Galaxy Vets Pet Parent Platform Privacy Policy

Version 01

Last Update: June 2023 

This notice describes how Personal Data (defined below) may be used and disclosed and how you can obtain access to this information. Please review it carefully. 

INTRODUCTION

We at Galaxy Vets Healthcare System, Inc. (“we”, “us”, “the Company”, or “Galaxy Vets”) value your privacy and are committed to keeping your personal data confidential. We use your data solely in the context of providing the Galaxy Vets mobile application (“App” or “Platform”), and providing tele-veterinary services, including all relevant content and functionality associated with the Platform and the tele-veterinary services (collectively, the “Services”) for use by Galaxy Vets veterinarians and other veterinary service providers (each, a “Galaxy Vets Service Provider”) to provide services to pets and pet parents (“Pet Parents”). Such Services may also include asynchronous chat between you and a Galaxy Vets Service Provider, appointment scheduling (in-hospital and virtual), access to previous medical records, and health/service reminders.

Privacy Policy Applicability

This Platform Privacy Policy applies to personal data that Galaxy Vets collects from Pet Parents (“Personal Data”). The term “Personal Data” includes any information that can be used on its own or with other information in combination to identify or contact one of our users. 

We believe that privacy and transparency about the use of your Personal Data are of utmost importance. In this Platform Privacy Policy, we provide you detailed information about our collection, use, maintenance, and disclosure of your Personal Data. The Platform Privacy Policy explains what kind of information we collect, when and how we might use your Personal Data, how we protect Personal Data, and your rights regarding your Personal Data. 

For additional information related to how we use and disclose your Personal Data, please contact our Privacy Officer at [email protected].

Note regarding third-party sites: Our Services may contain links to other sites that are not operated by Galaxy Vets. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy(ies) of every site you visit. Galaxy Vets has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Platform Privacy Policy does not apply to your use of or access to any third-party sites or services.

Agreement to Platform Privacy Policy Terms

BY ACCESSING AND/OR USING THE SERVICES, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS PLATFORM PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE USING THE SERVICES. YOU FURTHER ACKNOWLEDGE AND AGREE THAT SOME SERVICES PROVIDED THROUGH THE PLATFORM VIA AUDIO AND/OR VISUAL CAPABILITIES, INCLUDING VIDEO VISITS AND COMMUNICATIONS BETWEEN YOU AND GALAXY VETS SERVICE PROVIDERS MAY NOT BE CONFIDENTIAL AND/OR PRIVILEGED. VISITS AND COMMUNICATIONS MAY BE RECORDED AND ARCHIVED FOR TRAINING AND QUALITY CONTROL PURPOSES. 

Platform Privacy Policy Updates

Please note that we occasionally update this Platform Privacy Policy, and it is your responsibility to stay up to date with any amended versions. The current Platform Privacy Policy will be posted on the Pet Parent login page(s) of the Platform. It will also be accessible from the Pet Parent Account Profile. Any changes to this Platform Privacy Policy will be effective immediately upon its posting to the Platform login page(s) and will apply to all Personal Data that we maintain, use, and disclose. If you continue to use the Services and Platform following such notice, you are agreeing to those changes. 

Account Deletion

If at any point you no longer agree to the use and disclosure of Personal Data, as described in this Platform Privacy Policy, you can delete your user account on the Platform (“User Account”) through the “delete account” option in the Pet Parent Account Profile. Upon deletion of a User Account, all information associated with that User Account will be irretrievably deleted.

Questions or Concerns

If you have any questions or concerns after reading this Platform Privacy Policy, please contact us at [email protected]. We appreciate your feedback. 

COLLECTION AND USE OF PERSONAL DATA

What Personal Data Does Galaxy Vets Collect?

We collect five types of information from Pet Parents: (i) pet parent data; (ii) pet health data; (iii) user-generated content; (iv) support data; and (v) technology data. Each category of data is explained in depth below. 

Pet Parent Data: Galaxy Vets collects data from Pet Parents, which may include, but is not limited to, the Pet Parent’s first and last name, zip code, email address, home address, and phone number. The collection of this data is primarily used to create your User Account, which you can use to securely receive the Services. 

Pet Health Data: Galaxy Vets may collect pet health data from Pet Parents which may include, but is not limited to, your pet’s name, age, location, species, breed, microchip ID, medical history, symptoms, lifestyle, and communications between you and the Galaxy Vets Service Provider who is providing services to you and your pet via the Platform. We may also collect pet health data from third parties who have treated your pet. We collect this information to provide you with the Services and to provide the Galaxy Vets Service Provider with the information required to provide treatment through the Platform. 

