Pet Assure Corp doing business as Pet Assure Corp, a proud brand of Synergy Pet Group, (hereinafter referred to as “Company”, “we”, “our” or “us”) understands that you care about how information about you is collected, used, and shared, and we appreciate that each individual, entity, user or visitor (collectively “you” or “your”) trust this information with us. We take your privacy very seriously and are committed to protecting your information. We act in accordance with applicable data protection and privacy laws when collecting and using information about you.

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

This Privacy Policy (“Privacy Policy”) applies to your use of our website located at www.petassure.com (collectively, “Website”), our mobile application called Pet Assure (“App”), and our Services as defined under Section 1.1 of the Pet Assure Website Terms of Use agreement located at https://www.petassure.com/terms-of-use. This Privacy Policy describes what kind of information we collect, when and how we might use that information, how we protect the information, and the choices you have with respect to your personal information. We may change, add to, or remove all or any portion of this Privacy Policy at any time, and will post the current Privacy Policy so that you will always have the current Privacy Policy available to you.

Should you have any comments or questions about how we collect and use your personal information, please reach out via email to Legal@petassure.com or via our Contact Us form on our website at https://www.petassure.com/contact-us.

1. Applicability & Eligibility. This Privacy Policy applies to this Website, App, Services, and our collection, use, disclosure, and protection of your data. It does not apply to third-party websites, applications, or services. Before accessing, using, or interacting with our Website, App, or Services, you should carefully review the terms and conditions of this Privacy Policy.

By using our Website, App, or Services, you are agreeing to our Privacy Policy, without modification, and confirming you have read and understand these policies, including how and why we use your information. If you do not want us to collect or process your personal information in the ways described in this Privacy Policy, you should not use the Website, App, or Services.

This Website and App are not intended for individuals under the age of 18. We do not knowingly collect personal information directly from individuals under 18 years of age. Our Services are not intended for individuals under 18 years of age. If you are under 18 years of age, you should not submit or post personal information on our Website, App, or Services.

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

Personal information

Any information relating to an identified or identifiable individual

Sensitive Personal Information

A specific subset of personal information that includes certain government identifiers; account log-in, financial account, debit or credit card numbers with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of messages; genetic data; biometric information; information regarding health, sex life, or sexual orientation; or information about race, ethnic origin, religious or philosophical beliefs, or union membership.

3. Personal Information Collection and Use. We collect information about you and your use of our Website, App, and Services through various means, including information we receive from you on Website forms, as well as through your access, use, or interaction with our Website, App, and Services. Such processing is utilized to provide our Website, App, and Services to visitors.

Where we gather your information using consent, your opt-in consent will be clearly obtained. You may withdraw this consent at any time by contacting us at Legal@petassure.com.

4. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	Name, postal address, Internet Protocol address, email addresses, and telephone numbers. If required by your employer for enrollment purposes, we may collect social security number, date of birth, or other identifier to facilitate payroll deductions.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Name, postal address, telephone numbers, bank account number, debit card number, Venmo/Paypal account number, credit card number, employment history, employment, email addresses, social security number, and pet health insurance policy number and coverage information.
Characteristics of protected classifications under California or federal law.	We do not collect.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	Products or Services purchased, obtained, or considered, customer service call recordings, and veterinary invoices and pet medical records.
Biometric information	We do not collect.
Internet, metadata, or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	The information we collect could be aggregate and/or user-specific individual information but does not reveal your specific identity (like your name and/or contact information).  This information is primarily needed to maintain the security and operation of our Website, App,  and for internal analytics and reporting purposes.  This information includes device characteristics (including operating system and name), your IP address, browser characteristics, communication data, referring URLs (what web websites or search terms that referred you to the Website), how and when you use our and other technical information, time zone, location, country, language preferences and patterns of use (information on the individual web pages, App screens, or Services you view on our Website, and browsing and navigation patterns within our Website).
Geolocation data	We do not collect.
Audio, electronic, visual, thermal, olfactory, or similar information	We do not collect.
Professional or employment-related information	Employment history as provided by the employer offering pet employee benefits.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	We do not collect.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	We may create a pet spending profile based on the information provided during provision of Services to you via the Company or any of our Affiliates (as defined below).

This personal information is required to provide Services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing Services to you.

5. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text, email, and/or via our Website, App, and Services. However, we may also collect information:
• From your employers
• From your pets’ veterinarians and service providers
• From publicly accessible sources (e.g., property records);
• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
• From a third party with your consent (e.g., your bank);
• From cookies on our Website;
• Google Analytics*; and
• Via our IT systems, including automated monitoring of our Website and App and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

* Google Analytics uses persistent cookies to allow us to see behavior information relating to visitor age, gender, and interests. We may also use this data to create remarketing lists. You can opt out of Google Analytics without affecting how you visit this Website. For more information on opting out of Google Analytics tracking and customizing Google Display Network ads, visit Google’s Ad Settings.

6. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

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.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and/or Services to you	To provide our products and/or Services to you or to take steps at your request before providing products and/or Services to you
To prevent and detect fraud against you or us	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity, screening for financial and other sanctions or embargoes, or other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., 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 for 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, e.g., in relation to our financial performance, customer base, product and/or service 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 for you at the best price
Preventing unauthorized 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 us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
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, e.g., 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
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and Services
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or 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

The above table does not apply to special category personal information, which we will only process with your explicit consent.

7. How Your Personal Information is Secured. We use a third party service provider, namely, Amazon Web Services (“AWS”) to deliver the Website and Services to you. As such, AWS implements security measures that include encryption, firewalls, password management and secure socket layer technology, which are designed to protect your information from unauthorized access and potential security breaches. You can find out more about AWS’s security measures by clicking here: https://wa.aws.amazon.com/wellarchitected/2020-07-02T19-33-23/wat.pillar.security.en.html

We will notify you and any applicable regulator of a breach where we are legally required to do so.

Payment information is directly processed and secured by Braintree, Stripe or other third party payment processors and cannot be accessed by us. We do not collect or store sensitive cardholder data, such as credit card numbers, or card authentication data.

You acknowledge that no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and another registered user on the Website, App, and/or the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite our best efforts.

8. How Your Personal Information is Stored. All Personal Information is stored securely on AWS’s Relational Database Service (RDS). While your full payment information is not stored by us, but parts of your payment information such as the last four digits, expiry, type, and provider of the credit card is stored for future use, and secured respectively, on Braintree or other third party payment processor located at https://www.braintreepayments.com, in order to meet the legislative requirements. The partial payment information Braintree or other third-party payment processor stores may be used in future to verify you before providing you with customer service or technical support.
9. Cookies. Cookies are small text files placed on your device when you visit a website. They help enhance your browsing experience by remembering your preferences and activities on our website.

Types of cookies we use:

• Essential cookies: Essential cookies are necessary for the proper functioning of our website and used solely for that purpose. Essential cookies cannot be disabled.
• Functionality cookies: Functionality cookies allow our website to remember choices you made in the past, such as your name, email, login tokens, and stored quote information.
• Analytical cookies: Analytical cookies are used to track behavior in order to make improvements to our site.
• Marketing cookies: Direct marketing cookies help to deliver a tailored and customized marketing experience, including but not limited to advertisements, retargeting, and social media.
• Third-party cookies: Third-party cookies track user behavior across multiple websites.

Managing cookies: You can control cookie settings in your browser settings. Most browsers allow you to refuse cookies or delete them. However, please note that disabling cookies may affect the functionality of our Site and your user experience. You can also manage your cookie preferences and opt out by clicking here. Please note, that certain cookies cannot be disabled.

10. Do Not Track. Most web browsers and some mobile operating systems and mobile applications include a “do not track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored or collected.  Our web services may not alter, change, or respond upon receiving Do Not Track (DNT) requests or signals in browsers. As described in more detail above, we track user activity using cookies and similar technologies.
11. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our products and/or Services, including exclusive offers, promotions, or new products and/or Services.

We have a legitimate interest in processing your personal information for promotional purposes (see above How and why we use your personal information). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside the Synergy Pet Group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at Legal@petassure.com;
• Using the “unsubscribe” link in emails or “STOP” number in texts.

