VETS & CLINICS PRIVACY POLICY
In accordance with applicable data protection regulations, this Privacy Policy is intended to help you understand what data is collected by this Vets & Clinics’ platform of Affinity Petcare, S.A.U. (hereinafter “Affinity”) and how it is processed.
1. Data controller
The data controller is Affinity Petcare, S.A.U., with registered office at Plaza Europa, 54-56, L’Hospitalet de Llobregat, 08902, Barcelona, Spain.
Affinity will process the personal data collected on this website, as well as on any platforms Affinity may make available to you, Affinity’s social media profiles and other domains owned by us (hereinafter the “Site” or “Website”).
Affinity is not subject to any obligation to appoint a Data Protection Officer. However, as a proactive measure, it has appointed a data protection committee dedicated to responding to any queries, requests or clarifications regarding the processing of personal data, which may be sent to the postal address indicated at the beginning of this document and to the email address gdpr@affinity-petcare.com, with the reference “Data Protection”.
2. How we obtain your personal data
The personal data processed will be that which you provide to us through the various channels made available by Affinity, for example, via the available forms or through the use of the Vets & Clinics platform.
Furthermore, when you visit or use the Vets & Clinics platform, various technologies are used to collect and store information, and this may include the use of cookies or similar technologies to identify your browser or device. Affinity also uses these technologies to collect and store information when you interact with services offered by Affinity or other features. You can find out more about how Affinity processes personal data obtained through cookies or as a result of your browsing activity if you accept the use of cookies (for more information about the Website’s cookies, please visit our Cookie Poli
3. What personal data do we process, for what purpose, and on what legal basis
These purposes are listed below, indicating what data will be processed (type of data) and on what grounds or legal basis we rely on to do so. This list has been drawn up taking into account the category of data subject to which you belong for the purposes of the processing of personal data that Affinity may carry out:
3.1. Users registered on the Vets & Clinics platform
The following processing of personal data applies to the categories of data subjects who are part of the database of users registered on Affinity’s various websites; or who are subscribers to the Affinity Newsletter.
USER REGISTRATION ON THE VETS & CLINICS PLATFORM
PURPOSE
Registration and maintenance of your user account on Affinity’s Vets & Clinics website, including, where applicable, data modifications and account deletion, in relation to the provision of services by Affinity to its users.
TYPE OF DATA
Those requested on each personal data collection form and, as a minimum, the following:
- Identifying details: Full name and user ID.
- Contact information: Email address, postcode.
- Browsing details.
- Access credentials.
LEGAL BASIS
The performance of the contractual relationship established with Affinity following acceptance of the terms and conditions of registration.
SENDING OF COMMERCIAL COMMUNICATIONS BASED ON CONSENT
PURPOSE
Sending commercial communications, including by electronic means, such as instant messaging channels, including SMS and push notifications, regarding Affinity’s products, services, activities, news, offers and promotions based on your interests and in accordance with your profile, as explained in the processing activity entitled “User Segmentation”.
Affinity contracts email marketing services with external providers that allow us to collect information about campaigns, i.e. to track email opens and clicks on the content or links included in those emails. This information is collected to prepare statistical reports on recipients’ behaviour in order to optimise the campaign.
TYPE OF DATA
- Identifying details: Full name and username.
- Contact information: Email address, postal address, postcode, telephone number.
- Consumption and browsing habits.
- Aggregated data relating to the tracking of commercial communications and/or newsletters, such as total opens; forwarded opens; time of open; last open; subscribers with the most opens.
LEGAL BASIS
The processing of your personal data is authorised by the express consent you provide to us.
You may withdraw your consent and unsubscribe from these communications at any time.
SENDING OF COMMERCIAL COMMUNICATIONS BASED ON LEGITIMATE INTEREST
PURPOSE
Sending of commercial communications, including by electronic means such as instant messaging, SMS and push notifications, regarding Affinity’s products, services, activities, news, offers and promotions based on your interests and in accordance with your profile, as explained in the processing activity entitled “User Segmentation”.
