This privacy policy, as a part of the Terms and Conditions, governs and explains how the Company uses the personal data we collect from you when you use the Application and www.keep.pet, the Company’s website (the “Website”) as well as when you communicate with us via email, phone or mail.

Electronic or phone communications via the Website or the Application are not confidential or privileged and will not be the subject of any associated confidences or privileges. You understand and agree that all communications may be recorded for training and quality control purposes. You consent to the exchange and release of information and records between the Company and your veterinary professional. The Company may store your pet’s medical records in the Company’s system so that proper care may be given.

Topics:

What data do we collect?

How do we collect your data?

How will we use your data?

With whom will we share your data?

How do we store your data?

How do we protect your data?

What are your data protection rights?

Cross-Border Data Transfers

Cookies

How do we use cookies?

What types of cookies do we use?

How to manage cookies?

Privacy policies of other websites

Changes to our privacy policy

How to contact us?

How to contact the appropriate authority?

What data do we collect?

The Company collects the following data:

- Your personal identification information (e.g., name, email address, phone number, social media account information, location data and photo(s));

- Information about your pet (e.g., name, gender, date of birth, type, breed, color, videos and photos);

- Information about your using the Application (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, advertising that you click on);

- Device information, including hardware and software information (e.g., IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs, browser type, version and language, operating system, time zones, identifiers associated with cookies, or other technologies that may uniquely identify your device or browser, as well as information on device sensors such as accelerometers, gyroscopes and compasses);

- Information on your wireless and mobile network connection (e.g., service provider, signal strength); and

- Other information with your consent, which you can withdraw at any time (e.g., geolocation even when you aren’t using the Application only if you gave us an express permission to such collection).

The following data is mandatory to create an account: email address, phone number, or a social media account (Google or Facebook). Without providing at least one of those data points, you will not be able to use the Application.

The following data is mandatory to create a pet passport: name, gender, DOB, type, breed, color, and photos.

How do we collect your data?

You directly provide the Company with most of the data we collect. We collect and process data when you:

- Create your account;

- Create a pet passport;

- Use the Application;

- Communicate with other users via “Chat”;

- Voluntarily complete a customer survey or provide feedback on any of services;

- Use or view the Website via your browser’s cookies;

- Voluntarily participate in our promotions, events or contests; and

- Contact our customer care team.

The Company may also receive your data indirectly from the following sources:

- Your social media accounts (if you used any to create your account);

- Other users;

- Government authorities;

- Pet tracking services; and

- Third-party partners (e.g., where the Application’s ads are published on a partner’s websites and platforms, in which case they may pass along details on a campaign’s success).

How will we use your data?

The Company collects your data so that we can:

- Confirm your identity, create and maintain your account;

- Prevent, detect and fight fraud or other illegal or unauthorized activities;

- Provide you with customer support and respond to your requests;

- Link the various devices you use by linking devices and browser data, so that you can enjoy a consistent experience of our services on all of them;

- Develop, display and track content and advertising in the Application tailored to your interests;

- Communicate with you by email, phone, social media or the Application about products or services that we think may interest you based on what sections of the Application and the Website you have been using the most;

- Conduct research and analysis of users’ behavior to make it more intuitive and improve the Application and its content (e.g., we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior);

- Develop new features and services (e.g., we may decide to build a new interests-based feature based on the requests received from users);

- Administer focus groups and surveys;

- Address complaints, ongoing or alleged misbehavior on the Application;

- Comply with the legal requirements and assist law enforcement, when required; and

- Enforce or exercise the Company’s legal rights (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce or exercise our rights stated in the agreements, for example the User Agreement; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

The Company does not carry out any processing activity which is automated (i.e., does not involve human oversight) and leads to decisions that produce significant impacts on individuals (e.g., mortgage applications, job applications, etc.).

With whom will we share your data?

- With other users only when you voluntarily disclose your data on the Application (e.g., contact information and location data specified at registration);

- With our service providers and partners which assist us with various tasks, including data hosting, payment processing, validation and maintenance, analytics, customer care, marketing, advertising, security operations, corporate audit, analysis and consolidated reporting as well as compliance with applicable laws;

- With governmental authorities, when required by law (e.g., to comply with a court order, subpoena or search warrant, to assist government/ law enforcement investigation in the prevention or detection of crime or to protect the safety of any person);

- With advertisers to develop and deliver targeted advertising of the Application, and to analyze and report on advertising you see; and

- With other third parties only if you consent, and in any such case, we will make it clear why we want to share the information.