User-Generated Content: Some features of the Platform allow you to input original content, such as comments, photos, videos, messages, survey responses, or any other files shared via the chat which may contain Personal Data (“User-Generated Data”). Galaxy Vets owns and may use any User-Generated Content to provide the Services.

Support Data: If you contact us for support or to lodge a complaint, we may collect technical or other information from you through log files and other technologies, some of which may qualify as Personal Data (e.g., IP address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Platform and related Services in accordance with this Platform Privacy Policy. 

Technology Data: We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data from your computer or mobile device as you navigate our Platform or interact with emails or other communications we have sent you. The information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, help us provide and improve our Services, and ensure the proper functioning and security of the Platform and Services. 

How Will Galaxy Vets Use Your Personal Data? 

Galaxy Vets processes your Personal Data based on legitimate business interests, the fulfillment of our Services to you and your pet, compliance with our legal obligations, and/or your consent. We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill those purposes described in this Platform Privacy Policy. Where required by law, we will ask for your prior consent before disclosing your Personal Data to a third party. 

More specifically, Galaxy Vets processes your Personal Data for the following legitimate business purposes: 

  • To provide Services; 
  • To fulfill our obligations to you under the Platform Terms of Use; 
  • To communicate with you about and manage your User Account; 
  • To properly store and track your data within our system; 
  • To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings and court orders; 
  • To protect our rights, privacy, safety, or property, and/or that of you or others by providing proper notices, pursuing available legal remedies, and acting to limit our damages; 
  • To handle technical support and other requests from you;
  • To enforce and ensure your compliance with our Platform Terms of Use or the terms of any other applicable services agreement we have with you; 
  • To manage and improve our operations and the Platform, including the development of additional functionality; 
  • To evaluate the quality of service you receive, identify usage trends, and improve your user experience; 
  • To keep our Platform safe and secure; 
  • To send you information about changes to our terms, conditions, and policies; 
  • To allow us to pursue available remedies or limit the damages that we may sustain; and
  • To enable you to connect with or share Personal Data with Galaxy Vets Service Providers, which enables Galaxy Vets Service Providers to monitor your pet’s health and overall condition as they deem appropriate. 

Does Galaxy Vets Use Personal Data for Analytics?

Galaxy Vets uses third-party service providers to monitor and analyze the use of the Platform as part of our Services. Presently, Galaxy Vets uses internal analytics tools to gather insights on how Pet Parents interact with the Platform. The analytics services we use may include, but are not limited to, Google Analytics for Firebase and Amplitude.

Does Galaxy Vets Collect Personal Data to Share with Social Media Platforms? 

Galaxy Vets’ Services may contain social media features that collect your IP address and information about which page you are visiting on our Services. These social media features may also set a cookie to enable a “share” button to function properly. The social media platforms we may incorporate on the Platform include, but are not limited to, Instagram, Facebook, Twitter, Pinterest, and Tik Tok. 

Where Is Personal Data Processed?

The Personal Data we collect through the Platform will be stored on secure servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. The App is “native” to your device, meaning information you enter into the App may also be stored directly on the device that you use to access and enter information into the App. 

With Whom Does Galaxy Vets Share Personal Data? 

We may share your personal information with the following categories of individuals/entities: 

Business Partners and Vendors: We share Personal Data with a limited number of partners, service providers, and other persons/entities who help run our business (“Business Partners”). Specifically, we may employ third-party companies and individuals to facilitate our Services, provide Services on our behalf, perform Service-related functions, or assist us in analyzing how our Services are used. Our Business Partners are contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, and customer services. 

Our Advisors: We may share your Personal Data with third parties that provide advisory services to Galaxy Vets, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”). Personal Data will only be shared with Advisors if Galaxy Vets has a legitimate business interest in the sharing of such data. 

Galaxy Vets Service Providers: As part of the Services, we will share your Personal Data with Galaxy Vets Service Providers. If at any point you want to deny access to one or more Galaxy Vets Service Providers, you can do so by emailing [email protected].

Third Parties Upon Your Direction or Consent: You may direct Galaxy Vets to share your Personal Data with third parties. Upon your request and consent, we may share such Personal Data with those third parties that you identify. 

Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Galaxy Vets’ corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may share your Personal Data with a third party. 

Government and Law Enforcement Authorities: If reasonable and necessary, we may share your Personal Data to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Platform Privacy Policy or the Platform Terms of Use; or (iii) bring legal action against someone who may be violating the Platform Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of Galaxy Vets or any third party, including other users of our Services. 

How Long Does Galaxy Vets Retain Personal Data?

