Privacy Policy

Introduction

At SmartPak Equine, LLC ("SmartPak"), we're committed to protecting the privacy and security of your information. This Privacy Policy ("Policy") is designed to help you understand what information we collect, why we collect it, how we use it, and how you can manage your information with us. SmartPak strives to improve the health of horses and companion animals, and to improve the experience of the people involved along the way. Information you provide to us allows us to alert horse and dog owners when their animal's supplement is running out, and to make sure we always stock enough of the products you rely on us to provide. In order to do these things, we collect both Personal and non-personal information in a few different ways.

We comply with data privacy laws and regulations applicable in the jurisdictions in which we operate. In particular, SmartPak complies with its obligations under Canada's federal Personal Information Protection and Electronic Documents Act ("PIPEDA") and substantially similar provincial privacy legislation with respect to the Personal Information that is collected, used, transferred or disclosed as part of our services.

This Policy applies to all SmartPak website visitors and product users, and other customers of SmartPak and affiliated entities. By using our website, downloading any application from our website, or buying our products or services, you signify your acceptance of this Policy and consent to the collection, use and disclosure of your Personal Information by SmartPak in accordance with the terms of and for the purposes set out in this Policy and SmartPak's Terms of Service.

Summary of SmartPak Privacy Policy

We may collect the following Personal Information when you contact us, register with us, use our services, website and applications:

Your internet ISP, location, type of device, and browsing history

We may use your Personal Information for the following purposes:

Provide more accurate shipping arrival time estimates should you decide to order from us
Recognize you when you return to the website for a more personalized shopping experience
Advertise to you on our website and select third-party websites and social media platforms

We may share your Personal Information with the following parties:

Payment providers such as credit card processors for the purposes of completing transactions;
Shipping service provider and customs broker providers for the purposes of arranging for shipping and delivery of SmartPak products;
Advertising, marketing and analytics service providers;
Social media companies (e.g. Twitter, Facebook, Instagram, YouTube) where you interact with SmartPak on social media, or receive ads within social media.

You have the following choices:

You can adjust your cookies settings and preferences and the ability to disable cookies and other tracking technologies on your computer or mobile device;
You can opt out of marketing e-mails by clicking on the "unsubscribe" link

In case of a breach of security safeguards, we will:

Determine whether the breach creates a real risk of significant harm to you, including physical, financial or reputational harm;
Notify you, the Office of the Privacy Commissioner of Canada and/or any provincial Information and Privacy Commissioner(s), as appropriate;
Notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach; and Keep a record of the breach in accordance with our legal obligations.

How to contact us:

For more information about this Policy, our privacy practices or to obtain access to or correction of your personal information, please contact us at:

SmartPak Equine, LLC
Attn: Chief Technical Officer
40 Grissom Road
Suite 500
Plymouth, MA 02360 USA

And at CustomerSupport@SmartPak.ca or 1-800-326-0294

Full Version of SmartPak Privacy Policy

This Policy covers the following:

Type of Personal Information We Collect and How We Collect It
How We Use Your Personal Information
How We Share Your Personal Information
Retention and Storage of Personal Information
How We Protect Personal Information and Security Breach Procedure
Access to and Correction of Your Personal Information
Your Choices With Respect to Collection, Use, and Disclosure of Your Personal Information
Links to Other Websites and Social Media Functionality
Protecting Children's Privacy
Changes to this Policy and How to Contact Us for More Information

Scope

This Policy applies to the Personal Information we collect from you. "Personal Information" means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, and may or may not include business contact information, depending on the jurisdiction.

This Policy does not cover anonymized aggregated data from which the identity of an individual cannot be determined. SmartPak reserves the right to use anonymized data in any way it determines appropriate.

1. Type of Personal Information We Collect and How We Collect It

Information you provide to us

We collect information at several different points as we interact with you. This includes when you create an account, order from the online store, chat with customer service, speak with your account representative, use one of our products or services, register for our newsletter, participate in promotions, or participate in surveys. The information we collect includes things like the name of a pet owner, a horse or dog's name, animal health updates, mailing addresses, email addresses, telephone numbers, payment information, and passwords.

Information we collect when you use our product and services

When you use our products and services, we collect information about how you are using them and how well those products and services are working. For example, this can include usage data and device data. Our products, websites and emails utilize technology to collect information. This includes things like web beacon data in emails, and via cookies and flash cookie data and device data such as IP addresses, operating system types, and browser types when you use our website. You can adjust your settings in your device browser to disable some of these if you prefer not to share this information.

