1 About this Notice

Virtual Recall Limited (7 Huxley Road, Guildford, GU2 7RE and company registration 09360598) take your privacy very seriously. We take all steps to protect the privacy of all information that we receive while you surf the Virtual Recall website at www.irecall.vet (the Site), communicate electronically with us and provide us with your personal information (Personal Data).

We believe it is important for you to know how we treat any Personal Data you share with us via our site or otherwise and how we process your Personal Data. This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of the Site and whenever you provide Personal Data to us. The Site is not intended for children and we do not knowingly collect data related to children.

This privacy policy (together with the Site Terms and Conditions, Cookie Policy and any other documents referred to in them) set out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us.
Please read the following information carefully to understand our views and practices regarding your Personal Data and how we will treat it.

BY REGISTERING FOR ANY SERVICES ON OUR SITE OR BY PROVIDING ANY INFORMATION (INCLUDING ANY PERSONAL DATA) TO US, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR INFORMATION (INCLUDING ANY PERSONAL DATA), AND THE STORAGE AND USE OF COOKIES, UNDER THE TERMS OF THIS PRIVACY POLICY, OUR SITE TERMS AND CONDITIONS AND OUR COOKIE POLICY.

If you do not accept and agree with this Privacy Policy then you should not use our services.

2 Definitions and Interpretation

In this Privacy Policy the following terms shall have the following meanings:

• “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 data and/or privacy (including, but not limited to, (a) the Data Protection Act 2018 (b) the General Data Protection Regulation (EU) 2016/679 (GDPR), (c) the Privacy and Electronic Communications (EC Directive) Regulations 2003, and (d) any data protection and privacy laws enacted in replacement of (a), (b) or (c) and/or as a result of the GDPR ceasing to have direct effect in the UK (in each case as amended, updated or re-enacted from time to time)), and all applicable guidance and codes of practice issued by the Information Commissioner and/or any other relevant regulator from time to time.

• "You" or "your" means you, the individual using our site; and

• "We", "we", "Our", "our", "Us" and "us" refers to Virtual Recall Ltd whose registered address is 7 Huxley Road, Guildford. GU2 7YG.

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 practices' practice management system ("PMS") database in order to generate personalised communications to your clients.

These communications are sent by any combination of web-based chat, 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 Data Controller

For the purpose of Data Protection Laws, we are the data controller for any personal data that you share as a customer of Virtual Recall and data processor in connection with any personal data that you share with us related to your clients.

5 Our Commitments

5.1 Transparency

We are committed to protecting your Personal Data and your right to privacy. If you have any questions or concerns about our Privacy Policy or our practices about your Personal Data, 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 Data. 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.

5.2 Security

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

6 What: Personal Data We Collect

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

We may collect and process the following Personal Data about you:

• 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 the 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 services you have requested.

• We may also process personal data through our web-based two-way messaging platform, iRecall® Chat, our web-based messaging platform that allows the Vet Practice to have two-way communications with Pet Owners.

 

• Unless we make it clear otherwise, we will not to ask for any sensitive Personal Data, that is (including but not limited to) Personal Data relating to: race or ethnic origin; political opinion; religious or other similar beliefs; trade union membership; physical or mental health; sexual orientation; criminal records. We recommend that you do not provide such sensitive Personal Data 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 Personal Data for the reasons described in this Privacy Policy, or as explained at the time you provide that sensitive Personal Data to us.

• If you provide any Personal Data to us about any person other than yourself, you must ensure that they understand how their Personal Data will be used and shared with us and that you have a legal basis to share their Personal Data or they have given their express consent for you to disclose their Personal Data 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 Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. 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 that will be used in accordance with this Privacy Policy.

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 Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

7. Who: Sharing Your Personal Data

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

7.1 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 data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7.2 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 Data 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.

7.3 Under a legal obligation

In certain circumstances, we may be legally required to share certain Personal Data held by us, which may include your Personal Data, for example, where We are involved in legal proceedings such as a safeguarding incident, 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 Data in such circumstances and will comply as required with any legally binding request that is made of us.

8. How: Using your Personal Data

8.1 Processing

We comply with applicable Data Protection Laws and will only collect, utilise and share Personal Data in compliance with those Data Protection Laws.

In line with the above, we may use process your Personal Data 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 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 Data 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 Data is disclosed to our service providers for these purposes, they only have access to the Personal Data needed to perform their functions, and our contractual arrangements with them do not permit them to use your Personal Data for their own purposes.

