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This Website is owned and operated by Hexpress Healthcare Limited (‘we’, ‘us’, ‘our’) trading as https://pets.healthexpress.co.uk to users and visitors (‘you’, ‘your’). We take your privacy and that of your pet very seriously, and we are committed to protecting and respecting you and your pet’s privacy, and to using technology to enhance you and your pet’s online security. We ask that you read this Privacy Policy ('the Policy') carefully as it contains important information on who we are, why we collect, store, and how we will use and share your and your pet’s personal data. It also explains your rights in relation to your and your pet’s personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we collect and use your personal or your pet’s data, we are subject to the General Data Protection Regulation (GDPR) (EU) 2016/679 ('the Regulation') and for the purposes of the Regulation, Hexpress Healthcare Limited is the 'data controller', that is, the company which is responsible for and controls the processing of your personal and that of your pet’s data.
The Department of Health recommends minimum retention periods for health records. The Organisation will follow these at all times.
It would be helpful to start by explaining some key terms used in this policy:
We, us, our |
HEXPRESS HEALTHCARE LIMITED, trading as https://pets.healthexpress.co.uk |
Our data protection officer |
Crawford Brysland |
Personal data |
Any data relating to an identified or identifiable individual |
Pet data |
Any data relating to an identified or identifiable animal that you have ownership rights to or care responsibility for, whether on a part or full-time basis. |
Special category personal data |
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation |
We may collect and use the following personal or pet information about you or your pet:
Before you use certain areas of this Website, we will ask you to register yourself or your pet on it by requiring you to enter your personal and your pet’s information, including ‘sensitive personal data’ as defined by the Regulation. For example, we will obtain your personal and/or that of your pet’s data when you register to use this Website, complete an online questionnaire, send us feedback, post material, contact us for any reason, sign up to a service, and purchase goods or services.
We may also obtain sensitive personal data about you or your pet if you provide it in the check-out process. If you volunteer such information, you and your pet will be consenting to our processing it for the purpose of obtaining treatment. This pet and personal data is required to provide products and services to you and your pet. If you do not provide the pet and personal information we ask for, it may prevent us from providing products and services to you and your pet.
We may monitor your use of this Website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on our use of cookies, please see our Cookie Policy. Occasionally we may receive information about you or your pet from other sources (such as credit reference agencies), which we will add to the information we already hold about you and your pet in order to help us personalise our service to you and your pet.
We collect most of this personal information directly from you via our Website and app, or by telephone, text or email, or video consultation. We may also collect information directly from a third party, e.g. sanctions screening providers, credit reference agencies and customer due diligence providers; and from a third party with your consent, e.g. your vet, from cookies on our Website, and via our IT systems, e.g. automated monitoring of our Websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
Under data protection law, we can only use your personal and your pet’s information if we have a proper reason for doing so. Our reasons include but are not limited to:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests and that of your pet’s.
The table below explains what we use (process) your personal information and that of your pet’s for and our reasons for doing so:
What we use your personal information for | Our reasons |
---|---|
To provide treatment to our customers and for billing and order fulfilment |
Necessary for the purposes of diagnosis and for the provision of healthcare and treatment to your pets or animals To comply with our legal and regulatory obligations For our legitimate interests or those of a third party Because you have given consent |
To prevent and detect fraud against our company or our customers |
For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for our customers |
Conducting checks to identify our customers and verify their identity and that of their pets or animals as well |
To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g. policies covering security and internet use |
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to our customers |
Operational reasons, such as administration, improving efficiency, training and quality control |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for our customers at the best price |
Ensuring the confidentiality of commercially sensitive information |
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information |
Statistical and behavioural analysis, and research to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for our customers at the best price |
Preventing unauthorised access and modifications to systems |
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for our customers and their pets or animals |
Updating and enhancing customer and pet records |
For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
Statutory returns |
To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments |
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to our customers |
Marketing our services to: |
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
Credit reference checks via external credit reference agencies |
For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services |
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts |
For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
We may use your personal and your pet’s information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal and your pet’s information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal and your pet’s information with the utmost respect and never share it with other organisations for marketing or other purposes. If you have given permission for us to process your personal or your pet’s data, we may share your personal or pet’s data with associated companies and organisations that are our business partners and we or they may contact you (unless you have asked us or them not to do so) by mail, email, telephone, SMS, text/picture/video message, fax, about our services, products, promotions, offers, charitable causes that may be of interest to you.
