Abbey House – Privacy Policy

Last updated 14th May 2018

1. Introduction

Abbey House respects your right to privacy. This Privacy Policy explains in detail the types of personal information we may collect about you when you interact with us. It also explains how we will store and handle that personal information, how we keep it safe, how you can exercise your privacy rights and how we combine data across Abbey House to build a picture of you.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided in the section of this Privacy Policy headed “how to contact us” below.

2. What is Abbey House?

Abbey House is one of the largest independently owned veterinary practices in West Yorkshire. The terms “we”, “us” or “our” in this Privacy Policy refers to :

* Abbey House Veterinary Hospital;

* Abbey House Veterinary Clinics;

* Croft House Veterinary Clinic;

* Leeds Emergency Vets;

* Abbey House Referral Services;

* Abbey House: Pet Cancer Care;

Together, “Abbey House”

3. When do we collect personal information?

We collect your personal information in a number of instances, including when you:

* Register your details as a new client at one of our surgeries or make appointments at a surgery or with one or our specialist referral services;

* Complete a form asking to be contacted by one of our surgeries regarding an appointment;

* Book to attend an event, for example one of our veterinary professional seminars or professional training events or sign up to view one of our online professional webinars;

* Are referred by a vet to one of our specialist referral services;

* Visit any of our Websites or Apps;

* Engage with us on social media;

* Download or install one of our Apps;

* Contact us by any means with questions about a service, product or treatment or to raise a complaint;

* Ask one of our colleagues to email you information about a service, product or treatment;

* Enter prize draws or competitions;

* Choose to complete any surveys we send you;

* Use our micro-chipping service;

* Comment on or review our products and services. Any individual may access personal information related to them, including opinions. So if your comment or review includes information about the colleague who provided that service, it may be passed on to them if requested;

* Fill in any forms. For example, if an accident happens in a Abbey House surgery a colleague may collect your personal information;

* Have given a third party permission to share the personal information they hold about you with us;

* Phone us, we sometimes record phone conversations for record or training purposes; and/or

* Use our car parks or veterinary surgeries which may have CCTV systems operated for the security of both customers and colleagues and for the prevention of crime. These systems may record your image during your visit.

We also collect your personal information when our suppliers and partners share information with us about the service, product or treatment you have purchased.

4. What personal information do we collect and why?

The personal information that we collect about you broadly falls into the following categories:

Information that you provide voluntarily

When you register as a client, book an appointment, attend an event or seminar or sign up to view one of our webinars, apply for 4 weeks free pet insurance or download one of our Apps or enter a prize draw/competition, you will be asked for some essential information including your title, first name, surname, postal address, email address, telephone, details of your pet and, if applicable, payment information. These are collected to help us:

* Provide veterinary care to your pet;

* Register your details as a new client at one of our surgeries or with one or our specialist referral services (or update your details if they change) or make appointments at a Abbey House surgery or with one or our specialist referral services;

* Manage and process your health plans;

* Process payments due to us (including for treatments for your pet);

* Contact you about your pet, account or credit status where required;

* Prevent and detect fraud – to do this, we may need to disclose information to assist legal or debt recovery processes;

* Understand your needs and listen to your feedback via market research/analysis, customer polls and surveys;

* Enhance your Abbey House experience by delivering personally tailored offers;

* Send you reminders about appointments, vaccination dates and flea and worm treatment dates

* Send you marketing and promotional offers and to manage your marketing preferences if you elect not to receive marketing and promotional offers from us;

* Speed up your form filling processes if you’ve registered online;

* Respond to any issues or queries.

* Conduct analytics to understand how our services are used; and/or

* Notify you about changes to our service.

Information that we collect automatically

When you visit our Websites or Apps, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, operating system, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Websites and Apps, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Websites or Apps, where they come from, what content on our Websites and Apps is of interest to them, what they have viewed or looked at and in some instances what they have purchased. We use this information for internal analytics purposes, to improve the quality and relevance of our Websites and Apps to our visitors and users and to deliver personally tailored retail offers (both on the website and through triggered email, SMS and direct mail (but only where you have agreed to these channels)).

Some of this information may be collected using cookies, tracking pixels and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. For example we may receive personal information from other veterinary professionals if you are referred to one of our specialist referral services or if you transfer from

another veterinary surgery and register as a client of a Abbey House surgery.

If you have any questions about the third parties we obtain personal information from, please contact us using the contact details provided under the “How to contact us” heading below.

Enhancing our data

Where we have obtained your personal information from various sources (including personal information we have lawfully obtained from third parties) we may combine this information in certain circumstances in order to enhance our understanding of your requirements and preferences in relation to our products and services. This is necessary for the purposes of our legitimate interests to ensure that we provide you the most appropriate offers for products and services and to personalise your Abbey House experience.

