Privacy Policy

Defined Terms:
Capitalised terms used herein that are not otherwise defined shall have the meanings ascribed to them in the Terms of Use.
What is this Privacy Policy for?
Wherever you are located, the aim of this Privacy Policy is to advise all users of the website www.groomer.io, and all associated sites linked to www.groomer.io, its subsidiaries and affiliates (the “Website”), as well as any grooming facility that has subscribed to use one or more of our products, including our online booking software and pre-appointment questionnaire, and any other products of ours which are subscribed to from time to time (together, the “Products”) on how we collect, protect and process the information that is supplied to us, and in particular, Personal Data. We request that you read this Privacy Policy and only if you are satisfied with it should you continue to use the Website or our Products (as appropriate).
Updates to this Privacy Policy:
The Privacy Policy may change from time to time, details of any such changes shall be posted on this page of the Website. It is your responsibility to check the Privacy Policy when you visit the Website and/or each time that you use our Products. By using this Website and/or our Products you accept that you are bound by the Privacy Policy in force at that time and displayed on this page.
What information does Groomer.io collect?
Groomer.io collects and stores information and data provided by (or otherwise directly or indirectly collected from) you in accordance with this Privacy Policy. We collect information from 5 sources as follows:
1. All users: Users of the Website can access the Website’s homepage and browse some areas of the Website without disclosing any Personal Data. We might track information provided to us by your browser, including any website you came from, the type of browser you use, the time and date of access, and other information that does not personally identify you. In addition, we might gather information about you that is automatically collected by our web server, internet protocol address, connection information, operating system and platform, unique reference number linked to the data entered on the system, cookie number, and activity on the Website including the pages you visit and searches you may have made (collectively all of the foregoing being known as “User Data”).
2. If you are a grooming facility customer: If you are a grooming facility customer using our Products, we collect certain Personal Data from you on behalf of your grooming facility. This Personal Data includes name, address, telephone number and e-mail address and any other Personal Data that you provide to us about you when using such Products, and always based on our instructions from the grooming facility (all of the foregoing being “Customer Data”). Your grooming facility may also provide the Customer Data directly to us, based on the records that it already holds about you.
3. If you are a grooming facility: If you are a grooming facility who enters into our Master Subscription Agreement granting you a licence to use one or more of our Products, we will collect certain Personal Data from you in order to provide such Product(s) to you. This includes a contact name, address, e-mail address and telephone number as well as any other Personal Data that you decide to provide to us during the subscription process (“grooming facility Data”).
4. Information from outside sources: We may also legally obtain information from third parties. For instance, if you are a grooming facility, we may collect information about you from other sources in order to verify your licensure status and identity; where necessary (for example, to process an order for a purchase), in some cases this information may be Personal Data;
5. Any information that you voluntarily provide to us: We may collect information that you voluntarily provide to us through responses to surveys, search functions, questionnaires, feedback, contact us forms and the like or if you make a payment to us. Some of this information may be Personal Data, such as national change of address information.
Processing ground:
Groomer.io relies on the legitimate interests processing ground to collect each of the above items of information, excluding the Customer Data for which Groomer.io is a data processor only. The Customer Data is processed by Groomer.io on behalf of your grooming facility and therefore is subject to whatever processing ground your grooming facility is relying on to process such Personal Data. Please see your grooming facility’s privacy policy for details. It is necessary for Groomer.io to collect such items of Personal Data listed above: (i) in the case of the User Data, to improve the functionality of the Website and to ensure that these run as smoothly as possible; (ii) in the case of the grooming facility Data and the information in paragraph 5(v), to provide the Products to the grooming facility or the applicable survey/questionnaire and so forth; and (iii) in the case of the information listed in paragraph 5(iv), for fraud and security purposes. In each case, the items of Personal Data collected are being limited to “business card” type data, not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