Affinity contracts email marketing services with external providers that allow us to collect information about campaigns, i.e. to track email opens and clicks on the content or links included in those emails. This information is collected to prepare statistical reports on recipients’ behaviour in order to optimise the campaign.TYPE OF DATA
- Identifying data: Full name and username.
- Contact information: Email address, postal address, postcode, telephone number.
- Consumption and browsing habits.
- Aggregated data linked to the tracking of commercial communications and/or newsletters, such as total opens; forwarded opens; time of opening; last open; subscribers with the most opens.
LEGAL BASIS
The processing of your personal data is justified by our legitimate interest in being able to send you markketing communications, based on the existence of a prior relationship as a customer or user of Affinity’s services, as is the case with Vets & Clinics.
Furthermore, you may, at any time, express your wish not to be subject to this processing by exercising your right to object to it.
COMMERCIAL CONTACTS
PURPOSE
Management and development of commercial contacts via telephone calls and face-to-face visits for the purpose of providing information on Affinity’s products, services, offers and promotions, as well as maintaining and strengthening the commercial relationship with customers and potential customers.
TYPE OF DATA
- Identifying data: Full name.
- Contact information: Email address, telephone number, postal address.
LEGAL BASIS
The processing of your personal data is justified by Affinity’s legitimate interest inmaintaining its relationshipwithyou .
Affinity has carried out the analyses required by privacy regulations, which confirm that Affinity’s interest prevails over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the ‘Exercising Your Rights’ section of this Privacy Policy. Furthermore, you may, now or at any other time, express your wish not to be subject to this processing by exercising your right to object to it.
USER SEGMENTATION
PURPOSE
Preparation of a commercial profile based on your tastes and interests, derived from an analysis of the products you have purchased or shown an interest in, and enquiries made, with the aim of better tailoring our promotional activities, such as the sending of commercial communications.
This profile will be created using internal sources based on your browsing information, information obtained regarding your needs or preferences expressed by you during your relationship with Affinity, the activities in which you actually participate, and your various interactions and exchanges of information with our organisation. For example, the type of pet you have, pet food preferences, amongst other aspects.
You can find further information on how your personal data is processed for this purpose in section 4. Recipients of this Privacy Policy.
TYPE OF DATA
- Identifying data: Full name, user ID, sex.
- Contact details: Email address, postcode.
- Browsing data.
- Preferences and needs regarding your pets and products that may be useful to you for your type of pet.
- Browsing preferences and interests.
LEGAL BASIS
Affinity’s legitimate interest in accordance with the provisions of applicable data protection legislation, as the processing is carried out using internal sources and involves low-level profiling.
Affinity has carried out the analyses required by privacy regulations, which confirms that Affinity’s interest prevails over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the ‘Exercising Your Rights’ section of this Privacy Policy. Furthermore, you may, now or at any other time, express your wish not to be subject to this processing by exercising your right to object to it.
WEBSITE SEGMENTATION AND CUSTOMISATION VIA COOKIES
PURPOSE
To customise and segment the content of the Website through the use of cookies or similar technologies when these are agreed by the user via the related banner.
TYPE OF DATA
- Browsing data.
- Technical data.
- IP address.
LEGAL BASIS
The processing of your personal data is legitimised by the express consent you provide via the cookie banner made available to you by Affinity.
You may withdraw your consent at any time in accordance with the information provided in our Cookie Policy.
However, Affinity may process information obtained through cookies or similar technologies without your consent provided that such information is anonymised or aggregated and does not contain any data that could directly or indirectly identify you.
SURVEYS AND STUDIES
PURPOSE
To conduct surveys and market studies to find out your opinion on our products and services.
TYPE OF DATA
- Identifying details: Full name, user ID and sex.
- Contact information: Email address.