Online Behavioral Advertising

As part of our ad delivery and reporting, we may log page views and collect information for the purpose of delivering ads or providing advertising-related services, including providing a specific advertisement based on a particular type of browser or time of day; statistical reporting in connection with the activity on a website; and tracking the number of ads served on a particular day to a particular website (tracking web analytics data). To do so, we may collect information about the type of browser, referrer and operating system of website visitors, as well as the domain name, day and time of visit, and page(s) visited. We do so across multiple web domains owned or operated by different entities.

Consent

Unless permitted by law, no Personal Information is collected without first obtaining the consent of the individual concerned to the collection, use and disclosure of that information. By using our website, downloading any application from our website, or using our products or services, you signify your acceptance of this Policy and consent to the collection, use and disclosure of your Personal Information by SmartPak in accordance with the terms of and for the purposes set out in this Policy and our Terms of Service. You can withdraw your consent at any time by unsubscribing from the product and discontinuing use.

2. How We Use Your Personal Information

When you use our products and services, we may also use your information:

In order to maintain and improve our products and services by making sure they are working well. For example, knowing which pages of our website frequently result in calls from confused customers helps us know where we need to improve our site design.
To help develop new products and services. For example, tracking the number of calls for basic subscription updates enabled us to redesign our subscription management area to make things easier on our horse and dog owners.
In order to personalize your experience with our products and services according to the information we collect. This means we talk to horse owners about horses, and dog owners about dogs -- or we remind you when your supplement needs to be repurchased so that it arrives before your current supply runs out.
To provide services to you, including through our contractors, such as payment providers, delivery providers, and cloud hosting providers.
For regulatory compliance. We maintain records as required by law, and we may share your Personal Information to comply with regulatory agency laws, rules, and regulations. This can include providing required Personal Information in connection with mandatory disclosures to regulatory agencies and providing disclosures of records in response to a regulatory agency request.
For legal reasons. We may share your Personal Information to comply with inquiries from governmental authorities, or to protect, defend, exercise legal rights or claims, in connection with end user license agreements, Terms of Service or other applicable agreements, or as otherwise required by law. If we are legally required to share your Personal Information, we will attempt to notify you, unless such notification would violate law or court order.
In the event of business transfer. If SmartPak is involved in a sale of assets, merger, acquisition, business transfer, or other change of control, we may share your Personal Information with other entities involved. We will require any such successor business entity to honor this Policy, and we will notify you of any changes that could affect your information. In the event of a business transfer, unless we are otherwise required by law to retain or provide your information to the other entity, you may request that your information be deleted from our records.

We may also use statistical or aggregated information about the website's use and share, publish, post, disseminate, transmit or otherwise communicate or make available such information to, suppliers, business partners, affiliates, and any other third party, at our sole discretion. SmartPak does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information we have obtained.

3. How We Share Your Personal Information

SmartPak may disclose your Personal Information to the following parties:

Our shipping service providers, including UPS, FedEx, USPS, Canada Post, and DHL. This includes sharing your address for the purposes of arranging for shipping and delivery of our products;
Our advertising, marketing and analytics service providers, including e-commerce platform and marketing providers.
Other service providers, including individuals or organizations, that provide SmartPak with email solutions, cloud hosting services, payment processing, website support and maintenance, and legal, regulatory, or audit services.

4. Retention and Storage of Personal Information

SmartPak keeps your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. SmartPak stores Personal Information on servers located in the United States and Canada.

When your Personal Information is no longer required for the purposes for which it was collected, SmartPak will destroy, delete, erase or convert it into an anonymous form. If we learn that we have unintentionally stored Personal Information, we will use commercially reasonable efforts to anonymize or purge this information.

SmartPak may use service providers located in the United States, and, if applicable, your Personal Information may be processed and stored in the United States, and therefore may be subject to access or disclosure to foreign law enforcement authorities under the laws the United States and individual U.S. states. You may request information from SmartPak on the jurisdictions in which SmartPak and/or its service providers will process and store Personal Information. Where we transfer, store, and process your Personal Information in the United States, we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

5. How We Protect Personal Information and Security Breach Procedure

The security and confidentiality of your information is extremely important to us. We have implemented technical, administrative, and physical security measures to protect your information. As part of our efforts to protect your information, we have technical safeguards in place across our products and services, which may include the following:

Requiring a password in order for you to access your Personal Information;
Using firewalls to protect information held in our servers;
Utilizing Transport Layer Security (TLS) encryption in transmitting Personal Information to our servers;
Limiting the number of personnel who have potential access to Personal Information; and
Routinely backing up the systems to protect the integrity of Personal Information.