Use of cookies:
Groomer.io, like many websites, may use cookies from time to time. A cookie is a small amount of information that is sent to a person’s browser from a web server and stored on that computer’s hard drive so that the Website can remember who they are. A cookie will typically contain the name of the domain from which the cookie has been sent, the lifetime of the cookie, and a unique value number. Cookies cannot read your hard drive. For more information about our cookie policy, please visit our cookie policy page.
Advertising:
Along with many other internet sites, Groomer.io may use third-party advertisers to fill advertising space on the Website. These third parties may use cookies and other similar technologies to assess information about you. Groomer.io has no access to or control over third party activity which is not covered by this Privacy Policy. Groomer.io is not responsible for the privacy policies and practices of other sites, including your grooming facility, even if you access them using links from the Website. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions, including, in the case of concerns about the Customer Data, your grooming facility. In addition, if you link to the Website from a third-party site or via a social network (e.g. Twitter, Facebook), Groomer.io is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
How does Groomer.io use the information collected?
Groomer.io may use the information set out in paragraph 5 above in the following ways:
1. We use cookies or other non-identifying information such as the User Data referred to in paragraph 5(i) above, in order to recognise you when you visit or return to the Website, track anonymised traffic, demographic and usage pattern, to prevent or detect fraud or abuses and help to improve the Website.
2. We use the Customer Data that is provided to us in accordance with paragraph 5(ii) above to provide the services that your grooming facility has subscribed to, such as those services offered by our Products, including facilitating appointments with your grooming facility, and sending reminders of such appointments to you. We may also use your Customer Data in order to provide you with adverts or other commercial messages that we believe may be of interest to you on behalf of your grooming facility, but only where your grooming facility confirms that we are entitled to do so in accordance with applicable data protection and direct marketing legislation (which in certain circumstances will require your consent). You may opt-out of this use of your Customer Data at any time by contacting your grooming facility.
3. We use the grooming facility Data in order to license to you the Products specified under our Master Subscription Agreement with you.
4. We use the information provided to us or obtained by us under paragraph 5(iv) and 5(v) above as stated therein. For example, if you submit information to us via a survey that you complete, we will use such information to assess the results of the survey in question.
Security, Data Storage and Retention:
Groomer.io takes the security of Personal Data (including the Customer Data and grooming facility Data and all other Personal Data collected by Groomer.io under paragraph 5) very seriously. Precautions are taken to protect Personal Data from loss, misuse, unauthorised access or disclosure, alteration or destruction. Groomer.io maintains stringent safeguards in connection with the collection, storage and disclosure of Personal Data. Further information about Groomer.io’s security practices is available on request. Groomer.io stores Personal Data on a regional basis i.e., if you are based in the EEA then it is stored in the EEA, if you are based in the U.S. then it is stored in the U.S. and so forth. Where Groomer.io transfers and/or stores Personal Data outside the EEA it takes steps to ensure that such transfer is deemed adequate under applicable data protection legislation. All Personal Data is stored by us for the period of time for which, if you are a grooming facility, you are licensed to use our Products or, if you are a customer, the period of time for which your grooming facility is licensed to use our Products. Following the expiry of such licence, the Personal Data is anonymised. It may, however, take us up to three months following the expiry of such licence to fully anonymise your Personal Data.
We may transfer your Personal Data to third parties as follows:
1. Aggregate: We may anonymise the Personal Data collected in accordance with paragraph 5 and aggregate it, without any individually identifying information, to third parties. Aggregate information is obtained from the collection of many individual records; however, any data that could be used to identify an individual is removed before it is used. Any third party that receives aggregate data must agree not to attempt to re-identify the people it belongs to.
2. Your grooming facility: If you are a customer, we will provide the Customer Data and any other information that you voluntarily provide to us (as indicated in paragraph 5(v)) to the grooming facility with which you are registered in order for it to process such data in order to e.g., provide you with an appointment.
