Privacy Policy

Welcome to PetFocus Veterinary Group , a subsidiary of VetStrategy (collectively referred to as “VetStrategy”, we”, “us” or “our”).

Choosing us as your veterinary services provider means you have placed a great deal of trust in us, and we take this responsibility very seriously. This means we are committed to respecting your privacy and protecting your personal data.

It is important that you read this policy carefully so that you understand how we look after and process your personal data, and you are aware of your privacy rights and how the law protects you. 

What is included in this policy?

1. Important information and who we are
2. The personal data we collect and how we use it
3. Who we share your personal data with
4. International transfers
5. Keeping your personal data secure
6. Data retention
7. Being in control of your own information
8. Changes to this privacy notice and your duty to inform us of changes

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information about how we collect and process your personal data in relation to providing veterinary services to the animal entrusted into our care. This covers your use of our website, app and veterinary services provided in our practice, and when you contact us.

Controller

In accordance with federal and provincial privacy legislation, VetStrategy, 7000 Pine Valley Drive, Suite 201, Woodbridge, ON L4L 4Y8 is the data controller who is responsible for your personal data.

Contact details

We have appointed a Privacy Coordinator who is responsible for overseeing questions in relation to this privacy notice.

If you have any questions about this notice, including any requests to exercise your legal rights, please contact us:

• By telephone - +1 (905) 264-0707
• By post - FAO: Privacy Coordinator, VetStrategy, 7000 Pine Valley Drive, Suite 201, Woodbridge, ON L4L 4Y8
• By email - privacy@vetstrategy.com.    

Third-party links

This website may include links to third-party websites, plug-ins and applications.

In some instances, we may be “joint controllers” with this third party. This means that we might be jointly responsible with that third party for determining the collection and/or use of your personal information with this organisation.

Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

You may find links on our website to other services operated by our group companies and by trusted third parties. Clicking on such links may allow third parties to collect or share personal data about you, so we encourage you to read the privacy notice on the websites and apps you visit.

2. The personal data we collect and how we use it

We process the following categories of personal data:

To register you with a practice

• We obtain your full name, date of birth and contact details to register you and your animal at the practice you choose. If your practice has an app or client log in functionality on their website, we will capture these details and ask you to set a password to create and protect your account and provide you with the services you request.

To provide you with veterinary services and products

• We use your full name, contact details, address and account information to book a face-to-face or video appointment with one of our vets, make a referral to a specialist clinic, lab or other provider that supports us in providing veterinary care, prescriptions and prescription medication.
• We use your full name, contact details, postal address and details about your order to deliver the products that you have purchased from us, or we have prescribed to you.
• We use your payment card details to process payments you make through our websites or in practice. We share these details with Chase Merchant Services, our chosen payment processor, who stores your payment card details at your request to provide you with an efficient checkout process. We do not store any financial details.
• If you enter or allow us to use your location on the practice’s website, we will search for a practice near to this location.

To provide customer service to you

• We use your full name, contact details and any other information that you provide us with when contacting us through our website, app or social media account, via email or telephone or when visiting a practice to respond to your query or resolve a complaint.
• We do not intend to collect or any sensitive data however, if you voluntarily provide us with this information, we will only process it in order to respond to your query. Any sensitive data you provide will be deleted as soon as your query is resolved.

To support with an application for credit from a third party

• The application of credit is made via a third party and the required details will be shared with them as part of the application. This includes collecting your full name, telephone number, email address, date of birth, account history, income, resident status, and bank account details.
• We will use your full name, contact details and how you have interacted with our services to collect and recover money that you may owe us. This may involve referring the matter to debt recovery agencies.

To personalise and improve your experience when visiting a practice’s website or app

• We will use information about how you interact with our website, app and services to target our adverts so that they are most relevant to you.

To inform you about products and services that may interest you

• If you provide us with your consent, we will use your full name, email address, pixel tracking, cookie data and preferences to receiving marketing communication to send you information relating to offers, services and pet health advice. Read our Cookie Policy to learn more about how we use pixels and cookies.

To keep in touch with you

• We use your full name, contact details and postal address to send you service communications, such as reminders of appointments, product recalls and important information relating to your practice or account.

To ensure a practice’s website, App and veterinary services operate properly

• We use technical information about your device (such as your IP address, browser type and version, time zone setting and location, browser plug-in types, versions and screen sizes, operation system and platform, URL clickstream to and from our website and app and download errors) to ensure the website is secure and works on your device. We also use this information for management information and reporting duties.

To develop and improve our products and services

• We use information about how you interact with our website, app, services and emails and your survey and feedback responses to learn where to target our adverts so that they are most relevant to you and to improve our customer service.
• We may record any calls made to and from the practice to provide quality service, training and assurance to our employees and clients.
• If there a requirement for a consultation to be recorded for training and professional development purposes, you will be notified of this prior to the consultation. 

For safety and security and to prevent and detect crime

• Where CCTV is in use at a practice, there will be signs bringing this to your attention. We use this CCTV data to ensure the safety and security of our employees, clients and practice and if necessary, we will share this where the law requires us to.
• We will use your account information, credit applications and some technical information about your device to confirm your identity, detect fraudulent behaviour and prevent criminal activity.