- Any personal data collected as a result of your responses to the surveys.
LEGAL BASIS
Affinity’s legitimate interest in improving its commercial offering.
Affinity has carried out the analyses required by privacy regulations, which confirm that Affinity’s interest prevails over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the ‘Exercising Your Rights’ section of this Privacy Policy. Furthermore, you may, at any time, inform of your wish not to be subject to this processing, thereby exercising your right to object to it.
3.2. Users participating in competitions and promotions
The following processing of personal data applies to data subjects participating in competitions and promotions managed by Affinity through any of its brands, platforms or websites:
COMPETITIONS, DRAWS AND PROMOTIONS
PURPOSE
To enable and manage your participation in competitions, draws and/or promotions. This includes sending communications to inform winners and publishing the results on Affinity’s website and social media or other media, as well as providing information on matters directly related to such promotions, including all of the foregoing via electronic means.
TYPE OF DATA
Those requested on each personal data collection form and, as a minimum, the following:
- Identifying details: Full name and username.
- Contact information: Email address, postcode, postal address.
- Data specific to the competition, draw or promotion.
- Bank details, such as bank account number. (You will never be asked for bank account login details or transaction authorisation codes).
- Product details, such as the product’s EAN 13 barcode and the supermarket where the product was purchased.
LEGAL BASIS
The performance of the contractual relationship upon acceptance of the legal terms and conditions of the various contests, raffles and/or promotions.
PUBLICATION OF IMAGES SENT BY WINNERS TO AFFINITY
PURPOSE
The image that each winner sends to Affinity will be published if they send it upon being notified that they are a winner.
TYPE OF DATA
Image and name of each winner
LEGAL BASIS
The processing of your personal data is legitimised by the express consent you provide by replying to Affinity with the photograph.
You may withdraw your consent at any time.
SURVEYS AND STUDIES
PURPOSE
To conduct surveys and studies research to find out your opinion on our products and services.
TYPE OF DATA
- Identifying details: Full name, user ID, sex.
- Contact information: Email address.
- Any personal data collected as a result of your responses to the surveys.
LEGAL BASIS
Affinity’s legitimate interest in improving its commercial offering.
Affinity has carried out the analyses required by privacy regulations, which confirm that Affinity’s interest prevails over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the ‘Exercising Your Rights’ section of this Privacy Policy. Furthermore, you may, at any time, express your wish not to be subject to this processing by exercising your right to object to it.
3.3. Users of Affinity’s social media profiles
Affinity has active profiles on Facebook, Instagram, Twitter, YouTube and TikTok; the following processing of personal data applies to individuals who become data subjects of Affinity by virtue of being a member, follower or participant of these profiles:
REGISTRATION/SUBSCRIPTION TO AFFINITY’S OFFICIAL USER PAGES AND PROFILES ON SOCIAL MEDIA
PURPOSE
To manage interactions between you and Affinity using the information you provide on social media platforms where Affinity has an active profile. This includes gathering your opinions and feedback, and keeping you updated on activities, news, special offers, promotions and competitions relating to Affinity’s products, through Affinity’s publication of such information on these profiles.
TYPE OF DATA
The personal data permitted by the privacy policy of the social media platform on which you have an account/user profile, as well as the privacy settings you have as a user of that platform. This data depends on your own privacy settings on the social media platform and the privacy policy of that platform.
LEGAL BASIS
Affinity’s legitimate interest in improving its commercial offering.
Affinity will process this personal data in compliance with the obligations arising from your status as a registered user on the social media platform and the terms of use of that platform.
SURVEYS AND STUDIES
PURPOSE
To conduct surveys and market studies to find out your opinion on our products and services.
TYPE OF DATA
- Identifying details: Full name, user ID, sex.
- Contact information: Email address.
LEGAL BASIS
Affinity’s legitimate interest in improving its commercial offering.
Affinity has carried out the analyses required by privacy regulations, which confirm that Affinity’s interest prevails over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the ‘Exercising Your Rights’ section of this Privacy Policy. Furthermore, you may, at any time, express your wish not to be subject to this processing by exercising your right to object to it.
COMPETITIONS, DRAWS AND PROMOTIONS ON SOCIAL MEDIA
PURPOSE
To enable and manage your participation in competitions, draws and/or promotions. This includes sending communications to inform winners, publishing the names of winners on Affinity’s website and social media or other media, as well as providing information on matters directly related to such promotions, including all of the foregoing via electronic means.
TYPE OF DATA
Those requested on each personal data collection form and, as a minimum, the following:
- Identifying details: Full name and username.
- Contact information: Email address, postcode, postal address.
- Data specific to the competition, draw or promotion.
- Bank details, such as bank account number. (You will never be asked for bank account login details or transaction authorisation codes).
- Product details, such as the product’s EAN 13 barcode and the supermarket where the product was purchased.
LEGAL BASIS
The performance of the contractual relationship upon acceptance of the legal terms and conditions of the various competitions, prize draws and/or promotions.
PUBLICATION OF IMAGES SENT BY WINNERS TO AFFINITY
PURPOSE
The image that each prize winner sends to Affinity will be published, provided they send it to Affinity once they have been notified that they are the winner.
TYPE OF DATA
Image of each winner.
LEGAL BASIS
The processing of your personal data is legitimised by the express consent you provide by sending a reply message to Affinity with the photograph.
You may withdraw your consent at any time.
COMMERCIAL COMMUNICATIONS
PURPOSE
To carry out advertising campaigns regarding Affinity’s products, services, activities, news, offers and promotions on social media platforms where Affinity has an active profile, in accordance with the provisions of section 4. Recipients in relation to the creation of custom audiences and Lookalike audiences.
TYPE OF DATA
- Identifying data: First name, surname, username, gender.
- If you are a registered user:
- Contact details: email address, postcode.
- Consumption and browsing habits.
LEGAL BASIS
Affinity’s legitimate interest arising from the contractual relationship established when you register on the social media platform of which you are a user and follower of Affinity, thereby maintaining a prior and direct relationship, which allows us to send you promotional information regarding Affinity’s products and services that are related to your interests. You may object now or at any other time to receiving these promotional campaigns via the tools made available to you by the owners of the social networks on which you have created a profile, or via the email addresses indicated in the ‘Exercising Your Rights’ section of this Privacy Policy.
For further information on data processing by social media platform operators and how you can opt out, please consult their privacy policies:
- Facebook: https://www.facebook.com/privacy/explanation
- Instagram: https://help.instagram.com/519522125107875
- Twitter: https://twitter.com/es/privacy
- YouTube: https://policies.google.com/privacy?hl=es&gl=de
- TikTok: https://www.tiktok.com/legal/page/row/privacy-policy/es
You can opt out of interest-based advertising from Facebook, Google or other companies via the following link: https://optout.aboutads.info/ or by adjusting the settings on your browser or mobile device.
Affinity has carried out the analyses required by privacy regulations, which confirm that Affinity’s interests take precedence over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses listed in the ‘Exercising Your Rights’ section of this Privacy Policy.
In the event that the promotional campaign is carried out via Facebook or any of the social media platforms owned by Meta Platforms Inc. (formerly known as Facebook Inc.), Affinity may act as a joint controller together with FACEBOOK IRELAND LTD. (or equivalent company name), with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 (Ireland) (hereinafter, “Facebook”) for those processing operations covered by the Facebook Addendum for Data Controllers, available at https://www.facebook.com/legal/controller_addendum
Affinity and Facebook have entered into the relevant data controller agreement to determine their respective responsibilities regarding compliance with the obligations set out in data protection regulations in relation to joint processing (as specified in the applicable Product Terms).
