a. When commercially practical, VETgirl will obtain your consent to collect, use or disclose personal information (including Personally Identifiable Information and Non-Personal Data, as those terms are defined below). VETgirl may collect, use or disclose personal information without your consent:
(i) when the collection, use or disclosure of personal information is permitted or required by law;
(ii) in an emergency that threatens an individual’s life, health, or personal security;
(iii) when the personal information is available from a public source;
(iv) when VETgirl or its affiliates require legal advice from an attorney;
(v) for the purposes of collecting a debt;
(vi) to protect VETgirl and its affiliates from fraud;
(vii) to create, develop, operate, deliver, and improve our products, services, content and advertising; or,
(viii) to investigate an anticipated breach of an agreement or a contravention of law.
b. Consent may be provided orally, in writing, electronically, through an authorized representative or affiliate, or it may be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and you voluntarily provide personal information for that purpose.
c. Consent may also be implied when you are given notice and a reasonable opportunity to opt-out of providing personal information being used for mail-outs, marketing, or other VETgirl functions, and you do not opt-out.
d. You may have a right under the European Union General Data Protection Regulation 2016/679 of 2018 (“GDPR”), as amended, or similar laws of other jurisdictions, as applicable, to: (i) withdraw consent; (ii) request your Personally Identifiable Information (defined below) previously collected by VETgirl; or (iii) pause any data processing relating to your Personally Identifiable Information in the event you object to it. If you are subject to GDPR (if you are a resident of a jurisdiction subject to GDPR protections and are also using the Sites within a jurisdiction subject to GDPR protections) and would like to exercise any of the options listed in this subsection, please contact VETgirl’s Privacy Officer.
e. In the event you are a resident of a jurisdiction subject to GDPR protections and are also using the Sites within a jurisdiction subject to GDPR protections, VETgirl will ensure your consent is consistently accurate with your most up-to-date information and the purpose for which the data is being used. If either of those changes, VETgirl will make a new request for your consent.
f. California Consumer Privacy Act.
These disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act (“CPRA”) may provide additional rights to know, delete and opt out, and may require some applicable businesses collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise. By voluntarily providing notice of and explaining some of these rights, VETgirl in no way acknowledges or consents to being subject to either the CCPA or CPRA, and expressly disclaims applicability of CCPA or CPRA to its business based on exemptions to both laws.
(i) Notice of Collection and Non-Collection.
(a) VETgirl may collect or may have collected information corresponding to the following categories of information enumerated in the CCPA:
Identifiers, including name, address, email address, account name, Social Security Number, IP address – and an ID number assigned to your account.
Customer records, including phone number, billing address, credit or debit card information, employment or education information.
Demographic information, such as your age or gender. This category includes pieces of Personal Information that also qualify as protected classification characteristics under other pre-existing California or federal laws.
Analytics and Advertising, including purchases and engagement with the Services.
Internet activity, including history of visiting and interacting with our Service, browser type, browser language and other information collected automatically.
Geolocation data, including location enabled services such as Wi-Fi and GPS.
Inferences, including information about your interests and preferences.
(b) VETgirl will not intentionally collect the following categories of information enumerated in the CRPA:
Sensitive Personal Information, including biometric data, social security numbers, driver’s license numbers, geolocation data, race, ethnicity, religious or philosophical beliefs, union membership, content of nonpublic communications, genetic data, or sex life or sexual orientation information.
VETgirl does not generally sell information. However, to the extent VETgirl “sells” information under the CCPA, if required, we will comply with applicable law as to such activity.
VETgirl may disclose the following categories of information for commercial purposes: Commercial Information; Demographic Data; Location Data; Identifiers; Inferences; and Internet activity.
We may use and/or partner with different types of entities to assist with our daily operations and manage our Service.
(ii) Right to Know and Delete. If you are a California resident and the CCPA or CRPA is or becomes applicable to VETgirl, you may have the right to know certain information about our data practices in the preceding 12 months. In such circumstances, you may request the following from us:
The categories of Personal Information we have collected about you;
The categories of sources from which the Personal Information was collected;
The categories of Personal Information about you we disclosed for a business purpose or sold;
The categories of third parties to whom the Personal Information was disclosed or sold;
The business or commercial purpose for collecting or selling the Personal Information; and
The specific pieces of Personal Information we have collected about you.
In addition, you may have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and we may have legal grounds for keeping such data.
To exercise any of these rights, please submit a request to VETgirl’s Privacy Officer at [email protected]. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity or the CCPA or CPRA are not applicable to VETgirl in the context of your requests, we may deny your requests.
(iii) Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
(iv) Right to Non-Discrimination. You have the right to non-discriminatory treatment by us, should you choose to exercise any of your rights.
