Difference between revisions of "Privacy Policy"
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We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via our customer contact page and state that your query is for the attention of the DPL. | We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via our customer contact page and state that your query is for the attention of the DPL. | ||
− | Data Protection Lead: | + | Data Protection Lead: Bev Panto |
− | Email address: | + | Email address: bev@wikivet.net |
− | You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at | + | You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at wikimaster@wikivet.net |
==='''CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES'''=== | ==='''CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES'''=== | ||
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We may process certain types of personal data about you as follows: | We may process certain types of personal data about you as follows: | ||
− | + | Identity Data may include your first name, maiden name, last name, username, title, date of birth, gender and professional association registration numbers | |
− | + | Contact Data may include your billing address, delivery address, email address, telephone numbers and employer | |
− | + | Financial Data may include your bank account and payment card details. | |
− | + | Transaction Data may include details about payments between us and other details of purchases made by you. | |
− | + | Technical Data means details about the device(s) you use to access our website including your internet protocol (IP) address, browser type and version, location, time zone settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the websites. | |
− | + | Profile Data includes your username (email address) and password, your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses. | |
− | + | Usage Data includes information about how you use our website, products and services. This includes your browsing patterns and information such as how long you might spend on one of our webpages, what you look at and for on our website, the click stream to and from our website, page response times and page interaction information such as scrolling, clicks and mouseovers. | |
− | + | Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. | |
We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or page. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. | We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or page. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. | ||
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You may provide data by filling in forms on our sites (or otherwise) or by communicating with us by post, phone, email, social media or otherwise, including when you: | You may provide data by filling in forms on our sites (or otherwise) or by communicating with us by post, phone, email, social media or otherwise, including when you: | ||
− | + | create an account on any of our sites; | |
− | + | subscribe to our services or publications; | |
− | + | request resources or marketing be sent to you; | |
− | + | enter a competition, prize draw, promotion or survey; | |
− | + | or give us feedback | |
===='''AUTOMATED TECHNOLOGIES OR INTERACTIONS'''==== | ===='''AUTOMATED TECHNOLOGIES OR INTERACTIONS'''==== | ||
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We will only use your personal data when legally permitted. The most common uses of your personal data are: | We will only use your personal data when legally permitted. The most common uses of your personal data are: | ||
− | + | Where we need to perform the contract between us. | |
− | + | Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. | |
− | + | Where we need to comply with a legal or regulatory obligation. | |
− | + | Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at wikimaster@wikivet.net | |
==='''PURPOSES FOR PROCESSING YOUR PERSONAL DATA'''=== | ==='''PURPOSES FOR PROCESSING YOUR PERSONAL DATA'''=== | ||
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We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at wikimaster@wikivet.net if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. | We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at wikimaster@wikivet.net if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. | ||
− | + | Purpose/Activity | |
− | + | Type of data | |
− | + | Lawful basis for processing | |
− | + | To register you as a new user | |
− | + | (a) Identity | |
− | + | (b) Contact | |
− | + | Performance of a contract with you | |
− | + | To process and deliver your service including: | |
− | + | (a) Verification of Professional Membership where relevant | |
− | + | (b) Collect and recover money owed to us where relevant | |
− | + | (a) Identity | |
− | + | (b) Contact | |
− | + | (c) Financial | |
− | + | (d) Transaction | |
− | + | (e) Marketing and Communications | |
− | + | (a) Performance of a contract with you | |
− | + | (b) Necessary for our legitimate interests to recover debts owed to us | |
− | + | To manage our relationship with you which will include: | |
− | + | (a) Notifying you about changes to our terms or privacy policy | |
− | + | (b) Informing you of changes and additions to content | |
− | + | (c)Asking you to leave a review or take a survey | |
− | + | (a) Identity | |
− | + | (b) Contact | |
− | + | (c) Profile | |
− | + | (d) Marketing and Communications | |
− | + | (a) Performance of a contract with you | |
− | + | (b) Necessary to comply with a legal obligation | |
− | + | (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services | |
− | + | To enable you to participate in a prize draw, competition or complete a survey | |
− | + | (a) Identity | |
− | + | (b) Contact | |
− | + | (c) Profile | |
− | + | (d) Usage | |
− | + | (e) Marketing and Communications | |
− | + | (a) Performance of a contract with you | |
− | + | (b) Necessary for our legitimate interests to study how users use our products/services, to develop them and grow our resource/business | |
− | + | To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | |
− | + | (a) Identity | |
− | + | (b) Contact | |
− | + | (c) Technical | |
− | + | (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise | |
− | + | (b) Necessary to comply with a legal obligation | |
− | + | To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising | |
− | + | (a) Identity | |
− | + | (b) Contact | |
− | + | (c) Profile | |
− | + | (d) Usage | |
− | + | (e) Marketing and Communications | |
− | + | (f) Technical | |
− | + | Necessary for our legitimate interests to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy | |
− | + | To use data analytics to improve our websites, products/services, marketing, user/consumer relationships and experiences | |
− | + | (a) Technical | |
− | + | (b) Usage | |
− | + | Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy | |
− | + | To make suggestions and recommendations to you about goods or services that may be of interest to you | |
− | + | (a) Identity | |
− | + | (b) Contact | |
− | + | (c) Technical | |
− | + | (d) Usage | |
− | + | (e) Profile | |
− | + | Necessary for our legitimate interests to develop our products/services and grow our business | |
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==='''AUTOMATED DECISION MAKING'''=== | ==='''AUTOMATED DECISION MAKING'''=== | ||
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If you wish to exercise any of the rights set out above, please email us at wikimaster@wikivet.net | If you wish to exercise any of the rights set out above, please email us at wikimaster@wikivet.net | ||
− | ==='''FEES'''=== | + | ===''''''FEES''''''=== |
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may legitimately refuse to comply with your request in these circumstances. | You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may legitimately refuse to comply with your request in these circumstances. | ||
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=='''COOKIES'''== | =='''COOKIES'''== | ||
− | You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see WikiVet's [ | + | You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see WikiVet's [https://en.wikivet.net/Cookies_Policy Cookie Policy] |
=='''GLOSSARY'''== | =='''GLOSSARY'''== | ||
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Because everyone (not just lawyers) should be able to easily understand how and why their information is collected and used, we use common language instead of more formal terms throughout this Policy. To help ensure your understanding of some particular key terms, here is a table of translations: | Because everyone (not just lawyers) should be able to easily understand how and why their information is collected and used, we use common language instead of more formal terms throughout this Policy. To help ensure your understanding of some particular key terms, here is a table of translations: | ||
− | + | When we say... | |
− | + | ... we mean: | |
− | + | "WikiVet" / "The WikiVet Trading Company”/WTC/The WikiVet Educational Foundation" /”WEF” "we" / "us" / "our" | |
− | + | The WikiVet Trading Company Ltd, and/or The WikiVet Educational Foundation, the UK registered charity that operates the WikiVet sites. | |
− | + | "WikiVet Sites" / “The Websites”/"our services" | |
− | + | WikiVet websites and services (regardless of language), including our main projects, such as WikiVet and WikiVet LIVE!, as well as mobile applications, APIs, emails, and notifications; excluding, however, sites and services listed in the "What This Privacy Policy Doesn't Cover" section below. | |
− | + | "you" / "your" / "me" | |
− | + | You, regardless of whether you are an individual, group, or organization, and regardless of whether you are using the WikiVet Sites or our services on behalf of yourself or someone else. | |
− | + | "this Policy" / "this Privacy Policy" | |
− | + | This document, entitled the "WikiVet Privacy Policy". | |
− | + | "contributions" | |
− | + | Content you add or changes you make to any WikiVet Sites. | |
− | + | "personal information" | |
− | + | Information you provide us or information we collect from you that could be used to personally identify you. To be clear, while we do not necessarily collect all of the following types of information, we consider at least the following to be “personal information” if it is otherwise nonpublic and can be used to identify you: | |
− | + | (a) your real name, address, phone number, email address, password, identification number on government-issued ID, IP address, user-agent information, credit card number; | |
− | + | (b) when associated with one of the items in subsection (a), any sensitive data such as date of birth, gender, sexual orientation, racial or ethnic origins, marital or familial status, medical conditions or disabilities, political affiliation, and religion; and | |
− | + | (c) any of the items in subsections (a) or (b) when associated with your user account. | |
− | + | "third party" / "third parties" | |
− | + | Individuals, entities, websites, services, products, and applications that are not controlled, managed, or operated by WTC or WEF. | |
− | + | Legitimate Interest | |
− | + | The interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting Us. | |
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+ | Performance of Contract | ||
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Processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. | Processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. | ||
− | + | Comply with a legal or regulatory obligation | |
− | Comply with a legal or regulatory obligation | ||
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Processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. | Processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. | ||
+ | Cookie | ||
− | |||
