. Audio, electronic, visual, or similar information, such as voice recordings when speaking with our customer service representatives. YES
I. Professional or employment-related information. Current or past job history, such as current job title. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

A.1. Category of Information

As set forth above, we collect the categories of Personal Information listed in Table A above from the following categories of sources: (a) directly from you, for example, when you create an account and use our Platforms; and (b) automatically and indirectly from you, for example, information may be collected automatically from your actions on the Platforms and Services, as may be logged from cookies on our websites.

A.2. Purposes for Use of Personal Information

Please see Section 3 (How We Use Your Information), above.

B. Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for business purposes as described above in Section 3 (How We Use Your Information). Table B below details the categories of third parties to whom we disclose Personal Information, including those we disclosed to within the last twelve (12) months.

We do not and have not sold Personal Information in the preceding twelve (12) months. We also do not share and have not shared in the preceding twelve (12) months, Personal Information with third parties for cross-contextual behavioral advertising.


Table B: Categories of Third-Parties for Disclosure

Personal Information Category Category of Third-Party Recipients
Business Purpose Disclosures Sales
A: Identifiers. • Vetcove’s Affiliates
• Service Providers
• Vendors (as defined)
• Veterinary Customer
• Internet cookie data recipients, such as partner customer data platforms (“CDPs”)
• Government Agencies (if required)
None
B: California Customer Records personal information categories. • Vetcove’s Affiliates
• Service Providers
• Vendors (as defined)
• Veterinary Customer
• Internet cookie data recipients, such as partner CDPs
• Government Agencies (if required)
None
C: Protected classification characteristics under California or federal law. None None
D: Commercial information. • Vetcove’s Affiliates
• Service Providers
• Vendors (as defined)
• Veterinary Customer
• Government Agencies (if required)
None
E: Biometric information. None None
F: Internet or other similar network activity. • Vetcove’s Affiliates
• Service Providers
• Internet cookie data recipients, such as partner CDPs
• Government Agencies (if required)
None
G: Geolocation data. • Vetcove’s Affiliates
• Service Providers
• Internet cookie data recipients, such as partner CDPs
• Government Agencies (if required)
None
H: Sensory data. • Vetcove’s Affiliates
• Service Providers
• Vendors (as defined)
• Veterinary Customer
• Internet cookie data recipients, such as partner CDPs
• Government Agencies (if required)
None
I: Professional or employment-related information. • Vetcove’s Affiliates
• Service Providers
• Vendors (as defined)
• Veterinary Customer
• Internet cookie data recipients, such as Partner CDPs
• Government Agencies (if required)
None
J: Non-public education information. None None
K: Inferences drawn from other personal information. None None

Your Rights and Choices

We offer you choices in relation to your Personal Information provided to us based on the Privacy Laws applicable to you. If you are a California resident, and subject to the CCPA and applicable Privacy Laws, the following rights are available:


i. Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and confirm your identity as provided below, we will disclose to you:

(a) The categories of Personal Information we collected about you.

(b) The categories of sources for the Personal Information we collected about you.

(c) Our business or commercial purpose for collecting or selling that Personal Information.

(d) The categories of third parties with whom we share that Personal Information.

(e) If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

(f) The specific pieces of Personal Information we collected about you.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.


ii. Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity as provided below, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

(a) Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

(b) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

(c) Debug our Platforms to identify and repair errors that impair existing intended functionality.

(d) Exercise free speech, ensure the right of another Consumer to exercise their free speech rights, or exercise another right provided for by law.

(e) Comply with a legal obligation, including but not limited to the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

(f) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

(g) Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.

(h) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action. For information on retention, please see Section 5 of the Privacy Policy (Security and Retention of Your Information).


iii. Right to Correct

You may request that we correct inaccuracies in your Personal Information.


iv. Right Against Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of products or services; (d) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

However, from time to time we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.


v. Opt-Out Rights

See Section E of this California Supplement (Opt-Out Rights), below.

D. Exercising Your Rights and Our Response

i. Exercising Your Rights

To request access, correction, deletion, restriction, or confirmation of your Personal Information, contact us using any of the methods listed in the Contact Us section. You may only submit a request to know under Section C(i) of this California Supplement twice within a 12-month period. Your request to know or delete must:

(a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

(b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.


ii. Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please follow up or contact us using a different contact method than your initial request under Contact Us. We endeavor to substantively respond to a verifiable request under this Privacy Policy within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

E. Opt-Out Rights

i. Opt-Out of Sale

Where CCPA applies, you have the right to direct us to not sell your Personal Information at any time. However, we currently do not sell Personal Information (nor do we collect any information from Consumers who are less than 16 years old).

ii. Opt-Out of Cookies

There are several ways to opt-out of our use of cookies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If, however, you do not accept any cookies, you may experience some inconvenience in your use of the Platforms and Services. For example, we will not able to recognize your computer, and you will need to log-in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests.

Promotional Offers from Vendors: If you do not wish to have your Veterinary Customer's information used by Vetcove to promote Vendor's products, you can opt-out by logging into the Platforms and adjusting your user preferences in your account profile, or by contacting us using any of the methods listed in the Contact Us section. If we sent you a promotional email, you may send us a return email asking to be omitted from future promotional email distributions.

Targeted Advertising: If you do not wish your Personal Information to be used as part of delivering advertisements to your Veterinary Customer, in accordance with our Vendor's target-audience preferences, you can opt-out by contacting us using any of the methods listed in the Contact Us section. For this opt-out to function, you must have your browser set to accept all browser cookies.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

1. As we do not disclose your Personal Information with third parties for their own direct marketing purposes, California’s Shine the Light law does not apply. In addition, we do not use sensitive personal information (as defined under CCPA) for the purpose of inferring characteristics about a consumer, and as such in accordance with the CCPA, sensitive personal information will be treated as Personal Information under this Privacy Policy.

Veterinary Supply Starts Here.

Contact

382 NE 191st St. PMB 46115

Miami, FL 33179

support@vetcove.com

646.504.2696