1. About this Policy

Virtual Recall Pty Limited ACN 603 898 120 takes your privacy very seriously. This Privacy Policy sets out how we collect, hold, use and disclose your personal information. Please read this policy carefully.

2. Definitions and Interpretation

In this Privacy Policy the following terms shall have the following meanings:
(a)          “Data Protection Laws" means all applicable laws, statutes, bye-laws, regulations, orders, regulatory policies, guidance or industry codes and/or rules of court relating to the processing of personal information and/or privacy (including, but not limited to the Privacy Act 1988 (Cth) (as amended, updated or re-enacted from time to time)), and all applicable guidance and codes of practice issued by the Office of the Australian Information Commissioner and/or any other relevant regulator from time to time.

(b) “Personal Information” means information or an opinion (including information or an opinion forming part of a database and whether or not recorded in a material form) about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.

3. Our Products and Services

We provide software that enables veterinary practices to communicate with their clients in either an automated or a semi-automated way.
Our software reads information from a veterinary practice’s practice management system (“PMS”) database in order to generate personalised communications to your clients.
These communications are sent by any combination of SMS, email and post using contact details contained in the PMS database.
We provide message logs of all communications sent and report on data provided back to the practice such as survey responses, or client requests such as product orders or appointment bookings.

4. Our Commitments

4.1. Transparency

We are committed to protecting your Personal Information and your right to privacy. If you have any questions or concerns about our Privacy Policy or our practices about your Personal Information, please contact us at dpo@virtualrecall.com.
When you use the Site and any other services provided by us, you trust us with your Personal Information. We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important.

4.2. Security

We are committed to maintaining and enhancing the security in connection with your Personal Information. We take various steps to protect the Personal Information you share with us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Personal Information we collect, process and store, and the current state of technology.

5. What and how: Personal Information we collect

5.1. What and how

We collect and handle different types of Personal Information from you. Depending on how you interact with our services, the type of Personal Information and method of collection will vary.

We may collect and handle the following Personal Information:

• Information that you provide by filling in forms on our site or otherwise (for example, every time you email us or provide us with your details via customer forms, customer reviews, over the telephone, by fax, by email or by mail). This includes information provided at the time of requesting or subscribing to any service, making a purchase or registering for information;
• If you contact us, we may keep a record of that correspondence;
• We may also ask you to complete customer feedback or surveys that we use for research purposes, although you do not have to respond to them;
• Details of online payment transactions you carry out through our site or electronic invoicing system and of the fulfilment of your orders;
• Information that you do not enter into a form at our site: for example, we log details of your visits to our site including, but not limited to, traffic data, weblogs and other communication data, your web browser's request header information and the resources that you access. This information is used for statistical purposes only;
• Information provided to us when you communicate with us for any other reason. For example, to report a problem with the site or to submit comments or suggestions;
• We may also collect information about your computer, including where available your IP address, operating system and browser type, for our system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
• You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the products, services or information you have requested.
• Unless we make it clear otherwise, we will not to ask for any Sensitive Information, which is a special category of personal information and includes: (a) information about an individual’s race or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; trade union membership; sexual orientation or practices; or criminal record; and (b) health information about an individual. We recommend that you do not provide such Sensitive Information to us. If you choose to do so for any reason, this will mean that you have given (and we accept) your explicit consent for us to use that Sensitive Information for the reasons described in this Privacy Policy, or as explained at the time you provide that Sensitive Information to us.
• If you provide any Personal Information to us about any person other than yourself, you must ensure that they understand how their Personal Information will be used and shared with us, and that you have a legal basis to share their Personal Information, or they have given their express consent for you to disclose their Personal Information to us.

We also collect, use and share aggregated data such as statistical information about your pet or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Information but will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information that will be used in accordance with this Privacy Policy.

5.2. If you fail to provide Personal Information

Where we need to collect your Personal Information, and you fail to provide that Personal Information, we may not be able to provide the product, service or information that you have requested.