For further information on data processing by Facebook, please refer to Facebook’s Data Policy at the following link: https://www.facebook.com/about/privacy
We also inform you that we cannot be held responsible for the processing of personal data carried out by Facebook; such processing is carried out in accordance with the applicable Product Terms. You can find further information on how Facebook processes your personal data, including the types of data, purposes, and legal bases on which Facebook relies, in Facebook’s Data Policy. In this regard, Affinity shall only be responsible for its own data processing activities, as described below.
As regards the exercise of rights, Affinity and Facebook have agreed that, between the Parties, Facebook is responsible for enabling you to exercise your rights in accordance with the above in relation to the personal data that Facebook stores following joint processing.
If you wish to exercise the aforementioned rights with Facebook, you can find further information on how to exercise your rights against that entity in Facebook’s Data Policy at https://www.facebook.com/about/privacy
3.4. All categories of data subjects covered by this Privacy Policy
The following processing of personal data applies to all individuals who become data subjects of Affinity, regardless of the category of data subject to which they belong:
PETITIONS, QUERIES, COMPLAINTS
PURPOSE
To respond to petitions, suggestions, queries or complaints via Affinity’s customer service in the “Contact” section of the Website, or via other channels.
TYPE OF DATA
Those requested in each personal data collection form and, as a minimum, the following:
- Identifying details: Full name and username.
- Contact informations: Email address.
- Data relating to the request or enquiry provided by the user.
LEGAL BASIS
Where complaint forms are used, this will be based on the legal obligation in accordance with consumer and user protection regulations.
In the case of other petitions or complaints, this is based on theexisting contractual or pre-contractual relationship between the user and Affinity in providing the Customer care service.
STATISTICAL STUDIES
PURPOSE
To carry out statistical studies on the use of the Website and the reception of Affinity’s products and services.
TYPE OF DATA
- Browsing data.
- Technical data.
- IP address.
LEGAL BASIS
Affinity’s legitimate interest in improving its features and the service provided.
The data controller has carried out the analyses required by privacy regulations, confirming that Affinity’s interest prevails over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the ‘Exercising Your Rights’ section of this Privacy Policy.
LEGAL OBLIGATIONS
PURPOSE
To comply with our legal obligations in civil, commercial, tax and accounting matters, and in relation to compliance with personal data protection regulations, amongst others that may apply.
TYPES OF DATA
- Any personal data you provide to us and that is generated during the course of our relationship.
LEGAL BASIS
To comply with a legal obligation.
We may also process any additional data that you provide to us or that is generated during the course of your relationship with Affinity for the purposes set out above.
4. Recipients
Your personal data may be disclosed to the following recipients for the reasons explained below:
RECIPIENT
PURPOSE
LEGAL BASIS
Public authorities,
courts and tribunals,
security forces and bodies
To comply with the legal obligations Affinity is subject to in the performance of its activity and in the cases provided for by law.
To comply with a legal obligation.
Forwarders
To deliver prizes or products resulting from promotions run by Affinity for which you have duly registered.
The performance of the contractualrelationship upon acceptance of the terms and conditions of the various competitions, draws and promotions. As well as the performance of obligations arising from any type of contractual relationship maintained.
Service providers
Third parties acting as service providers may have access to your personal data in order to provide the services and/or fulfil the obligations arising from the legal relationships between those third parties and Affinity in the context of the provision of contracted services. In any event, Affinity has entered into the relevant confidentiality and data protection agreements with these providers, in full compliance with the provisions of current data protection legislation.
The performance of the contractual relationship between you and Affinity
Social network service providers and others
Facebook Ireland Ltd.: Affinity has contracted the services of Facebook Ireland Ltd, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter “Facebook”), for the provision of online marketing and advertising services, amongst others. Facebook acts as a data processor for the personal data processed for the creation of audiences via the tool known as Custom Audiences. You can access the legal terms and conditions regarding the Custom Audiences service via the following link: https://www.facebook.com/legal/terms/customaudience. The purpose of the Custom Audiences service is to create audiences amongst Facebook users based on Affinity’s customer lists, which Affinity has provided to Facebook in a fully anonymised form. Facebook guarantees that it will not be able to identify the individuals comprising a customer list used to generate a custom audience. Therefore, personal data protection regulations do not apply to this processing.
