The Simini Technologies Inc. (“Simini”) websites (including our online store(s)) , www.simini.com, www.surgerysam.com, www.ordersimini.com, www.getyourclinicapp.com, and our software applications (including our mobile apps such as Simini Review and Surgery Sam and white label versions of Surgery Sam for individual veterinary clinics) and any other websites and apps which may be added from time to time (the “Digital Assets”), are owned and operated by Simini.
1. What personal data we will collect;
2. How we use collected data;
3. Who has access to the data collected;
4. The rights of Digital Assets users; and
THE TYPES OF PERSONAL INFORMATION WE COLLECT
Data Collected in a Non-Automatic Way
When you perform certain functions, such as open an account or place an order on one or more of our Digital Assets, we will ask you to provide the following data:
First and last name;
Payment information (where relevant); and
Auto fill data
Pet’s surgeon, referring vet, and their clinic
The apps may also allow Users to send pet updates to their surgeon. These updates are completely voluntary. These data can be shared with your surgeons, their surgery clinic, or individuals your surgeon selects to review these data.
These data may become part of the veterinary records at your surgeon’s and referring veterinarians practice.
These data may be anonymized and used to improve care of pets following clinical procedures.
NON-PERSONAL IDENTIFICATION INFORMATION
We may collect non-personal identification information about Users whenever they interact with our Digital Assets. Non-personal identification information may include the browser name, and the type of computer and technical information users use to access our Digital Assets such as the operating system and the Internet service providers utilized and other similar information.
HOW WE USE PERSONAL DATA
We may need to hold, process, and transfer your Personal Information but will do so solely for legitimate business purposes in accordance with applicable laws, regulations, and guidelines. We will only disclose your Personal Information on a need-to-know basis to those who are authorized to use it for these purposes.
The personal data we collect when the user performs certain functions may be used for the following purposes:
• To set up a user account;
• Completion of orders;
• To tailor your experience when accessing or using our websites;
• To operate and manage our business (including developing, maintaining and supporting our Digital Assets);
• To provide you marketing and information about our Digital Assets that we think may interest you (if you have not opted out of receiving marketing or, where an affirmative opt-in is required under applicable to law, you have affirmatively opted in to receive marketing);
• To provide supplemental information to veterinary healthcare teams to support the care of your pet
• To comply with applicable law;
• To establish, exercise or defend our legal claims and rights; and,
• For any other purpose(s) set forth in any consent you provide
HOW LONG WE STORE PERSONAL DATA
User personal data will only be stored until the purpose the data was collected for has been achieved. You will be notified if your data is kept for longer than this period.
WHO WE SHARE PERSONAL DATA WITH
We will never sell your data to third parties. We will not share your data with third parties who are not our service providers as set out above, except in the following cases:
1. If the law requires it;
2. If it is required for any legal proceeding; and
3. To prove or protect our legal rights.
If you follow hyperlinks from our Digital Assets to another website or app, please note that we are not responsible for and have no control over their privacy policies and practices. We strongly recommend that you review all privacy policies for any website or app you use that is not our Digital Assets.
HOW WE MANAGE AND PROTECT PERSONAL INFORMATION
We will never sell, rent or trade your personal information. We protect all the personal information we collect. While we take all reasonable precautions to ensure that user personal data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, your computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.
These pieces of information are used to improve services for you, such as analyzing anonymized data to help us understand how people interact with our services so we can make them better. A cookie often includes a randomly generated number which is stored on your device. Many cookies are automatically deleted after you finish using the Digital Assets.
DO NOT TRACK NOTICE
Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers.
We do not currently have the technical capability to implement DNT preferences in our systems, and therefore do not respond to browser-initiated DNT signals.
By using our Digital Assets, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Digital Assets. Your continued use of the Digital Assets following the posting of changes to this policy will be deemed your acceptance of those changes.
You can withdraw your consent by Contacting the Privacy Officer, as set out below.
When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.
You are responsible for the accuracy of the information that you provide to Simini Technologies Inc. through our Digital Assets or otherwise.
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
LEGAL BASIS FOR PROCESSING
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal bases to collect and process the personal data of users in the EU:
1. Users have provided their consent to the processing of their data for one or more specific purposes;
2. Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interest(s) are set out above in: HOW WE USE PERSONAL DATA.
YOUR RIGHTS AS A USER
Under the GDPR, you have the following rights:
1. Right to be informed;
2. Right of access;
3. Right to rectification;
4. Right to erasure;
5. Right to restrict processing;
6. Right to data portability; and
7. Right to object.
HOW TO ACCESS, MODIFY, DELETE, OR CHALLENGE THE DATA COLLECTED
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to whom we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our Privacy Officer here:
Simini Technologies Inc.
HOW TO OPT-OUT OF DATA COLLECTION, USE OR DISCLOSURE
In addition to the method(s) described in the: HOW TO ACCESS, MODIFY, DELETE, OR CHALLENGE THE DATA COLLECTED section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:
1. You can opt-out of the use of your personal data for marketing emails;
2. You can opt-out by clicking "unsubscribe" on the bottom of any marketing email; or
3. You can opt-out by updating your email preferences under "Your Account".
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Simini collects personal information categories including identifiers, inferences, and usage data. Simini collects this information when you visit our website to operate, manage, and promote our business, including developing, maintaining and supporting our Digital Assets, and to tailor your experience when accessing or using our websites.
California residents have the right to make the following requests, up to twice every 12 months:
• The right to request the specific pieces of personal information Simini has collected about You.
• The right to request that Simini disclose what personal information we collect, use, disclose, or sell.
• The right to request that Simini delete personal information that Simini has collected about You (subject to certain exceptions).
• The right to opt out of the sale of Your personal information.
You may exercise your rights to access and delete data by emailing us at firstname.lastname@example.org.
Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to the value of your information.
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