A ''cookie'' is a tiny data file that is transferred onto your computer, mobile phone, or any other device that you use to access the WikiVet Sites, generally used for authentication and occasionally tracking. Every cookie expires after a certain period of time, but that period varies depending on what the cookie is used for and how your browser is configured. A “session” cookie is one that generally expires when you close your web browser or mobile application. A “persistent” cookie is one that remains in your device, even after you close your browser or mobile application. A persistent cookie expires according to the duration set by us (or when you delete it manually). | A ''cookie'' is a tiny data file that is transferred onto your computer, mobile phone, or any other device that you use to access the WikiVet Sites, generally used for authentication and occasionally tracking. Every cookie expires after a certain period of time, but that period varies depending on what the cookie is used for and how your browser is configured. A “session” cookie is one that generally expires when you close your web browser or mobile application. A “persistent” cookie is one that remains in your device, even after you close your browser or mobile application. A persistent cookie expires according to the duration set by us (or when you delete it manually). | ||
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You may remove or disable cookies through your browser settings. | You may remove or disable cookies through your browser settings. | ||
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Your browser accesses the cookie file only when you visit the website that generated it. This helps to ease your navigation by automatically logging you in and remembering things like your preferences and recent visits. | Your browser accesses the cookie file only when you visit the website that generated it. This helps to ease your navigation by automatically logging you in and remembering things like your preferences and recent visits. | ||
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The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site. | The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site. | ||
− | + | Partners | |
− | + | Any of WikiVet’s partner organisations, with whom we may share your information in line with this Privacy Policy, in order to optimise the user experience and security of your data. | |
− | + | Email service providers | |
− | + | WikiVet uses third party Email service providers such as MailChimp in order to send you marketing content, newsletters and update emails. In order to deliver this service, we share your details with our email service providers. | |
− | + | Analytics tools | |
− | + | WikiVet uses analytics tools such as Google Anaytics to track the way that users interact with our website and produce aggregate data for further analysis. | |
− | + | Payment providers | |
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In order to facilitate any payments or donations made on our sites, we facilitate the sharing of your Financial Data with payment providers eg Paypal. | In order to facilitate any payments or donations made on our sites, we facilitate the sharing of your Financial Data with payment providers eg Paypal. | ||
− | + | Marketing and insights providers | |
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Marketing and insights tools allow us to understand our users better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our consumers to facilitate this process. | Marketing and insights tools allow us to understand our users better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our consumers to facilitate this process. | ||
− | + | Feedback forms | |
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On occasion we may ask you for your feedback or to review a new page, resource or event, and in order to do this efficiently, we engage a third party to send out feedback forms on our behalf. | On occasion we may ask you for your feedback or to review a new page, resource or event, and in order to do this efficiently, we engage a third party to send out feedback forms on our behalf. |
Revision as of 20:49, 24 May 2018
WikiVet's Privacy Policy was last Updated 23rd May 2018
INTRODUCTION
WikiVet respects your privacy and is committed to protecting your personal data. This Privacy Policy (The Policy) informs you of your privacy rights and how the law protects you. It tells you how WikiVet looks after your personal data which you may provide through your registration and/or use of our websites (www.wikivet.net, es.wikivet.net, fr.wikivet.net, www.wikivetlive.com, (together referred to as the “websites”), by signing up to our newsletter, or by participating in any of our live or interactive events, prize draws, competitions or surveys. Please use the Glossary at the end of this Privacy Policy to understand the meaning of some of the terms used in it.
The WikiVet websites are not intended for children and we do not knowingly collect data relating to people under 18 years old.
It is important that you read this Privacy Policy together with any other privacy notice on our website from time to time so that you are fully aware of how and why we are using your data.
WIKIMEDIA SITES
Some of the websites (eg. www.wikivet.net) are editable Wikimedia sites. Any content you add or any change that you make to a Wikimedia Site will be publicly and potentially permanently available. If you add content or make a change to a Wikimedia Site without logging in, that content or change will be publicly and permanently attributed to the IP address used at the time rather than a username.
As part of our commitment to education and research around the world, we occasionally release public information and aggregated or non-personal information to the general public through data dumps and data sets.
Public content such as this is not within the remit of this privacy policy.
IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
WikiVet is the controller and is responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy).
CONTACT DETAILS
Full name of legal entity: The WikiVet Trading Company Ltd (“WTC”), a UK registered limited company number 09692958.
WTC is wholly owned by the WikiVet Educational Foundation (“WEF”), a UK registered charity number 1160546, which operates, in England and Wales.