(v) Shine the Light. Clients who are residents of California may request: a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes, and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please contact us at [email protected]. Requests must include “California Shine the Light Request” in the subject line and include your name, street address, city, state, and ZIP code. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please note that VETgirl is not required to respond to requests made by means other than through the contact information provided herein.
g. We may decline to process any requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which we are not otherwise required to respond by applicable law. We may also decline aspects of deletion or data access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and/or security purposes.
4. Information VETgirl May Collect.
a. Personally Identifiable Information: We may collect information that identifies you (“Personally Identifiable Information”) when you contact us, or otherwise interact with VETgirl, including, but not limited to, applying for any membership or enrollment in any VETgirl program or continuing education, registering for a VETgirl event or program, or purchasing VETgirl products or services on the Sites. Types of Personally Identifiable Information collected may include without limitation your name, address, phone number, birth date, occupation/job title, billing and delivery information, email address, credit card, or other financial account information.
b. Non-Personal Data: As you interact with our Sites, we may collect information about your browsing history or certain other information that is not Personally Identifiable Information through your use of and visits to the Sites and our use of a variety of technologies, including, but not limited to, cookies (explained in detail below), tags, beacons, Internet Protocol (IP) address, and other tools. The types of Non-Personal Data collected on our Sites, and other tools as VETgirl may add from time to time, include, but are not limited to: the search terms you used, new or returning user, browser information, computer type, operating system, internet service providers, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, and ads viewed. Additionally, cookies, tags and other tools placed by third parties may collect other information about you and your visits to the Sites and elsewhere on the Internet (collectively, all of the foregoing data is referred to as the “Non-Personal Data”).
5. How VETgirl May Use Personally Identifiable Information.
a. Once collected, we may use your Personally Identifiable Information in a variety of ways including, but not limited to:
(i) Provide service communications such as bill reminders, order confirmations, program registrations, and customer service messages;
(ii) Respond to your emails or online requests for products, services, or information;
(iii) Deliver or process surveys;
(iv) Personalize and improve the usability of the Sites;
(v) Fulfill or deliver VETgirl products and services;
(vi) Tailor content on the Sites, advertising and marketing;
(vii) Share with third parties as required by law;
(viii) Share your email address as permitted under the VETgirl “Sharing Your Email Address” policy as described below;
b. Sharing Your Personally Identifiable Information to Perform Business Functions. When VETgirl fulfills service requests initiated by you, we may share your Personally Identifiable Information with certain third parties to fulfill the requests or share such information with service providers that perform business functions for us. VETgirl may occasionally hire other companies to provide limited services on our behalf including, but not limited to, packaging, mailing and delivering promotional offers, answering customer questions about products or services, sending postal mail and processing registrations. In such cases, VETgirl may share your Personally Identifiable Information to the extent permitted by applicable law.
c. Sharing Your Personally Identifiable Information When Legally Necessary or to Protect VETgirl’s Interests. VETgirl may disclose your Personally Identifiable Information if required to do so by law or in the good-faith belief that such action is necessary to: (i) conform to legal requirements or comply with legal process served on VETgirl; (ii) protect and defend the rights or property of VETgirl; or (iii) protect the personal safety of VETgirl personnel or members of the public in appropriate circumstances. In addition, if VETgirl and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if VETgirl undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise, information may be transferred as part of that transaction or change.
d. Sharing Your Email Address. Your email address will only be used by VETgirl and its entities and will not be sold to anyone outside VETgirl. As such, VETgirl will refrain from sharing email addresses to unrelated third parties. VETgirl may share your email address with third parties: (i) to enable VETgirl to take security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data, and (ii) to perform certain services on our behalf, such as packaging, mailing and delivering products and processing event registrations and to respond to your service requests.
e. You can manage your profile and email preferences, including opting out of email either online or by contacting us.
6. How VETgirl May Use Non-Personal Data.
a. We may collect Non-Personal Data to improve the usability of our Sites/services and for other business purposes. We may share the Non-Personal Data we collect with third parties or permit third parties to place tools like cookies, tags and web beacons, to collect additional Non-Personal Data when you browse our Sites. VETgirl or other third-party companies may then use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). However, VETgirl will refrain from sharing any Personally Identifiable Information with third parties with whom we share your Non-Personal Data.
b. Use of Google Analytics®, Constant Contact®, GoToWebcast/ GoToWebinar®, and/or similar services. We may implement Google Analytics features based on Display Advertising (Google Analytics Demographics and Interest Reporting). You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings. In addition, you can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. We will use the data provided by Google Analytics Demographics and Interest Reporting to develop the site and content around our users’ interests and to help refine our advertising strategies.