There is always some risk that an unauthorized third party may breach our security safeguards. A "breach of security safeguards" is defined as the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization's security safeguards or from a failure to establish those safeguards.

In case of a breach of security safeguards involving your Personal Information under our control, we will notify you, the Privacy Commissioner of Canada, and any provincial Information and Privacy Commissioner(s), as appropriate, if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you, including physical, financial or reputational harm. We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach. We will keep a record of all breaches in accordance with our legal obligations.

6. Access to and Correction of Your Personal Information

SmartPak permits the reasonable right of access and review of Personal Information held by us. You can contact us anytime at security@covetrus.com or CustomerSupport@smartpak.ca. if you would like to change or update your Personal Information. We endeavour to provide the information in question within a reasonable time, generally no later than 30 days, following a request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.

In some cases, we may not be able to provide you with access to your Personal Information, for example, where an exception to access to is permitted or required by applicable law.

7. Your Choices With Respect to Collection, Use and Disclosure of Your Personal Information

Websites and Opt-Out Functions. You can adjust and manage the privacy of your information via our websites, which allow you to opt out of certain features that we offer. By adjusting your device or browser settings, you can manage information by adjusting your personal profile, your subscriptions, your cookies, and your location services.
Email. You can opt out of emails through links in the emails you receive from us. Every email you receive from us will give you the ability to unsubscribe from receiving future emails.
Products. All use of products is subject to the user consent in the product's subscription terms and conditions for each product. You can withdraw your consent at any time by unsubscribing from the product and discontinuing use.
3rd Party Mailings or Advertisements. If you prefer to exclude your physical mailing address from 3rd party mailings or advertisements, you can contact us anytime at CustomerSupport@SmartPak.ca or 1-800-326-0294.

8. Links to Other Websites and Social Media Functionality

The SmartPak website may contain links or other references to websites and/or services operated by third parties including, without limitation, social media and social networking services (the "Third Party Sites"). Your use of any Third Party Sites is subject to the privacy policies and terms of use established by the specific Third Party Site, and SmartPak disclaims all liability associated therewith. The presence of any link or reference to a Third Party Site does not indicate any approval or endorsement by SmartPak. Further, descriptions of, or references to, third party products, services or publications within SmartPak's services do not imply endorsement of, and SmartPak is not responsible for and disclaims any endorsement of, any such product, service or publication. To personalize your experience with our services, you may have the ability to log in via certain Third Party Sites. Third Party Sites will provide us with access to certain information that you have provided to such Third Party Sites, and we will use, store and disclose such information in accordance with this Policy. However, please remember that the manner in which Third Party Sites use, store and disclose your information is governed solely by the policies of such third parties, and we shall not have any liability or responsibility for the privacy practices or other actions of any Third Party Sites that may be enabled within our website.

Further, our website uses YouTube's API services in connection with embedding videos provided by YouTube LLC ("YouTube"). Accordingly, you acknowledge and agree that by accessing such embedded YouTube videos on our website that you are also bound by YouTube's Terms of Service and Google's Privacy Policy.

9. Protecting Children's Privacy

SmartPak does not knowingly sell products to, solicit, collect or retain personal information about children under the age of 18 without parental consent. If we learn that a child under 18 has submitted information to us without parental consent, we will take all reasonable measures to delete it from our databases and not use the information for any purpose (except where necessary to protect the child or others). If you become aware of any personally identifiable information we have collected from children under 18, please contact us.

10. Changes to this Policy and How to Contact Us for More Information

We review and may revise this Policy from time to time as we add new features and services, as laws change, and as industry best practices evolve. We indicate the date the most recent changes were published on this page. If we update the Policy with significant changes, we will let you know, for example by placing a note on our website. Please review this Policy periodically, and especially before you provide any information to us.

If you have any questions about this Policy or our practices at SmartPak, please contact us at:

SmartPak Equine, LLC
Attn: Chief Technical Officer
40 Grissom Road
Suite 500
Plymouth, MA 02360 USA

And at CustomerSupport@SmartPak.ca or 1-800-326-0294

SmartPak will work with customers and website users to resolve any concerns you may have about this Policy. If we are unable to resolve your privacy concerns, you have the right to complain to the Office of the Privacy Commissioner of Canada.

You may also direct your inquiry/complaint to the relevant Information and Privacy Commissioner in your jurisdiction of residence.

Policy Updated: November 16, 2020