Privacy And Cookie Policy

1. General information

In this privacy and cookie policy (the “Privacy Policy”), we explain in detail the policies and procedures governing the collection and processing of individual users’ (“you” and “your”) personal data through the website https://borovalleyvetclinic.ie (the “Website”).

Definitions. In the Privacy Policy, you will encounter recurrent terms. We would like to explain you what such terms mean:

• “Consent” means your freely given, specific, informed and unambiguous agreement to the processing of your personal data;
• “Data controller” means the entity that determines the purposes and means of the processing of your personal data;
• “Data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller;
• “Personal data” means any information relating to a natural person who can be identified, directly or indirectly, by using such information (e.g., your name, email, and IP address);
• “Processing” means the use of personal data in any manner, including, but not limited to, collection, storage, erasure, transfer, and disclosure of personal data.

Responsible entity (data controller). The company that is responsible for collecting and processing your personal data through the Website is Borovalley Veterinary Clinic having a principal place of business at Ballybrittas, Bree, Enniscorthy, Co. Wexford Y21HD91, Ireland (“we”, “us”, and “our”).

Applicable laws. The processing of your personal data is done in accordance with the applicable data protection laws, including the Irish Data Protection Act 2018 and the EU General Data Protection obligation (GDPR).

 

2. About the Website

The Website features information about the veterinary services (the “Services”) provided by us and the contact details of The Borovalley Veterinary Clinic operated by us. The Website also offers a possibility to make payments for the Services provided at the premises of the The Borovalley Veterinary Clinic.

Minors. The Website is not intended for users under the age of 18. If a person under 18 has provided us with his/her personal data without obtaining parental or guardian consent in advance, the parent or guardian may request us to destroy or de-identify the personal data. Our contact details are specified in Section 14 of this Privacy Policy.

 

3. What personal data do we collect?

We adhere to data minimization principles. Therefore, we collect and processes only a minimal amount of information that is strictly necessary for performing the operations requested by you (e.g., sending you a newsletter).

We collect the following personal data:

• When you browse the Website, we collect your IP address.
• When you sign up for our online newsletter through the subscription form available on the Website, we collect the following information:
  • Your first name (optional);
  • Your last name (optional);
  • Your email address (required);
  • Your county (optional); and
  • Your role as an animal owner (optional).
• When you contact us by email, we collect:
  • Your email address;
  • Your name; and
  • Any other information that you decide to provide us.

Making payments. When you make payments through the Website, you will be requested by our third-party payment processor Stripe (“Stripe”) to submit information, such as your name, credit/debit card number, phone number, and email address. Please note that we do not store and have no access to the payment information. Stripe handles all steps of payment processing on its website. Stripe provides an adequate level of protection of your personal data by adhering to the principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. For more information about Stripe’s privacy practices, please visit https://stripe.com/be/privacy.

Accuracy of personal data. By providing your personal data, you acknowledge and agree to submit the personal data that is up-to-date, true, accurate, current, and complete. In case your personal data changes, you agree to notify us as soon as such changes occur by following the instructions described in Section 10 entitled “Your rights regarding your personal data”.

Sensitive data. Please note that we do not collect any sensitive personal data from you (e.g., your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation.).

Failure to provide personal data. If you decide not to provide your personal data (e.g., your email address), we will not be able to deliver the requested services (e.g., the newsletter you subscribe to).

 

4. For what purposes do we use personal data?

We respect strictest data protection principles and use your personal data only for the legitimate purposes for which it is provided:

• Your IP address will be used to conduct research on our users’ demographics, interests, and behaviors, and to analyze and improve our business activities. Such purposes fall within the scope of the legal ground of pursuing our legitimate business interests (i.e., to analyze, grow and promote our business).
• Your email address and other details provided to subscribe to a newsletter will be used to send you a newsletter and other marketing communication that can be of interest to you. Such purpose falls within the scope of the legal ground of your freely provided consent (i.e., your voluntary decision to subscribe to a newsletter).
• Your email address, name, and other information that you decide to provide us when you contact us by email will be used to reply to your emails and provide you with the requested information and services (e.g., to book an appointment).

Repurposing your personal data. If we would like to use your personal data for purposes that are not mentioned in this Privacy Policy (i.e., repurpose your personal data), we will notify you and, if required by the applicable law, seek your prior consent to those specific purposes.