Galaxy Vets retains your Personal Data only as long as necessary and as required for our business operations, the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact period of retention will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which we process your Personal Data, including whether those purposes can be achieved through other means; and (iv) business operations and legal requirements. Specifically, Galaxy Vets strives to retain pet health data for no longer than 7 years after last contact with your pet (the “Retention Period”); however, the above factors may extend or decrease this Retention Period. 

At the end of the applicable Retention Period, we will remove your Personal Data from our databases and will require that our Business Partners remove any identifiable Personal Data from their databases. If there is any data that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing of such data. Please note that once we disclose your Personal Data to third parties, we may not be able to access that Personal Data and we cannot force the deletion or modification of such information by third parties.

Galaxy Vets and its Business Partners reserve the right to continue using de-identified data indefinitely, even after Personal Data has been removed from Galaxy Vets’ databases. We may continue to disclose de-identified data to third parties in a manner that does not reveal personal information, as described in this Platform Privacy Policy. Our continued use of de-identified data will comport with applicable law. 

What Happens to Personal Data Submitted by Minors?

Galaxy Vets does not knowingly collect Personal Data from individuals under the age of 18. Additionally, our Services are not directed to individuals under the age of 18. We request that these individuals not provide Personal Data to us. If we learn that Personal Data from users under the age of 18 has been collected, we will deactivate the User Account associated with that data and take reasonable measures to promptly delete such data from our records. If you are aware of a user under the age of 18 accessing the Services, please contact us at [email protected]. 

If you are a resident of California under the age of 18 and have registered for a User Account with us, you may ask us to remove content or information that you have posted to our Platform. 

PET PARENT RIGHTS

What Rights Do Pet Parents Have Concerning Their Personal Data?

As a user of Galaxy Vets’ Services, you have certain rights relating to your Personal Data, including pet health data. These rights are subject to local pet medical record confidentiality rules, and data protection and privacy laws, and may include the right to:

  • Access Personal Data, including pet health data, held by Galaxy Vets; 
  • Erase/delete your Personal Data, to the extent permitted by applicable pet medical record confidentiality, data protection, and privacy laws and to the extent technologically feasible; 
  • Receive communications related to the processing of your Personal Data, including pet health data; 
  • Restrict the processing of your Personal Data to the extent permitted by law; 
  • Object to the further processing of your Personal Data, including the right to object to marketing; 
  • Request that your Personal Data and/or pet health data be transferred to a third party, if possible; 
  • Receive your Personal Data, including pet health data, in a structured, commonly used, and machine-readable format; and/or
  • Rectify inaccurate personal information and, taking into account the purpose of processing the Personal Data, ensure it is complete. 

Where the processing of your Personal Data by Galaxy Vets is based on consent, you have the right to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the above rights, please contact us at [email protected]. 

How Can Pet Parents Update, Correct, or Delete Personal Data or Their User Account? 

You have the right to request restrictions on uses and disclosures of your Personal Data. While we are not required to agree to all restriction requests, we will attempt to accommodate reasonable requests when appropriate. 

You may change your email address and other contact information by accessing your Galaxy Vets User Account. If you need to make changes or corrections to other information, you may contact us at [email protected]. In order to comply with certain requests to limit use of your Personal Data, we may need to terminate your ability to access and/or use some or all of the Services. BY REQUESTING TO LIMIT USE OF YOUR PERSONAL DATA OR DELETE PERSONAL DATA, YOU ACKNOWLEDGE AND AGREE THAT GALAXY VETS WILL NOT BE LIABLE TO YOU FOR ANY CORRESPONDING LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS NECESSARY TO COMPLY WITH YOUR REQUEST. 

You have the right to request deletion of any Personal Data from your User Account or the Galaxy Vets Platform. To request deletion of your Personal Data, please email us at [email protected] and include a description of the Personal Data you would like removed. We will respond to all requests for data deletion as soon as reasonably possible.

Should you decide to delete your User Account entirely, you may do so through your Galaxy Vets User Account profile . By terminating your User Account, you agree that you will not be able to access certain Personal Data previously contained in your User Account, but you will be able to access pet health data by submitting a written request to Galaxy Vets within the Retention Period described above. You further understand that it may not be technologically possible to remove all of your Personal Data from our systems. While we will use reasonable efforts to remove your Personal Data, the need to back up our systems to protect information from inadvertent loss means a copy of your Personal Data may exist in a non-erasable form that will be difficult or impossible for us to locate or remove. 

PROTECTION OF PERSONAL DATA

Is Personal Data Secure?

Galaxy Vets understands the importance of data confidentiality and security. We use a combination of reasonable physical, technical, and administrative security controls to: (i) maintain the security and integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of your Personal Data; and (iii) protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm to you or your pet. 

While Galaxy Vets uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA. GALAXY VETS IS UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME. 