To comply with our legal obligations

• We may use the data that we collect about you to ensure we comply with any legal obligations that may be imposed on us.
• We will use information about you, how you interact with our services and your contact details to inform you of product recalls or other product quality issues, and to comply with our legal obligations in connection with the sale of age restricted products.

We use different methods to collect data including through:

a) Direct interactions - you may give us any of the above information when you use our website or App, or when corresponding with us via telephone, post, email or face-face in our practice. We may also collect data if you attend any events that we are participating in.

b) Automated technologies or interactions - as you interact with our website, we will automatically collect some 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 this technical data about you if you visit other websites which employ our cookies. Read our Cookie Policy to learn more about how we use our cookies.

c) Third parties - we may receive information about you from third parties such as:

• Providers of technical, payment and delivery services
• Microchip companies and databases
• Appointed persons or guardians
• Advertising networks (based on your cookie consent)
• Analytics providers
• Credit reference agencies
• Where the animal is referred to us from another practice, information that practice holds about you
• Other VetStrategy companies
• Debt recovery agencies
• Insurance companies

Where we have received information from other sources, we will have informed you when we collected that data that it may be shared internally and combined with the data that we collect about you from your use of this website.

Lawful basis for processing your personal data

Depending on the processing activity, we rely on at least one of the following lawful bases for processing your personal data under the Canadian federal and provincial legislation:

• Consent - where you have given us your consent (or explicit consent where appropriate)
• Contract - it is necessary for entering into or the performance of a contract
• Legal Obligation - it is needed to comply with a legal obligation that is imposed on us
• Legitimate Interest - it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests
• Vital interest - it is necessary in an emergency, such as emergency medical care
• Public task - it is necessary for the performance of a specific task that is in the public interest that is set out in law

If you fail to provide your information

If you fail to provide certain information when requested (such as your payment card details), we will not be able to provide veterinary care to the animal entrusted into our care.

Marketing

You can ask us to stop sending you marketing messages at any time by clicking “unsubscribe” on our emails. If you have provided your consent, read our Cookie Policy for information on how you can reject cookies and opt out of targeted advertising online.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

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 us at  privacy@vetstrategy.com

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, we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law.

3. Who we share your personal data with

We share your personal data with the following categories of companies so that we can provide the service you have requested from us.

• Companies that help us to form a contract with you such as: Payment service providers, including Chase, Affirm (formerly known as PayBright) and Scratchpay
• Partners such as AllyDVM that enable us to book your appointment and send you reminders and where you have consented, marketing communications
• Technology service providers that support our IT, host our websites and help us analyse the data we hold
• IVC Evidensia companies where they assist us in providing our services to you
• Insurance and health plan providers
• Microchip registers
• Canadian Colleges of Veterinary Medicine (where it is in the public interest or the interests of animal welfare) 
• Indemnity providers (Veterinary Defense Service)
• Other professional and legal advisors
• Debt recovery agencies
• Law enforcement and fraud prevention agencies
• Companies approved by you (such as social media sites)
• Referrals to other vets or specialist clinics and labs or other providers who support us in providing veterinary services to the animal entrusted into our care
• Suppliers (when ordering products and when we are obliged to report a suspected adverse event associated with providing veterinary drugs or microchips)
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you, including Facebook Ad Manager (we will only send marketing communications to you where you have consented to receiving them from us),
• Where any part of our business is outsourced, sold, or merged, and where permitted by law, we will share your data with the new provider so that we may continue to provide services to you. They may use your personal data in the same way as set out in this policy. We will of course inform you of any such change and give you an opportunity to opt out of your data being shared with a new provider.
• Academic bodies (some information about your account may be used by our vets and nurses when participating in academic research or completing additional qualifications)

Before we share your data with any third party, we will check:

They can provide sufficient guarantees regarding the confidentiality and security of your personal data;

We have a written contract with them which defines how they can use your data, how they can protect it and what to do with it when our relationship with them is terminated; and

We only share the data that they need in order to fulfil their services to us.

4. International Transfers

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

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in Canada which give personal data the same protection it has in Canada.
  
  Please contact us at privacy@vetstrategy.com if you want further information on the specific mechanism used by us when transferring your personal data out of Canada.

5. Keeping your personal data secure

We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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 we will notify you and any applicable regulator of a breach where we are legally required to do so.

If you would like to know more about how to protect your information and your computer and devices against fraud, identity theft, viruses and other online problems, please visit Get Cyber Safe. Get Safe Cyber Safe is free initiative set up by the Government of Canada.

6. Data retention

We will only retain your 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 or reporting requirements.  

If you no longer wish to have an account, please contact your local practice to confirm that you wish to close your account. For app users you can delete your account through the app. If you have any questions in relation to closing your account and what data, we will retain please contact privacy@vetstrategy.com

7. Being in control of your own information

Under the federal and provincial privacy legislation you have some important rights available to you. In summary, these include:

• Be informed about how we use your personal data (hopefully this privacy notice explains it all)
• Access to the personal data that we hold about you
• Challenge compliance, if you believe you disagree with how we manage the processing of personal data.
• The right to complain to applicable regulator, within British Columbia and Alberta you will go to your provincial privacy regulator and for the rest of Canada you will go to the federal privacy regulator (British Columbia Complaints, Alberta Complaints, and Rest of Canada Complaints)

If you want to exercise your rights, please complete the Privacy Rights Form.

8. Changes to this privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on 25 October 2022.

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.