Introduction 

Welcome to Vet-AI Limited’s Privacy Policy.

Vet-AI Limited (Vet-AI, we, us, our) is the data controller of any personal data that is collected when you use our websites, apps, systems or services, and when otherwise interacting with us. We are registered with the Information Commissioner’s Office (ICO) under registration number ZA576403 and have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you do have any questions about this privacy policy, how we process your data and your rights, then you can always contact our data privacy manager using the details set out below.

1. Important information and who we are

About this Privacy Policy

We respect your privacy and are committed to protecting your personal data. This privacy policy has been designed to give you important information about how Vet-AI collects and processes your personal data, and applies to any data that you provide to us through our websites, through any apps or other systems operated by us, when communicating with us, when registering with us, when taking part in any consultation with us or any person working for us, when purchasing a product or service from us or when using any system or platform operated by us, and when taking part in a competition or otherwise engaging with us in any way.

This website is not, and the various systems we operate and the products and services we offer are not, intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Vet-AI Limited Email address: [email protected]

Postal address: Vet-AI Limited, Nexus. Discovery Way, University of Leeds. Leeds. LS1 3AA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 13^th February 2023.

It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our websites, Apps and other systems we use for any form of communication with you may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications and are not responsible for their privacy statements. When you leave our websites, Apps, and other systems we encourage you to read the privacy policy of every website or other system you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• “Personal Contact Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and dependents, billing address, delivery address, postcode, email address and telephone

• “Health Related Data” includes any details concerning your mental and/or physical health and/or wellbeing, and/or any condition affecting you, which you disclose to us at any time, or which otherwise becomes apparent during the course of your relationship with us. Please also see the section below under the heading ‘Health Related Data’ for a fuller explanation of how this may
• “Transaction Data” includes bank accounts, payment card details, tax status and details about payments to and from you and other details of products and services you have purchased from
• “Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access websites, Apps, and other systems we use for any form of communication with
• “Profile Data” includes your username and password, your interests, preferences, feedback, reviews, and survey responses, together with details of any pets or companion animals you own or care for or with which you are connected or have owned and/or cared for or with which you have been connected in the past. This may include weight, age and breed of your pet or companion
• “Usage Data” includes information about how you use our websites, Apps and any other systems we use for any form of communication with you, together with records and/or recordings of your usage of the same in the form of photography, film and video footage with or without sound, sound recordings and other records relating to any consultation we may have with you in relation to any pet or companion animal you own and/or care for or with which you are connected, together with details of your enquiries in relation to and purchases of our products and services and/or any products and/or services you have accessed through us, through any website, App or other system operated by us, or as a result of any referral or recommendation by It also includes your queue time for any online consultations you buy.
• “Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication

Insurance Policy Holders

If you provide us with your insurance policy number at any time when interacting with us through the App then in addition to the other personal data we collect, we also collect the following:

• Identity Data: policy number;

• Usage Data: any services or products we provide to you which is paid for (in whole or part) by your pet insurance provider (whether through a discount code or otherwise); this may include medication or treatment products and an online consultation with one of our vets which is paid for by your insurance

Service Partners

We work with service partners; charities, universities, pet food companies, and pet supplement providers, who may offer our services and products to you by way of referral, and in some cases pay for those services and products for you. If we identity you as someone who has been referred by a partner, in addition to the other personal data we collect, we also collect the following:

• Usage Data: any services or products we provide to you which is paid for (in whole or part) by a service partner (whether through a discount code or otherwise).

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. In addition, Aggregated Data may include services or products that you purchase from us.

Except as set out below under the heading ‘Health Related Data’, we do not collect any Special Categories of Personal Data about you.

Special Category Data is defined as:

• personal data revealing racial or ethnic origin;

• personal data revealing political opinions;

• personal data revealing religious or philosophical beliefs;

• personal data revealing trade union membership;

• genetic data;

• biometric data (where used for identification purposes);

• data concerning health;

• data concerning a person’s sex life; and

• data concerning a person’s sexual

We do not collect any information about criminal convictions and offences.

Health Related Data

We will not actively collect Health Related Data and do not ask for this Special Category of Personal Data to be provided to us. We ask that you take care not to disclose to us any Special Categories of Personal Data (including Health Related Data), in particular during any audio or video consultation, which are recorded as part of our normal procedures.

Where any Health Related Data is disclosed to us, which may be directly or indirectly via any of our websites, Apps, systems, products or services, we process this data only as an incidental part of the recording in which it is contained.

We use the information in the recordings for the purpose of conducting scientific research regarding your pet, to enable us to diagnose and assess potential health complications and to enable us to advise you accordingly. Where any recording does contain Health Related Data, then we may subsequently transcribe conversations included in the recording and delete the original recordings. We will not transfer or otherwise provide copies of recordings to third parties without your explicit consent.

