Petsofi Animal Platform Privacy Policy (May 24, 2018)

1. Definitions:
Personal Data: means any information relating to an identified or identifiable natural person. A natural person is identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Animal Owner: is a person who has a user account within Petsofi Animal Platform.

Service Provider: is a person or company who can provide services to Animal Owners.

Data Subject: is an Animal Owner or Service Provider registered within Petsofi Animal Platform.

Petsofi Animal Platform: is a system which collects animals’ Animal Owners’ and Service Providers’ data in to a database. The Petsofi platform is operated by MediSapiens Ltd. The data server is in a Tier 3 data center located in Helsinki.”

Cookies: A cookie is a text-based data file which a website can use to save information on the computer of the website visitor. Cookies are often used to enable access to different functions or services on the website. The information contained in cookies varies from website to website but usually concerns information which enhances the user experience. There are two types of cookies: cookies and session cookies. Cookies can e.g. be used to report to the visitor what has happened on the website since the last time it was visited. This type of cookies can also be used to gather statistics or save a username and/or a password necessary to log into a service. The information is stored for a varied length of time, determined by the website. Session cookies can be used during the time a user is visiting the website. These cookies are only saved temporarily on the work memory of the website visitor’s computer and are automatically deleted when the visitor closes the web browser. A usual function for this type of cookies is to maintain temporary settings like language, CSS or alike. They can also facilitate navigation on the website.

2. Scope:

This privacy policy applies to all pages of https://petsofi.com, https://app.petsofi.com and the research services provided by Petsofi you may subscribe to via this website.

3. Responsible provider and representative

Petsofi Oy
Mannerheiminaukio 1
00100 Helsinki
CEO Laura Laakso
laura.laakso@petsofi.com

4. Purpose of processing:

The company’s website uses cookies. However, we do not save personal identifying information in the cookies. By using cookies, visitors can not be identified and personal data is not saved. The cookie does not affect security and can not spread viruses or malware. The Petsofi sites use cookies to steer the functioning of the website, gather statistics and manage sessions. Should you choose not to accept cookies you can change the settings of your web browser so that it automatically denies saving cookies or that you are informed every time a website requires to save a cookie. You can also delete previously saved cookies on your web browser.

We use Google Analytics on our website. Google Analytics is a piece of software that grabs data about our visitors (like an advanced server log). Google Analytics records what website you came from to get here, how long you stayed for, what kind of computer you’re using and when you used our website. The tracking information allows us to better understand the kind of people who come to our site and which content they are reading. This allows us to make better decisions about design and services.

Petsofi Animal Platform users use username and password when signing in. We collect and analyse animals’ health and behavioral information for better and healthy life of pets. It is necessary to store also basic personal contact data to connect Animal Owners’ and Service Providers or when needed to contact the owner e.g. for additional information and reporting the results. We store Animal Owner’s name, email, phone and address. Animal Owner’s month and year of birth are needed to define the age of the user when they register. Animal Owner’s age is not shared from Petsofi.  Persons under 16 are not allowed to register without a parental consent. Veterinary id is required to validate the Service Provider capability and Service Providers’ name, email, phone and address information is used to contact the Service Provider when services are required. When contacting a Service Provider an Animal Owner gives a separate consent in case information is shared with the Animal Owner. We do not collect and process sensitive personal data.

5. Lawful basis for processing

Processing (Art. 6(1)(b) GDPR) is necessary for the performance of a contract (Petsofi Terms of Services) to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract

6. Provided Personal Data

Due to the nature of services provided by Petsofi it is necessary to store a limited amount of Personal Data of Animal Owner. Personal Data is limited to contact details to enable Petsofi to follow up and report research results to Animal Owner and if research results indicate a need for further services, provided by third-parties, to allow Animal Owner to connect with these Service Providers.

7. Recipients of Personal Data

a. Occasionally (e.g. as a part of a research project) selected Animal Owner Data can be migrated from Petsofi platform to 3rd party register only after the Animal Owner has given a written (e.g. email, approval within Petsofi-system) consent for the data transfer.

8. Data transfers
No personal data is transferred outside EU/ETA.

9. Data retention
a. Personal Data of Animal Owner who has no animals on his/her account will be removed after 24 months from the remove of last animal from the system.
b. Personal Data of Animal Owner whose user accounts are inactive will be removed after 24 months of inactivity.
c. 24 months is considered as reasonable time to allow an Animal Owner to continue using Petsofi platform.

10. Security Safeguards
Securing the integrity and confidentiality of Personal Data is important to us. We have taken adequate technical and organisational measures in order to keep Personal Data safe and to secure it against unauthorized access, loss, misuse or alteration by third parties, such as encryption, access controls, and firewalls. Nevertheless, considering the cyber threats in modern day online environment, we cannot give full guarantee that our security measures will prevent illegally and maliciously operating third parties from obtaining access to Personal Data or absolute security of the Personal Data during its transmission or storage on our system

11. Other
We may make changes to this Privacy Policy at any time by giving a notice on the website and/or by other applicable means. The Data Subjects are highly recommended to review the Privacy Policy on our website every now and then, referring to the date of the last modification listed at the top of this page. If the Data Subject objects to any of the changes to this Privacy Policy, the Data Subject can request that we remove the Personal Data concerning him/her from the service, unless applicable laws require storage of such Personal Data. Unless stated otherwise, the then-current Privacy Policy applies to all Personal Data we process at the time.

12. Animal Owner’s rights regarding Personal Data stored by Petsofi
a. Right of access (Art. 15 GDPR)
b. Right to rectification (Art. 16 GDPR)
c. Right to erasure (Art. 17 GDPR)
d. Right to restriction of processing (Art. 18 GDPR)
e. Right to data portability (Art. 20 GDPR)
f. Right to withdraw consent (Art. 7(3) GDPR)
g. Right to lodge a complaint to a supervisory authority (Art. 77 GDPR)

Rights laid down in sections a. and b. can be exercised by Animal Owner by logging into the Petsofi System. Rights set out in sections c., d., e. and f. can be exercised by contacting admin@petsofi.com. In the event of request of erasure Animal Owner Personal Data will be deleted from the Petsofi Database within 14 working days from receiving the request. If Animal Owner wants to migrate his/her data to an external system Personal Data provided by Animal Owner to Petsofi will be exported in electronic format if possible.

In case the Data Subject considers that its rights under the data protection laws have been infringed, the Data Subject may lodge a complaint with the supervisory authority of the Data Subject’s residence in the EU (e.g. in Finland the Finnish Data Protection Ombudsman).

All contacts and inquiries related to this Privacy Policy should be addressed to: admin@petsofi.com.