What Safeguards Does Galaxy Vets Have in Place to Secure Personal Data and/or Pet Health Data?

Galaxy Vets stores Personal Data on secured servers and uses a combination of technical, administrative, and physical safeguards to protect your personal information. Such safeguards include, but are not limited to, authentication, encryption, backups, and access controls. 

How Can Pet Parents Protect Their Personal Data? 

You are solely responsible for preventing unauthorized access to your devices and your User Account by protecting your account credentials and limiting access to your devices. Galaxy Vets has no access to or control over your device’s security settings, and it is your responsibility to implement any device-level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability). We recommend that you take all appropriate steps to secure any device that you use to access our Services. 

Please note that Galaxy Vets will never send you an email requesting confidential information, such as account numbers, usernames, passwords, or Social Security Numbers. If you receive a suspicious email from Galaxy Vets, please notify us at [email protected].

Further, if you know of or suspect any unauthorized use or disclosure of your User Account information or any other security concern, please notify Galaxy Vets immediately. 

What If Galaxy Vets Experiences a Data or Security Breach?

Galaxy Vets takes the security of your Personal Data seriously. In the event of a data or security breach, Galaxy Vets will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within Galaxy Vets’ control which may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to Galaxy Vets in connection with such security incident; (iii) as applicable, cooperate with any affected Galaxy Vets user or client in accordance with the terms of Galaxy Vets’ contract with such user or client; and (iv) document and record actions taken by Galaxy Vets in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations taken to prevent similar security incidents in the future. Galaxy Vets will notify you of any data or security breaches as required by and in accordance with applicable law. 

ADVERTISING, MARKETING, AND TRACKING

Does Galaxy Vets Send Marketing or Advertisement Materials?

Presently, Galaxy Vets does not send marketing or advertising materials. In the event that Galaxy Vets uses your Personal Data to contact you with newsletters, marketing, or promotional materials, or other information that may be of interest to you, you may opt out of receiving such messages at any time by following the unsubscribe link within the applicable message or by contacting us. 

Can Pet Parents Opt Out of Receiving Communications from Galaxy Vets? 

We may send communications, including emails and push notifications, to you regarding your User Account and the Services. You can choose to filter any User Account and Services emails using your email settings, but we do not provide an option for you to opt out of these communications. You may opt out of receiving push notifications by changing the settings on your mobile device.

If You selected your email address as Your method to access the App, We will send email messages for verification of access, for sending one-time PIN codes for authorization, and to notify You of follow-up messages relating to Your pet that have not been timely viewed on the Platform. If You selected your email address as your method to access the App, if You opt out of emails from Galaxy Vets, you will not be able to receive the one-time PIN codes and will be unable to access the App. However, You can opt out of text messages from Galaxy Vets by following the instructions in the text message or replying “STOP” to a text message.

If you selected your phone number as your method to access the App, We will send SMS messages for verification of access, for sending one-time PIN codes for authorization, and to notify You of follow-up messages relating to Your pet that have not been timely viewed on the Platform. While replying “STOP” to a text message You have received from us will opt You out of receiving SMS messages, if You selected your cell phone number as your method to access the App, You will not be able to receive the one-time PIN codes and will be unable to access the App. Thus, if You want to continue using the Platform, you cannot opt out of SMS messages. But You can opt out of email messages from Galaxy Vets by following the instructions provided in the applicable message. 

What Is Galaxy Vets’ Cookie Policy?

Cookies are small files that a web server sends to your computer or device when you visit a web application that uses cookies to keep track of your activity on that site. Cookies also exist within applications when a browser is needed to view or display certain content within the application. Cookies hold a small amount of data specific to a web application, which can later be used to help remember information you entered in the application (like your email or username), preferences selected, and movement within the application. We do not use cookies; however, we use third-party software development kits that do use cookies and other technologies to, among other things, better serve you with more tailored information, and to facilitate efficient and secure access to the Services. Specifically, we use Google Analytics for Firebase and Amplitude which collect data that may be considered Personal Data, such as User IDs, IP addresses, device-unique IDs, and device metadata. 

Do Not Track Disclosure

Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. To date, there is no industry standard for DNT and users cannot know how a given company responds to a DNT signal they receive from browsers. Galaxy Vets is committed to remaining apprised of DNT standards. However, Galaxy Vets does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Galaxy Vets to respond to signals or other mechanisms regarding the collection of your personal information. 

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to you. Please see the CCPA Attachment for an explanation of your rights. 

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from us an annual list identifying the categories of personal customer information which we shared, if any, with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 

Galaxy Vets Healthcare System, Inc. 

8608 NE 222nd Avenue

Vancouver, WA 98682

Attn: Privacy Officer