6. Who: Sharing Your Personal Information

We may disclose your Personal Information to third parties. We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law:

6.1. Business Partners

Business partners (for example our web and technology hosting companies, payment processors, accountancy organisations, database management company, printing companies, mailing houses, fulfilment companies and SMS data handling company). We do not allow our third party business partners to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

6.2. Third Parties

We will NOT otherwise disclose any personally identifiable information to any third party except where: (1) we have contractual protections in place; (2) are under a duty to disclose or share your Personal Information as required by Data Protection Laws; (3) in order to enforce or apply the Site terms and conditions and other agreements; or (4) to protect the rights, property, or safety of Virtual Recall, our customers, or others. This includes exchanging information with other organisations for the purposes of crime prevention, fraud protection and credit risk reduction.

6.3. Under a legal obligation

In certain circumstances, we may be legally required to share certain Personal Information held by us, which may include your Personal Information, for example, where we are involved in legal proceedings, where we are complying with the requirements Data Protection Laws, a court order, or a governmental or regulatory authority. We do not require any further consent from you to share your Personal Information in such circumstances and will comply as required with any legally binding request that is made of us.

7. How: Using your Personal Information

7.1. Use

We comply with applicable Data Protection Laws and will only collect, utilise and share Personal Information in compliance with those Data Protection Laws.
In line with the above, we may use your Personal Information for the following purposes:

• To ensure that content from our site is presented in the most effective manner for you and for your computer
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
• To carry out our obligations arising from any contracts entered into between you and us
• To communicate with you, including where we are required to provide notice to you under our agreement with you
• To carry out market research campaigns
• To notify you about any changes to our services or site, such as improvements or service/product changes, that may affect our service
• To keep information in compliance with our legal obligations

The Personal Information that we collect from you is processed by staff who work either for us or for one of our service providers. Such individuals may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Where your Personal Information is disclosed to our service providers for these purposes, they only have access to the Personal Information needed to perform their functions, and our contractual arrangements with them do not permit them to use your Personal Information for their own purposes.
We may also use and disclose anonymised data (containing no Personal Information) for marketing and strategic development purposes or use and analyse the information we collect so that we can administer, support, improve and develop our business.

7.2. Your Consent

When Personal Information, such as your name and e-mail address, is collected from you with your consent (for example, through the use of on-line or offline data collection forms, via e-mail or telephone etc.), we generally let you know at the time of collection how we will use that Personal Information. If, at any time, we decide to use your Personal Information for a purpose that is different from the original purpose of collecting your Personal Information, we will contact you regarding this change.

The Personal Information that we collect and store relating to you is primarily used to enable us to provide requested services to you.
We may, in accordance with Data Protection Laws, also use your Personal Information to provide you to provide you, with information about goods and services which may be of interest to you and we or they may contact you about these by post, email or telephone.
If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you.
If you are a new customer, and where we permit selected third parties to use your Personal Information, we (or they) will contact you by electronic means only if you have consented to this.
You won't receive any unsolicited email as a result of visiting our site. Web server log files: we log your browser's request header information for statistical purposes only. We draw up these statistics because they contain important anonymous information that we use to improve the quality of the information that you find at our site.

7.3. Contractual Necessity

In order for us to provide you with our services, it will be necessary for us to capture Personal Information to process your requests. To fulfil the contractual obligations between you and us, it is also necessary to process Personal Information in order to deliver our services. In this regard, we may use Personal Information to process your application and to liaise with you about this. We also need to administer contracts and agreements between you and us in relation to our services.

7.4. Legal Obligations

We obtain, collect and process your Personal Information in order to comply with all our legal obligations.

7.5. Your Vital Interests

We may process Personal Information where it is deemed to be in your vital interests. This is an extremely rare circumstance for processing Personal Information and usually only occurs when essential for the life of the data subject or that of another.

