CALIFORNIA PRIVACY SUPPLEMENT
This CALIFORNIA PRIVACY SUPPLEMENT is in addition to the information contained in the SmartPak Equine Privacy Policy, and applies to California residents. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other related privacy laws. Any terms defined in the CCPA have the same meaning when used in this supplement.
SmartPak Customers, Products and Services
Where a SmartPak customer interacts with SmartPak products and/or services, including, but not limited to SmartPak websites, applications, services and products, SmartPak collects information on California residents that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). We may obtain data provided by veterinarian customers, directly from individuals using SmartPak products and services such as websites or applications, and from consumers purchasing goods or services from SmartPak. SmartPak has collected the following categories of Personal Information from consumers located in the State of California within the last twelve (12) months:
- Identifiers including names, mailing addresses, unique personal identifiers, ISP addresses, account names, and other similar identifiers;
- Personal information under Cal. Civ. Code Sec. 1798.80 including names, telephone numbers, credit card numbers, and other financial information of SmartPak customers who have purchased goods or services;
- Commercial information such as products or services purchased, and purchasing history;
- Internet or similar network activity such as browsing history, search history, or users’ interaction with SmartPak websites, apps, or ads.
Job Applicants and Employees
In addition to Personal Information set forth above, SmartPak also collects information provided by job applicants and employees of SmartPak. SmartPak has collected the following categories of Personal Information from job applicants and employees located in the State of California within the last twelve (12) months:
- Protected classification characteristics such as age, race, ancestry, national origin, marital status, medical conditions, and veteran status; and
- Professional or employment related information including job history or performance evaluations.
Excluded Information
SmartPak does not collect biometric information, geolocation data, audio, visual, thermal, olfactory or other sensory data, educational records, non-public Family Education Rights and Privacy Act related data, or inferences drawn from Personal Information. Personal Information does not include information that is de-identified or aggregated, publicly available in government records, and information otherwise excluded from CCPA’s scope including pursuant to the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other excluded state and federal laws.
Use of Personal Information
SmartPak uses Personal Information as set forth in the SmartPak Privacy Policy. SmartPak has sold the Personal Information of California residents for 3rd party marketing purposes in the last 12 months.
Access to Information (‘Right to Know’)
SmartPak complies with your rights regarding your Personal Information, including the right to request information about SmartPak’s use of your Personal Information. Where SmartPak receives a validated request, it will provide information to you about the use of your Personal Information in the last 12 months including the following:
- General categories of Personal Information SmartPak has collected;
- Purposes for collecting such Personal Information
- Third Parties which whom SmartPak shares Personal Information
Deletion Requests (‘Right to Forget’)
SmartPak complies with your rights regarding your Personal Information, including the right to request deletion of your Personal Information. Where SmartPak receives a validated request, and SmartPak is not otherwise legally obligated to retain such Personal Information, SmartPak will delete your Personal Information. SmartPak may deny your deletion request where it is legally required to retain your Personal Information, including as follows:
- Where SmartPak has a legal obligation to retain your Personal Information, in conformity with state or federal laws that require the storage of prescription records, records related to the sale of controlled products, veterinary board data retention requirements, and where otherwise subject to state or federal law requiring the retention of data;
- Where it is necessary to protect you from unwanted data mis-use, fraudulent activity, or to maintain the security of data, data security, and in the protection of data security incidents;
- Where retention of data by SmartPak is to comply with a legal or contractual requirement to a SmartPak customer, such as a veterinarian who is required by veterinary board rules to retain your Personal Information related to your pet’s medical records; and
- To make use of any Personal Information pursuant to other recognized exceptions in the CCPA.
CCPA Requests
Requests to access or delete Personal Information may be made by calling 800-461-8898 800-461-8898 or by completing the form available here: https://ccpa.covetrus.com. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your child. You may only request access or deletion of Personal Information twice in any 12-month period. Your request must contain a valid email address, and describe within sufficient detail such that SmartPak may evaluate and respond to such request. SmartPak will not respond to requests without a verifiable email address. Making a request does not require you to create an account, and SmartPak will only use information in the request form to verify your authority to make the request and your identity. SmartPak does not discriminate against anyone making a CCPA request, and will not deny goods or services, charge different prices, or provide a different level of quality of goods or services based on any CCPA request. SmartPak will comply with the statutory time periods in which to respond to any CCPA request, and where we require additional time to comply with a request, we shall communicate with you on that request via email. We may also respond via email stating the reasons why we cannot respond to your request, cannot verify you, or cannot comply with a request. Where data is requested, SmartPak will select a format to provide a response to allow you to transmit that information to another entity. Where requests are deemed by SmartPak to be excessive, repetitive, or unfounded, SmartPak may charge a fee for response to your request.
Changes to CA Supplement
SmartPak may change or amend this supplement at any time, and any changes shall appear on the SmartPak website at www.SmartPakEquine.com.
Contact
You may contact SmartPak about your rights under CCPA as follows:
800-461-8898 800-461-8898
SmartPak 40 Grissom Road, Suite 500
Plymouth, MA 02360