Fluffy privacy policy

Hello

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Welcome to the Fluffy privacy policy.

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We take your privacy seriously. We want you to know why we need certain information from you, what we're doing with it, and how we keep it secure.

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Table of contents

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• 1. What this policy covers

• 2. What data we hold and how we get it

• 3. What we use your data for

• 4. How we store and move your data

• 5. How and why we share your data

• 6. How long we keep your data

• 7. Your rights

• 8. Changes to this policy

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1. What this policy covers

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This policy explains how we use your data to deliver our healthcare app, websites and services. This includes:

• Our app, including any beta versions

• Our websites (www.joinfluffy.com)

• Some of our services we offer with our partners, or on behalf of them

• The technology we use to support our partners' services

 

2. What data we hold and how we get it

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Personal data is any information we have that can identify you, such as your name, medical history or credit card details.

 

Personal details

 

When you register with us, we'll ask you for your:

• Name

• Date of birth

• Address

• Email address

The information you give us must be accurate. If you give us information about yourself or another person, you're confirming that you're authorised to do so.

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Health and medical data

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When you use our services, we collect information about your pet’s health, including:

• General health

• Symptoms, treatments and medications

• Consultations, such as notes and recordings

• Interactions with our services, like using our Symptom Checker or other digital services. These interactions may be shared with our clinical staff so that we can provide your pet with healthcare, and so that we can provide a better experience

Some of this information comes directly from you, but it can also come from third parties, such as your veterinarian or a laboratory.

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Details of your conversations with us

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We also keep a record of your consultations and your conversations with us. This is so we have an easy way to access your consultations to monitor the quality of our service and healthcare.

And, if you have consented, so that we can use them to improve our services. This includes:

• Your conversations with our Symptom Checker

• Your emails, calls or live chat conversations with our support team

• Video and/or audio recordings from consultations

We keep your health and medical data secure by applying technical and organisational measures to protect it.

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Data from other sources

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We might also receive some data about you and your pet’s health from other apps, devices and services.

This will only happen if you've agreed to sharing that data with us. 

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Credit and debit card information

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If you make a payment on the app, your credit and debit card details are processed by a third-party payment provider.

We don't store any of your credit or debit card information and we only keep details of the transactions on our secure servers.

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Technical information and analytics

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When you use our app, or visit our website, we may collect the following data, where this is allowed by your device or browser settings:

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• The IP address used to connect your mobile phone or other device to the internet

• Your browser information, such as Google Chrome or Apple Safari

• Login and operating system

• The make and model of your device

• Resettable device identifiers

• Time zone, language and location settings

• Your mobile network provider and your location (based on your IP address)

• Information about your visit to our website or use of our app, for example when you first visited the site or how many times you've visited

• Information about the products or services you viewed or used

• App response times and updates

• Information about your interactions, like what notifications you opened

• Any phone number used to call our customer service number

 

We work with other companies that provide us with analytics and advertising services. This is to:

• Help us understand how people interact with our services

• Provide the adverts for our services on the internet

• Measure the performance of our services and our adverts

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Your pet’s health information is not used for these advertising services.

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Cookies

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We also use 'cookies'. Cookies are files saved on your phone, tablet or computer when you visit a website. They collect information about how you use the website and the pages you visit. 

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Information from third-party services

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It's possible to connect your social media account with our services. For example, you can sign up for Fluffy using your Facebook login details. If you choose to do this, we'll receive the following information about you from the third party:

• Name

• Email address

• Username or ID

• Lifestyle habits and information

If you use login details from third parties, they will also process your login data, and they are solely responsible for handling this.

We may also get information from other sources, such as companies who offer information on consumer trends.

We use this information to help us make our services better. We comply with data protection laws when we do this. If this information is used alongside your personal data, we will make sure that our interests never come before your rights.

 

3. What we use your data for

 

This is how we use your data and the legal reasons for using it.

 

Providing you with a service

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We need your personal information to enter into a contract with you and deliver services.

We use your financial details to charge you if you use our paid service or buy our products.

We use your pet’s health and medical information to provide you with a healthcare service, including when it's in your (or your pet’s) vital interests. This includes giving you health advice, as well as diagnosis and treatments if you use our televet services (our video and audio consultations, where you can talk with one of our vet professionals).

The health and medical information we use includes information from your:

• Consultations, like notes, recordings, and transcripts

• Use of products like Symptom Checker

• Data from test kits

Depending on how you access our services, we get your location from your phone, internet browser, IP address or postal address.

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Improving Fluffy's services

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If you've given explicit consent, we use your pet’s health and medical information to improve our services, including our artificial intelligence systems. This helps us deliver better healthcare to you and other Fluffy users.

We remove details that could identify you from this information, such as your name, address and contact details. These are called 'personal identifiers'.

The health and medical information we collect (with your personal identifiers removed) includes information from your pet’s:

• Medical records

• Consultations, like notes, recordings and transcripts

• Use of products like Symptom Checker

This doesn't involve making any decisions which would have a big effect on you. We only use this information to deliver a better experience to you and other Fluffy users. This explicit consent relates to when we use your personal data.

 

Helping health research

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If you've given explicit consent, we use your data for health research. For example, to better understand health behaviour, disease risk or health outcomes.

We aim to publish our research results in peer-reviewed journals or by working with academics.

We may conduct research with partner organisations such as universities or other academic institutions.

