PETLAB CO. PRIVACY NOTICE

Introduction

PetLab Co. Inc, PetLab Group Limited, and PetLab Co. Netherlands (“PetLab” or “we” or “us”) respects your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Notice (our “Privacy Notice”) describes the types of Personal Data (as defined below) we may collect from you or that you may provide when you visit the websites www.thepetlabco.com, www.thepetlabco.ca, www.petlabco.co.uk, https://thepetlabco.de (the “Websites”) and Personal Data sent to us when you make a purchase from us, either through one of the Websites (when available) or on or through an authorized third-party platforms where we advertise our products and services, such as Walmart.com, Chewy.com, and Amazon.com (collectively, “Authorized Third-Party Marketplaces”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Data. It also applies when you contact us either through social media or through any of our customer support channels. However, this Privacy Notice does not cover Personal Data and other information collected and/or used by Authorized Third-Party Marketplace, and such information is subject to their own privacy notice.

This Privacy Notice applies to Personal Data we collect:

• on our Website;
• through telephone calls, emails, texts, and other electronic messages between you and us, including when you contact us through social media or through any other customer support channels or when you comment on any of our posts on the Websites or on social media channels;
• from Submitted Materials (defined below) on our Websites or when you comment on or review our products; and
• from Authorized Third-Party Marketplaces to fulfill your order.

It does not apply to Personal Data or any other information collected by:

• us through any other means, including on any other website operated by PetLab, or any third party where this Privacy Notice is not linked;
• us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us;
• Authorized Third-Party Marketplaces that they use for their own purpose;
• Social media platforms that they use for their own purposes; or
• any other third party, including through any application or content (including advertising) that may link to or be accessible from the Websites.

Please read this Privacy Notice carefully to understand our policies and practices regarding your Personal Data and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites and not to purchase our products and services from us through an Authorized Third-Party Marketplace. By accessing or using one of our Websites or making a purchase through an Authorized Third-Party Marketplace, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Websites or purchasing our products and services through an Authorized Third-Party Marketplace after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

Children Under the Age of 18

Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any Personal Data to, on or through the Websites. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Websites or on or through any of its features, register on the Websites, make any purchases through the Websites or through an Authorized Third-Party Marketplace, use any of the interactive or public comment features of our Websites or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us at using the Contact Information at the end of this Privacy Notice.

Information We Collect About You and How We Collect It

Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, household, or device. However, Personal Data does not include any deidentified or aggregated information.

Generally

We collect Personal Data from various sources, including:

• directly from you when you provide it to us;
• automatically as you navigate through the Websites;
• information we create about you when you purchase our products and services; and
• from third parties, for example, operators of Authorized Third-Party Marketplaces and other business partners.

Information You Provide to Us

We collect the following types of Personal Data directly from you when you access or use our Websites or otherwise choose to provide it to us, such as when you contact our customer service personnel or post a comment on or through the Websites or our social media accounts: real name, alias, postal address, email address, telephone number and account name. In addition, we also collect other types of information directly from you when you contact us and choose to provide it, including information about your pet, such as name, breed, age, and diet, and health issues. While we do not receive your credit card or other payment information, our payment processors described below may collect this information and we may receive a tokenized version of your payment information. This tokenized version of your payment information may only be used by our payment processor to process payments and to process your returns.

We collect Personal Data through:

• information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use any of our Websites, making a purchase or creating a subscription, posting material (such as comments, reviews, and other feedback), or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us or when you report a problem with any of our Websites or our products;
• information you provide when you contact our customer service or leave a comment or other post on social media;
• when you report an adverse event related to our products through any means, which may include on or through the Website, social media, customer service, or other government mechanism;
• records and copies of your other correspondence (including email addresses), if you contact us;
• your responses to surveys that we might ask you to complete for research purposes; and
• details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites.

You also may provide information, such as product reviews, to be published or displayed (hereinafter, “posted”) on public areas of the Websites or transmitted to other users of the Websites or third parties (collectively, “Submitted Materials”). Your Submitted Materials are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your Submitted Materials. Therefore, we cannot and do not guarantee that your Submitted Materials will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Websites, including:

• details of your visits to our Websites. This includes: browsing history, email address (such as if you enter your email address into the email text field on the checkout page on our Websites), location data, advertising ID, communication data and the resources that you access, use, or otherwise interact with on the Website;
• your general physical location based upon IP address;
• information about your computer and internet connection, i.e., your IP address, operating system, and browser type;
• and other similar network or browsing information.