We may also use and disclose anonymised data (containing no Personal Data) 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.

8.2 Your Consent

When Personal Data, 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 Data. The Personal Data that we collect and store relating to you is primarily used to enable us to provide requested services to you.

We may also use your Personal Data to provide you, or permit selected third parties (for example, our mutual business partners, sponsors of our software, pharmaceuticals companies, buying groups etc.) 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 Data, we (or they) will contact you by electronic means only if you have consented to this
As a supporter of the Coalition Against Unsolicited Email (CAUCE) we strongly disapprove of spamming. 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 the Site.

8.3 Contractual Necessity

In order for us to provide you with our services; it will be necessary for us to capture Personal Data to process your requests. To fulfil the contractual obligations between you and us, it is also necessary to process Personal Data in order to deliver our services. In this regard, we may use Personal Data 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.

8.4 Legal Obligations

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

8.5 Your Vital Interests

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

8.6 Our Legitimate Interests

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

8.7 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 Data 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 Data for the purposes for which it was originally collected by Us.

9. Your Data Protection Rights

You have certain rights under applicable Data Protection Laws. These include the right (i) to request access and obtain a copy of your Personal Data, (ii) to request correction or erasure of your Personal Data; (iii) to restrict the processing of your Personal Data; and (iv) if applicable, to data portability (ie. transferring your Personal Data). In certain circumstances, you may also have the right to object to the processing of your Personal Data. To make such a request, please contact us at dpo@virtualrecall.com or at the address set out 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 Data, 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.

If you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details below.

9.1 Account Information

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.

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 the Site Terms and Conditions and/or comply with Data Protection Laws.

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.

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.

9.2 Third Party Links

The 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 Data to these websites.

Web server log file information: if you want to provide as little request header information as possible you can use services like Anonymizer.com to surf the web. They will cut certain information from your page requests, such as your browser's name, your operating system, and the web address of the page that you looked at before you visited our site ("http_referer"). We do not recommend doing this. If you don't tell our program which web browser you use it assumes that the request originates from a non-standard web browser and will, therefore, run in a very simple mode without any advanced features.

10. Exercising Your Rights with Us

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

Contact Details of the Controller and Data Protection Officer Post
Data Protection Officer, Virtual Recall, 7 Huxley Road, Guildford, GU2 7RE

Website                                       Email                                     Telephone
www.irecall.vet      dpo@virtualrecall.com           0208 123 3965

11. Enforcing Your Data Protection Rights

If you feel that the processing of your Personal Data is not in line with our data protection obligations, you can complain to a data protection supervisory authority.

Our Data Protection Supervisory Authority
You can contact the Information Commissioner offices at:

Telephone / Lo Call Number: 0303 123 1113

Postal Address:                  E-mail:
Wycliffe House,                    casework@ico.org.uk
Water Ln,
Wilmslow
SK9 5AF,
UK

12. Data Retention: How long do we keep your Personal Data

We will not retain your Personal Data longer than is necessary to fulfil the purposes for which it was collected. However, we may be required by Data Protection Laws to hold your Personal Data longer than this period. If no contradicting legal obligation exists, we will delete your Personal Data in line with our Retention Policy or when you request that your Personal Data be erased and no longer processed by us. Additionally, where there is a contradicting statutory obligation for us to retain your Personal Data, we will restrict/block further processing and then erase the relevant Personal Data when we no longer have a requirement to retain it.

13. Notification of a Data Breach

If a security breach causes an unauthorized intrusion into our system that materially affects you, we will notify you as soon as possible and later report the action we took in response to any breach

14. Where We Send and Store Your Personal Data

Once we have received your Personal Data, 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 Data from loss, misuse or alteration and to safeguard and secure the Personal Data you provide to us.

Where legal requirements have been complied with we may transfer Personal Data that we collect from you to locations outside of the European Economic Area for processing and storing. Also, it may be processed by staff operating outside the European Economic Area who work for us or for one of our suppliers.

However, certain Recipients (our third party business partners) who process your Personal Data on our behalf may transfer your Personal Data outside the EEA to a country that does not have an adequacy decision of protection to your Personal Data. 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 Data. 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 Data, 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.

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

15 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. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal data changes during your relationship with us.

If, at any time, we decide to use your Personal Data for a purpose that is different from the original purpose of collecting your Personal Data, we will contact you regarding this change.