WTC Registered Address:
- The WikiVet Trading Company Ltd, Calyx House, South Road, Taunton, Somerset, TA1 3DU
WEF Registered Address:
- The WikiVet Educational Foundation, Calyx House, South Road, Taunton, Somerset, TA1 3DU
You can also contact us by email: wikimaster@wikivet.net
DATA PROTECTION LEAD (DPL)
We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via our customer contact page and state that your query is for the attention of the DPL.
Data Protection Lead: Bev Panto Email address: bev@wikivet.net
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at wikimaster@wikivet.net
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We may need to update this Policy at any time and without notice and where we do this we will notify you by including pop up boxes on the website and/or emailing our customers. This Policy was last updated on 23rd May 2018.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us and periodically review your account settings on our websites.
THIRD-PARTY LINKS
Our websites may include links to third-party websites, plug-ins, applications and other resources. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.
WHAT DATA WE COLLECT ABOUT YOU
PERSONAL DATA
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may process certain types of personal data about you as follows:
Identity Data may include your first name, maiden name, last name, username, title, date of birth, gender and professional association registration numbers
Contact Data may include your billing address, delivery address, email address, telephone numbers and employer
Financial Data may include your bank account and payment card details.
Transaction Data may include details about payments between us and other details of purchases made by you.
Technical Data means details about the device(s) you use to access our website including your internet protocol (IP) address, browser type and version, location, time zone settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the websites.
Profile Data includes your username (email address) and password, your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services. This includes your browsing patterns and information such as how long you might spend on one of our webpages, what you look at and for on our website, the click stream to and from our website, page response times and page interaction information such as scrolling, clicks and mouseovers.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or page. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
SENSITIVE DATA
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you do not provide suitable email contact to provide you with account validation). In this case, we may have to cancel or not be able to provide a product or service you have requested. We will notify you if this is the case at the time.
HOW WE COLLECT AND USE YOUR PERSONAL DATA
DATA COLLECTION
We collect data about you through a variety of different methods including:
YOUR PUBLIC CONTRIBUTIONS
Whatever you post on a Wikimedia Site can be seen and used by everyone.
When you make a contribution to any Wikimedia Site such as wikivet.net, including on user or discussion pages, you are creating a permanent, public record of every piece of content added, removed, or altered by you. The page history will show when your contribution or deletion was made, as well as your username (if you are signed in) or your IP address (if you are not signed in). We may use your public contributions, either aggregated with the public contributions of others or individually, to create new features or data-related products for you or to learn more about how WikiVet Wikimedia sites are used and edited.
DIRECT INTERACTIONS
You may provide data by filling in forms on our sites (or otherwise) or by communicating with us by post, phone, email, social media or otherwise, including when you:
create an account on any of our sites; subscribe to our services or publications; request resources or marketing be sent to you; enter a competition, prize draw, promotion or survey; or give us feedback
AUTOMATED TECHNOLOGIES OR INTERACTIONS
As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES
We may receive personal data about you from various third parties and public sources as set out below:
- analytics providers such as Google based outside the EU;
- advertising networks such as such as Facebook, Twitter and LinkedIn based outside the EU; and
- search information providers Google based outside the EU.
CONTACT, FINANCIAL AND TRANSACTION DATA
We may receive data from providers of technical, payment and delivery services such as Mailchimp and PayPal, including those based outside the EU.
IDENTITY AND CONTACT DATA
We may receive this from publicly available sources such as Companies House and the Electoral Register based inside the EU.
THIRD PARTY SOURCES OF DATA/DATA SHARING
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Essential Service Providers
As hard as we try, we are a small team and we can't do it all. So sometimes we use third-party service providers or contractors who help run or improve the WikiVet sites and business for the benefit of you and other users. We give access to your Personal Information to these providers or contractors as needed to perform their services for us or to use their tools and services. We put requirements, such as confidentiality agreements, in place to help ensure that these service providers treat your information consistently with, and no less protective of your privacy than, the principles of this Policy.
Other Businesses
Sometimes, other businesses may give us data about you which we may need for our legitimate interests of conducting business with you and on occasion are necessary to perform our contract with you. In the event of you purchasing any products or services, this will usually comprise Financial Data or Transaction Data. This happens when we link through to third party payment providers. They tell us where relevant that you have paid for your products and, where relevant and/or necessary they will provide us with your Contact Data and Transaction Data. We also might engage third party contractors to provide us with technical or delivery services that are related to your account with us.
