- When you make use of or interact with, our Website
- When you create an account and purchase a product
- When you use our “drop a hint” functionality
- When you send an “engagement moment”
- When we request a review of our products
- When you contact us for support or otherwise (e.g. customer support and/or via chat)
- When you sign up to receive our newsletters/email list/SMS
- When we use the Personal Data of our service providers
- When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
- HOW WE PROTECT AND STORE YOUR INFORMATION
2.1. Security. We have implemented appropriate technical, organizational, and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device, or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- HOW WE SHARE YOUR PERSONAL DATA
We may share your information as follows:
- Affiliates: We may share your information with our affiliates and subsidiaries for business, operational, promotional, and/or marketing purposes;
- Our Service Providers: We share your information with our third-party service providers that provide business, professional, or technical support functions for us (including to the extent necessary or desirable to fulfill or ship your order or complete your transaction; provide customer support; process your purchases), help us operate our business, IT and the Website, or administer activities on our behalf. We also share your Personal Information with our business partners with whom we jointly offer products or services.
- Select Third Parties: With our joint marketing partners for the purposes described in this Policy, including when we believe such partners may have offers of interest to you;
- Sale or Transfer of Business or Assets: If, in the future, we sell or transfer some or all of our business or assets to a third party, or in the event of bankruptcy or a comparable event, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
- With Your Consent: Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with any marketing consents or opt-in to optional additional services or functionality if required by applicable law).
- Aggregate or Anonymous Non-Personal Information: We may share aggregate, anonymous, or de-identified non-personal data with third parties for their marketing or analytics uses.
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
- Internal transfers: Transfers within the PetsAlpha group will be covered by an internal processing agreement entered into by members of the PetsAlpha group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
- External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When PetsAlpha engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by the European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. PetsAlpha also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.
YOUR PRIVACY RIGHTS AND CHOICES
5.1. Rights under GDPR: The following rights (which may be subject to certain exemptions or derogation), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
- You have a right to access information held about you. Your right of access may normally be exercised free of charge, however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
- You have the right to request the erasure/deletion of your Personal Data (e.g. from our records)… Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise, or defense of legal claims;
- You have the right to object to or to request the restriction of the processing.
- The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
- The right to withdraw your consent at any time. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular, if the processing is required to meet our legal and regulatory obligations.
- You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
- You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.
5.2. Rights under CCPA: The following rights (which may be subject to certain exemptions or derogation) shall apply to certain individuals (some of which only apply to individuals protected by the CCPA:
- You have the right to know what personal information is being collected about you;
- You have the right to request the erasure/deletion of your personal data (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise, or defense of legal claims;
- You have the right to know whether your personal information is sold or disclosed and to whom;
- Restriction of, or object to, processing of your Personal Information, including the right to opt-in or opt-out of the sale of your Personal Information to third parties, if applicable, where such requests are permitted by law; and
- You have the right to equal service and price, even if you exercise your privacy rights.
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You can exercise your rights by contacting us at [email protected]
or, if you are an individual protected by CCPA, you can make your requests by email. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
5.3. Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and the personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
5.4. . Marketing emails – opt-out: You may choose not to receive marketing emails of this type by unsubscribing from the link that you can find at the bottom of the email to opt-out of receiving future emails, and we will process your request within a reasonable time after receipt.
- COOKIES, TRACKING OPTIONS, AND CALIFORNIA DO NOT TRACK DISCLOSURES
- Cookies. Our Website utilizes “cookies”, anonymous identifiers, and other tracking technologies in order for us to provide our Website and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Most browsers allow you to control cookies, including whether to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. You are free to adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Website or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.
- Do Not Track Disclosures. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Website.
- Log files. We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
- Analytic tools.
Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use, and sale of your personal data and your rights, please use the below links:
Your Rights: https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/
- We reserve the right to use additional analytic tools
- Interest-Based Advertising Choices. Through our services, we allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, Website identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for the purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable, or otherwise of interest to you. If you prefer not to share your Personal Information with third-party advertising partners, you may let us know. To understand your choices for receiving more relevant advertising provided on the Website or across other websites and online services, please review the information below:
- DAA: To opt-out of such collection and use it for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit: http://www.aboutads.info/choices
- EDAA: To opt-out from the use of information about your online activities for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) participating companies, please visit: http://www.youronlinechoices.eu/
- NAI: To opt-out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) participating companies, please visit: http://www.networkadvertising.org/choices/
- For Mobile Devices: On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.
- Even if you opt-out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third parties if they are not a DAA or NAI participating company.
HOW TO CONTACT US? If you have any questions, concerns, or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected]