Comprehensive Privacy Policy

Effective Date: December 2024

Last Updated: December 2024

Policy Version: 2.1

1. Scope and Application

1.1 Policy Coverage

This Privacy Policy applies to:

  • PetVisit website (www.petvisit.com and all subdomains)
  • PetVisit mobile applications (iOS and Android)
  • All related services, tools, and platforms
  • Offline interactions and communications
  • Third-party integrations and partner services
  • Marketing and promotional activities
  • Customer support and administrative functions

1.2 Legal Framework Compliance

  • Australian Privacy Act 1988 and Australian Privacy Principles
  • General Data Protection Regulation (GDPR) for EU residents
  • California Consumer Privacy Act (CCPA) for California residents
  • Personal Information Protection and Electronic Documents Act (PIPEDA) for Canadian residents
  • State and territory privacy legislation across Australia
  • Industry-specific regulations for veterinary and animal care services

1.3 Definitions and Interpretation

  • "Personal Information" means any information relating to an identified or identifiable individual
  • "Sensitive Information" includes health data, biometric data, and other categories requiring special protection
  • "Processing" means any operation performed on personal information
  • "Data Controller" means PetVisit as the entity determining purposes and means of processing
  • "Data Processor" means third parties processing data on our behalf
  • "Data Subject" means the individual to whom personal information relates

2. Comprehensive Information Collection

2.1 Personal Information Categories

Identity and Contact Information:

  • Full name, date of birth, gender, nationality
  • Email addresses (primary and backup)
  • Telephone numbers (mobile and landline)
  • Home address, billing address, service addresses
  • Emergency contact details
  • Preferred communication methods and languages
  • Social media profiles and handles (when connected)

Professional Information (Pet Professionals):

  • Professional qualifications, certifications, and licenses
  • Educational background and training records
  • Years of experience and specializations
  • Business registration numbers and permits
  • Insurance policy details and coverage amounts
  • Professional references and recommendations
  • Background check results (where legally permissible)
  • Business addresses and service areas
  • Bank account details for payment processing
  • Tax identification numbers
  • Professional portfolio and work samples

Pet and Animal Information:

  • Pet names, species, breeds, ages, weights
  • Physical descriptions, photos, and identification markings
  • Microchip numbers and registration details
  • Vaccination records and health certificates
  • Medical history and current health conditions
  • Behavioral characteristics and training status
  • Dietary requirements and feeding schedules
  • Medication schedules and administration instructions
  • Veterinary contact information
  • Pet insurance details
  • Previous care provider information
  • Emergency procedures and preferences

2.2 Financial and Transaction Information

  • Payment method details (encrypted and tokenized)
  • Billing and transaction history
  • Tax-related information and receipts
  • Refund and dispute records
  • Credit assessments and payment behavior
  • Bank account details for direct deposits
  • Financial verification documents

2.3 Technical and Usage Information

  • Device information (type, model, operating system, browser)
  • IP addresses and geolocation data
  • Session data and activity logs
  • Search queries and browsing patterns
  • App usage statistics and feature interactions
  • Performance data and error reports
  • Cookie and tracking technology data
  • Network connection information
  • Security event logs and access attempts

2.4 Communication and Interaction Data

  • Messages exchanged through the Platform
  • Customer support communications
  • Survey responses and feedback
  • Review and rating content
  • Community forum posts and comments
  • Video and audio recordings (with consent)
  • Email open rates and engagement metrics

2.5 Information Collection Methods

  • Direct Collection: Information you provide during registration, bookings, and communications
  • Automatic Collection: Technical data collected through cookies, analytics, and monitoring tools
  • Third-Party Sources: Social media platforms, payment processors, identity verification services
  • Public Sources: Professional licensing boards, business registries, online directories
  • Partner Integrations: Veterinary clinics, pet insurance companies, other service providers

3. Detailed Information Usage and Processing

3.1 Primary Business Purposes

Service Delivery and Operations:

  • Creating and managing user accounts and profiles
  • Facilitating connections between pet owners and professionals
  • Processing bookings, payments, and transactions
  • Providing customer support and resolving issues
  • Sending service-related communications and notifications
  • Managing cancellations, refunds, and disputes
  • Maintaining service quality and safety standards

Safety and Security Operations:

  • Verifying professional qualifications and credentials
  • Conducting background checks (where legally permitted)
  • Monitoring for fraudulent or suspicious activities
  • Implementing security measures and access controls
  • Investigating incidents and policy violations
  • Protecting against cyber threats and attacks
  • Ensuring compliance with safety regulations

3.2 Platform Improvement and Development

  • Analyzing usage patterns and user behavior
  • Developing new features and services
  • Optimizing platform performance and user experience
  • Conducting research and data analytics
  • Testing new technologies and implementations
  • Personalizing content and recommendations
  • Improving search and matching algorithms

3.3 Marketing and Communications

  • Sending promotional offers and service recommendations
  • Creating targeted advertising campaigns
  • Analyzing marketing effectiveness and ROI
  • Building customer personas and segments
  • Conducting market research and surveys
  • Managing loyalty programs and rewards
  • Sharing success stories and testimonials

3.4 Legal and Regulatory Compliance

  • Meeting legal obligations and regulatory requirements
  • Responding to law enforcement requests
  • Maintaining business records and audit trails
  • Protecting intellectual property rights
  • Enforcing terms of service and policies
  • Managing legal disputes and proceedings
  • Reporting regulatory violations or concerns

3.5 Legal Basis for Processing (GDPR Compliance)

  • Contract Performance: Processing necessary for service delivery
  • Legitimate Interests: Platform security, fraud prevention, business operations
  • Legal Obligation: Compliance with laws and regulations
  • Consent: Marketing communications and optional features
  • Vital Interests: Emergency situations and safety protection
  • Public Interest: Animal welfare and public safety

4. Comprehensive Information Sharing and Disclosure

FUNDAMENTAL PRINCIPLE: We never sell personal information to third parties for commercial purposes. All sharing is conducted under strict contractual obligations and security requirements.

4.1 Sharing with Platform Users

Information Shared with Pet Professionals:

  • Pet Owner name and verified contact information
  • Pet information necessary for service delivery
  • Service location and access instructions
  • Appointment details and special requirements
  • Emergency contact information
  • Previous service history (with consent)
  • Payment status and method (without financial details)

Information Shared with Pet Owners:

  • Professional name and verified credentials
  • Business information and service descriptions
  • Availability, pricing, and service areas
  • Reviews, ratings, and performance metrics
  • Insurance and licensing status
  • Contact information for confirmed bookings
  • Background check status (where applicable)

4.2 Third-Party Service Providers

Essential Service Providers:

  • Payment Processors: Stripe, PayPal, bank payment systems
  • Cloud Infrastructure: Amazon Web Services, Microsoft Azure, Google Cloud
  • Communication Services: Twilio, SendGrid, Mailchimp
  • Analytics Platforms: Google Analytics, Mixpanel, Amplitude
  • Customer Support: Zendesk, Intercom, LiveChat
  • Identity Verification: Jumio, Onfido, Persona
  • Background Checks: Checkr, Sterling Volunteers, ANZABC

4.3 Legal and Regulatory Disclosures

  • Law Enforcement: When required by court order, warrant, or legal process
  • Regulatory Authorities: Animal welfare agencies, licensing boards, tax authorities
  • Emergency Services: During life-threatening situations or imminent harm
  • Legal Proceedings: In response to subpoenas, litigation holds, or court orders
  • Government Agencies: For compliance with national security or public safety requirements

4.4 Business Transfer Scenarios

  • Mergers, acquisitions, or asset sales
  • Bankruptcy or insolvency proceedings
  • Corporate restructuring or reorganization
  • Partnership or joint venture arrangements
  • Licensing or franchising agreements

4.5 Data Processing Agreements

All third-party processors are bound by comprehensive agreements requiring:

  • Equivalent security and privacy protections
  • Purpose limitation and data minimization
  • Confidentiality and non-disclosure obligations
  • Incident reporting and breach notification
  • Right to audit and compliance verification
  • Secure data deletion upon contract termination
  • International transfer safeguards where applicable

5. Advanced Data Security and Protection Measures

5.1 Technical Security Controls

Encryption and Cryptography:

  • AES-256 encryption for data at rest
  • TLS 1.3 encryption for data in transit
  • End-to-end encryption for sensitive communications
  • Key management through Hardware Security Modules (HSMs)
  • Regular encryption key rotation and updates
  • Cryptographic hashing for password storage

Access Controls and Authentication:

  • Multi-factor authentication for all accounts
  • Role-based access control (RBAC) systems
  • Principle of least privilege enforcement
  • Regular access reviews and deprovisioning
  • Privileged account monitoring and logging
  • Session timeout and automatic logout
  • Device trust and certificate-based authentication

5.2 Infrastructure Security

  • Network Security: Firewalls, intrusion detection systems, DDoS protection
  • Server Security: Hardened configurations, regular patching, vulnerability scanning
  • Database Security: Encryption, access logging, query monitoring, backup security
  • Application Security: Secure coding practices, penetration testing, code reviews
  • Cloud Security: Multi-region deployment, data residency controls, vendor security assessments

