Data Processing Agreement

Last Updated MAY 2024

This We R Vets HQ Data Processing Agreement and its Annexes A, B, and C (“DPA”) is between We R Vets HQ and the party executing this agreement as Customer (“Customer”). This DPA reflects the parties’ agreement with respect to the Processing of Personal Data by We R Vets HQ on behalf of Customer in connection with the Service under the contemporaneously-executed Terms of Service agreement between the parties (“Agreement”).

This DPA is part of the Agreement and is effective upon execution or another time as specified in the Agreement, an Order or an executed amendment to the Agreement. In case of any conflict or inconsistency with the terms of the Agreement, this DPA will take precedence over the terms of the Agreement to the extent of such conflict or inconsistency, and it will supersede any previous DPA.

1. Definitions

a. CCPA means California Civil Code Sec. 1798.100 et seq. as amended (also known as the California Consumer Privacy Act of 2018), including the California Privacy Rights Act amendments to the CCPA.

With Affiliates and Subsidiaries. For purposes limited to and consistent with this Privacy Policy.
With Suppliers.Our authorized vendors and suppliers may require Personal Information to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at We R Vets, and we process Personal Information using these tools as a regular course of business. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.
With Partners. We occasionally have relationships with third parties that are not suppliers or vendors but are working with us to offer certain opportunities such as marketing and similar promotions, to enable joint products or research studies, or to facilitate services on the Platform. In these cases, additional terms or Privacy Policies may be provided. For third parties or uses not described in this Privacy Policy, we share your information only with a lawful basis to do so.
For Advertising and Marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalized ads and to study the effectiveness of our campaigns.

In particular, we use third-party companies to communicate regarding goods and services that may be of interest to you, in accordance with your preferences. You may receive this content by a variety of means such as email, phone or when you access and use the Platform or other We R Vets Services, and other websites. Content may be based on information obtained, for example, through prior purchases or transactions, through your device’s physical location, through information about what advertisements and content you have viewed, or through cookies and similar technologies relating to your access to and use of the Platform and other websites. Please read our Cookies Policy for more information. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, our partners may not be able to provide you with the applicable Platform Services and content.

For Connections to Social Networks and Third Party Services. Where you are using our Services and have chosen to connect your social networks profiles to the We R Vets Services, or if you authorize a third party service to access your account, you are agreeing to provide information about you to the social networks and the third party services under their respective terms and privacy policies. For example, if you choose to connect your YouTube account to the We R Vets Services, this connection uses YouTube’s API services, and the Google Privacy Policy (located here) will apply to you. If you have authorized us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, located here.
Sales, Mergers & Acquisitions. We may disclose Personal Information as part of a contemplated or actual corporate transaction such as a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
With Your Consent. We R Vets may disclose your Personal Information to any other person or entity where you consent to the disclosure. For information about how to decline our advertising and marketing, please see the section entitled "Your Choices & Rights" below.

We also share non-personally identifiable information, such as anonymized or aggregated information, with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new We R Vets Services.

We R Vets does not sell any of your Personal Information for monetary compensation.

6. Information From Children

We do not knowingly collect, use, or disclose Information from children under 16. If we learn that we have collected the Personal Information of a child under 16—or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States per the Children’s Online Privacy Protection Act—we will take steps to delete the information as soon as possible. If you are under 16, do not provide any Information about yourself to We R Vets, including your name, address, telephone number or email address. If you become aware that Information of a child under 16 years of age has been provided, please use one of the methods provided under the “HOW TO CONTACT US” section below.

7. Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on behalf of We R Vets, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any Personal Information you disclose to other organizations through or in connection with the Platform or other We R Vets Services.

8. Do Not Track

Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

9. YOUR LEGAL RIGHTS

We R Vets respects your rights in how your Personal Information is used and shared. Depending on where you live, you may have rights to request access or corrections to your personal data and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from We R Vets at all). See below for more information, depending on your location.

10. European Privacy Rights

If you are in Europe, you may have additional rights under the GDPR, the UK GDPR, or nFADP. Additional choices and rights may be available to you depending on which We R Vets Services you use.

Access, Correction to or Deletion of Your Information. If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the “HOW TO CONTACT US” section below. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.
At your request and where the law requires us to do so, we will confirm what Personal Information we hold about you. You may also have a legal right to obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the “HOW TO CONTACT US” section below. We may charge a processing fee for this service where permitted by law and we will require evidence of your identity before fulfilling your request.
Data Privacy Rights Specific to Individuals in the European Economic Area, the United Kingdom, and Switzerland. 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 making a written request in the ways described in the “HOW TO CONTACT US” section below.
Similarly, if we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.
If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, contact your local data protection authority.
Advertising and Marketing Choices. We give you many choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes. You may access or update your contact details and modify your communication preferences by using one of the methods provided under the “HOW TO CONTACT US” section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue or product delivery. Some advertising content is delivered through the Platform’s use of cookies and similar technologies. Our Cookies Policy includes more information on We R Vets’s use of such technologies for advertising and other purposes.

11. International Compliance

We R Vets is a global company with its headquarters in the United States. As such, we may transfer your Personal Information between the United States and our affiliates and business partners in other countries. We may also transfer your Personal Information to our third party service providers, who may be located in a different country to you.

We R Vets transfers information internationally in order to operate efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other problem. In so doing, we will process your Personal Information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.

