Privacy Notice

1. Introduction

VetsMart and its affiliates and subsidiaries (“VetsMart”, “our”, “we” or “us”) respect your right to privacy and personal data protection. VetsMart appreciates the interest you have shown in our company, products and services by visiting our websites such as www.VetsMart.cn or other related communication channels, including, but not limited to, our social media pages, channels, mobile apps and/or blogs (together “VetsMart Pages”). This Privacy Notice applies to all the Personal Information VetsMart collects online and offline when you interact with VetsMart, such as when you visit VetsMart Pages, when you use the products or services offered by VetsMart, when you purchase products of VetsMart, when you subscribe to newsletters and when you contact our customer support, either as a visitor, a customer or a potential customer, or an agent of our suppliers or business partners, etc.
We may also provide you with separate privacy notices to inform you how we collect and process your Personal Information for some specific circumstances like products, services or projects offered by VetsMart, for example when you attend our clinical research programs, or when you use our mobile apps. Such separate privacy notices shall in principle prevail over this Privacy Notice if there is any conflict or inconsistency between the separate privacy policies and this Privacy Notice, unless mentioned or agreed otherwise.
If you are from the United States or Canada, please visit our North American Privacy Notice . If you are a resident of the European Economic Area (EEA) or UK, please refer to our corresponding Privacy Notice that applies to you.

2. What Personal Information Do We Collect and for Which Purpose?

The term “Personal Information” in this Privacy Notice refers to information relates to you or allows us to identify you, either directly or in combination with other information that we hold. We encourage you to keep your personal settings and Personal Information complete and current.

VetsMart Account Data

You can create an online VetsMart account for a better service experience, such as online device registration or providing your feedback through VetsMart  Pages.When you create an account on VetsMart  Pages, we collect the following Personal Information:
· Username;
· Password;
· Email address;
· Country/Region;
· You may also choose whether to provide the following Personal Information about you to your account, such as the company you work for, the city that you are located in, your address, postal code and telephone number.
We use this Personal Information in order to create and maintain your VetsMart Account. You can use your VetsMart Account for various services. When you do so, we may add additional Personal Information to your VetsMart Account. The following paragraphs inform you of the services you may use and what Personal Information we will add to your VetsMart Account when you use the respective services.

Promotional Communication Data

You can choose to sign up for marketing and promotional communications. If you do so, we will collect and use the following Personal Information about you:
· Your email address;
· Your VetsMart Account Data;
· Your interactions with VetsMart, such as the subscription or un-subscription of newsletters and other promotional communications, the Personal Information you provided during your attendance of our events.
We use this Personal Information to send you promotional communications – based on your preferences and behavior – about VetsMart products, services, events and promotions.
We may contact you with promotional communications via email, SMS and other digital channels, such as mobile apps and social media. To be able to tailor the communications to your preferences and behavior and provide you with the best, personalized experience, we may analyze and combine all information associated with your VetsMart Account Data and data about your interactions with VetsMart. We also use this information to track the effectiveness of our marketing efforts.
VetsMart will give you the opportunity to withdraw your consent to receiving promotional communications at any time via the unsubscribe link at the bottom of each promotional email you may receive from us or otherwise contained in the communications we send you. You may also contact us to withdraw your consent via the contact information specified in the section “How to Contact Us”.

Marketing Activities Data

You may wish to attend certain events, webinars, exhibitions or fairs (“Marketing Activities”) held by VetsMart or other organizers. You may register for the Marketing Activities through VetsMart Pages, via our distributors or directly with the organizer of the Marketing Activities. We may send you invitation of such Marketing Activities. For this purpose we may need the following Personal Information from you:
· Name;
· Nationality;
· Company/Hospital you work for;
· Department;
· Email;
· Phone;
· The product/service that you are interested in;
Furthermore, we may need the following additional information when you interact with VetsMart as a professional, which includes but is not limited to your ID number and passport number, in order to communicate with you about the Marketing Activities or for other purposes depending on the actual situation. We will give you specific notice or otherwise inform you about purpose and collection and use of your Personal Information.
By registering for a Marketing Activity with VetsMart, you agree to receive communications from VetsMart directly related to the Marketing Activity, such as where the Marketing Activity will be hosted, when the Marketing Activity takes place.