c. How You Can Manage Collection of Non-Personal Data. Third-party advertising companies may collect data about your visit to our Sites and others; this is referred to as Online Behavioral Advertising. You may opt out from this collection and use of data by companies participating in the Digital Advertising Alliance (“DAA”) on the “Opt Out from Online Behavioral Advertising” website.
d. Third-Party Requests, Use or Analysis of Data. (i) We may disclose your information upon government demand in the form of a court order or subpoena, when otherwise required by law, to enforce the policies herein, or to protect VETgirl property or safety. (ii) We may share your information to prevent illegal use of our products or to defend VETgirl against any third-party claims. (iii) Your information may be transferred to a third party in whole or in part as part of a merger, acquisition, or similar transfer or assignment of assets. (iv) We may transfer your information to third-party service providers to conduct or improve VETgirl business or Sites, or for any business purpose, including, but not limited to credit card processing, shipping, data management, email distribution, marketing research, information analysis and promotions management.
7. Information Security.
a. VETgirl implements security measures as commercially reasonable to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data, and restricts access to personal information to certain companies who may need to know that information in order to operate, develop, or improve services.
b. Although VETgirl uses commercially reasonable security measures, data transmission over the Internet can never be guaranteed to be absolutely secure. VETgirl cannot guarantee or warrant the security of any information transmitted by you, or to or from our online products or services.
c. In the event of an information security breach relating to the VETgirl Sites and the breach involves your Personally Identifiable Information, VETgirl will notify you as quickly as is commercially reasonable, and, if applicable, will notify applicable local data protection authorities, as that term is defined in GDPR, of the breach within seventy-two (72) hours of discovery.
8. Your Password You are responsible for all actions taken with your user name and password. Do not share your user name and password with anyone else, as it is only for you. Sharing your user name or password will automatically give VETgirl the right to deactivate your account; you will not receive any refund and no continuing education certificates will be rewarded to you. For your protection, do not disclose your username or password to anyone.
a. The VETgirl website uses “cookies” to help you personalize your online experience. A cookie is a small piece of data in the form of a text file that is sent from a Web page server and placed on your hard drive. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
b. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to track your activities on a website (e.g., pages visited, links clicked on, etc.), and to record information about your use of the website so when you return to the site, customized features can be provided. For example, when you sign in to the Sites, a cookie helps the VETgirl Sites recall your specific information on subsequent visits. This simplifies the process of recording your personal information for continuing education access.
c. You have the ability to accept or decline/disable cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline or disable cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the VETgirl continuing education services or websites you visit.
10. Children’s Privacy.
a. Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), as amended. COPPA and its accompanying regulations protect the privacy of children using the Internet. VETgirl does not knowingly contact or collect personal information from children under 13. The VETgirl website is only directed toward adult users and is not intended to solicit information of any kind from children under 13. Similarly, VETgirl complies with the provisions in GDPR regarding privacy of children and does not solicit information of any kind from children under 16 in jurisdictions subject to GDPR.
b. It is possible that by fraud or deception we may receive information pertaining to children under 13, or equivalent minimum age depending on jurisdiction (under 16 in the case of jurisdictions subject to GDPR, for example). If we are notified of this, as soon as we verify the information, we will immediately obtain parental consent or otherwise delete the information from our servers. If you want to notify us of our receipt of information by children under 13, or equivalent minimum age depending on jurisdiction, please do so by sending an e-mail to VETgirl’s Privacy Officer at: [email protected].
11. Social Media and Third-Party Websites. VETgirl uses social media tools and websites to interact with its customers and resource partners (e.g., Facebook, Twitter, Instagram, Tumblr, Pinterest, LinkedIn, etc.). Social media websites are used to publicize VETgirl programs and services and engage with members of the public. VETgirl does not use third party websites to solicit and collect personal information from individuals. Any personal information collected by a third-party website, with the exception of Apple Inc.’s App Store and Google LLC’s Google Play Store (where VETgirl Mobile Apps are or may in the future be sold), will not be transmitted to VETgirl unless required for law enforcement purposes or as otherwise permitted by law. VETgirl’s privacy and other web policies do not apply to these third-party sites and we encourage you to read the policies of the third-party site when deciding whether to use it.
NOTE: Please abide by state and federal regulations when it comes to using technology. Please don’t text, stream, e-mail, or surf while driving, running, or doing anything that can jeopardize you or anyone else! Be safe and smart.
© 2021 VETgirl. All rights reserved.
This document was last updated on May 24, 2021
 Including, but not limited to, “LGPD” – Brazil’s Lei Geral de Proteção de Dados data privacy law, “POPI” – South Africa’s act on Protection of personal information, and “CSL” – China’s Cyber Security Law of 2017.