7.6. Our Legitimate Interests

We may process Personal Information where it is within our legitimate interests to do so. Where we process your Personal Information on this basis for direct marketing (including profiling related to direct marketing), you have a right to object to us processing your Personal Information. Your right to object is detailed below in this Privacy Policy and can be exercised at any time.

7.7. Change of Ownership

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Personal Information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Personal Information for the purposes for which it was originally collected by Us.

8. Your Rights

8.1. What you can do

You have certain rights under applicable Data Protection Laws. These include the right (i) to request access and obtain a copy of your Personal Information, and (ii) to request correction of your Personal Information. To make such a request, please contact us at dpo@virtualrecall.com or at the address set out in paragraph 10 below. We will consider and act upon any request in accordance with applicable Data Protection Laws.
If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

8.2. Account Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
You may at any time review or change the information in your account or terminate your account by:
Contacting us by email, telephone or post using the details in paragraph 10 below.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce contractual and other rights, and/or comply with Data Protection Laws.

8.3. Cookies and similar technologies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services. For further information, please see our Cookie Policy.

8.4. Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us at dpo@virtualrecall.com. You will then be removed from the marketing email list however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

8.5. Third Party Links

Our site may, from time to time, contain links to and from the websites of our partner networks (such as our online payment provider), advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Information to these websites.

9. Complaints

If you wish to make a complaint about a breach of this policy, or the Australian Privacy Principles, you can contact us using the contact details below. You will need to provide sufficient details regarding your complaint, together with supporting evidence and information. We will investigate your complaint and determine what steps we need to take to resolve your complaint. We will contact you if we require further information from you, and will notify you in writing of the outcome of our investigation.

If you are not satisfied with our determination, you can contact us to discuss your concerns, or you can contact the Australian Information Commissioner using the details available on the website www.oaic.gov.au.

10. Contacting Us

You may contact Virtual Recall's Data Protection Officer about all issues related to this Policy, your Personal Information and to exercise your rights under Data Protection Laws.

E-mail: animalhealth.privacyANZ@zoetis.com or privacy@zoetis.com or dpo@virtualrecall.com

Postal address: 

Data Protection Officer/Legal department 

PO Box 6066

Silverwater NSW 2138

Australia

11. Data Retention: How long do we keep your Personal Information

We will destroy or de-identify your Personal Information when it is no longer necessary to fulfil the purposes for which it was collected. However, we may be required by Australian law to hold your Personal Information longer than this period.  Where there is a legal obligation for us to retain your Personal Information, we will restrict/block further use of it and then erase the relevant Personal Information when it is no longer required to retain it.

12. Data security

Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access.
In accordance with Data Protection Laws, we have put in place appropriate physical, electronic, and managerial procedures to provide a high level of data security on our servers.
We won't disclose those measures for obvious reasons but you can be sure that we take reasonable precautions to protect all Personal Information from loss, misuse or alteration and to safeguard and secure the Personal Information you provide to us.

Notwithstanding the security measures that we take, it is important to remember that the transmission of Personal Information via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting Personal Information to us via the internet.

13. Where We Send and Store Your Personal Information

Where legal requirements have been complied with we may transfer Personal Information that we collect from you to locations outside of Australia for storing.
However, certain recipients (our third party business partners) who handle your Personal Information on our behalf may transfer your Personal Information outside Australia a country that does not have an adequacy decision of protection to your Personal Information. Where such transfers occur, we ensure that: a) they do not occur without our prior written authority; and b) that an appropriate transfer agreement is put in place to protect your Personal Information. If you would like to find out more about any such transfers, please contact our Data Protection Officer.
For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your personal data is treated securely and in agreement with this Privacy Policy.

Changes to this Policy

We may change this Policy from time to time, in whole or part, at our sole discretion or to fulfil a legal obligation. The updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. You may also request a copy of the most recent version of this Policy by contacting us. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.