Purchase & Registration Data

When you purchase products and/or services from VetsMart, or when your register your product and/or services, we may collect the following Personal Information:
· Name;
· Telephone number;
· Company/Hospital you work for;
· Department;
· Position;
· Email;
· Country;
· Nation;
· Shipment/Invoice Address;
· Postal Code;
· Fax;
· Invoice history, which includes an overview of VetsMart products/services purchased by you;
· Details of conversations that you may have with the Customer Service around your purchase;
· Details of your registered Product/service, such as the name of the product/service, the product category it belongs to, the product model number, date of purchase, proof of purchase.
We collect this Personal Information to help you complete your purchase and/or registration of your product and/or services.

Customer Service Data

When you interact with our Customer Service through our call center, WeChat subions, WhatsApp, email or other VetsMart Pages, we will use the following Personal Information about you:
· Your VetsMart Account Data;
· Name;
· Telephone;
· Position;
· Department;
· Company and hospital that you work for;
· Your call recording and history, purchase history, the content of your questions, or requests that you addressed.
We use this Personal Information to provide you customer support related to the product and/or service you purchased from VetsMart, such as to respond to your inquiries, fulfil your requests as well as repair or replace products.
We may also use this Personal Information to improve our products and services, to solve any potential disputes with you, and to educate our customer service representatives during training.

User Feedback Data

You could choose to submit any comments, questions, requests or complaints about our products and/or services (“User Feedback Data”) through various channels offered by VetsMart Pages. When you do so, we may collect the following Personal Information from you:
· Your VetsMart Account Data;
· Title;
· Department;
· Details of your comment/ questions/ requests/ complaints.
We use this Personal Information to respond to your questions, fulfil your requests, resolve your complaints as well as to improve our VetsMart Pages, products and services.

Usage Data

We may use Personal Information we collect from you while you use VetsMart products, services and/or our VetsMart Pages for analytical purposes. We do this in order to understand your interests and preference, to improve our Products, Services and/or our VetsMart Pages and to enhance your user experience.

Online Activities Data

VetsMart may use cookies or similar techniques which store information about your visit to VetsMart website to make your online experience and interaction with our websites more informative and supportive. For further information about the use of cookies or similar techniques used and your choices regarding cookies, please read our Cookie Notice .

3. Sharing Your Personal Information with Others

Affiliates and subsidiaries

We may share your Personal Information with our affiliates and subsidiaries within the VetsMart Group for the purposes described in this Privacy Notice.

Service providers and other third parties

· We may share your Personal Information with our third party service providers, in accordance with this Privacy Notice and applicable laws, in order for them to assist us in providing certain services, such as website hosting, information technology and related infrastructure provision, cloud service, order fulfilment, customer service, email delivery, auditing and other services. We will require these service providers to protect your Personal Information that they process on our behalf with contract or other manners.
· We may share your Personal Information with third parties, for them to send you marketing communications, if you agreed to receive marketing communications from them.
· We may also share your Personal Information with our business partners where it is necessary for the purposes listed in this Privacy Notice, for example where we may sell a product or offer certain services to you together with our business partners.

Other uses and disclosures

We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.
In addition, VetsMart may also share your Personal Information to a third party (including any agent, auditor or other service provider of a third party) in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

4. Third-party services

During your online journey across VetsMart Pages, you may encounter links to other service providers or directly use services offered by third party service providers, which may include social media platform provider, other app developer or other website operator (such as WeChat, Microsoft, LinkedIn, Google, etc.). These contents, link or plug-in are added on our websites for the purpose of facilitating your log-in to our Websites, sharing information to your account on these third party services.
These service providers normally operate independently from VetsMart, and may have their own privacy notices, statements or policies. We strongly suggest that you review them beforehand to understand how your Personal Information may be processed in connection with those sites, as we are not responsible for the content of non-VetsMart-owned or -managed sites or apps, or the use or privacy practices of those sites. For example, we may use and direct you to a third-party payment service to process payments made through VetsMart Pages. If you wish to make such a payment, your Personal Information may be collected by such third-party and not by us and will be subject to the third-party’s privacy policy, rather than this Privacy Notice.

5. Cookies or other similar technologies

We use cookies or similar technologies when you interact with and use the VetsMart Pages – for instance when you visit our websites, receive our emails and use our mobile apps and/or connected devices. In most cases we will not be able to identify you directly from the information we collect using these technologies.The information collected is used to:
· Ensure that the VetsMart Pages function properly;
· Analyze VetsMart Pages usage so we can measure and improve performance of VetsMart Pages;
· Help better tailor advertising to your interests, both within and beyond VetsMart Pages.
For further information about the use of cookies or other similar technologies used and your settings regarding cookies, please read our Cookie Notice.

6. Your Rights and Choices

Subject to applicable laws and regulations, you may have the following rights in relation to your Personal Information we hold: access, rectification, erasure, restriction on processing, objection to processing, withdrawal of consent, and portability. More specifically, you could submit a request to access certain Personal Information we maintain about you; request us to update, correct, amend, erase or restrict the processing of your Personal Information. Where provided by law, you may withdraw consent you previously provided to us or object at any time to the processing of your Personal Information on legitimate grounds relating to your situation, and we will apply your preferences going forward as appropriate. Besides the options available in various VetsMart Pages, such as the unsubscribe option contained in promotional emails, the possibility to access and manage your VetsMart Account Data after you log in, to request to exercise these rights, you may also directly contact VetsMart as indicated in the How to Contact Us section of this Privacy Notice.
We will respond to your requests in accordance with applicable laws and we may need to ask you to provide additional information to verify your identity. Please also understand that under some circumstances we may not be able to respond to your requests for some lawful grounds under applicable laws, for example where the response to your requests may make us violate our legal obligations.
In your request, please make clear what Personal Information you would like to access or have changed, whether you would like to have your Personal Information limited from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information.

7. How we Protect your Personal Information

VetsMart uses a variety of technical and organisational measures and procedures under the guidance of ISO/IEC 27001 information security management system (ISMS) to protect your Personal Information. For example, we implement access controls, use firewalls, secure servers and we anonymize, pseudonymise or encrypt certain types of data, such as financial information and other sensitive data. Furthermore, VetsMart will regularly test, assess and evaluate the effectiveness of the technical and organisational measures to ensure the security of your Personal Information. You have the responsibility to properly keep your account name and password safe.
Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards.

8. Retention Period of Personal Information

Unless indicated otherwise at the time of the collection of your Personal Information (e.g. within a form completed by you), we will store your Personal Information for a period of time that is necessary (i) for the purposes for which they were collected or otherwise processed as specified in this Privacy Notice, or (ii) to comply with legal obligations (such as retention obligations under tax or commercial laws), depending on which one is longer.

9. International Transfer of Data

VetsMart is a China-headquartered global company. For the purposes specified in this Privacy Notice, we may transfer your Personal Information to our headquarter in China, VetsMart Co., Ltd. Your Personal Information may also be transferred to any VetsMart group company worldwide or our third-party service providers located in countries other than where you are located that assist us in processing your Personal Information for the purposes described in this Privacy Notice.
These countries may have different data protection rules than that in the country in which the information was collected. In this case, we will transfer the Personal Information only for the purposes described in this Privacy Notice. To the extent required by applicable law, when we transfer your Personal Information to recipients in other countries, we will take adequate measures to protect that information.

10. Special Information Regarding Minors

While VetsMartPages are not generally targeted at minors under the age of 18, it isVetsMart’ policy to comply with the law when it requires parent or guardian permission before children’s Personal Information is collected, used or disclosed. If we become aware that we have collected Personal Information from a minor, we will immediately delete the data from our records.
VetsMart strongly recommends parents or guardians to take an active role in supervising the online activities of their children. If a parent or guardian becomes aware that his or her child has provided us with his or her Personal Information without their consent, please contact us as specified in the How to Contact Us section of this Privacy Notice.

11. Changes to this Privacy Notice

The services thatVetsMart provides are always evolving and the form and nature of the services that VetsMart provides may change from time to time without prior notice to you. We reserve the right to change or update this Privacy Notice from time to time to reflect these changes in our services as well as updates in applicable laws and will post any material revisions on our websites.
We will post a prominent notice on our privacy notice page to notify you of any significant changes to this Privacy Notice and will indicate at the top of the notice when it was most recently updated.

12. How to Contact Us

Contact us at linda@VetsMart.cn if you have any questions, comments, concerns or complaints related to your Personal Information held by us or in case you wish to exercise any of your data privacy related rights. Please note that this email address is strictly for privacy related queries.
Alternatively, you always have the right to approach the competent data protection authority with your request or complaint.