Privacy Statement

Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

This policy (together with our end-user licence agreement and terms of use) applies to your use of:

“Project Pet” whether provided via our web app https://projectpet.app or via our native app once you have downloaded a copy of our app onto your mobile telephone(s) or handheld device(s) (in all use cases Our App).
Any of the services accessible through Our App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our App is not intended for children, and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Project Pet Limited, a company registered in England and Wales. Our company registration number is 12380259 and our registered office is Silverstream House, 4th Floor, 45 Fitzroy Street, Fitzrovia, London, England, W1T 6EB.
Personal data	Any information relating to an identified or identifiable individual.
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data (when processed to uniquely identify an individual). Data concerning health, sex life or sexual orientation. Information about criminal convictions and offences.
Data subject	The individual who the personal data relates to.

Personal data we collect about you

Depending on your user type within Our App, we may collect and use the following personal data about you:

your name and contact information, including email address and telephone number;
information to check and verify your identity, e.g., your date of birth;
your gender;
licences you may hold;
insurance policies you may hold;
financial information such as your bank or building society account;
the type of mobile device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, internet protocol (IP) address, your login data and the time and date the Services were used, browser type and version, time zone setting and location, browser plug-in types and versions; operating system and error data;
information stored on your devices(s) including login information; your contact history, purchase history and saved items;
information about how you use our website, IT, communication and other systems; and
your responses to surveys, competitions and promotions.

We collect and use this personal data to provide our Services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing our Services to you. In this case, we may have to cancel our Services, but we will notify you if this is the case at the time.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. 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 which will be used in accordance with this privacy policy.

Depending on your user type within Our App, the following data that we may process is considered special category personal data about you:

any data revealing criminal convictions and/or offences;

We collect special category data only for specified, explicit and legitimate purposes, which is to provide our Services to you. We will not use special category personal data for purposes that are incompatible with the purposes for which it was collected. There may be situations when we will ask for your consent to process your special category personal data. The consent will contain information on that specific processing activity. If you have given consent to a processing of your special category personal data you can always withdraw the consent.

How your personal data is collected

We collect most of this personal data directly from you by telephone, email and/or via our website and Our App. This includes personal data you provide when you:

apply for and use our Services;
create a user account in Our App;
subscribe to our publications;
request marketing to be sent to you;
enter a competition, promotion or survey; and
give us feedback or contact us.

However, we may also collect information:

directly from a third party who could be based inside or outside of the UK such as:
- analytics providers such as Google;
- advertising networks such as Google, Facebook or LinkedIn;
- search information providers such as Google; and
- providers of technical, payment and delivery services such as Stripe (https://stripe.com/)
from a third party with your consent such as your bank or building society;
from cookies, server logs and other similar technologies on our website; for more information on our use of cookies, please see our cookie policy https://projectpet.app/pages/cookie_policy

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason such as:

where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract we are about to enter into or have entered into with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons for using your personal data
Providing services to you.	To perform our Services.
Preventing and detecting fraud against you or us.	For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for you and/or us.
Activities necessary to comply with professional, legal and regulatory obligations that apply to our business such as under health and safety law.	To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to such as policies covering security and internet use.	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training and quality control.	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price.
Ensuring the confidentiality of commercially sensitive information.	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our business such as in relation to our financial performance, customer base, product range or other efficiency measures.	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price.
Preventing unauthorised access and modifications to systems.	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for you and/or us. To comply with our legal and regulatory obligations.
Updating and enhancing customer records.	To perform our Services. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party such as making sure that we can keep in touch with our customers about existing orders and new products.
Ensuring safe working practices, staff administration and assessments.	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party such as to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our Services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our Services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers.
External audits and quality checks such as for ISO and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws such as:

we have your explicit consent;
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
the processing is necessary to establish, exercise or defend legal claims.

Marketing

With your permission and/or where permitted by law, we may use your personal data for marketing purposes, which may include contacting you with information, news, and offers on our Services. We will always work to fully protect your rights and comply with our obligations under UK GDPR, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time by following the opt-out links on any marketing message sent to you. You have the right to withdraw consent to marketing at any time by using the ‘unsubscribe’ link in our marketing emails.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it or share it without your consent with other organisations for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

third parties approved by you such as social media sites you choose to link your account to or third party payment providers or to third party online verification providers;
other third parties we use to help us run our business such as marketing agencies, website hosts, lawyers, auditors, insurers and brokers;
HM Revenue & Customs, regulators and other authorities; and
our bank.

We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide Services to us and to you.

We may also need to:

share personal data with external auditors in relation to the audit of our accounts;
disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring; usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

Where your personal data is held

Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.

How long your personal data will be kept

We will keep your personal data while you have an account with us, or we are providing Services to you. Thereafter, we will keep your personal data for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly; and
to keep records required by law.

We will not keep your personal data for longer than necessary. When it is no longer necessary to keep your personal data, we will delete or anonymise it.

Transferring your personal data out of the UK

To deliver our Services to you, it may sometimes be necessary for us to share your personal data outside the UK such as:

with our service providers and/or our affiliated companies located outside the UK; and
if you are based outside the UK.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:

the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
a specific exception applies under data protection law.

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, based on an adequacy decision. These include:

all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
Gibraltar; and
Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law such as:

you have explicitly consented to the proposed transfer after having been informed of the possible risks;
the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
the transfer is necessary for a contract in your interests, between us and another person; or
the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers, and we will provide relevant information if we seek to transfer your personal data on this ground.

Further information

If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data.
Rectification	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data in certain situations.
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, e.g., if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations.
To object	The right to object: at any time to your personal data being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal data such as processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please:

email or write to us—see below: ‘How to contact us’;
provide enough information to identify yourself such as your full name and address and any additional identity information we may reasonably request from you; and
let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner (www.ico.org.uk).

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:

Full name of legal entity: Project Pet Limited

Email address: info@project-pet.co.uk

Postal address: Silverstream House, 4th Floor, 45 Fitzroy Street, Fitzrovia, London, England, W1T 6EB

Changes to this privacy policy

We keep our privacy policy under regular review. This privacy policy was published on 27th March 2023 and was last updated on 27th March 2023. We may change this privacy notice from time to time, when we do so we will inform you via e-mail and we will post a new version to this website.