Except as provided above, we will not process or disclose medical or health related information to any person unless permitted to do so under the Data Protection Legislation, such as where it has been manifestly made public by that person.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Personal Contact Data, Health Related Data, Transaction Data, Profile Data, Usage Data and Marketing and Communications Data by filling in forms or by corresponding or interacting with us by post, phone, email or otherwise, and/or

by way of our website, or by way of any App or system operated by us. This includes personal data you provide when you:

• apply to use our facilities or for us to supply our products or services;

• create an account on our website or in any App or system operated by us;

• subscribe to our service or publications;

• engage in any consultation or other direct communication with us by way of our website or any App or system operated by us;
• request the supply of any goods or services from us, including where this is paid for by an insurance provider, or one of our service l partners;
• make any enquiry or request any information from us;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact

Automated technologies or interactions. As you interact with our website or any App or system operated by us, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:

• analytics providers such as Google based outside the UK;

• advertising networks which we may use now or in the future based inside or outside the EEA; and
• search information providers based inside or outside the

• Personal Contact and Transaction Data from providers of technical, payment and delivery services such PayPal, VISA, Mastercard and other providers of such services based inside or outside the UK

• Personal Contact and Profile Data from our commercial and research partners based inside or outside the
• Personal Contact, Transaction, Profile, Usage, and Marketing and Communications Data, Identity Data from your insurance provider or other service partner we are affiliated with and through whom you have access to our services. Some of this data may already have been collected by us when you sign up to our services or buy our products, but we are also provided this data by insurance providers or service partners. The data provided by the insurance providers or service partners includes: email, name, phone number, postcode, policy details, and details of any pet information that is linked to your name, including breed, date of birth, gender, name, and species. Where we are provided with information from your insurance provider, we are also given information about churn rates in terms of renewing or cancelling insurance policies, but this is generally provided on an aggregated and anonymised
• Personal Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the

4. How we use your personal data

We are committed to protecting privacy and will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those
• Where we need to comply with a legal

Read our glossary (section 10) to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before providing copies of recordings to third parties or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or, where you have received marketing communications be electronic means, by using the unsubscribe option provided in the communication.

Purposes for which we will use your personal data

We need to process your personal data so that we can manage your customer accounts and to provide you with the products and services you want to buy. We have set out below, in further detail, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you would like to change any of your marketing and communications preferences, then you can do so by using the unsubscribe options included within the communication you have received or by contacting us at: [email protected] We may use your Personal Contact, Transaction, Technical, Usage and Profile Data to form a view on what we think you may want or need for your pet(s), or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have given your consent to do so, or if you have engaged with us in relation to our products and services (for example, by making a purchase or otherwise requesting information from us about our products or services, or by registering to partake in one of our competitions or promotions) consent means any freely

given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to yourself.

Third-party marketing

We will get your express consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at the following address at any time: [email protected]

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, veterinary consultation, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact at the following address at any time: [email protected].

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Internal Third Parties as set out in the

• External Third Parties as set out in the

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, or from whom we may seek to acquire other businesses or assets, in each case along with their professional

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we will seek to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal
• Where we use certain service providers, we may use specific contracts approved by the relevant authorities which ensure that personal data transferred will be subject to the substantively the same degree protection as in the

Please contact us at [email protected] if you want further information on the specific mechanisms used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil 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 in 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 unauthorised 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at [email protected].

By law we also have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

You are entitled to delete your account directly via the App and in some circumstances, you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In line with our duties and obligations to RCVS (Royal College of Veterinary Surgeons) any data that we need to retain beyond our retention period will be anonymised and shall only be attainable or retrieved by our specialist technicians.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

· Request access to your personal data.

• Request correction of your personal data

• Request erasure of your personal data

• Object to processing of your personal

• Request restriction of processing your personal

• Request transfer of your personal data.

• Right to withdraw

If you wish to exercise any of the rights set out above, please contact us.

Subject Access Rights

You have the right to see the personal data we hold about you. This is called a Subject Access Request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). If you would like a copy of the personal data we hold about you, please email us at [email protected].

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary Lawful Basis

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden

by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

11. Third parties Internal Third Parties

• Veterinary nurses and surgeons and their applicable support staff where the same have entered into any contractual obligations with us to supply services accessed or used by

External Third Parties

• Service providers who provide various support services such as IT and system administration and data storage and/or transmission services;
• Service providers to whom we may subcontract any of our obligations in relation to any supply of goods and/or services to you or any aspect of the same;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and other services to support us;
• Providers of market research, after sales services, and reviews and customer feedback services;
• Financial services providers for payment process such as Stripe, PayPal, VISA, Mastercard and related services;
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
• Veterinary Practices that you and your pet are registered with and which you provide your consent to use liaising
• Third party providers of services to you through whom you have access to our services, such as your insurance provider or other services provider with whom we are affiliated, that may supply products or services to you directly following any purchase by you

facilitated by way of our websites, Apps or other systems or otherwise following referral by us.

12. Your Legal Rights

You have the right to:

“Request access” to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

“Request correction” of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

“Request erasure” of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

“Object to processing” of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

“Request restriction of processing” of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s

• Where our use of the data is unlawful but you do not want us to erase

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use

“Request the transfer” of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

“Withdraw consent at any time” where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.