The Veterinary Emergency Group LLC, and its affiliates and subsidiaries (hereinafter, the

“Company,” “we,” “our,” or “us”) values privacy and is committed to providing transparency regarding our privacy practices. This Privacy Policy ( “Policy”) sets forth how we collect, use, disclose and otherwise process the personal information we collect, as well as the rights and choices individuals have regarding their personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS,

RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THIS WEBSITE OR OUR SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND THE COMPANY’S TERMS OF SERVICE, WHICH ARE HEREBY INCORPORATED INTO, AND FORM AN INTEGRAL PART OF, THIS PRIVACY POLICY. PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THIS WEBSITE OR OUR SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND THE COMPANY’S TERMS OF SERVICE, WHICH ARE HEREBY INCORPORATED INTO, AND FORM AN INTEGRAL PART OF, THIS PRIVACY POLICY.

1. Scope

This Policy applies to the personal information we collect related to

• visitors and users of our websites (each a “Site” and collectively, the “Site”), mobile

  applications (each an “App” and collectively, the “Apps”), downloadable software, and other products, services and online features operated or provided by us that display or include link to this Policy (collectively, the “Services”) ;

• visitors and customers of the veterinary hospitals and clinics we own or manage as well as individuals that use other in-person services, events and operations we may offer;

• our current, former and prospective partners, vendors, suppliers and customers;

• individuals who subscribe to our newsletters and receive marketing communications

  from us;

• individuals who participate in surveys, contests and research conducted by us; and

• individuals that otherwise contact, communicate or engage with us on- or offline.

This Policy does not apply to the personal information that we collect and process related to our employees, contractors, job applicants, and candidates, or to any information that is exempt under applicable privacy laws. Except for any customer personal information collected within a patient record, the Policy generally, does not apply to any information related to the medical treatment of an animal/patient and such records and information are handled in accordance with confidentiality requirements and other obligations set forth under federal, state, and local law, as and to the extent applicable.

Additional Notices. Additional or supplemental notices and disclosures (each an “additional notice”) may be provided and will apply to certain personal information collected and processed by us. Generally, we provide additional notices in order to clarify our privacy practices in specific circumstances and provide you with additional information about certain processing activities. To the extent there is a conflict with this Policy, the additional notice will control with respect to the personal information subject to that additional notice.

Additional Information and Rights for Residents in Certain U.S. States. For information about the privacy choices you have regarding your personal information, review Section 13 below, as well as Section 16, Additional Information for Individuals in certain US  jurisdictions, which includes additional information about privacy rights for residents of certain U.S. states. If you are a California resident, please see Section 16, ‘Additional Information for California Residents’ below for more information pursuant to the California Consumer Privacy Act, as amended (“CCPA”).

2. The Types and Categories of Personal Information We Collect

We collect personal information directly from individuals and, in some cases, we may collect personal information and data automatically (e.g., when you access our Sites or Apps) as well as from third parties.

Information Collected Directly. The actual personal information we collect, and how we use it, varies depending upon the nature of your relationship and interactions with us. Also, in some cases, including where required by applicable law, we ask for your consent or give you certain choices prior to collecting or using certain personal information. The Company collects personal information in order to provide our products and services, comply with our legal obligations, promote our business interests, and for the other purposes as set forth in this Policy. Where we ask you for personal information, we will indicate to you what information is mandatory and what is optional to provide. However, if you do not provide personal information to the Company marked as mandatory, we may not be able to provide you the products and Services or complete a transaction you requested.

Generally, we collect the following categories and types and of personal information:

• Contact Information: we may collect and receive certain contact information about current, former and prospective customers, vendors, business partners, partner veterinarians, and others with whom we have a business relationship (e.g., referring veterinarians), such as name, company name, IP address and e-mail or physical address, from you directly, or indirectly, through business relationships, or from publicly available sources.
  

• Registration and Account Information: if you create an account via our Services, we collect certain personal information from you, such as your name, user name, address, email address, phone number, and if you provide such billing details, as well as information about your pet and its health.
  

• Transaction and Payment Information: in connection with a purchase or payment you submit to us, we collect information such as your name, shipping and billing address, credit card and other payment information, as well as other transaction details. We also maintain transactional records about your past visits, services used, and purchases made.
  