3. Practice Management System (PMS) Partners: A PMS is a system commissioned by grooming facilitys to help manage day-to-day hospital operations. When Groomer.io shares information with such grooming facility as indicated in paragraph 11(ii) above, this is usually done via the technical integration which Groomer.io shares with the Practice Management Systems.
4. Our group entities: We have a number of subsidiaries (a list of which is available on the Website) with whom the data which we collect in accordance with paragraph 5 may be shared in order to allow us to provide our services to you.
5. Our service providers: We contract with other companies and individuals to help us provide services and in the operation of our business. Using such service providers’ infrastructure means that we store and process information on hardware and/or services owned by them. All of the information, including Personal Data, that we collect as listed in paragraph 5 will be provided to such service providers. A list of infrastructure and other service providers which we use include:
  - Amazon AWS: server and database infrastructure, and outgoing email servers.
  - Our internal business applications such as Google, QuickBooks and third-party payment processors like Stripe, PayPal and GoCardless.
  - Our application tools including, Mouse flow, Walk-me, Twilio.
  - Our e-mail and SMS campaign management and customer relationship management service providers such as Campaign Monitor.
  - Our customer support tools including Hubspot, Freshdesk, Survey Monkey, Smartsheet, Jotform and Zoom.
  We take your privacy very seriously and to that effect, we require such companies and individuals to comply with the terms of our Privacy Policy or privacy policies which are substantially similar with the terms of this Privacy Policy, to limit their access to any Personal Data to the minimum necessary to perform their obligations, and not to use the information they may access via Groomer.io for purposes other than fulfilling their responsibilities to us.
6. Third parties for marketing purposes:
  If your grooming facility has appointed us as a third party marketing service provider we may disclose the Customer Data to third parties with whom we are running promotional offers, including third parties who are responsible for co-ordinating such marketing campaigns for them, only on the instructions of your grooming facility and where your grooming facility has confirmed to us that we are permitted to do so in accordance with applicable data protection and direct marketing legislation (which in certain circumstances will require your consent). You may opt out of this use of your Customer Data at any time by contacting your grooming facility.
7. Business transfers or combinations:
  In the case of an actual or proposed sale or merger or business combination involving all or the relevant part of the business or in the case of insolvency, we may disclose all of the information that we collect as listed in paragraph 5 to third parties to the extent necessary in our reasonable judgment. This information may include Personal Data.
8. Legal:
  We may disclose all of the information that we collect as listed in paragraph 5 to third parties if Groomer.io considers that you have breached the Terms of Use, to enforce Groomer.io’s rights, to protect the public or if it is required by law or regulation or requested by any legal or regulatory authority. Again, this information may include Personal Data.Other than described above, Groomer.io will not release any of the information that it collects as indicated in paragraph 5 to a third party without your consent.
You have the right to:
(i) access a copy of the Personal Data that we have collected from you in accordance with paragraph 5; (ii) correct any items of such Personal Data; and/or (iii) have any items of such Personal Data erased or object to our processing of such items of Personal Data (subject to Groomer.io not requiring such Personal Data for legitimate business purposes or other legal reasons). You can carry out any of these actions from time to time by contacting info@groomer.io. Please note that if you are a customer and you wish to exercise any of the foregoing rights in respect of your Customer Data, such rights must be exercised by you contacting your grooming facility although we will co-operate with the grooming facility if any such request is made.
How we operate:
Groomer.io operates in accordance the UK and EU General Data Protection Regulation 2016/679, as well as other applicable privacy legislation such as the Data Protection Act 2018.
Ceasing use of our services:
You may at any time stop using the Website or our Products (subject, in the case of our Products where you are a grooming facility, to the terms of our Master Subscription Agreement with you governing the use of such Products).
Change of details:
If you are a grooming facility and you change your contact details, please send an email with your new details to info@groomer.io.
Contact us:
If you have any questions or concerns about the information Groomer.io holds about you, you may email Groomer.io at info@groomer.io or, if you are a grooming facility customer, your grooming facility.

