GuardianVets Connect Privacy Policy

Last Updated: February _, 2022

Protecting your private information is important to us. This Privacy Policy (this “Privacy Policy”) describes how information about you is collected, used and disclosed by GuardianVets, Inc., a Delaware corporation ("GuardianVets" or "we," “us” or “our”), when you access or use the GuardianVets Connect mobile or desktop application and or otherwise interact with us or use our services and features we make available or content provided by us (collectively, the “App”). “You” refers to any person accessing and/or using the App, as a Doctor of Veterinary Medicine (“DVM”) or as a member of a veterinary practice. 

BY USING THE APP, YOU ACCEPT AND EXPRESSLY AGREE TO OUR PRACTICES SURROUNDING THE COLLECTION, USE, AND SHARING OF PERSONAL INFORMATION (REFERRING TO ANY INFORMATION THAT RELATES TO AN IDENTIFIED OR IDENTIFIABLE INDIVIDUAL) AND NON-PERSONAL INFORMATION (REFERRING TO INFORMATION THAT DOES NOT IDENTIFY YOU AS A SPECIFIC INDIVIDUAL) PROVIDED BY YOU IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THE PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO ACCESS, BROWSE OR USE THE APP IN ANY MANNER OR PROVIDE US WITH ANY OF YOUR INFORMATION.

Updates to our Privacy Policy
GuardianVets reserves the right to change or modify this Privacy Policy at any time and in our sole discretion. If we make changes to this Privacy Policy, we will provide notice of such changes, such as by sending an email or SMS text message notification, providing notice through the App or updating the “Last Updated” date at the beginning of this Privacy Policy. We encourage you to review this Privacy Policy whenever you use or access the App or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

What this Privacy Policy Covers
This Privacy Policy applies to our collection, use and sharing of your personal information (a) when you use the App, (b) receive our communications, and (c) that we obtain from third parties.

This Privacy Policy does not apply to information collected by: www.guardianvets.com, GuardianVets Triage Service GuardianVets offline or by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the App.

Minors
The App is not intended for or directed to persons under the age of 13, and we will not knowingly collect information from such persons. Any person who provides information to us through registration or in any other manner on the App represents to GuardianVets that they are 13 years of age or older. If we learn that a child under 13 has submitted personal information to us, we will attempt to delete the information as soon as possible.

Information We Collect 
Information You Give Us. Personal information you may provide through the Application or otherwise communicate to us includes:

Account Registration and Validation. In order to use the App, you will need to register for an account and provide identification and licensing validation, if applicable, depending on your role in the veterinary practice. In this process we will collect certain personal information including your first and last name, a username, phone number, and email. In addition, you will be asked to provide us with a digital scan or picture of your government issued ID (including name, ID state, ID number, expiration dates and address information). You will further be asked to provide us with  your veterinary license details (including licensing state, number and expiration date) or such other license as is required by your role in the veterinary practice. See [INSERT LINK TO FAQ] for further details


Profile Information. We collect information provided to us when individual or organizational profiles are created for use in connection with the App.

Uploaded Content. We collect information you provide while using the App including communications, consultation summaries, payment requests, and images and videos you may upload during the course of or in connection with a virtual consultation. Such information may also include contact information for pet owners or others.

Communications and Contact. We collect information about you when you provide contact and identity confirmation and other information to us via SMS message, email, phone call, mail, or through the App, including as a result of creating an account, signing up for communications, response to surveys, requesting support or any other communications through the App or with us. This information may include your first and last name, email, phone number, photos, gender, date of birth, location and information related to the reason for contact. 

Recordings of Consultations.  We may record calls and other communications for the applicable clinic’s use as required for medical record keeping.

Payment information. We collect information related to payment methods that could be used for purchases or payments. This information may include your first and last name, bank routing and account number, credit card information (card number, expiration, CVV number) and zip code.

Other information. We may collect other information from you that is not specifically listed here. We may use such information in accordance with this Privacy Policy.