• Communications: if you contact us by e-mail, mail, phone, text message, or otherwise regarding our products or services, we collect and maintain a record of your name and contact information, information regarding your pet and its health conditions or treatment plans, your communications and our responses, including a transcript of the communication and any information (including attachments and pictures) you may provide to us. If you call us, for example our hospitals or customer care, we may also record calls and maintain logs and records of those calls. Additionally, we may use third- party provided technologies that transcribe such recorded calls .
  

• Images and Video Recordings: if you visit our veterinary clinics, premises and events, we may collect CCTV, , and video recordings on and around our clinics, office premises or at an event we host or sponsor. We also collect images and recordings you submit to us via the Services or otherwise, for example images that show your pet’s disease or condition. In addition, we may record phone/video calls and other interactions you have with our veterinarians, nurses, or customer support. 
  

• Events, Contests and Promotions: we also collect information related to your participation in our on- and offline events, including promotional events, contests and sweepstakes, as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event. When you fill out a ‘Contact Us’ form, sign up for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests. When you complete a survey or submit ratings, we collect personal information about you, including your responses and ratings.

We also may collect information about your pet(s), including name, breed, gender, birthdate, size, weight, veterinary and health information and records, treatment and prescription information, pet insurance information, and photos including regarding your pet’s condition if you provide such to us. Please note, that such information does not, generally, constitute personal

information and thus is not subject to this Policy.

Automatically Collected Information. We may collect personal information about how you use our Services and your interactions with us and others, including information we collect automatically (e.g., through cookies and pixel tags and other tracking technologies), as well as information we derive about you and your use of the Sites and Services, such as:

• Device and browser information: we use cookies, log files, pixel tags and other tracking technologies to automatically collect information when and how you access or use our Sites and Services, such as traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history), IP address, domain name, browser type, device type, device ID, IMEI, Wi-Fi MAC, internet service provider, referring and exiting URLs, operating system, language, clickstream data, similar device and usage information, operating system, browser type, and mobile network information. We may also collect or derive general location information about you, such as through your IP address.
  

• Usage data: we also collect activity information related to your use of our Sites and Services, such as information regarding what pages you accessed and when, date and time of your visit, the links clicked, searches, features used, items viewed, and time spent within the Services. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or

  energy use), and any other data collected for the purposes of measuring technical diagnostics. We may also use pixels in HTML e-mails to understand if individuals read or open the e-mails we send to them.
  

In addition, to the extent permitted by applicable law, we may also collect certain personal information from third parties, such as:

• Third-party and Social Media Platforms: if you connect with us, or share information about us, through social media networks and other third-party platforms that you use, we may receive personal information from these platforms. These third-party platforms control the personal information they collect, use and share about you and their respective privacy policies, not this Policy applies to their data practices;
  

• Vendors and Other Providers: we may engage vendors and work with other

  veterinarians, clinics and other veterinary specialist who provide services to us or you on our behalf (such as partner clinics we refer your case to or that refer a case to us, specialized vet service providers (such as for example pet radiologists), payment processors, cloud hosting, and data storage providers). In addition, we may receive personal information from ad networks, analytics providers, and others who we work with to deliver, improve, and measure our online advertising and marketing campaigns; and
  

• Prospective customer information: we may receive lead and prospect information from third parties about prospective customers that may be interested in our products and veterinary services. We may also engage with third parties to enhance or update our own customer information.

Aggregate and Non-Identifiable Information. The Company may also collect, use, share, disclose, and otherwise process aggregate, anonymous or in some cases de-identified personal information related to our veterinary clinics, products and services, for research, marketing, analytics, and other purposes, and such data is not subject to this Policy.  Where the Company

collects, uses, discloses or otherwise processes any de-identified information, we will maintain and use such information in de-identified form and not attempt to re-identify the information, except in accordance with applicable privacy laws.

3. Purposes of Collection, Use and Processing

The purposes for which we collect, use, disclose and otherwise process personal information vary depending upon the circumstances. Generally, we process personal information for the business and commercial purposes described below:

• Services and Support: To operate the Sites and Services and our clinics and related services, including to communicate with you about your use of the Services and visits to the clinics, schedule and confirm your vet appointments, manage and facilitate your visits to our veterinarian clinics, provide vet services to your pet, including recommending treatments or procedures, provide troubleshooting and technical support, fulfill and respond to your requests and inquiries, process your payments and other

  transactions, for customer support purposes, and to carry out our obligations arising from our contracts with you.
  