5.3 Monitoring and Incident Response

  • 24/7 security monitoring and threat detection
  • Automated anomaly detection and alerting
  • Comprehensive audit logging and retention
  • Security incident response team and procedures
  • Forensic analysis capabilities and evidence preservation
  • Business continuity and disaster recovery plans
  • Regular security drills and tabletop exercises

5.4 Security Certifications and Standards

  • ISO 27001 Information Security Management System
  • SOC 2 Type II compliance for service organizations
  • PCI DSS compliance for payment processing
  • OWASP Top 10 security vulnerability assessment
  • Regular third-party security audits and penetration testing
  • Industry-specific security frameworks and guidelines

5.5 Employee Security Training

  • Mandatory security awareness training for all employees
  • Role-specific privacy and data protection training
  • Phishing simulation and security testing exercises
  • Clear desk and clear screen policies
  • Confidentiality agreements and code of conduct
  • Background checks for employees with data access

6. Comprehensive Data Breach Response

6.1 Breach Detection and Assessment

  • Automated monitoring systems for breach detection
  • Immediate containment and impact assessment procedures
  • Classification of breach severity and affected data types
  • Risk assessment for potential harm to individuals
  • Coordination with cybersecurity and legal teams

6.2 Notification Requirements and Timelines

  • Regulatory Authorities: Notification within 72 hours (GDPR) or as required by local law
  • Affected Individuals: Notification without undue delay, typically within 72 hours
  • Business Partners: Immediate notification if their data is affected
  • Media and Public: Public disclosure if required by law or if high risk to individuals

6.3 Breach Response Actions

  • Immediate containment and system isolation
  • Forensic investigation and evidence preservation
  • Vulnerability remediation and system hardening
  • Credit monitoring services for affected individuals
  • Customer support and communication management
  • Legal and regulatory compliance coordination
  • Post-incident review and improvement implementation

6.4 Individual Rights and Remedies

  • Free credit monitoring and identity theft protection
  • Assistance with account security and password changes
  • Regular updates on investigation progress
  • Compensation where legally required or appropriate
  • Enhanced monitoring and protection services

7. Comprehensive Privacy Rights and Controls

7.1 Universal Privacy Rights

Right to Information and Access:

  • Detailed explanation of data processing activities
  • Copy of all personal information we hold
  • Information about data sources and recipients
  • Processing purposes and legal basis
  • Data retention periods and deletion schedules
  • Automated decision-making and profiling details

Right to Rectification and Correction:

  • Correction of inaccurate or incomplete information
  • Update of outdated or changed information
  • Addition of missing information or context
  • Verification of corrected information accuracy

Right to Erasure and Deletion:

  • Complete account deletion and data removal
  • Selective deletion of specific information
  • Secure deletion from all systems and backups
  • Verification of deletion completion
  • Third-party notification of deletion requests

7.2 Advanced Privacy Controls

  • Data Portability: Export data in machine-readable formats
  • Processing Restriction: Limit how data is processed
  • Objection Rights: Object to processing for marketing or legitimate interests
  • Automated Decision-Making: Opt-out of profiling and automated decisions
  • Consent Withdrawal: Withdraw consent at any time for consent-based processing

7.3 Communication and Marketing Preferences

  • Granular email communication preferences
  • SMS and push notification controls
  • Marketing segment and targeting preferences
  • Third-party marketing and sharing opt-outs
  • Frequency and timing preferences
  • Content type and topic preferences

7.4 Privacy Rights Exercise Process

  • Online privacy request portal for easy submission
  • Identity verification to prevent unauthorized requests
  • Request tracking and status updates
  • Response within statutory timeframes (typically 30 days)
  • Appeals process for denied or incomplete requests
  • Free exercise of rights (fees only for excessive requests)

8. Detailed Data Retention and Deletion

8.1 Retention Periods by Data Category

Account and Profile Information:

  • Active account data: Retained while account is active
  • Inactive accounts: Deleted after 3 years of inactivity
  • Closed accounts: Deleted within 30 days unless legal obligations require longer retention
  • Professional credentials: Retained for 7 years after account closure for verification purposes

Transaction and Financial Records:

  • Payment transactions: 7 years for tax and legal compliance
  • Refund and dispute records: 7 years from resolution
  • Financial verification documents: 7 years from account closure
  • Tax-related information: As required by applicable tax laws

Communication and Support Records:

  • Customer support communications: 3 years from last interaction
  • Platform messages: 1 year after account closure
  • Marketing communications: Until opt-out or account closure
  • Survey responses: 2 years from collection

8.2 Technical Data Retention

  • Usage analytics: Aggregated and anonymized after 2 years
  • Security logs: 1 year for incident investigation
  • Error logs and diagnostics: 6 months for system improvement
  • Backup data: Automatic deletion according to backup rotation schedules

8.3 Legal Hold and Extended Retention

  • Data subject to legal proceedings: Retained until case resolution
  • Regulatory investigation data: Retained until investigation completion
  • Safety incident records: Retained for 5 years for analysis and prevention
  • Compliance audit data: Retained according to regulatory requirements

8.4 Secure Deletion Procedures

  • Multi-pass overwriting for magnetic storage devices
  • Cryptographic erasure for encrypted data
  • Physical destruction of storage media when necessary
  • Certificate of destruction for sensitive data disposal
  • Third-party deletion verification and confirmation

9. Enhanced Cookie and Tracking Technology Policy

9.1 Comprehensive Cookie Classification

Strictly Necessary Cookies:

  • Authentication and session management
  • Security and fraud prevention
  • Load balancing and performance optimization
  • GDPR consent management
  • Shopping cart and booking functionality

Functional Cookies:

  • Language and region preferences
  • Accessibility settings and customizations
  • User interface preferences
  • Form auto-completion and data persistence
  • Chat widget and customer support features

Analytics and Performance Cookies:

  • Google Analytics and similar platforms
  • Heatmap and user behavior analysis
  • A/B testing and optimization
  • Error tracking and performance monitoring
  • Conversion tracking and funnel analysis

9.2 Third-Party Tracking and Pixels

  • Social media pixels (Facebook, Instagram, Twitter)
  • Advertising network tracking (Google Ads, Microsoft Advertising)
  • Email marketing tracking (open rates, click tracking)
  • Affiliate program tracking and attribution
  • Customer support and live chat tracking

9.3 Mobile App Tracking

  • Device identifiers (IDFA, Google Advertising ID)
  • App usage analytics and crash reporting
  • Push notification preferences and delivery
  • Location services and geofencing
  • In-app purchase and conversion tracking

9.4 Tracking Control and Opt-Out Options

  • Granular cookie consent management
  • Browser-based tracking prevention
  • Do Not Track signal recognition
  • Advertising opt-out tools and preferences
  • Third-party opt-out aggregation services

10. Children's Privacy Protection

10.1 Age Verification and Restrictions

  • Platform is not intended for individuals under 18 years of age
  • Age verification during account registration process
  • Immediate account deletion if underage access is discovered
  • Parental consent requirements where legally mandated
  • Special protections for family accounts and shared devices

10.2 COPPA and International Children's Privacy Compliance

  • Compliance with Children's Online Privacy Protection Act (COPPA)
  • GDPR Article 8 requirements for children's consent
  • Australian Privacy Act protections for children
  • Enhanced security measures for accounts with minors
  • Parental access rights and control mechanisms

10.3 Reporting and Response Procedures

  • Clear reporting mechanisms for underage account detection
  • Immediate investigation and response protocols
  • Secure deletion of all collected information
  • Notification to parents or guardians where required
  • Documentation and compliance record maintenance

11. International Data Transfers and Cross-Border Processing

11.1 Transfer Mechanisms and Safeguards

  • Adequacy Decisions: Transfers to countries with adequate protection levels
  • Standard Contractual Clauses: EU Commission-approved transfer contracts
  • Binding Corporate Rules: Internal data protection policies for group companies
  • Certification Schemes: Privacy Shield successors and similar frameworks
  • Code of Conduct: Industry-specific data protection standards

11.2 Data Localization and Residency

  • Primary data storage in Australian data centers
  • EU data residency options for European users
  • Backup and disaster recovery in multiple jurisdictions
  • Content delivery networks for performance optimization
  • Cloud service provider geographic restrictions

11.3 Cross-Border Transfer Recipients

  • Cloud infrastructure providers (AWS, Azure, Google Cloud)
  • Payment processing services (global payment networks)
  • Customer support and communication platforms
  • Analytics and business intelligence services
  • Professional verification and background check providers

11.4 Transfer Impact Assessments

  • Regular assessment of transfer destination countries
  • Monitoring of legal and political developments
  • Risk evaluation and mitigation strategies
  • Alternative transfer mechanism implementation
  • Data subject notification of significant changes