Furthermore, Affinity uses Facebook’s Lookalike Audience service, which utilises data collected through Facebook’s custom audiences to display adverts to Users whose behaviour is similar to that of Users already included in a custom audience list, based on their previous use of this Application or interaction with relevant content across Facebook’s various applications and services. Based on this data, personalised adverts will be shown to users suggested by Facebook’s Lookalike Audience.
Affinity and Facebook have entered into the relevant agreements for the processing of personal data in accordance with the provisions of the GDPR. For further information on the processing of personal data carried out by Facebook on behalf of Affinity, please visit the following link: https://www.facebook.com/legal/terms/dataprocessing.
You can also find out about the processing of personal data carried out by Facebook through custom audiences via the following link: https://www.facebook.com/privacy/explanation.
You can opt out of the use of these types of technologies and the receipt of adverts via Facebook via the following link: https://www.facebook.com/settings?tab=ads; however, you can also choose not to receive interest-based adverts from either Facebook or other companies via the following link: https://optout.aboutads.info/o or by configuring your own browser or mobile device.
Google Ireland Limited: Affinity has contracted the services of Google Ireland Ltd, with registered office at Gordon House, Barrow Street, Dublin 4, Ireland, (hereinafter “Google”), for the provision of online marketing and advertising services, amongst others. Google acts as the data processor for personal data processed through Google Analytics services and, furthermore, for the creation of audiences using the tool known as Customer Match (segmentation by customer list). You can find out how the Customer Match service works via the following link: https://support.google.com/google-ads/answer/6379332?hl=es. The purpose of the Customer Match service is to create audiences amongst Google users based on Affinity’s customer lists, which Affinity has provided to Google in a fully anonymised form. Google guarantees that it will not be able to identify the individuals included in a customer list used to generate a custom audience. Therefore, personal data protection regulations do not apply to this processing.
Furthermore, Affinity and Google have entered into the relevant agreements for the processing of personal data in accordance with the provisions of the GDPR. For further information on the processing of personal data carried out by Google on behalf of Affinity, please visit the following link: https://business.safety.google/adsprocessorterms/.
You can also access further information on the processing of personal data carried out by Google in the Customer Match service via the following link: https://support.google.com/google-ads/answer/6334160?hl=es.
You can manage and opt out of the use of these types of technologies and the receipt of adverts via GooAffinity’s legitimate interest arising from the contractual relationship established when you register on the social network of which you are a user, in order to target you with Affinity products and services that are related to your interests.
gle at the following link: https://policies.google.com/technologies/partner-sites;.
Affinity’s legitimate interest arising from the contractual relationship established when you register on the social network of which you are a user, in order to target you with Affinity products and services that are related to your interests.
You may opt out of receiving these promotional campaigns using the tools provided by the owners of the social media platforms on which you have created a profile.
Account auditing firms
To comply with the legal audit obligations to which Affinity is subject by virtue of its business activities.
To comply with a legal obligation.
Companies that partner with Affinity
To prevent fraud in the running of promotions and contests in compliance with the legal terms and conditions of such promotions or competitions.
Affinity’s legitimate interest in ensuring that its promotional activities comply with the established legal framework.
Other companies belonging to Affinity
We may share the data with the other companies within Affinity for internal organisational purposes.
Affinity’s legitimate interest, as recognised by the applicable data protection regulations.
Affinity will not share your data with other third parties without first obtaining your consent, except in cases where it is necessary to comply with the legal or contractual obligations to which Affinity is subject at any given time due to its nature and activity.
Should Affinity carry out any further transfers of personal data in the future, you will be informed in due course.