MOBILE ACCESS
If you are visiting WikiVet websites with a mobile device, we may use your IP address to provide anonymized or aggregated information to service providers regarding the volume of usage in certain areas.
PUBLICLY POSTED INFORMATION
WikiMedia Site Content
Any information you post publicly on the WikiVet sites is just that – public. For example, if you put your address or other personal information on your user page, that is public, and not protected by this Policy. And if you edit content without registering or logging into your account, your IP address will be seen publicly. Please think carefully about your desired level of anonymity before you disclose Personal Information on your user page or elsewhere.
Professional Bodies
In order to verify that users are members of the veterinary profession, we may check relevant registers such as the Royal College of Veterinary Surgeons (RCVS).
Professional Advisors and Investors
We may also share your data with professional advisers such as our lawyers and insurers to manage risks and legal claims, and/or as part of our relationship and obligations to our investor organisations. This is in our legitimate interests.
Group
In the unlikely event that we sell our business to a third party or re-organise our business or become insolvent, our database would need to be shared with the third-party buyer and their advisors. This is in the legitimate interests of selling our business. In the extremely unlikely event that ownership of all or substantially all of the WikiVet websites changes, or we go through a reorganization (such as a merger, consolidation, or acquisition), we will continue to keep your Personal Information confidential, except as provided in this Policy, and provide notice to you via the websites and a notification via our mailing list at least thirty (30) calendar days before any Personal Information is transferred or becomes subject to a different privacy policy.
Law Enforcement/Legal Compliance
We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. These uses of your data are in our legitimate interests of protecting our business security. We may also use your data and share it with the recipients listed in this Policy for the purpose of complying with our legal obligations.
The lawful basis for sharing and processing this data is set out in this policy. Please refer to the Glossary for further information.
HOW WE USE YOUR PERSONAL DATA
WHY WE USE YOUR DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are: Where we need to perform the contract between us. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at wikimaster@wikivet.net
PURPOSES FOR PROCESSING YOUR PERSONAL DATA
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at wikimaster@wikivet.net if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Purpose/Activity Type of data Lawful basis for processing To register you as a new user (a) Identity (b) Contact Performance of a contract with you To process and deliver your service including: (a) Verification of Professional Membership where relevant (b) Collect and recover money owed to us where relevant (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Informing you of changes and additions to content (c)Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services To enable you to participate in a prize draw, competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests to study how users use our products/services, to develop them and grow our resource/business To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy To use data analytics to improve our websites, products/services, marketing, user/consumer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Necessary for our legitimate interests to develop our products/services and grow our business
AUTOMATED DECISION MAKING
We do not conduct any automated decision making. We may on occasion profile our customers for the purposes of targeting marketing at them and where this is done, this is undertaken for our legitimate interests of ensuring our marketing is relevant to its audience. For example, we may classify an appropriate audience for a promotion by what products on our website they have previously looked at or expressed an interest in. We do not conduct any online behavioural tracking.
MARKETING
DATA PROCESSING
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which resources, products, services and offers may be relevant to you. We only use the data you provide to us directly for this purpose along with the Aggregated Data provided to us by our analytics partners and we do not track what other websites you may visit after visiting our site, though in common with most websites, we may register the site which referred you to our site (e.g. a search engine). We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
MARKETING COMMUNICATIONS
We generally only send electronic marketing - such as email newsletters. We will always offer a way out of receiving this marketing when you first register and in every marketing or other communication afterwards (see Opting out below). Where you have have registered your details with us (for example by entering a competition or signing up for a newsletter, or as a user of the websites), we will only send you marketing communications if you have opted into receiving marketing at the time and so given us your express consent (which you may withdraw at any time – see Opting out below).
OPTING OUT
You can ask us or third parties to stop sending you marketing messages, newsletters or updates at any time by logging into your account and adjusting your marketing preferences, by following the opt-out links on any marketing message sent to you or by emailing us at wikimaster@wikivet.net at any time.
If you opt out of receiving email marketing from us, we will no longer share your email address with social media platforms (see ‘External Third Parties’ below). However, you may continue to see our ads through them, due to their general demographic targeting. Please check the social media platforms for more detail of how to opt out from seeing these ads. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at wikimaster@wikivet.net If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.
INTERNATIONAL TRANSFERS
THIRD PARTIES OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We may share your personal data within our partner organisations which involves transferring your data outside the European Economic Area (EEA). Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Occasionally, we may employ third parties service providers that are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
SAFEGUARDS
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the below safeguards is implemented.