12. Automated Decision-Making and Profiling

12.1 Automated Processing Activities

  • Professional matching algorithms and recommendations
  • Fraud detection and risk assessment systems
  • Dynamic pricing and demand forecasting
  • Content personalization and user experience optimization
  • Marketing segmentation and targeting
  • Customer support routing and prioritization

12.2 Profiling and Data Analysis

  • User behavior analysis and preference prediction
  • Professional performance scoring and ranking
  • Risk profiling for safety and security purposes
  • Market analysis and trend identification
  • Quality assurance and service improvement

12.3 Rights and Protections

  • Right to human review of automated decisions
  • Explanation of decision-making logic and consequences
  • Opt-out options for non-essential automated processing
  • Regular algorithm auditing and bias detection
  • Transparency about automated processing use

12.4 Algorithmic Transparency and Fairness

  • Regular bias testing and fairness assessments
  • Diverse training data and inclusive design practices
  • Clear criteria and weighting factors disclosure
  • Appeals process for disputed automated decisions
  • Continuous monitoring and improvement processes

13. Privacy by Design and Data Protection Impact Assessments

13.1 Privacy by Design Principles

  • Privacy considerations integrated into system design
  • Default privacy settings and minimal data collection
  • End-to-end privacy protection throughout data lifecycle
  • User-centric design and transparency
  • Security and privacy controls embedded in architecture

13.2 Data Protection Impact Assessments (DPIAs)

  • Systematic assessment of high-risk processing activities
  • Stakeholder consultation and input gathering
  • Risk identification and mitigation strategy development
  • Regular review and update of assessment findings
  • Documentation and compliance record maintenance

13.3 Privacy Engineering and Technical Measures

  • Data minimization and purpose limitation implementation
  • Privacy-enhancing technologies (PETs) deployment
  • Differential privacy and anonymization techniques
  • Homomorphic encryption for secure computation
  • Zero-knowledge proof systems for verification

14. Comprehensive Policy Updates and Change Management

14.1 Update Triggers and Procedures

  • Legal and regulatory requirement changes
  • Business model or service modifications
  • Technology platform updates and new features
  • Industry best practice evolution
  • User feedback and privacy concern responses

14.2 Notification and Communication

  • Email notification to all registered users
  • In-app notifications and prominent website placement
  • Social media announcements and press releases
  • Direct communication for significant changes
  • Multilingual notifications where appropriate

14.3 Transition Periods and Grace Periods

  • 30-day notice period for material changes
  • Extended notice for changes affecting fundamental rights
  • Grandfathering provisions for existing users
  • Opt-out periods for new processing activities
  • Transition assistance and support resources

14.4 Version Control and Historical Records

  • Comprehensive version history and change logs
  • Archive of previous policy versions
  • Change rationale and impact documentation
  • User acceptance and acknowledgment tracking
  • Legal review and approval records

15. Contact Information and Privacy Officer Details

15.1 Data Protection Officer (DPO)

  • Name: Dr. Sarah Mitchell, CIPP/E, CIPM
  • Email: dpo@petvisit.com
  • Phone: +61 2 8765 4322
  • Address: Data Protection Officer, PetVisit Pty Ltd, Level 15, 123 Pet Care Avenue, Sydney NSW 2000
  • Office Hours: Monday to Friday, 9:00 AM to 5:00 PM AEST

15.2 Privacy Team Contacts

  • General Privacy Inquiries: privacy@petvisit.com
  • Data Subject Rights: rights@petvisit.com
  • Data Breach Reporting: breach@petvisit.com
  • Privacy by Design Consultation: design@petvisit.com
  • Third-Party Privacy Issues: partners@petvisit.com

15.3 Regional Privacy Contacts

  • European Union Representative: eu-privacy@petvisit.com
  • United Kingdom Representative: uk-privacy@petvisit.com
  • California Consumer Privacy Act: ccpa@petvisit.com
  • Canadian Privacy Inquiries: canada-privacy@petvisit.com

15.4 Regulatory Authority Contacts

  • Australian Privacy Commissioner: Office of the Australian Information Commissioner (OAIC)
  • EU Data Protection Authorities: Contact details available at edpb.europa.eu
  • UK Information Commissioner's Office: ico.org.uk
  • California Privacy Protection Agency: cppa.ca.gov

15.5 Response Times and Service Level Agreements

  • Privacy Rights Requests: 30 days maximum response time
  • Data Breach Notifications: 72 hours for regulatory authorities, without undue delay for individuals
  • General Inquiries: 5 business days response time
  • Urgent Privacy Matters: 24-48 hours response time
  • Complex Investigations: Up to 90 days with regular updates