5. International data transfers
Affinity may contrate the services of providers located in countries outside the European Economic Area, based on adequacy decisions by the European Commission. In this case, the country is deemed to have regulations equivalent to those in Europe. Should Affinity need to contract the services of providers located in countries that do not have regulations equivalent to those in Europe, such engagement will include all the guarantees and safeguards required by law to protect your privacy, following verification of the legislation of the destination country.
Such safeguards may consist of the application of contractual clauses and additional guarantees thereto, in accordance with the regulations of each destination country, or of binding corporate rules approved by the data protection authorities. We also inform you that the regulations allow us to send your data to such countries, if necessary to fulfil our obligations arising from the service you have sought.
The following companies will have access to the personal information necessary to perform their duties as data processors, but may not use it for any other purpose. Furthermore, they must process personal information in accordance with this Privacy Policy and applicable data protection legislation.
- Google Cloud Platform and Google Marketing Platform: web analytics services provided by Google, Inc., a Delaware company with its principal office at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Cloud Platform and Google Marketing Platform use “cookies”, which are text files placed on your computer, to help Affinity analyse how users use the website. The information generated by the cookie about your use of Affinity (including your IP address) will be transmitted to and stored by Google on servers in the United States.
- Salesforce: a customer relationship management (“CRM”) service provided by Salesforce, Inc., a California company with its principal office at Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, United States (“Salesforce”). The information generated by the Salesforce CRM regarding your use of Affinity may be transmitted directly to and stored by Salesforce on servers in the United States.
For further information regarding your privacy safeguards, or the destination countries where we need to transfer your data to fulfil our contractual obligations with you, please contact our Data Protection Committee using the contact details provided in the “Exercising your rights” section of this Privacy Policy.
6. Automated decisions – making
In some cases, our use of your personal information may result in automated decision – making (including profiling) that has legal or similarly significant effects on you.
Automated decision – making means that a decision concerning you is made automatically on the basis of a computerised decision (using software algorithms), without human review. For example, we use automated decision – making to personalise the sending of commercial communications based on the responses you provide or your behaviour on Affinity. We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making, including controls on the parameters used for decision-making to prevent discriminatory outcomes.
When we make an automated decision – making about you, you have the right to challenge the decision, to express your point of view and to request a human review of it. You may exercise this right by contacting us using the contact details provided in the ‘Exercising your rights’ section.
7. Retention period of your data
We will only retain your personal data for as long as we need it, for the purposes for which we collected it and to comply with legal, financial, commercial or reporting requirements. In some circumstances, we may anonymise personal data so that it is no longer identifiable and we can continue to use it. When we no longer need the personal data, we will securely delete or destroy it.
Affinity will retain the data collected to carry out the aforementioned purposes for the duration of your relationship with Affinity and, even thereafter, until any legal liabilities arising therefrom have expired.
8. EXERCISING YOUR RIGHTS
You may exercise, in relation to the data collected, your rights of access, rectification, objection, erasure, restriction and data portability, in accordance with data protection regulations.
These rights may be exercised by sending a message:
- To the email address gdpr@affinity-petcare.com with the subject line “Data protection”; or
- Via any posat means, using a method that provides proof of receipt by Affinity, addressed to the following address: Affinity Petcare, S.A., Plaza Europa, 54-56, L’Hospitalet de Llobregat, 08902, Barcelona, Spain, indicating “Data Protection” on the envelope.
Furthermore, if you consider that the processing of your personal data breaches the law or your privacy rights, you may lodge a complaint:
- via the postal and email addresses given above, or
- to the Spanish Data Protection Authority, via its website or by post.
9. CHANGES, MODIFICATIONS OR UPDATES
Affinity reserves the right to review this Privacy Policy at any time it deems appropriate, in order to reflect regulatory changes, best practices or to update personal data processing activities. You will be informed of such updates in accordance with regulatory requirements, should your rights be significantly affected as a result of such a modification or update