The information we collect automatically is statistical data, may include Personal Data, and/or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences;
• customize our Websites according to your individual interests;
• send you email reminders to complete a purchase and other related emails;
• speed up your searches; and
• recognize you when you return to our Websites.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Websites may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Websites. Unless you opt-out, we place non-essential cookies on your device. You choose not to receive non-essential cookies through our cookie consent manager, which you may access at any time by clicking “cookies” at the bottom of any page on the Websites. You can also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Websites. You can find more information about cookies at https://www.allaboutcookies.org and https://youronlinechoices.eu. For more information about the specific cookies we may use on our Websites, please click the “cookies” link at the bottom of any page of our Websites, and review the detailed information provided under each category of cookies.
• Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Website, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Websites and track which pages of the Websites you access. Session cookies are required to use the Websites.
• Web Beacons. Pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit PetLab, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Website Interaction and Performance Monitoring Tools and Session Replay Technologies. Our Websites may also use interaction and/or performance monitoring tools (sometimes called tracking scripts, analytics tools, application programming interfaces (APIs), session replay tools, or heatmap tools). These tools execute code in your web browser or on our Websites to help us collect data about your use of and interactions with the pages and content on our Websites, including information automatically transmitted from your web browser to our Websites such as information about your operating system, computer hardware, and browser preferences. We use session replay technology provided by FullStory, who employs software code to record users’ interactions with the Websites in a manner that allows us to watch video replays of those user sessions. The replays include users’ mouse movements, keystrokes, navigation pathways, other actions that you take our Websites. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about FullStory at https://www.fullstory.com/legal/privacy-policy and you can opt-out of session recording by FullStory at https://www.fullstory.com/optout/.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Websites are served by third-parties, including analytics providers, social media companies, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content on other online platforms.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Information We Create About You

We may also create certain information about you. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: unique identifiers, and records of your pets, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Information We Collect from Third Parties

We may collect Personal Data from third parties, such as our social media sites and Authorized Third-Party Marketplaces. When we associate this information with other Personal Data about you, we also consider this information to be Personal Data. This information includes: real name, postal address, unique personal identifier, email address, telephone number, account name, and records of products and services purchased or obtained, or considered, or other purchasing or consuming histories or tendencies.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

• to provide and personalize our Websites and their content to you;
• to allow you to participate in interactive features on our Websites;
• to provide you with information, products, or services that you request from us through any channel, including via our Websites, telephone calls to our customer service representatives, or through an Authorized Third-Party Marketplace;
• to provide you with email reminders to complete a purchase and other related emails;
• to create, maintain, customize, and secure your account with us;
• to administer surveys, sweepstakes, promotions, and other contests;
• to process your requests, purchases, transactions, and payments and prevent transactional fraud;
• to provide you with notices about your subscriptions, including expiration and renewal notices;
• to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• to personalize and deliver content and product and service offerings relevant to your interests, including targeted offers and advertisements through our Websites, third-party sites, and via email or text message (with your consent, where required by law);
• to support, develop, troubleshoot, and debug our Websites, products, and services;
• to help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business;
• for internal testing, research, analysis, and product development, including to develop and improve our Websites, and to develop, improve, or demonstrate our products and services;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• in any other way we may describe when you provide the information;
• to fulfill any other purpose for which you provide it; and
• for any other purpose with your consent

We may also use your information to contact you about our own goods and services that may be of interest to you by email or, with your consent, by text message. If you do not want us to use your information in this way, you may do so at any time by sending us an email stating your request at privacy@thepetlabco.com. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

