Sustainapaws Privacy Policy.
The boring, but important bit!
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe in compliance with the General Data Protection Regulations (GDPR) (EU) 2016/679.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Sustainapaws uses your data. We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
When you are using the Sustainapaws website, Sustainapaws is the data controller.
For simplicity throughout this notice, ‘we’ and ‘us’ means Sustainapaws.
The GDPR (EU) 2016/679law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you buy a product from us, we need to know where to send it.
Legal compliance
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting Sustainapaws to law enforcement .
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
When you visit our website, and use your account for ancillary services, or redeem vouchers from Sustainapaws on the phone.
When you create an account with us.
When you engage with us on social media.
When you download or install one of our apps.
When you join a Sustainapaws loyalty programme
When you contact us by any means with queries, complaints etc.
When you enter prize draws or competitions.
When you choose to complete any surveys we send you.
When you comment on or review our facilities or services. Any individual may access personal data related to them, including opinions. So if your comment or review includes information about one of our suppliers or associates, it may be passed on to them if requested.
When you fill in any forms. For example, if an accident happens on our premises we may collect your personal data.
When you’ve given a third party permission to share with us the information they hold about you.
We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
When you visit our premises which usually has CCTV systems operating for security. These systems may record your image during your visit.
Accounts
If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password and (if applicable) payment card(s) information.
Details of your interactions with us through our office/reception.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of products you order, your dogs details, voucher redemptions, ancillary products & services you show interest in, web pages you visit and how and when you contact us.
Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Details of your visits to our websites or apps, and which site you came from to ours.
Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.
Personal details which help us to recommend items of interest.
For example, you might share information about your dog(s) which allows us to recommend appropriate products or services
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your experience with us. Of course, it’s always your choice whether you share such details with us.
Customer Experience
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements/promotions you clicked on, and any search terms you entered.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
We want to give you the best possible customer experience. One way to achieve this is to get a picture of you and your dog(s) by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below, and this can be done at anytime.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why
To process any bookings that you make by using our website. If we don’t collect your personal data during booking, we won’t be able to process your request and comply with our legal obligations.
To respond to your queries, care requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
To protect our customers, premises and assets from crime, Sustainapaws operate CCTV systems in the reception, premises and car parks which record images for security. We accept this on the basis of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our office about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to your booking. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.
To administer any of prize draws or competitions you may enter, based on your consent given at the time of entering.
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by letting us know.
To build a picture of who you are and what you like, and to better inform our business decisions, we’ll combine data captured from Sustainapaws, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest only.
For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different disciplines and areas of the country. This may then guide which products we offer and promote.
For example, if you consent through our apps, we may use your shopping preferences to offer you tailored rewards.
Here’s more information on how we share personal data with third parties.
We want to bring you offers and promotions that are most relevant to your dog(s) and your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the company as described above, for example your shopping history. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above.
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our website and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
Bookings
When you make a booking, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.
Warranties
If your booking includes a product with a warranty, the associated personal data will be kept until the end of the warranty period.
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems.
Operational companies such as Royal Mail and veterinary surgeries. Direct marketing companies who help us manage our electronic communications with you.
Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. (See our Cookies Notice for details)
Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
For example, if you enter a competition involving one of our suppliers and tick a box agreeing that the they can send you promotional information directly. Or if we run a joint event with a company, and you agree to receive direct communications from them.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We may, from time to time, expand, reduce or sell Sustainapaws and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
For further information please contact us.
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty or fulfilment of an order/or back order).
A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by Sustainapaws of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time by completing an online form.
If we choose not to action your request, we will explain the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as administration of a veterinary matter
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
If you have an account, log in into your Sustainapaws, visit the ‘My Account’ area and change your preferences.
In our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.
Write to: Sustainapaws, 8 Ash Close, Romsey, Southampton, SO51 5RX.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Joint use of your personal data
We will share data with our providers to bring you relevant offers, updates, products and services, and discounts that reward your loyalty to Sustainapaws.
We may check your details with appropriate third parties (for example credit reference agencies, such as Experian) before we send you promotions for our financial services products, to ensure your information is accurate and fulfils our legal and regulatory obligations, and to tailor those offers to you.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at sustainapaws@gmail.com
Or write to us at Sustainapaws, 8 Ash Close, Romsey, Southampton, Hampshire, SO51 5RX.