Whenever We R Vets transfers Personal Information beyond the country of origin, we will do so in accordance with applicable laws. We R Vets commits to the protection of your Personal Information and, as needed, will take additional steps to provide appropriate safeguards for the Personal Information we transfer. We R Vets may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We R Vets is liable in cases of onward transfers to third parties.

12. California Privacy Rights

This section is addressed to California residents only and provides more information about your rights under the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.), as amended. Subject to certain exceptions, the CCPA grants to California residents the rights to: be notified about the collection, use, disclosure, sale or sharing of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the “sale” or “sharing” of Personal Information (where such information is sold or shared); limit the use or disclosure of Sensitive Personal Information (as defined under CCPA); and to not be discriminated against for exercising such rights.

We R Vets does not sell your Personal Information. If you wish to exercise your right to opt-out of We R Vets using your Personal Information for cross-contextual targeted advertising purposes (called “sharing” under the CCPA), you may do so by using the details in the “HOW TO CONTACT US” section or the appropriate withdrawal mechanism provided to you on the Platform.

You can request access to, correction of or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that We R Vets may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by CCPA. If you submit a request to exercise rights under CCPA, We R Vets will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with We R Vets and the sensitivity of Personal Information at issue. If We R Vets denies your request, we will explain why.

You can designate an authorized agent to make a request under the CCPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, We R Vets may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CCPA. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and We R Vets will respond to any request from such authorized agent in accordance with the CCPA.

The Privacy Policy describes the categories of Personal Information that We R Vets collects and how We R Vets uses such Personal Information. If We R Vets collects Sensitive Personal Information, we limit our use of the Sensitive Personal Information to uses: (1) you have authorized, (2) that are required to fulfill your requests for goods or services, or (3) that are otherwise allowed by the CCPA or required by other laws or regulations.

The categories of Personal Information collected, disclosed, and sold from California residents over the preceding 12 months and We R Vets’s applicable retention periods include:

Personal Information Category

Retention Period

Business Purpose

Collected

Disclosed

Sold

Personal information defined in Civil Code Section 1798.80(e) (such as signature, SSN, financial information, and insurance information, etc.)

Protected personal information (such as gender, religion, sexual orientation, or disability)

Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, etc.)

See Section 3 of Privacy Policy: “Retention of Your Personal Information”

For development, customer support, business operations, communication, advertising and marketing, and statistical purposes.

Yes

Biometric information

Internet or other similar network activity (such as information on a consumer’s interaction with a website, application, or advertisement, etc.)

See Section 3 of Privacy Policy: “Retention of Your Personal Information”

For functionality, business operations, and statistical purposes.

Yes

Geolocation data

See Section 3 of Privacy Policy: “Retention of Your Personal Information”

For functionality, business operations, and statistical purposes.

Audio, electronic, visual, thermal, or olfactory information

Education information

Inferences (such as analytics and preferences

Yes

13. Colorado Privacy Rights

This section is addressed to Colorado residents only and provides more information about your rights under the Colorado Privacy Act or “CPA.” Subject to certain exceptions, the CPA grants to Colorado residents the rights to: be notified about the collection, use, disclosure, or sale of their Personal Information; request access to, deletion of, or correction of their Personal Information; and request to opt out of the use of Personal Information for targeted advertising, sale, or certain profiling.

You can request access to, correction of or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that We R Vets may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by CPA. If you submit a request to exercise rights under CPA, We R Vets will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with We R Vets and the sensitivity of Personal Information at issue. If We R Vets denies your request, we will explain why. If we have not responded to your request or asked for additional time to respond to your request within 45 days after you send us a request, you have the right to appeal our failure to take action. To appeal our failure to take action, contact us using the details in the “HOW TO CONTACT US” section.

You can designate an authorized agent to make a request under the CPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, We R Vets may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CPA.

14. Connecticut Privacy Rights

This section is addressed to Connecticut residents only and provides more information about your rights under the Connecticut Data Privacy Act or “CTDPA.” You can exercise your rights by using the details in the “HOW TO CONTACT US” section. If we inform you that we decline to take action regarding your request, you have the right to appeal our failure to take action by contacting us using the details in the “HOW TO CONTACT US” section.

15. Utah Privacy Rights

This section is addressed to Utah residents only and provides more information about your rights under the Utah Consumer Privacy Act or “UCPA.” You can exercise your rights by using the details in the “HOW TO CONTACT US” section.

16. Virginia Privacy Rights

This section is addressed to Virginia residents only and provides more information about your rights under Virginia’s Consumer Data Protection Act or “VCDPA.” Subject to certain exceptions, the VCDPA grants to Virginia residents the rights to: be notified about the collection, use, disclosure, or sale of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the use of Personal Information for targeted advertising, sale, or certain profiling; and to not be discriminated against for exercising such rights.

You can request access to, correction of or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that We R Vets may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by VCDPA. If you submit a request to exercise rights under VCDPA, We R Vets will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with We R Vets and the sensitivity of Personal Information at issue. If We R Vets denies your request, we will explain why. If we inform you that we decline to take action regarding your request, you have the right to appeal our failure to take action. To appeal our failure to take action, contact us using the details in the “HOW TO CONTACT US'' section.

17. How To Contact Us About This Privacy Policy

To ask questions about this Privacy Policy and our privacy practices, contact us at [email protected] or by mail at:

We R Vets

ATTN: Legal Department

8412 Williams Dr

Frederick, MD 21704