• Communications: To seek your ratings or comments on the products or services we provide on- and offline to you and your pet(s) and send you communications by post, text message (if you have opted-in), or e-mail, which you have requested or that may be of interest to you, including newsletters, or promotions of our products or Services or events, and to notify you of changes to our products and Services.
  

• Referrals and Supplementing Records: to receive or place referrals from other veterinarians, specialists, or similar pet care service providers and communicate with your pet insurance providers. For example, we may request or share your pet’s records with other pet service providers as requested by you.
  

• Research and Analytics: To measure the adequate performance of our interactions with you, improve our Sites and Services, for our internal business purposes, and for other research and analytical purposes;
  

• Customization and Personalization: To tailor content we may send or display on our Sites, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
  

• Marketing and Advertising: To promote our products and services on third-party websites, as well as for direct marketing purposes, including to send you newsletters, alerts and information we think may interest you.
  

• Planning and Managing Events: For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant on and offline events and services we host or sponsor.
  

• Legal Proceedings and Obligations: To manage risks or obtain professional advice and defend the Company’s rights and establish, exercise and defend our legal claims.
  

• Account Administration: Facilitate and administer your account on the Sites and Services.
  

• Security and Protection of Rights: To provide, create and maintain a trusted and safe environment and comply with the Company’s legal obligations. For example, to protect our Sites, Services, in-person clinics, veterinarians and other staff, and our business operations generally; to prevent, detect and investigate fraud, misuse, harassment or other types of unlawful activities; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this Policy, Terms of Service and our other applicable agreements.
  

• General Business and Operational Support: To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of the Company’s general business, accounting, record keeping and legal functions.

4. Disclosures of Personal Information

We may share your personal information with certain organizations and third parties as set out below.

• Affiliates and Subsidiaries: we may disclose the personal information we collect to our parent company, Veterinary Emergency Group LLC, among our clinics, affiliates and subsidiaries who may use your personal information in accordance with this Privacy Policy (e.g., marketing, surveys).
  

• Referrals: the Company may need to refer your information to other veterinary clinics or specialists (such as internists, radiologists, etc.) in order to provide you with the requested services or otherwise upon your request. 
  

• Other Veterinarians and Business Partners: upon completion of the Company’s treatment of your pet and related services we may provide, the Company will send your pet's (emergency) treatment and health records to your general veterinarian if you or a referring veterinarian have provided us with your current veterinarian's contact information. We may also disclose your personal information and your pet’s treatment and health records to other business partners and specialists involved in providing pet services, such as your pet insurance company, as necessary to fulfill the services that you requested or may interest you.
  

• Third Party Platforms and Providers: we may share your personal information with our third-party platform and service providers we use to provide or make available certain features or portions of the Sites and Services, or as necessary to respond to your requests. These third parties  perform services on our behalf, such as providing hosting and storage, conducting surveys, research and marketing services,  processing transactions and payments, and performing analyses to improve the quality of our Sites and Services.
  

• Please note that electronic payments to the Company are processed via our third-party vendor’s online payment systems. The Company does not store or have access to your full credit card information. Any personal or financial information you provide to our third-party payment providers is collected and processed subject to that third party’s  respective privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information. 
  

• Marketing, advertising and analytics providers: we may disclose certain information that includes personal information to third-party ad network providers, sponsors and/or traffic measurement services, who may use this data to improve and measure the effectiveness of our ads and those of third parties. For more information, see Section 5. below. We may also engage third party analytics companies to collect information about Site usage in order to help us to understand how users access and use the Sites and Services, to improve our Services and other online features, products and offerings, and for other research and analytical purposes.
  

• Business Restructuring: Circumstances may arise where for strategic or other business reasons the Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.

• Legal Obligations, Security and Protection of Rights: We may in some cases also disclose personal information (i) if required by law or government order, or as necessary to comply with a legal obligation or process we are subject to, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, the Company may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests.