You have the right to opt out of receiving promotional communications at any time by:
We may ask you to confirm or update your marketing preferences if you instruct 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.
We routinely share personal and your pet’s information with:
We only allow our service providers to handle your personal or your pet’s information if we are satisfied they take appropriate measures to protect your personal and your pet’s information. We also impose contractual obligations on service providers relating to ensure they can only use your personal or your pet’s information to provide services to us and to you. We may also share personal or your pet’s information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal or pet information with other parties, such as potential buyers of some or all of our business or during a restructuring process. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Information may be held at our offices and those of our associated companies,third party agencies, service providers, representatives and agents as described above, see above: 'Who we share your personal or pet information with'.
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal or pet information when this occurs, see below: 'Transferring your personal or pet information out of the EEA '.
We will keep your personal and your pet’s data while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal and your pet’s information for as long as is necessary:
We will not retain your personal or your pet’s information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal or pet information. When it is no longer necessary to retain your personal or your pet’s information, we will delete or anonymise it.
We have appropriate security measures to prevent personal and pet data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal and your pet’s data to those who have a genuine business need to access it. Those processing your information or that of your pet’s will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We will use technical and organisational measures to safeguard your personal or your pet’s data, for example:
While we will use all reasonable efforts to safeguard your personal and your pet’s data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal or pet data that are transferred from you or to you via the internet.
If you want detailed information from Get Safe Online on how to protect your and your pet’s information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We may monitor and record communications with you such as telephone conversations and emails for the purpose of complaint handling, training, quality assurance, fraud prevention and compliance.
To enable us and other companies in our group or partner companies to make credit decisions about you and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will record the search). We may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit grantors may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing and money laundering purposes. If you provide false or inaccurate information and we suspect fraud, we will record this.
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
We may transfer your personal or your pet’s data to countries located outside the European Economic Area, for the purpose of fulfilling our obligations and providing our service. We may share your personal or your pet’s data outside the European Economic Area (EEA), e.g.:
When you registered with this Website, you agreed that we may transfer your personal and your pet’s data to countries outside the European Economic Area. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal and your pet’s data. These transfers are subject to special rules under European and UK data protection law.
We may transfer your personal or your pet’s data to countries assessed by the European Commission as providing an adequate level of protection for personal and your pet’s information. We may equally transfer your personal and your pet’s data to non-EEA countries, which do not have the same data protection laws as the United Kingdom and EEA and in those circumstances, we will, ensure the transfer complies with data protection law and we will use standard data protection contract clauses that have been approved by the European Commission, thus safeguarding your and your pet’s privacy rights and giving you remedies in the unlikely event of a security breach.
If you would like further information please contact us or our Data Protection Officer (see ‘How to contact us’ below).
You have the following rights:
Access | The right to be provided with a copy of your personal and your pet’s information (the right of access) |
Rectification |
The right to require us to correct any mistakes in your personal or your pet’s information |
To be forgotten |
The right to require us to delete your personal or your pet’s information in certain situations |
Restriction of processing |
The right to require us to restrict processing of your personal or your pet’s information in certain circumstances, e.g. if you contest the accuracy of the data |
Data portability |
The right to receive the personal or your pet’s information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations |
To object |
The right to object: |
Not to be subject to automated individual decision-making |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you or your pet |
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
This Privacy Policy was published on 11 July 2022 and last updated on 11 July 2022.
We may change this Privacy Policy from time to time. You should check this Privacy Policy occasionally to ensure you are aware of the most recent version that will apply each time you access this Website.
Our contact details are shown below:
Registered office address: 106 Lower Addiscombe Road, Croydon CR0 6AD, United Kingdom |
Our Data Protection Officer contact details are shown below:
Crawford Brysland |
We hope that we or our Data Protection Officer can resolve any query or concern you may raise about our use of your or your pet’s information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).