The type of information we collect includes your pet’s:

• Medical records

• Consultation notes, recordings, and transcripts

• Use of products like Symptom Checker 

We remove any details that could identify you from this information. This includes your name, address and contact information.

As part of our research, we may use your contact details to invite you to take part in trials. These trials might be about things like how frequently we give you reminders or what exercise has the greatest impact on your pet.

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Using your data when it's in our 'legitimate interest'

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We sometimes analyse your data and how you use our products to help us manage our business better.

This could be things like fixing bugs in our app, understanding current user trends, or working out what users might want in the future.

This doesn't involve making any decisions which would have a big effect on you. If this information is used alongside your personal data, we will make sure that our interests never come before your rights.

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Keeping you up to date

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We may contact you when marketing our service. This includes sending you product updates, surveys and marketing information. You can opt in or out at any time. You can also choose if you want to get app notifications in your device settings.

As part of providing you with a healthcare service or public service, we may send you pet health information by text message, email or in other ways. 

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Regulating the quality and safety of our service

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We use your health and medical information for safety, training, regulatory, and compliance purposes.

This means that:

• If we're legally required to, or asked by a regulator, we may need to share your information with regulatory bodies

• We may audit how you use our services, for example to review the quality of results provided by our products

To detect and prevent fraud, we may need to share your personal and financial information with banks, financial institutions and fraud prevention services.

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4. How we store and move your data

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Personal health and medical information

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Your pet’s personal health and medical information is stored on secure servers. This includes information like:

• Your primary care information

• Information about your pet’s health

• Any information about a diagnosis of illness or other problems

If you've chosen a password or authentication method to access the app, you're responsible for keeping this password and/or authentication method confidential. Please don't share it with anyone.

We encrypt data transmitted to and from the app. Once we have your information, we use strict procedures and security features to try to prevent unauthorised access. We will take all steps reasonably necessary to make sure that your data is treated securely.

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Credit and debit card information

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We don't store any of your credit or debit card information. Payments are processed through a third-party payment provider that follows strict industry data security standards. These are known as Level 1 Payment Card Industry (PCI) data security standards.

Any payments you make are encrypted using SSL technology (which converts the information into code to stop fraud).

 

Where we store and process your data

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Your data may be processed or stored outside of the UK and the European Economic Area (EEA).

This is because we sometimes work with other companies who help us deliver Fluffy services to you. These companies might have servers outside of the UK or EEA.

This will always be in line with applicable data protection lawful mechanisms (such as appropriate contractual terms) and subject to strict safeguards.

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5. How and why we share your data

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To help us deliver our services we may share your personal data with other parts of Fluffy.

Service providers

Some companies provide services to you on our behalf, such as the live chat. We may share your personal data with them so that they can process it to provide these services.

These companies can only use your data based on our instructions and they cannot use the data for their own purposes.

They also have to act in line with data protection laws and contractual terms that specify how they can process data on our behalf.

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Partners

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If you use our services through your pet insurer or one of our partners we may share some of your information with them. This could include your:

• Name

• Date of birth

• Email address

• Policy number

• Location

We may also share with them the fact that you have registered with us and used our services. But we will not share any details about your consultations or pet’s medical records, unless you consent to this.

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Other healthcare providers

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If it's needed for your pet’s treatment or care, we will share your pet’s data with your other vets. These include:

• Our clinical partners who we work jointly or in connection with to provide you a service

• Your veterinarian 

• Testing service providers

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Protecting public health

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We might process your pet’s health data to protect public health. Your pet’s data could be vital to help research, monitor, track and manage public health emergencies.

We will limit the use or sharing of data to the period of the emergency and will only share data to the extent necessary.

 

Aggregated or anonymous data

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We may show on our website or share with our commercial partners data that does not personally identify you, but which shows general trends. This is 'aggregated' data and is not personal data.

This might include, for example, the number of users of our service or trends in a particular location.

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Statistical data in the public's interest

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We may also use data that does not identify you personally as part of statistics that we collect on certain types of illness, symptoms and conditions.

We may show these summarised statistics to our partners. They will always be anonymised. This is so we can improve our medical knowledge and help our members and the general public.

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6. How long we keep your data

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We follow advice from the government bodies on how long to keep information found in your pet’s medical records. This is called a 'retention period'.

We might also keep some information that doesn't identify you to help improve our business and our services.

In some circumstances, we might keep data longer if the law says we have to.

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7. Your rights

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You're in control of your personal information. Under data protection law, you have the right to:

• Remove or change your consent at any time, if we are using your data in a certain way based on it. 

• Ask for a copy of the personal data we hold about you. Your data is stored in line with our legal and medical obligations. 

• Ask us to correct information that's wrong, delete it, or ask that we only use it for certain purposes. There might be times when we're not able to help, like if the law obligations say we can't.

• Ask us to restrict any automated (computer-made) decisions made with your data

• Ask for your data to be provided in a portable format that allows you to move, copy or transfer it. Or ask us to send it in this format to someone else.

To do any of these things, please contact us at:

Craig Tower

1 Aqua Vista Square

London

E34EF

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8. Changes to this policy

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We might update this policy from time to time.If we make any important changes, we'll let you know, and give you the chance to review them.

If you agree to the changes, you don't need to do anything. Just keep using our services with the updated policy and we'll assume you are happy with the way we use your data.

If you don't agree to the changes, then you can stop using our services at any time