• Disclosure for Other Reasons: we may also disclose your personal information otherwise as permitted by law, upon your request, or with your consent.

5. Cookies, Advertising and Tracking

When you access the Sites and Services, we and our third party providers may use technical means and tools, such as “cookies,” “pixels,” “web beacons,” and other online tracking technologies on the Sites and Services, to automatically collect and record information about your browsing activities, and use of the Sites and Services. We may also combine such “usage data” with other personal information we collect about you.

• Cookies: a cookie is a small alphanumeric identifier placed on your computer device or web browser for record-keeping purposes. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Sites and Services may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. 
  

• Pixels (sometimes referred to as tags, pixel tags or clear GIFs) and other tracking technologies: these are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive or browser, pixels are embedded invisibly on web pages. We may use pixels (also referred to as web beacons, web bugs or pixel tags) in connection with our Services to, among other things, track the activities of users of our Sites and Services, help us manage content, and compile statistics about usage of our Sites and Services. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track e-mails and to evaluate and improve our marketing e-mails. Pixels can be embedded in a web page or in an e-mail for purposes such as traffic reporting, unique visitor counts, advertising auditing and reporting, as well as determining whether a recipient has opened a particular e-mail sent by the Company.
  

Advertising and Targeting. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising on our Sites and Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixel tags, and other tools to collect activity information on our Sites (as well as on third-party sites, platforms, and services), as well as IP address, location information, device ID, cookie and advertising IDs, and other unique identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content on our Sites and Apps as well as on third-party sites and apps, and to evaluate the success of such ads and content. 

Third-Party Analytics. We may use one or more third-party analytics services and tools to evaluate your use of our Sites and Services, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.  

Managing Your Cookie Preferences. You can review and manage your cookie preferences for our Sites and opt-out of most cookies, including targeting cookies and tags on our Sites, by reviewing and changing your preferences (including to opt out of all but ‘essential’ cookies) via our cookie preference manager. To access the cookie preference manager click the ‘Cookie Settings  symbol at the bottom of each of our Sites.  Most browsers also allow you to delete and block cookies (see the “Help” menu of your browser for more information). Please note that cookie preferences are browser and device specific, which means that you need to set preference for each browser and device you use to access our Sites; in addition, if you delete or block cookies, you may need set these preferences again. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us, they may just be less relevant to you. If you are a California resident, please review Section 16. for additional information about your opt-out rights under the CCPA.

In addition, you can also control how participating third-party ad companies use the personal information that they collect about your visits to our Sites and Apps, and those of other third parties, in order to display more relevant targeted advertising to you. For more information and to opt out of receiving targeted ads from participating third-party ad networks go to https://aboutads.info/choices (Digital Advertising Alliance) (you can also download the DAA AppChoices tool (https://youradchoices.com/appchoices) in order to help control interest-based advertising on apps on your mobile device). 

6. Social Media

Our Services may contain links to third-party social networking sites, platforms, and plugins (e.g., the “Facebook Like” button, the “Share This” button) or other interactive mini-programs to facilitate social media functions and features, which may collect personal information about you. These social media companies may collect information about you if you click on a link and may automatically record information about your browsing behavior every time you visit a third party’s respective site or social media services. Your interactions with and participation in such social media platforms, sites and forums (e.g., Facebook, X, TikTok, LinkedIn, YouTube or Instagram) and the collection of personal information by these companies is governed by the respective third party’s privacy policy and terms, not this Policy. Thus, we encourage you to familiarize yourself with any applicable privacy policies, notices and terms of use to better understand about how your personal information is collected, used and otherwise processed by these social media companies. Additionally, depending on your settings and preferences on the respective social media sites, these platforms may also automatically provide us with certain of your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets. 

7. Links to Other Websites

As a resource to you, the Sites and Services may include links to external third-party websites, mobile applications, platforms and other online services or provide you the opportunity to disclose information directly to third parties. Our Policy does not apply to the personal information collected via such third-party websites, mobile applications, services or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to such third parties the Services or Sites may link to and we recommend that you familiarize yourself with the data practices of these third parties by reading each of the party’s respective privacy statements and notices.