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

12. Who We Share Your Personal Information With. We routinely share personal information with:
• Business partners – These are businesses that we work with to offer you certain Services or promotions, employers, brokers and agents, pet plan providers, pet pharmacies, and insurance companies and reinsurers.
• Non-affiliated service providers – These non-affiliated service providers may offer services like, but not limited to, payment processing, data analysis, email delivery, hosting services, customer service and call centers, actuarial and analytics partners, marketing efforts, etc. These companies may use information about your visits to this Website and other websites that are contained in cookies to provide services, advertisements, or to collect data about how you interact with this Website over time.
• Affiliates – If we share your information with affiliates, they are required to adhere to this Privacy Policy. Affiliates as used in this Privacy Policy is defined as any entity, individual, firm, or corporation, directly or indirectly, through one or more intermediaries, controlling, controlled by, or under common control with Company.
• Government and regulatory authorities – We may provide information to government and regulatory bodies to provide the Services you have purchased or because of legal and regulatory obligations on our business.
• Auditors and financial and legal advisors – We may need to provide information to assist with the provision of Services or management of our business.
• Relevant industry self-regulatory bodies – We may need to provide information to assist with provision of Services or management of our business.
• Others only as permitted by law.

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

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We do not sell your personal information, and we have contracts with service providers to prohibit any sale of your personal information and to provide written assurances regarding the security and privacy protections they have in place to protect your personal information. 

13. Where Your Personal Information is Held. Information 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 Information with).
14. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing Services to you. Thereafter, we will keep your personal information 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; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

15. Important Notice to Users Outside the U.S. The Website, App, and Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Website or the Services, you consent to this transfer.
16. Accessing and Correcting Your Information. You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at Legal@petassure.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from the Website or App, copies of your User Content may remain viewable in cached and archived pages or might have been copied or stored by other Website or App users. Proper access and use of information provided on the Website, App, and Services, including User Content, is governed by our terms of use https://www.petassure.com/terms-of-use.

Residents of certain states, such as California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

17. Your State Privacy Rights. State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
• targeted advertising (excluding Iowa);
• sales; or
• profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. California residents can read Your Rights Under the CCPA below to learn more about their rights. To exercise your privacy rights under any state law, review the How to Exercise Your Rights section below. Anyone can access their rights by emailing Legal@petassure.com. To appeal a decision regarding a consumer rights request, please email Legal@petassure.com.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: Legal@petassure.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

18. Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: petassure.com/do-not-sell-or-share-my-personal-information.
Sensitive Personal Information	We may collect and use data considered “sensitive personal information” for necessary business purposes and to provide our products and services. Sensitive personal information is personal information that reveals: Personal identification numbers, including social security, driver’s license, passport, or state ID card numbers; Account or debit or credit card numbers combined with passwords or codes that would enable access to accounts; A consumer’s exact geolocation; A consumer’s racial origin, religious beliefs, or union membership; A consumer’s mail, email, or text message content unless the information was intentionally sent to the business; and A consumer’s genetic data, such as DNA samples or biometric data identifying the consumer. You have the right under the California Privacy Rights Act (CPRA) of the California Consumer Privacy Act (CCPA) to limit the use of your sensitive personal information to only those reasonably necessary to perform services or provide goods to an average consumer as well as additional statutorily approved ones. To limit the use of your sensitive personal information, visit our homepage and click on the “Limit the Use of My Sensitive Personal Information” or click the link here: petassure.com/limit-the-use-of-my-sensitive-personal-information.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny Services to you; Charge different prices or rates for Services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or Services to you; or Suggest that you receive a different price or rate for Services or a different level or quality of our Services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or Services to you, if that difference is reasonably related to the value provided to our business by your personal information.

19. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized 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.
20. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please email us at Legal@petassure.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email or phone, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

21. Linking to Third Parties. When you leave our Website or App and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that if you enter into a transaction on the third-party website, we do not represent either the third party or you. Further, the privacy and security policies of the linked website may differ from those practiced by us.
22. Changes to This Privacy Notice. This privacy notice was published on February 16, 2024, and last updated on June 9, 2024. We reserve the right to change this Privacy Policy at any time in our sole discretion. If we make changes, we will post the revised policy here. By continuing to use our Website and Services after notice is provided, you accept and agree to this Privacy Policy as modified.

How to Contact Us. Please contact us via our Contact Us form on our website at https://www.petassure.com/contact-us/.

23. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print) please contact us (see How to Contact Us above).