Conducting analytics

We will use the personal information we hold about you (as well as pseudonymised or anonymised information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our clients and ensuring that our services and products meet the needs of our customers. We undertake data analytics, whereby we combine information we hold on a large scale in order to:

* Learn more about our clients and their preferences;

* To identify patterns and trends amongst our clients;

* Enhance user experience on our Websites and Apps;

* Provide information, content and offerings tailored to our clients’ needs;

* For general research and statistical purposes;

* For aggregated reporting purposes within the Abbey House;

* To help us develop new services, treatment plans, health plans and products;

* To monitor performance of our services;

* To be able to send you personalised marketing messages; and

* To display online advertisements to you.

We will use your personal information (including by anonymising and aggregating it with other customers’ personal information) for sales, supply chain and financial analysis purposes, to determine how we are performing and where improvements can be made and where necessary to report back to other members of the Abbey House. This is necessary for the purposes of our legitimate interests in understanding how our business is performing, and considering how to improve our performance.

5. Who do we share your personal information with?

We may disclose your personal information to the following categories of recipients:

* to specialist referral centres or specialist veterinary hospitals, when we refer your pet for specialist diagnosis or treatment;

* to other veterinary professionals, if you request that we transfer your pet’s patient history on transferring to another veterinary surgery;

* to insurance companies with whom you have insured your pet;

* to laboratories and other suppliers who you have agreed we may provide your details to and who require them in order to provide services in relation to your pet;

* to other members of Abbey House, our third party services providers and business partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information. Examples of the kind of third parties we work with are:

* IT companies who support our Websites, Apps and other business systems;

* Direct marketing companies or other third parties who help us manage electronic communications with you;

* Google, Facebook, Instagram, Twitter and similar platforms to show you services that might interest you while you’re browsing the internet; This is based on either your marketing consent or your acceptance of cookies, tracking pixels or similar tracking technology on our websites, as explained further under the heading “Cookies and similar tracking technology” below; and/or

* Data insight and data analysis companies (to provide us with tools to analyse the data which we hold);

* Promotional partners;

* Customer review companies (so you can leave feedback and we can improve our service to you); and/or

* Competition or prize-draw partners

* To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or apply our Terms and Conditions, or (iii) to protect your vital interests or those of any other person;

* To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy;

* To any other person with your consent to the disclosure.

Where we share your personal information with third party service providers and partners we apply a policy to ensure your personal information is safe and in order to protect your privacy. Our policy requires:

* We provide only the information they need to perform their specific services.

* They may only use your data for the exact purposes we specify in our contract with them.

* We work closely with them to ensure that your privacy is respected and protected at all times.

* If we stop using their services, any of your personal information held by them will either be deleted or rendered anonymous (subject to applicable law).

If you have any questions about the third parties we share your personal information with, please contact us using the contact details provided under the “How to contact us” heading below.

6. Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

7. Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

8. How do we keep your personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include:

* Encrypting your personal information.

* Keeping your information up-to-date and accurate. Please note that, to do this, we require you to tell us if any of your details such as your name or address change; and

* Having in place strict security procedures for the storage and disclosure of your information to prevent unauthorised access.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to and/or through our Websites and Apps; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

To ensure that your credit, debit or charge card is not being used without your consent, we will validate name, address and other personal information supplied by you during the order process against appropriate third party databases. By accepting our Terms and Conditions you consent to these checks being made. In performing these checks personal information provided by you may be disclosed to a registered Credit Reference Agency which may keep a record of that information. You can rest assured that this is done only to confirm your identity, that a credit check is not performed and that your credit rating will be unaffected. All information provided by you will be treated securely and strictly in accordance with this Privacy Policy.

9. International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of the UK.

Our Website servers and group companies are located in the UK, but some of our third party service providers and partners operate outside of the UK, such as in Australia and the United States. This means that when we collect your personal information we may process it in any of these countries.

If we do this, we have procedures in place to ensure your personal information receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us using the contact details provided under the “How to contact us” heading below.

Any transfer of your personal information will follow applicable laws and we will treat the information under the guiding principles of this Privacy Policy.

10. Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. For more information about the specific periods for which we retain your data, please contact us using the contact details provided under the “How to contact us” heading below.

11. Your data protection rights

You have the following data protection rights:

* If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting the practice your pet is registered with.

* In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.

* You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.

* Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

* You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, see the section headed “contacting the regulator” below.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. Contacting the regulator

If you feel that your personal information has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to raise a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns(please note we cannot be responsible for the content of external websites).

13. Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

14. How to contact us

If you have any questions or concerns about our use of your personal information, please contact us by emailing reception@abbeyvetspets.co.uk.

The data controller of your personal information will be Abbey House.