8. Retention 

The period for which we retain your personal information varies depending on the purpose for which we collect and process your personal information. Generally, we retain your personal information for as long as reasonably necessary to fulfill the purposes for which we collected it (as outlined in this Policy or otherwise disclosed or consented to by you), such as providing you with our products and services, to facilitate transactions, communications or services you have requested. In certain cases, we may also retain your personal information for an additional period of time if permitted or required by law, necessary to comply with our legal obligations or to establish, exercise or defend our legal rights and business interests (including to respond to actual or potential legal claims). For more information on how long your personal information is retained by the Company, please contact us using the details provided in Section 15 below. information needed In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy. 

9. Security

    We strive to protect the personal information we collect and process by using certain security technologies and measures designed to help protect your personal information, including from any unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM OR ENVIRONMENT CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, THE COMPANY SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety, integrity and security of your personal information also depends on you and it is your responsibility to maintain the security and confidentiality of any credentials you use or were provided with related to the Services (such as your account login credentials) and to not reveal them to others. You must contact us immediately using the contact details provided in Section 15 below if you have reason to believe that your credentials (e.g., username and password combination) related to our Services have been compromised. 

10. Children

Our Sites and online Services are not directed at, nor intended for use by, children under the age of thirteen (13) and we do not knowingly collect personal information from individuals in this age group. If you believe we have inadvertently collected personal information about a child, please contact us using the details provided in Section 15 below, and we will endeavor to delete that information from our databases. 

11. User Content 

The Site and Services may provide you with the ability to submit comments on, provide an opinion about, rate, or otherwise review and discuss our products and services (including where provided in person, on- and otherwise offline) or provide other feedback and communications to us (“User Content”). We reserve the right to use and generate or infer information from any User Content you submit, including posting it to a publicly available portion of the Sites and Services. Any User Content you generate and provide within the publicly accessible parts of the Services (such as forums or feeds) will be available and visible to other users and visitors of the Company’s Sites and Services and may be retrievable by third-party search engines and may be further disseminated by third parties. Publicly posting any User Content on the Company’s Sites and Services is entirely voluntary on your part and we recommend you carefully consider the information you choose to make publicly available. We ask that you not upload any User Content that includes confidential or sensitive information and other personal information that you wish to keep confidential. 

12. Your Responsibilities

We ask that the personal information you provide to the Company is accurate, reliable, and relevant to our relationship and that your disclosure of such will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges of a third party. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO THE COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE THE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT THE COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH IN THIS POLICY WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY THE COMPANY FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY.

13. Your Privacy Rights and Choices

Access, Deletion and Correction. You may submit a request to us to access, correct or delete personal information by contacting the Company as set out in  Section 15. We will process your request in accordance with applicable privacy and data protection laws. We may ask you for additional information so that we can confirm your identity or process your request. If you have an account with us, you may review and update most of your account information directly within your account.

Direct Marketing. You have the right to opt-out of receiving email marketing communications from us at any time by clicking the unsubscribe link contained in each marketing or promotional e-mail we send to you or by contacting us using the details provided in Section 15 below. Please note, that even if you opt-out, we may, in accordance with applicable laws, still continue to send you transactional or service-related e-mail communications, such as service announcements and administrative messages.

Please see Section 16 and Section 17 for additional information, as required under certain privacy laws, including the rights certain individuals have under the privacy laws of California and other U.S. states.

14. Changes to this Policy

This Policy is effective as of the “Last Updated” date stated at the top of the Policy. We reserve the right to amend this Policy from time to time. We will post any changes to this Policy on this Site and the  it is your responsibility to periodically review the Policy to determine whether any amendments have been made hereto. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites or notifying you electronically.

15. Contact Us

If you have questions regarding this Policy or our handling of your personal information, please contact us via e-mail at vegpriv@veg.vet, by phone at  (866) 237-8831.

16. Additional Information for California Residents

This Section 16 provides additional information to California residents regarding the categories of personal information we collect, use, disclose and otherwise process and the right individuals have under the California Consumer Privacy Act of 2018, as amended (“CCPA”)with respect to their personal information (the “CCPA Notice”).

