Privacy Notice for Pet Owners

1. Organizations responsible for processing

Below are the two UK entities associated with the HomeAgain and Sure PetCare websites and products. HomeAgain is operated by MSD Animal Health UK Ltd, which serves as the legal entity and data owner. Meanwhile, Sure PetCare is managed by SureFlap Ltd, also acting as the legal entity and data owner.

MSD Animal Health UK Ltd

Walton Manor

Walton, Milton Keynes

MK7 7AJ

(hereinafter “MSD” or “We”)

 

SureFlap Ltd.

Ground Floor Building 2030

Cambourne Business Park

Cambourne, Cambridgeshire, CB23 6DW

England UK

This Data Privacy Notice for Animal Pet Owners (hereinafter “Pet Owners” or “You”) describes how we process the personal data of Animal Pet Owners, how we use personal data, and any rights you have regarding your personal data.

 

2. Personal data processed by us

MSD collects and use the necessary personal information to enable us to conduct our business activities.The personal information we collect relates to pet owners and other consumers (individuals accessing the Sure PetCare or Home Again website or using our products and services for personal needs), this may include but is not limited to:

• Pet owner contact details (Full name; billing address; shipping address; email address; phone number; country; user ID and password, product purchased; date of purchase; payment details (to the extent they are not held by the third-party payment services provider), communication preferences, survey details, social media usernames (if applicable); any other personal data you provide related to your query.
• Information on your pet (microchip identification number, name, date of birth, species, breed, colour, type of food, weight, medical conditions).
• Previous pet owners and alternative contacts.
• Navigation data on our websites or online services or those of our partners (see our Global Internet Privacy Policy and our Global Online Tracking Policy), cookies (see our Data Protection Preference Center in this regard, which can be found at the bottom of our website by clicking on the “Cookie Preferences” button

 

3. Purpose of processing

We can only process your personal information where we have a suitable legal basis under the applicable data protection laws. Please see below a list of our business processes with the associated legal basis:

• Collect pet owner details for the purpose of maintaining a pet registration database, provide support and facilitate the relocation of lost pets. Our legal basis for the processing of personal data is our legitimate business interests as a registration database provider.
• Provide you with information about other goods and services we offer that are like those that you have already been provided with or enquired about. Our legal basis for the processing of personal data is our legitimate business interests.
• To enable you to purchase products from us via the Website, and to ship those products to you or another designated recipient.  Our legal basis would be to enter and perform our obligations under a sales contract with you via the Website.
• To enable you to register your product warranty with us.  Our legal basis would be to fulfil our contractual obligations to provide you services with respect to your product warranty.
• To respond to your queries and provide customer support services when you contact us by phone, email, live chat, chatbot, or via our social media channels.  It is in our legitimate interest to respond to your queries and provide customer support services.
• To send marketing communications including promotional offers to you from us or third parties where you have accepted or consented to receive such offers and information in line with your interests and preferences.  You have the right to withdraw this consent at any time by selecting the “unsubscribe” link shown in every marketing communication you receive from us.
• To provide you with a more effective user experience and improve the performance of our website and to make our website more secure, and to administer our site, as well as for internal operations, including troubleshooting, data and analysis, identity verification checks and testing.  Our legal basis is our legitimate interest to provide a more effective user experience, improve the performance of and secure and administer our website.
• To conduct research and statistical analysis (including, inter alia, via standard third-party data analytics tools) and for survey and feedback purposes.  Our legal basis is our legitimate interest to conduct research and market analysis, including conducting optional surveys.
• To provide information in relation to a merger, acquisition, insolvency, or other business transaction.  Our legal basis is our legitimate interest to operate our business, sell or acquire other businesses, and ensure the ongoing continuity of such businesses.
• We may collect usage and error information to improve our products and services and will ask for your consent when doing so.
• We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.

 

4. Sharing personal data with Third parties

We may share or otherwise disclose your personal data to the following categories of recipients in the following circumstances:

• Our affiliates: to fulfil the purposes specified above in accordance with this Privacy Notice
• Business partners, suppliers and sub-contractors: to help us fulfil your order, process payment, provide specialized services (such as pet recovery services, customer service, the medical hotline that provides 24-hour/7-day-a-week pet telephone assistance, billing, marketing, advertising, hosting, data processing and other services related to improving and optimizing the website and our service/product, animal shelters, veterinary clinics, and animal welfare organizations that provide care until the lost pet is returned and to assess fraud, credit and/or security risks; 
• Law enforcement authorities, courts, and administrative or regulatory bodies: to comply with applicable legislation, a court order or legal process.  We may disclose information relating to you and/or any other person that has contacted HomeAgain regarding a microchipped pet (i) as required by law; (ii) when we believe in good faith that disclosure is necessary to protect our rights; (iii) to comply with judicial proceeding, court order, or legal process served on us; and/or (iv) in response to an inquiry by law enforcement personnel or receipt of a police report relating to a microchipped pet
• Other third parties as necessary: for purposes such as to protect and defend our (or our licensor’s) rights or property, prevent fraud or violations of our Terms of Use, and ensure the personal safety of other users of the Website (or the public at large).
• Potential purchasers or investors: in the event that we sell, assign or transfer some or all of our business or assets to a successor or acquirer, or if we are acquired by or merge with a third party, or if we file for bankruptcy or becomes insolvent, we may disclose, sell, assign or transfer all of your personal data as part of the transaction

 

5. Retention period of personal data

Pet registrations with owner details will be retained in our database for 30 years. Where we collect personal data in relation to a purchase, we will retain that information for a period of 7 years so that we can comply and assist with any accounting questions that may arise.  Other data, including commercial and marketing data will not be retained for longer than 3 years.  Where we process personal data for any other reason (such as where you have contacted us with a question in connection with the Website) we will retain your data for 5 years.

Please note that information will be retained for longer where we have a legal obligation to do so.

In some circumstances, we may anonymize your 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.

 

6. Disclosure of personal data abroad

Your personal data may be disclosed as needed to MSD entities and third parties located in the United States and other countries outside of the European Union (EU) or European Economic Area (“EEA”), including in countries that may not provide the same level of data protection as your home country. We have implemented appropriate security and compliance mechanisms to ensure your personal information is protected as required and your rights are respected, such as APEC Cross-Border Privacy Rules certification, Binding Corporate Rules (BCR), EU-U.S. Data Privacy Framework (DPF) program, the UK Extension to DPF and the Swiss-U.S. Data Privacy Framework program or EU approved data protection contractual clauses. Additionally, the recipients of your personal information are bound to duties of confidentiality through legally binding framework.

More information on these measures is described in our Global Cross Border Privacy Rules Policy and your rights provided by these can be obtained by contacting Global Privacy Office.

 

7. Your rights as a data subject

You can opt out of marketing emails by utilizing the “unsubscribe” link or other mechanism noted in marketing emails you receive from us.

In accordance with applicable law (including relevant exemptions, as applicable), you may have the right to object to or request restriction of processing of your personal data, as well as the right to request access, rectification, erasure, and portability of your personal data.Where we are using your personal data based on your consent, you have the right to withdraw this consent at any time without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

For Sure PetCare if you wish to exercise these rights, you can contact privacy@surepetcare.com

For HomeAgain or any other product if you wish to exercise these rights, you can use the data privacy request form.

You also have the right to file a complaint with the Information Commissioner's Office (ICO)