By submitting personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Information We Get From Others. We may obtain additional information about you from third party sources to provide you with more relevant information about our services. We may obtain information about you from other sources and combine that with information we collect directly. For example, we may collect information about you when you post content to feeds on third-party social media sites, or if you use credentials (e.g., username and password) from a third-party site to create or log into your GuardianVets Connects account. Additionally, we may receive information about you from our partners. For example, our payment processors may update your payment information, advertising partners may help us send communications to your email address, and third parties may help us prevent fraud by verifying your contact information.

Information Automatically Collected. Our App, servers and third party service providers may automatically record certain information about how you use the App, such as information about your device (phone, laptop, tablet, etc.), device identifiers, your Internet Protocol (IP) address, device and browser type, operating system, internet service provider, your mobile carrier, DNS, geographic or GPS information, purchase history, the frequency with which you use the App, and other statistics and information. We may collect information about how you use our App. We may use this information to gain a better understanding of the users of our App, to improve our App, and to improve our services.

We reserve the right to license or sell aggregate, de-identified information collected from or about the users of our App.

How We Use Your Information
We may use the information we collect about as disclosed and described in this Privacy Policy or at the time of collection:

To operate, maintain, enhance and provide features of the App;

To create and maintain your account;

To provide communication between you, pet owners, other DVMs and members of applicable medical practices in connection with the virtual veterinary consulting services you may provide through the App;

To facilitate calls or other communications including direct messaging between you, pet owners, other DVMs and members of applicable medical practices 

To keep your business emails, address, names, and phone numbers updated and publicly displayed through the GuardianVets platform;

To understand and analyze the usage trends and preferences of our users, improve the App, and develop new products, services, features, and functionality;

For marketing purposes, such as developing and providing promotional and advertising materials;

To contact you for administrative and informational purposes (including to provide customer support, to respond to your questions or requests, and contact you about your account, or updates to this Privacy Policy or the Terms of Use);

To aggregate and de-identify data collected through the App and use/disclose it for any purpose;

For account and licensing verification (as described in the Terms of Use), audits, security, compliance with applicable laws and regulations (including medical record keeping requirements), fraud monitoring and prevention; and to enforce our Terms of Use or other legal rights.

How We Share Your Information
When you provide information to us, you are granting us permission to use and take other actions regarding such information, to provide the services offered through the App. We do not sell or rent your personal information to third parties to use for their own marketing purposes. We do not otherwise distribute this information to others, except as disclosed in this Policy. 

We may process or share your personal information with third parties outside of GuardianVets based on the following legal basis:

Consent. We may share your information when you consent affirmatively, or through your use of the App as provided in this Privacy Policy. This also includes when you choose for us to share your account information with your or another veterinary practice. 

Legitimate Interests. We may process your information when it is reasonably necessary to achieve our business interests. 

Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process or share your personal information in the following situations: To

Service Providers and Contractors: We reserve the right to disclose to service providers, contractors, or other third parties any or all of the information that we collect online about you and other visitors to conduct business on our behalf. These activities could include processing payments, maintaining the App, or facilitating email delivery to you. We require that our service providers protect your personal information with the same standards we do but we are not responsible for their policies or practices.

Business Transactions: If we go through a business transfer, such as consolidation, merger, restructuring, acquisition, or sale of part or all of our assets, or a capital raise, you acknowledge and consent to the transfer of your information, and to the continued use of your information by the transferee so long as they comply with this Privacy Policy.

Third-Party Advertisers: We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the App and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the App and better understand your online activity.

Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include joint venture partners or other companies that we control or are under common control with us.

Please take note that whenever you voluntarily make your personal information available for viewing by third parties online – for example by posting comments in forums or through email – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.GuardianVets may also share non-personally identifiable information with third parties (e.g. aggregate or demographic data), which cannot reasonably be used to identify you.

Other Websites and Services 
We are not responsible for the practices employed by any websites and/or services linked to and/or from the App, including without limitation the content contained therein. Please remember that when you use a link to go from our App to another website, our Policy does not apply to those third-party websites and/or services. Your browsing and interaction on any third-party website, including those that have a link on our App, are subject to such third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk. 

Data Retention
We will retain your personal data only for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may retain and use this information indefinitely without further notice to you.

Security 
GuardianVets takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We believe this security program is appropriate to the size, scope and type of our business, the resources available to us, the amount of stored data and the need for security and confidentiality of the personal information we store. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to or from us over the Internet. 

