What is PII?
PII is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not PII. This includes, for example, the number of users of a website.
Responsible for data processing
Responsible for data processing in accordance with the provisions of the FIPA is:
Spencer & Bella
My Pet’s Health, LLC
111 North Orange Avenue, Suite 800,
Orlando, FL 32801, USA
E-Mail: [email protected]
What are your Rights
In accordance with the FIPA and GDPR, you can in relation to us processing your PII rely on the following rights:
- Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
- Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
- Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
- Request that a business that sells a consumer’s personal information, not sell the consumer’s personal information.
To assert these rights, please contact us at any time using the details provided.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal PII about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it.
We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your PII.
What are the legal bases for processing your PII?
Of course, to process your PII, we not only need to have a purpose such as you are sending us an enquiry or entering into a contract with us, but we also need to have a lawful basis to do so. The processing of your PII may be based on the following legal grounds:
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Contract – This is where we process your information to fulfil a contractual arrangement, we have made with you.
- Answering your business enquiries – This is where we process your information to reply to your messages, e-mails, posts, calls, etc.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.
Where do we get your data from?
Normally quite simple: you provide it to us. Perhaps you provide it during the processing of the purchase transaction or enter it in our contact form. It is basically up to you whether you enter personal or business data (e-mail addresses, names, addresses) on our website. Other, purely technical data is automatically collected by our IT systems as soon as you open our website. These are, for example, the time of the page call or the Internet browser used.
Duration of data storage
We only store your PII for a certain period of time. For example, if you have ordered something from us or had an appointment, or purchased our classes, then the retention periods under tax and commercial law are decisive: by law, we must store order or service-related data and the associated addresses for up to 10 years. We delete your data that we have stored for marketing purposes when you request us to do so, revoke your consent to store it or the purpose for storing the data no longer applies.
The individual data concerned, processing purposes, legal bases, recipients and, where applicable, transfers to third countries are listed below:
a) Log file during website visit
We log your website visit. In doing so, we process:
- Name(s) of our accessed website(s),
- date and time of the access,
- the amount of data transferred,
- the browser type and version,
- the operating system you use,
- the referrer URL (the previously visited website),
- your IP address,
- the requesting provider.
The legal basis for data processing is our legitimate interest in the ongoing provision and security of our website. The log file is deleted after seven days, unless it is needed to prove or clarify specific legal violations that have become known within the retention period.
b) Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your enquiry: Name, contact details (e-mail address and phone number) -if provided by you- and your message.
On our website, we offer you the opportunity to register by providing PII. The data is entered in the registration form is transmitted to us and stored and includes your full name, your e-mail address and your password. The processing of the data for this registration thus serves the fulfilment of the contract of use or the implementation of pre-contractual measures. You can delete your account at any time either by using the delete function in your account or by contacting us.
d) Storage of data in your account
For the conclusion and processing of contracts, we require contact details, such as name, delivery and billing address and e-mail address, as well as information on the type of payment method you have chosen. You can store this data in your account. In addition, we use your data to maintain our customer database so that only accurate data is stored by us.
Following your order, you will receive a corresponding order confirmation as well as further documents, which we are obliged to provide in order to fulfil our legal information obligations for an effective conclusion of a contract with you.
d) Contract fulfilment and data management in the context of your order
We process various data within the framework of the provision of our services and for the initiation and processing of the existing contractual relationship between you and us for example when you create a user account, or order one of our products.
If you have purchased one of our products, we process your data (if provided: Name, contact details (email address and telephone number), address, payment confirmations, and all information that is necessary in the context of fulfilling the services, exclusively for the purpose of processing and handling the contractual relationship. This includes in particular support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations.
In the case of payment for goods you may be required to pass on your payment data to PayPal our payment service provider as specified when the order was placed. We do not collect or store any payment transaction information such as credit card numbers or bank details during the payment process. You only provide this information directly to PayPal.
In order to process the contract and provide you with our services, or to send you a package, we use your contact details to send you customer service information, order confirmations, and contract documents. We are obliged to send you these documents in order to comply with our legal information obligations for an effective conclusion of a contract with you.
e) Champions Application
If you apply, we process the information we receive from you as part of the application process, e.g., through your letter of application, references, correspondence, telephone, or verbal details. Your data will initially be processed solely for the purpose of carrying out the application process. The legal basis for processing data during the application process is the purpose of processing and handling the contractual relationship and, if you have given your consent, for example by sending us information that is not necessary for the application process, it is consent.
If you register for our newsletter, we will regularly send you information about our offers. The only data required or sending the newsletter is your e-mail address. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. By activating the confirmation link, you give us your consent.
You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately.
Disclosure or transfer of PII
We do not transfer or disclose your information to third parties unless there is a legal basis for such disclosure. Example of such a basis is typically consent from you or a legal basis that requires us to disclose the data.
For the operation and optimization of our website and our services and for the processing of contracts, various service companies work for us, e.g., for central IT services or the hosting of our website, for the payment and delivery of products, or order fulfilment, to whom we pass on the data required for the fulfilment of the task (e.g., name, address).
Some of these companies act for us by way of commissioned processing and may therefore use the data provided exclusively in accordance with our instructions. In this case, we are legally responsible for appropriate data protection measures at the companies we commission. We therefore agree on specific data security measures with these companies and monitor them regularly.
We will disclose your data to third parties or government agencies within the framework of existing data protection laws if we are legally obliged to do so, e.g., due to official or court orders, or if we are entitled to do so, e.g., because this is necessary for the prosecution of criminal offenses or for the exercise and enforcement of our rights and claims.
If we use service providers in third countries, we take additional measures to ensure an adequate level of data protection for the transfer of PII and thus ensure that the transfer is generally permissible and that the special requirements for a transfer to a third country are met (e.g., by concluding standard contracts and additional guarantees, supplementary technical and organizational measures such as encryption or anonymization).
Direct marketing in the context of a customer relationship
Insofar as you have also given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
State-of-the-art internet technologies are used to ensure the security of your data. During the online enquiry process, your details are secured with SSL encryption. For secure storage of your data, the systems are protected by firewalls that prevent unauthorized access from outside. In addition, technical and organizational security measures are used to protect the PII you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.
We are present in various “social media” platforms in order to communicate with our customers, interested parties and users registered there and to be able to inform them about our offers there. We would like to point out that you use these platforms and their functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g., commenting, sharing, rating).
Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so within your account or by contacting us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of PII, notably where such requests would not allow us to provide our service to you anymore.
Links to other providers
Our website also contains – clearly recognizable – links to the websites of other companies. Insofar as there are links to websites of other providers, we have no influence on their contents. Therefore, no guarantee or liability can be assumed for these contents. The respective provider or operator of the pages is always responsible for the content of these pages.
The linked pages were checked for possible legal violations and recognizable infringements at the time of linking. Illegal contents were not recognizable at the time of linking. However, permanent monitoring of the content of the linked pages is not reasonable without concrete indications of a legal violation. Such links will be removed immediately if infringements of the law become known.
PII and children
Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose PII from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.
Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Concerns and Contact
If you have any concerns about a possible compromise of your privacy or misuse of your PII on our part, or any other questions or comments, you can contact using the following contact details:
Spencer & Bella
My Pet’s Health, LLC
111 North Orange Avenue, Suite 800,
Orlando, FL 32801, USA
E-Mail: [email protected]