 

5. Non-personal data

Types of non-personal data. We may collect non-personal data, such as your browser types, device types, operating systems, time/date stamps, search history, and the URL addresses of websites clicked to and from the Website.

Purposes of non-personal data. We collect the non-personal data mentioned in this Section 5 for online analytics purposes only, such as analyzing what kind of users visit the Website, how they find it, how long they stay, from which other websites they come to the Website, what pages they look at, and to which other websites they go from the Website.

Aggregated data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will treat such aggregated data as personal data.

 

6. Consent

Your use of the Website is subject to this Privacy Policy. Thus, we strongly encourage you to review the Privacy Policy. Please make sure that you fully understand it and you agree to the processing of your personal data through the Website.

Obtaining your consent. In some cases (where required by the applicable law), we may seek your prior consent in situations, such as:

• If we intend to collect other types of personal data that are not mentioned in this Privacy Policy;
• If we intend to use your personal data for the purposes that are not indicated in this Privacy Policy;
• If we would like to disclose or transfer your personal data to third parties that are not indicated in this Privacy Policy and cannot provide adequate level of protection; or
• If we significantly amend this Privacy Policy.

 

7. Marketing communication, advertisement, and notices

Marketing and advertising. To send you direct marketing messages, such as newsletters, brochures, promotions and advertisements, or contact you by any other means with the purpose to offer you our services, we will seek your express (“opt-in”) consent. Please note that your voluntary subscription to the newsletter substitutes such opt-in consent. We may also inform you, without obtaining your prior consent, about our new products and services that are closely related to the products and services already used by you.

Informational notices. From time to time, if we have your contact details, we may send you informational notices. We send such notices on an “if-needed” basis and they DO NOT fall within the scope of direct marketing communication that requires your prior consent (as described above). Such informational notices include:

• Important information about the Website, your privacy and security, and other important matters; and
• Updates about the Services requested by you.

Refusing marketing communication. You can opt-out from receiving marketing messages at any time free of charge by clicking on the “unsubscribe” link contained in any of the messages sent to you or contacting us directly.

 

8. Security of personal data

We use technical and organizational security measures, such as secured networks, secure physical environment, and limited access by our staff, to protect your personal data. We put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data.

Data breaches. Although we put our best efforts to protect your personal data, we cannot be liable for any destruction, loss, leakage, and falsification of personal data caused by circumstances beyond our reasonable control. In case a personal data breach occurs, we will inform the local data protection authority without undue delay and immediately take reasonable measures to mitigate the breach, as required by the applicable law.

Your responsibility for using the Website. In order to ensure the security of your personal data, we kindly ask you to keep all the information related to your use of the Website in a secure and confidential manner and use the Website through a secure network only.

 

9. Third party access to personal data

Do we disclose personal data? In some circumstances, we disclose your personal data to third-party service providers (data processors). For example, we may share your personal and non-personal data with entities that provide certain services to us, such as web analytics, data processing, advertising, email distribution, and developing services.

When do we disclose personal data? The disclosure and sharing of your personal data is limited to the situations when the personal data is required for the following purposes:

• Ensuring the operation of the Website;
• Pursuing our legitimate business interests;
• Carrying out our contractual obligations;
• Law enforcement purposes; or
• If you provide your prior explicit consent to the disclosure.

List of data processors. The data processors that we cooperate with include:

• Our hosting provider Hostgator;
• Our lead generation provider Leadshook;
• Our mailing partner MailChimp;
• Our payment processing partner Stripe; and
• Our web analytics provider Google Analytics.

The data processors listed above will access your personal data as a part of their partnership with us and only if they agree to ensure (by way of a data processing agreement) an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws.

Transfer of personal data outside the EEA. If you are a resident of the EEA, we may transfer your personal data from the EEA to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the recipient third party ensures an adequate level of protection of your personal data.

 

10. Your rights regarding your personal data

What rights can you exercise? You have the right to manage the personal data that we collect from you. We provide you with a possibility to request us to:

• Get a copy of your personal data that we store;
• Rectify inaccurate personal data;
• Move your personal data to another processor;
• Delete your personal data from our systems;
• Object and restrict processing of your personal data;
• Withdraw your consent; or
• Process your complaint.