Scope. This CCPA Notice applies, generally, to the personal information that we collect and otherwise process about California residents.  This CCPA Notice does not address or apply to our collection of personal information that is:

• Exempt from or not subject to the CCPA, such as consumer credit reports and background checks, publicly available data, or other information that is exempt under the CCPA; or

• Personal information we collect from our contractors, employees, or from job applicants, which is subject to different privacy notices. 
  

Sales and Sharing of Personal Information. Under California privacy laws, "sales" and “sharing” are broadly defined and include disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, or for purposes of cross-context behavioral advertising.  While we do not disclose personal information to third parties in exchange for monetary compensation, we may sell or share (as defined by the CCPA) the following categories of personal information as identified in the table above: [Identifiers, Commercial information, and Internet and electronic network activity information to/with third-party advertising networks, analytics providers, and social networks, in order to measure and improve our marketing and advertising campaigns and the Services.] We do not “sell” or “share” (as defined by the CCPA) (i) any sensitive personal information, or (ii) any personal information about individuals who we know are under sixteen (16) years old. 

Sources of Personal Information. In general, and as explained further above in this Policy, we obtain the categories of personal information directly from you, automatically and from third parties, which may include the following categories of sources:

• Business relationships, such as our business partners, including referring vets, clinics and pet service providers such as pet insurance providers or specialized veterinary services providers;

• Advertising companies and networks;

• Data analytics providers;

• Social media platforms and networks;

• Internet service providers;

• Operating systems and platforms; and

• Organizations involved in merger or acquisition activities and negotiations.;

• Information publicly available online.
  

Purposes of Collection, Use, Disclosure and Processing. As described in more detail in Section 3 and Section 4, we may collect, use, disclose and otherwise process personal information for one or more of the following purpose(s) and as otherwise directed or consented to by you:

• Services and support

• Communications

• Referrals 

• Research and Analytics 

• Customization and Personalization 

• Marketing and Advertising 

• Planning and Managing Events 

• Legal Proceedings and Obligations 

• Account Administration

• Security and Protection of Rights 

• General Business and Operational Support

Sensitive personal information: notwithstanding the above, we only use and disclose sensitive personal information as reasonably necessary (i) to perform  services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our products and services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.  We do not use or disclose your sensitive personal information other than as authorized pursuant to Section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)).

Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed or consented to you at the time of collection. For example, we will retain transactional data for as long as necessary to comply with our tax, accounting and recordkeeping obligations, administer applicable returns and warranty programs, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, comply with legal obligations and as may otherwise be required by law.

CCPA Privacy Rights.  California residents have certain rights under the CCPA with respect to their personal information we collect about them, subject to certain limitations and exceptions, including the right to:

• Know/Access: the right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.

• Correct: the right to request that a business that maintains inaccurate personal information corrects that personal information it has collected about them. 

• Deletion/Erasure: The right to request deletion of personal information we have collected about them under certain circumstances.

• Limit use or disclosure of sensitive personal information: the right to limit the use or disclosure of sensitive personal information to those uses authorized by California privacy laws (however, as noted above, we do not use or disclose sensitive personal information other than as authorized by the CCPA).

• To opt out of sales and sharing: the right to opt out of sales and sharing of their personal information by us.

• Non-discrimination: The right not to be subject to discrimination for asserting their rights under the CCPA. 

Submitting CCPA Requests. California residents may submit requests to know, correct and delete their personal information via:

• Our Privacy Portal

• E-mail to vegpriv@veg.vet

Privacy Request Verification Process. When you submit a request to know, correct, or delete, the Company will, to the extent required, need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log in to your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law. Authorized agents may initiate a request on behalf of another individual by submitting a request via our Privacy Portal here ; authorized agents will be required to provide proof of their authorization and we may also require that the relevant California consumer directly verifies their identity and the authority of their authorized agent.

• Requests to Opt Out of Sales and Sharing. California residents may submit a request to opt out of sales or sharing  via their browser (“Browser Opt Out”) and via other means (“Off-Site Opt Out”) as described below.  Browser Opt-Out: by enabling If our Sites detect that your browser is transmitting a Global Privacy Control (“GPC”) signal when you visit one of our Sites, we will opt your browser out of ‘sales’ and ‘sharing’ on that Site via cookies other than those that are ‘Essential.’ (More information on GPC is available here.)  You can also opt out via our ‘Cookie Preference Manager,’ which you can access from the footer of our Sites, by clicking the “Your Privacy Choices” link. 