Practice Management System (PMS) Partners: A PMS is a system commissioned by grooming facilitys to help manage day-to-day hospital operations. When Groomer.io shares information with such grooming facility as indicated in paragraph 11(ii) above, this is usually done via the technical integration which Groomer.io shares with the Practice Management Systems.

California Privacy Supplement:

This California Privacy Supplement (“Supplement”) is in addition to the information contained in the Groomer.io Privacy Policy and applies to California residents. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other related privacy laws. Any terms defined in the Privacy Policy or in the CCPA have the same meaning when used in this supplement. Where a Groomer.io any grooming facility or any of its customers or any user interacts with Groomer.io products and/or services, including, but not limited Groomer.io websites, applications, services and products, Groomer.io may collect information on California residents that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”).

We may obtain data provided by Customer Data directly from individuals using Groomer.io products and services, including its websites or applications. Groomer.io may have collected the following categories of Personal Information from consumers located in the State of California within the last twelve (12) months:

Identifiers including names, mailing addresses, unique personal identifiers, ISP addresses, account names, and other similar identifiers;
Personal information under Cal. Civ. Code Sec. 1798.80 including names, telephone numbers, account numbers, and other financial information of Groomer.io customers who have purchased goods or services;
Commercial information such as products or services purchased, and purchasing history; and
Internet or similar network activity such as browsing history, search history, or users’ interaction with Groomer.io websites, apps, or ads.

Job applicants and employees

In addition to Personal Information set forth above, Groomer.io also collects information provided by job applicants and employees of Groomer.io. Groomer.io has collected the following categories of Personal Information from job applicants and employees located in the State of California within the last twelve (12) months:

Protected classification characteristics such as age, race, ancestry, national origin, marital status, medical conditions, and veteran status; and
Professional or employment related information including job history or performance evaluations.

Job applicants and employees

Groomer.io does not collect biometric information, geolocation data, audio, visual, thermal, olfactory or other sensory data, educational records, non-public Family Education Rights and Privacy Act related data, or inferences drawn from Personal Information.

Aggregated Data

Personal Information does not include information that is de-identified or aggregated, publicly available in government records, and information otherwise excluded from CCPA’s scope including pursuant to the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other excluded state and federal laws.

Use of personal information

Groomer.io uses Personal Information as set forth in the Groomer.io Privacy Policy. Groomer.io has not sold the Personal Information of any California resident in the last 12 months.

Deletion requests (‘Right to Forget’)

Groomer.io complies with your rights regarding your Personal Information, including the right to request deletion of your Personal Information. Where Groomer.io receives a validated request, and Groomer.io is not otherwise legally obligated to retain such Personal Information, Groomer.io will delete your Personal Information. Groomer.io may deny your deletion request where it is legally required to retain your Personal Information, including as follows:

Where Groomer.io has a legal obligation to retain your Personal Information, in conformity with state or federal laws that require the storage of prescription records, records related to the sale of controlled products, veterinary board data retention requirements, and where otherwise subject to state or federal law requiring the retention of data;
Where it is necessary to protect you from unwanted data misuse, fraudulent activity, or to maintain the security of data, data security, and in the protection of data security incidents;
Where retention of data by Groomer.io is to comply with a legal or contractual requirement to a Groomer.io customer; and
To make use of any Personal Information pursuant to other recognized exceptions in the CCPA.

CCPA requests to access or delete Personal Information may be made by e-mailing info@groomer.io. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your child. You may only request access or deletion of Personal Information twice in any 12 month period. Your request must contain a valid email address and describe within sufficient detail such that Groomer.io may evaluate and respond to such request. Groomer.io will not respond to requests without a verifiable email address. Making a request does not require you to create an account, and Groomer.io will only use information in the request form to verify your authority to make the request and verify your identity. Groomer.io does not discriminate against anyone making a CCPA request, and will not deny goods or services, charge different prices, or provide a different level of quality of goods or services based on any CCPA request. Groomer.io will comply with the statutory time periods in which to respond to any CCPA request, and where we require additional time to comply with a request, we shall communicate with you on that request via email. We may also respond via email stating the reasons why we cannot respond to your request, cannot verify you, or cannot comply with a request.

Where data is requested, Groomer.io will select a format to provide a response to allow you to transmit that information to another entity. Where requests are deemed by Groomer.io to be excessive, repetitive, or unfounded, Groomer.io may charge a fee for responding to your request.

About this supplement

This Supplement applies to website visitors, grooming facilitys, pet and horse owners, application and product users, and other customers of Groomer.io, Inc. and its affiliated entities and business units in the United States.

Questions or comments?

Changes to CA supplement

Groomer.io may change or amend this supplement at any time, and any changes shall appear on the Groomer.io website at www.groomer.io.

Contact

You may contact Groomer.io about your rights under CCPA as follows:

info@groomer.io
Curtis Thorne, Data Privacy Officer