How to exercise your rights? If you would like to exercise your rights, please contact us by email at [email protected] and explain in detail your request. In order verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 2 weeks.

How to launch a complaint? If you would like to launch a complaint about the way in which your personal data is handled by us, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible but no later than 2 weeks. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority, such as Irish Data Protection Commission.

 

11. Retention period

Your personal data will be kept for as long as is necessary to provide you with the requested service (e.g., delivering a newsletter or replying to your request) or there are other legitimate grounds for data processing. When your personal data is no longer necessary for its legitimate purpose (e.g., you unsubscribe from the newsletter service), we will securely delete your personal data as soon as possible.

 

12. Third-party links

The Website may contain web links to other websites (e.g., social media providers). Please note that this Privacy Policy does not apply to any of such third-party websites and we are not responsible for the privacy and security practices of those third parties. Please familiarize with the privacy practices of such third-party websites before using them.

 

13. Cookies

The Website uses cookies. In this section, you can find information about the types of cookies that we use and the purposes for which the cookies are used. If you do not agree with our use of cookies, please disable your cookies after consulting the Section “How to disable cookies?”. Please note that the full functionality of the Website is available only if the cookies are enabled.

What is a cookie? A cookie is a small piece of data, typically consisting of letters and numbers. When you visit a website or use an application, the website or application may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer or mobile device. Cookies are designed to allow the recognition of user’s device and collection of certain information about the use of a website or application. Thus, over time, cookies allow the website or application to “remember” your actions or preferences. There are two types of cookies, namely, (i) persistent cookies and (ii) session cookies. Persistent cookies remain valid until their expiration date, unless deleted by the user before that date. Session cookies will be stored on a web browser and will remain valid until the moment when the browser is closed. Cookies may also be (i) first-party cookies set by us and (ii) third-party cookies placed by third party operators (e.g., social media providers).

What cookies do we use on the Website? The table below provides an overview of the cookies used by us on the Website, including their purposes and expiration time.

Cookie	Type	Expiration	Purpose
_gat	First-party Google Analytics session cookie	1 minute	Used to throttle request rate
fr	Third-party encrypted Facebook ID and browser ID cookie	3 months	Advertisement
_gid	First-party Google Analytics cookie	24 hours	Distinguishing users
_ga	First-party Google Analytics cookie	2 years	Distinguishing users

 

For what purposes do we use cookies? We will not use cookies for purposes, which are not mentioned in this Privacy Policy. We use cookies for the following purposes:

• To identify you as a unique user when you use the Website;
• To identify your unique sessions;
• To generate information and reports about your use of the Website;
• To track your online behavior; and
• To analyze and improve our business activities.

Cookie consent. Before you visit the Website for the first time, we will ask you to provide us with your consent to our use of cookies.

How to disable cookies? If you would like to refuse our use of cookies on the Website, you can do it at any time by declining cookies in your browser or device (please check your browser’s or device’s “help” functionality for more information) or visiting https://www.aboutcookies.org and for further information. Please be aware that some parts of the Website may not function properly without cookies.

Google Analytics. We use Google Analytics, the service provided by Google, Inc. (“Google”) to analyze your use of the Website. Google Analytics generates statistical and other information by means of cookies and we use its services to create reports about the use of the Website. Google Analytics cookies are anonymous first-party cookies. Such cookies include cookies entitled “__gat”, “__gid”, and “__ga”. Please note that the use of Google Analytics cookies is anonymous and does not allow us to identify you in any manner. The information generated by cookies about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Please note that your IP address will be anonymized and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245.

Opting-out from Google Analytics. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en or adjusting your browser settings to refuse cookies.

 

14. Contact

If you have any questions or concerns about this Privacy Policy, you would like to exercise your rights or get a copy of the Privacy Policy in a format convenient for you, please contact us by email at [email protected] or please write to the following address:

Borovalley Veterinary Clinic
Ballybrittas, Bree
Enniscorthy
Wexford Y21HD91
Ireland.

 

15. Amendment of the Privacy Policy

We may amend this Privacy Policy from time to time by posting an amended version on the Website and, if we have your contact details, we will send you a notice about all the changes implemented by us. For significant changes in the Privacy Policy, or where required by the applicable law, we may seek your consent.

 

16. Last amendment

This Privacy Policy has been last modified on 17^th of October 2018.