Data Transfers 
The App is targeted for users in the United States. Please be aware that the App is subject to United States laws, including those governing privacy and security of your information. We may host and process data, including your personal information in the United States and in other countries, if applicable, through third parties that we use to operate and/or manage the App. If you are a visitor from outside the United States, by using the App, you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in the European Union or other countries, and to the processing of that information as described in this Policy.

Your ChoicesAccount Information
You may update, correct or modify information about you at any time by logging into your online account or by emailing us at support@guardianvets.com. If you wish to deactivate your account, please email us at support@guardianvets.com, but note we may continue to store information about you as required by law or for legitimate business purposes or to comply with legal requirements or in accordance with the terms of any agreement between you and GuardianVets.

Location Information
With your consent, we may collect information about your actual location when you use the App. You may stop the collection of this information at any time by changing the settings on your mobile device, but note that some features of our mobile applications may no longer function if you do so.

Promotional Communications
You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at support@guardianvets.com. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Push Notifications
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our mobile application.

Advertising and Analytics
For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. California residents may have additional personal information rights and choices. Please see “Special Note Regarding California Residents” below for more information.

Special Note Regarding Residents of California
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please see our Privacy Notice for California Residents.

Notice to European Users
This App is targeted for users in the United States. Any information you enter on the App may be transferred outside of the European Union to the United States which does not offer an equivalent level of protection to that required in the European Union. By using the App or utilizing any of the services through the App, you consent to the transfer of all such information to the United States which may not offer an equivalent level of protection to that required in the European Union and to the processing of that information by GuardianVets on its servers located in the United States as described in this Privacy Policy.

Contact Us
If you have any questions about this Privacy Policy, please contact us at [INSERT MAILING ADDRESS], [INSERT PHONE NUMBER] or by email at support@guardianvets.com. We will use our commercially reasonable efforts to promptly respond and resolve any problems or questions.Privacy Notice for California ResidentsLast Updated: February, 2022

This Privacy Notice for California Residents
supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect
Our App may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). Personal information does not include:—Publicly available information from government records.—Deidentified or aggregated consumer information.—Information excluded from the CCPA’s scope, like:-health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California -Confidentiality of Medical Information Act (CMIA) or clinical trial data;-personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.We obtain the categories of personal information listed above from the following categories of sources:—Directly from you. For example, from information you provide when registering for an account on our Site.—Indirectly from you. For example, from observing your actions on our Site or interactions with our advertisers.

Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following business purposes:—To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.—To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.—To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.—As described to you when collecting your personal information or as otherwise set forth in the CCPA.—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 except as set forth in this Privacy Policy or our Terms of Use.

Sharing Personal Information
GuardianVets may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, GuardianVets has not sold or disclosed personal information for a business purpose that is not anonymized as set forth in this Privacy Policy or our Terms of Use.

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
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 and confirm your verifiable consumer request, we will disclose to you:—The categories of personal information we collected about you.—The categories of sources for the personal information we collected about you.—Our business or commercial purpose for collecting or selling that personal information.—The categories of third parties with whom we share that personal information.—The specific pieces of personal information we collected about you (also called a data portability request).—If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that GuardianVets delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:—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, or otherwise perform our contract with you.—Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.—Debug products to identify and repair errors that impair existing intended functionality.—Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.—Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).—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.—Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.—Comply with a legal obligation.—Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on the App. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.The verifiable consumer request must:—Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.—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.We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.We will deliver our written response by mail or electronically, at your option.Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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, specifically by electronic mail communication.We do not charge a fee to process or respond to your verifiable consumer 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.

Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting the App and sending us a message.We will only use personal information provided in an opt-out request to review and comply with the request.Additionally, California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to use using the contact information provided below.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:—Deny you goods or services.—Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.—Provide you a different level or quality of goods or services.—Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the App and update the notice’s effective date. Your continued use of the App following the posting of changes constitutes your acceptance of such changes.

Contact Information
If you have any questions or comments about this notice, the ways in which GuardianVets collects and uses your information described herein and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at [INSERT MAILING ADDRESS], [INSERT PHONE NUMBER] or by email at support@guardianvets.com

Copyright © 2021 GuardianVets. All Rights Reserved.
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