• Offline opt out: To opt out of Off-Sites ‘sales’ and ‘sharing’ for targeted advertising, please also submit an opt-out request via our Privacy Portal here.

NOTE: Your browser opt outs are browser and device specific. So, if you use more than one device and/or browser to access one of our Sites, you will need to either turn on GPC or use the ‘Cookie Preference Manager’ to turn off Targeting, and Performance, and Functional cookies, for each browser and device that you use to access that Site.

Our Sites do not currently recognize or respond to browser “do not track” signals.

Mobile Devices. If you access our Services from an Android or iOS mobile device, you can also set certain privacy and advertising preferences for your device, through the device settings menu. For example, iOS users can turn off cross-site tracking for the Safari browser and choose whether or not to allow mobile applications to request to track you. See below for more information about device privacy settings for your device for:

• Apple iOS: The Apple Support pages provide information on available iOS privacy settings, including Safari (browser) settings, App tracking settings, and other built-in device privacy settings; you can also search for information on settings for your device and iOS version in the online user guide.

• Android: Users can find information on managing permissions and privacy settings here.

17. Additional Information for Residents of Certain U.S. States

In the United States personal information is collected and processed by the Company, its affiliates and subsidiaries. In addition to any rights explained in Section 13, residents of certain U.S. states have additional rights under the respective applicable state privacy laws, subject to certain limitations, as set forth below.

California Residents.  If you are a California resident, please review our CCPA Notice under Section 16 above, which includes additional information about the categories of personal information we collect about California residents and their rights under the CCPA.

Privacy Rights for Residents of Certain Other U.S. States. Subject to certain limitations and exceptions under applicable law, residents in certain U.S. states (including but not limited to  Colorado, Connecticut, Indiana, Maryland, Minnesota, Nevada, New Jersey, Tennessee, Texas, Utah, Virginia, and Washington residents) have additional privacy rights under applicable privacy laws. These additional privacy rights may include the rights listed below (as applicable), specifically the right to:

• Correction: The right to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of their personal information.

• Deletion: To delete their personal information provided to or obtained by us.

• Access: To confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.

• Opt-Out: To opt out of certain types of processing, including:

  • to opt out of the “sale” of their personal information.

  • to opt out of targeted advertising by us.

  • to opt out of certain uses and disclosures of sensitive personal information by us.

  • to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

• Appeal: If we deny your request, residents in certain jurisdictions (including without limitation Colorado residents) appeal our decision. If you do so, please be sure to include sufficient information to enable us to identify the request you are appealing. To appeal contact us via e-mail at vegpriv@veg.vet.
  

Residents in certain U.S. states (such as Maryland and Minnesota), also have the right to request from us additional information regarding specific third parties (other than a consumer, controller, processor, or affiliates of a controller or processor) to whom we disclose your personal information. To request such information, email us at vegpriv@veg.vet.

You may submit your privacy request, including for access, correction, and deletion online through our Privacy Portal here or as otherwise specified herein. We will respond to your request as required under applicable privacy law. Except with respect to opt-out requests, we will take steps to verify your identity and authority before responding to your request, for example by sending a verification link to your account or email to your registered email address, requesting validation using one time code sent to registered phone, or call back using phone registered on the system. In some cases, we may request additional information in order to verify the validity of your request or identity or as necessary to process your request. We will apply your request to the information we have in our records and on file and that is linked or reasonably linkable to the information you provide in your request and related communications to us.

If you have an account with us, you may also review and update your account information directly within your account settings.

To opt out of targeted advertising via our one of our Sites (i.e., via cookies and pixel tags on that Site), visit the Cookie Preference Manager for that Site, which is accessible via the “Your Privacy Choices” link in the footer of our Sites, where you can turn off ‘Non-Essential’ cookies, including “Targeting” cookies by switching the relevant Toggle(s) to the left. (Please also see Section 13 above for additional information about the general privacy choices we provide and how to exercise them.)

Nevada residents have the right to opt out of the sale of “covered information” as defined by Chapter 603A of the Nevada Revised Statutes (“Nevada Law”). The Company does not currently conduct “sales” of covered information as those terms are defined by Nevada Law.