European Commission Protection of Personal Data
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information see European Commission: Adequacy of the protection of personal data in non-EU countries
Contracts for transfer of Personal Data
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
US Privacy Shield
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Explicit Consent
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email us at wikimaster@wikivet.net if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
DATA PROTECTION LAWS AND YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data. Request correction of your personal data. Request erasure of your personal data. Object to processing of your personal data. Request restriction of processing your personal data. Request transfer of your personal data. Right to withdraw consent.
You can see more about these rights at: GDPR - Individual Rights
If you wish to exercise any of the rights set out above, please email us at wikimaster@wikivet.net
'FEES'
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may legitimately refuse to comply with your request in these circumstances.
WHAT WE NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIMING OF REQUESTS
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
THIRD-PARTY LINKS
The WikiVet websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see WikiVet's Cookie Policy
GLOSSARY
We recognize that not everyone is familiar with technical terms like “tracking pixels” and “cookies” used in the Privacy Policy. Whether you are brand new to privacy terminology or you are an expert who just wants a refresher, you might find our Glossary of Key Terms helpful.
Because everyone (not just lawyers) should be able to easily understand how and why their information is collected and used, we use common language instead of more formal terms throughout this Policy. To help ensure your understanding of some particular key terms, here is a table of translations:
When we say... ... we mean: "WikiVet" / "The WikiVet Trading Company”/WTC/The WikiVet Educational Foundation" /”WEF” "we" / "us" / "our" The WikiVet Trading Company Ltd, and/or The WikiVet Educational Foundation, the UK registered charity that operates the WikiVet sites. "WikiVet Sites" / “The Websites”/"our services" WikiVet websites and services (regardless of language), including our main projects, such as WikiVet and WikiVet LIVE!, as well as mobile applications, APIs, emails, and notifications; excluding, however, sites and services listed in the "What This Privacy Policy Doesn't Cover" section below. "you" / "your" / "me" You, regardless of whether you are an individual, group, or organization, and regardless of whether you are using the WikiVet Sites or our services on behalf of yourself or someone else. "this Policy" / "this Privacy Policy" This document, entitled the "WikiVet Privacy Policy". "contributions" Content you add or changes you make to any WikiVet Sites. "personal information" Information you provide us or information we collect from you that could be used to personally identify you. To be clear, while we do not necessarily collect all of the following types of information, we consider at least the following to be “personal information” if it is otherwise nonpublic and can be used to identify you: (a) your real name, address, phone number, email address, password, identification number on government-issued ID, IP address, user-agent information, credit card number; (b) when associated with one of the items in subsection (a), any sensitive data such as date of birth, gender, sexual orientation, racial or ethnic origins, marital or familial status, medical conditions or disabilities, political affiliation, and religion; and (c) any of the items in subsections (a) or (b) when associated with your user account. "third party" / "third parties" Individuals, entities, websites, services, products, and applications that are not controlled, managed, or operated by WTC or WEF. Legitimate Interest The interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting Us.
Performance of Contract
Processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation Processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Cookie
A cookie is a tiny data file that is transferred onto your computer, mobile phone, or any other device that you use to access the WikiVet Sites, generally used for authentication and occasionally tracking. Every cookie expires after a certain period of time, but that period varies depending on what the cookie is used for and how your browser is configured. A “session” cookie is one that generally expires when you close your web browser or mobile application. A “persistent” cookie is one that remains in your device, even after you close your browser or mobile application. A persistent cookie expires according to the duration set by us (or when you delete it manually). You may remove or disable cookies through your browser settings. Your browser accesses the cookie file only when you visit the website that generated it. This helps to ease your navigation by automatically logging you in and remembering things like your preferences and recent visits. The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site. Partners Any of WikiVet’s partner organisations, with whom we may share your information in line with this Privacy Policy, in order to optimise the user experience and security of your data. Email service providers WikiVet uses third party Email service providers such as MailChimp in order to send you marketing content, newsletters and update emails. In order to deliver this service, we share your details with our email service providers. Analytics tools WikiVet uses analytics tools such as Google Anaytics to track the way that users interact with our website and produce aggregate data for further analysis. Payment providers In order to facilitate any payments or donations made on our sites, we facilitate the sharing of your Financial Data with payment providers eg Paypal. Marketing and insights providers Marketing and insights tools allow us to understand our users better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our consumers to facilitate this process. Feedback forms On occasion we may ask you for your feedback or to review a new page, resource or event, and in order to do this efficiently, we engage a third party to send out feedback forms on our behalf.