• to our subsidiaries and affiliates
• to contractors, service providers, and third parties we use to support our business. Our contractors and service providers are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. These contractors, service providers and third parties provide services such as information technology and infrastructure support services, communication tools, payment processing services, shipping, and other services to support our Websites and related services and functionality. We also use third-party interest-based advertising providers, as described further below. Certain entities that we use to support our business, such as our payment processors and shipping partners, may use Personal Data in accordance with their privacy policies, which may be found at:
  • AfterShip: https://www.aftership.com/legal/privacy
  • James and James: https://www.ecommercefulfilment.com/en/privacy/
  • ShipBob: https://www.shipbob.com/privacy-policy
  • Stalco: https://www.stalcofulfillment.com/information/privacy-policy/
  • Checkout: https://www.checkout.com/legal/privacy-policy
  • PayPal: https://www.paypal.com/bm/legalhub/privacy-full?locale.x=en_US
  • Stripe: https://stripe.com/
  • Klaviyo: https://www.klaviyo.com/legal/privacy/privacy-notice
• to advertising partners, including analytics providers, social media companies, and application providers;
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PetLab’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by PetLab about our Websites’ users is among the assets transferred;
• for any other purpose disclosed by us when you provide the information; and
• with your consent or to fulfill a purpose for which you provide the information to us.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms & Conditions of Sale and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PetLab, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can adjust your cookie preferences for non-essential cookies by clicking on the “cookies settings” link at the bottom of any page on our Websites or by clicking on the cookie consent widget available in the bottom left corner of any page. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Websites may then be inaccessible or not function properly.
• Promotional Offers from PetLab. We may use your email address to promote our own products and services with your express consent. If you wish to opt-out, you may do so at any time by sending us an email stating your request to privacy@thepetlabco.com. If we have sent you a promotional email, you may click the unsubscribe link in the body of that email to be omitted from future email distributions. With your consent, we may also contact you with promotional offers via text message. You may opt out of text message communications by sending us an email stating your request to privacy@thepetlabco.com. If you receive a promotion text message, you may opt-out by responding “STOP”. Note if you opt-out, you will no longer receive marketing or promotional communications from us, but we may still send you transactional or service-related communications, such as order confirmations.

We use certain third parties to provide interest-based advertising. These third-party interest-based advertising providers may aggregate the information they collect with information from their other customers for their own purposes, and may use your information to serve interest-based advertising through other online websites and services. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).

The jurisdiction in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see Jurisdiction-Specific Privacy Rights for more Information.

Correcting, and Deleting Your Personal Data

You can review and correct certain Personal Data by logging into one of our Websites and visiting the My Account page.

You may also send us an email at privacy@thepetlabco.com to request to correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data 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.

You may also exercise your rights by contacting us by phone at 1-866-4-PETLAB (1-866-473-8522) and via our help center web form HERE.

If you delete your Submitted Materials from the Website, copies of your Submitted Materials may remain viewable in cached and archived pages or might have been copied or stored by users of our Websites.

The jurisdiction in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see Jurisdiction-Specific Privacy Rights for more information.

Jurisdiction-Specific Privacy Rights

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Privacy Notice. Please note that we may extend certain rights regarding your Personal Data to you as a courtesy, regardless of the jurisdiction in which you reside.

U.S. State Privacy Rights

If you are a resident of U.S. state that has a privacy law applicable to us, you may have additional rights as described in the State Privacy Law Addendum.

Do Not Track Signals

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Websites like message boards. The information you share in public areas may be viewed by any user of the Websites.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Websites.

Retention

We will keep your Personal Data for no longer than is necessary for the purpose(s) it was provided for, or for as long as necessary or appropriate to serve you, maintain your account or as otherwise needed to operate business. To determine the appropriate retention period for Personal Data, we may consider factors such as the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we process Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Further details of the periods for which we retain Personal Data are available on request. However, we may retain any or all categories of Personal Data when your information is subject to one of the following exceptions:

• When stored in our backup and disaster recovery systems. Your Personal Data will be deleted when the backup media your Personal Data is stored on expires or when our disaster recovery systems are updated.
• When necessary for us to exercise or defend legal claims.
• When necessary to comply with a legal obligation.
• When necessary to help ensure the security and integrity of our Website and IT systems.

When we no longer require the Personal Data we have collected about you, we may either delete it, de-identify it, anonymize it, or isolate it from further processing.

Consent to Processing of Personal Data in the United States

In order to provide our Websites, products, and services to you (including through an Authorized Third-Party Marketplace), we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States. Federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.

Your Personal Data is transferred by PetLab to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Privacy Notice when we transfer it to a third party for processing on behalf of PetLab, PetLab enters Data Protection Agreements between PetLab and all other recipients of your Personal Data whenever possible.

Changes to Our Privacy Notice

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically visiting our Websites and this Privacy Notice to check for any changes.

YOUR CONTINUED USE OF OUR WEBSITES OR CONTINUED PURCHASES THROUGH AN AUTHORIZED THIRD-PARTY MARKETPLACE FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE TO SUCH CHANGES.

Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Websites.