We use a third-party payment service to process your Payment Method. We do not receive, store or process your Payment Method. By submitting your Payment Method through the Application, you agree that we may use a third party to receive, store and process your Payment Information including your phone number. You further agree that we will not be responsible for any failures of the third party to adequately protect your Payment Method and other information in such third party’s possession. You agree that your provision of your Payment Information and other information to such third party is subject to the conditions of the third party payment service provider's terms of service and by providing your Payment Method and related information you agree to such third party’s terms and conditions of service. The current third party payment processor is Stripe, and their current terms and conditions of service and privacy policy are available at https://stripe.com/us/privacy. You acknowledge that we may change the third party payment service and move your information to other service providers that encrypt your information using industry standard security technology.

The Company would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. You have the right to stop the Company from contacting you for marketing purposes or giving your data by sending an email at support@keep.pet at any time.

How do we store your data?

The Company uses Amazon Web Services to securely store your data.

The Company will keep your identifiable personal data from the day you registered with the Application. The Company will delete your identifiable personal data after three (3) months following account deletion or two (2) years of continuous inactivity in the Application (the “Retention Period”), unless:

1. we must keep it to comply, or evidence compliance, with applicable laws and regulations (e.g., we keep records of consents to the User Agreement and other similar consents for five (5) years);

2. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

3. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security (e.g., information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).

Once the Retention Period has expired, we will delete your identifiable data by transforming it into a non-identifiable data for historical research and statistical purposes. Keep in mind that even though our systems are designed to carry out data deletion and transformation processes according to the above guidelines, we cannot promise that all data will be deleted or transformed within a specific timeframe due to technical constraints.

How do we protect your data?

Although we work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal data, we cannot promise, and you should not expect, that your personal data will always remain secure. Only you are responsible for protecting the security of your user name and password.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please email us immediately at: info@keep.pet.

What are your data protection rights?

The Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request the Company for copies of your personal data. We may charge you a reasonable fee for this service.

The right to rectification – You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that the Company erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that the Company restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to the Company’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that the Company transfer the data that we have collected about you to another organization, or directly to you, under certain conditions. If you make a request, we have thirty (30) days to respond to you.

The right to refuse the data processing – You have the right to withdraw your consent if the processing is based on consent.

The right to lodge a complaint with a data protection authority – If the Company cannot resolve your complaint, you have a right to bring the complaint to the relevant data protection authority, which has the power to enforce the General Data Protection Regulation.

California Privacy Rights – If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Application that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@keep.pet.

For more information about how to get access to personal data and for exercising your rights, you can submit a request by sending an email to info@keep.pet with a subject line “I would like to exercise my individual data rights”. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. You also have the right to lodge a complaint with a supervisory authority.

Cross-Border Data Transfers

The Company’s processing of the personal data sometimes involves cross-border data transfers, for instance from and to the United States of America, countries in the European Economic Area (“EEA”), and Russian Federation. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you access the Application and visit the Website, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

How do we use cookies?

The Company may use cookies in a range of ways to improve your experience on the Application and the Website, including:

- Keeping you signed in; and

- Understanding how you use the Application and the Website.

What types of cookies do we use?

There are a number of different types of cookies, however, the Application and the Website use:

- Functionality – the Company uses these cookies so that we recognize you and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

- Advertising – the Company uses these cookies to collect information about your visit, the content you viewed, the links you followed and information about your hardware and software information such as IP address, device ID and type, device- specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address). The Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website or application, you may be shown advertising based on your browsing patterns.

How to manage cookies?

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of the Website’s and Application’s features may not function as a result.

Privacy policies of other websites

The Application and the Website contain links to other websites. Our privacy policy applies only to the Application and the Website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

The Company keeps its privacy policy under regular review and places any updates on the Application or the Website. This privacy policy was last updated on August 4, 2020.

How to contact us?

If you have any questions about this privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@keep.pet

Call us: [(747)215-7345]

Or write to us at: 431 Myrtle St., Apt. 7, Glendale CA 91203, United States

How to contact the appropriate authority?

Should you wish to report a complaint or if you feel that the Company has not addressed your concern in a satisfactory manner, you may contact a data protection’s office in your country. For example, the Ireland residents should contact Data Protection Commission at

Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Phone number: +353 578 684 800

First appearance of KeepPet prototype