Privacy Policy

Last Updated: Nov 14th 2024

We are Crumb Pet LTD ("Crumb", “we”, “us” or “our”). Our company details are set out at the end of this privacy policy (this “Policy”). We are your “Data Controller” for the purposes of data protection laws, such as the General Data Protection Regulation (GDPR). This means that we determine how your information is handled concerning your use of our website and services. In this Policy, we seek to explain in the most possible way how we (and carefully selected third parties we work with) collect and use your information. Please read this Policy carefully and make sure you’re comfortable with the content. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information based on the following legal grounds/bases: - Where we need to perform the contract we are about to enter into or have entered into with you. - Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests. - Where we need to comply with a legal or regulatory obligation. - Where you have given explicit consent to our use of the information, in which case, you’ll have the right to withdraw your consent at any time by reaching out to us at [email protected]. By accessing our website, submitting information and using our services, you acknowledge and agree to our Policy (and Terms and Conditions). If you disagree with this Policy, we ask that you refrain from using our services.

1. What is Personal Information?

According to data protection laws, “personal information” refers to any information that can be used to directly identify a natural individual. This may include a name, email address, physical address and photo, and in locations such as the United States, the device properties (IP Address, browser type, geolocation, etc.) may be considered as personal information. Any information collected that is not personal is regarded as anonymised, de-identified, or aggregated information.

2. What Information We Collect

We collect the following categories of personal and non-personal information when you use our website and subscribe to our services: a. Registration information. You may provide us with your name, email address and login credentials when you create an account. You may provide additional information when you complete your profile. b. Pet information. You may provide us with information about your pet, including the name, breed, age, health information and owner’s physical address. c. Location information. We may receive the precise location of your pet when their pet’s tag is scanned. d. Payment and billing information. You may provide us with your payment method and billing information, including your card details and registered address when you make payments, including tag shipping fees and subscriptions. We use Checkout.com and Worldpay to process payments securely. e. Contact information. This may include your email address and phone number. You may share this information when you create an account, reach out to us for support, subscribe to our promotional emails and provide your shipping address. f. Shipping information. You may submit your shipping address to receive a tag for your pet. Your shipping information may include your physical address, including street, city, country, and postal/zip code. g. Media and visual information. You may provide us with additional information through visuals, voice and video. This may include when you submit files to us or interact with a vet through our vet video service. h. Cookie and analytics information. We may use cookies, pixels, beacons and similar tracking technologies and third-party analytic tools (such as Google Analytics) to automatically gather certain information about your device and interaction with our website, app and content. The information gathered automatically may include your device IP Address, browser type, geolocation, operating system, timezone, your access time, referring website, features accessed, duration of access, errors encountered and similar analytics, usage and log information. Please review our Cookie Policy to learn more about cookies, similar tracking technologies and third-party tracking tools. i. Transaction information. Our third-party payment processor may provide us with information relating to your transactions, including subscription and tag shipping payments, date of payment, payment method used and similar information. As already highlighted, we may collect the above information when you provide them through forms on our website or app; when we use cookies and similar tools to automatically gather them; and when third parties, such as our payment processor and shipping third parties provide us with additional information. Please note that you are not under any obligation to submit any information through our forms or other means when you use our services. However, you are aware that we may be unable to provide our services without access to your information.

3. Why We Collect Your Information

We collect your information for the following reasons: - We collect most information to provide our services. This may include primarily to help locate and reunite pets with their owners. - We collect account and profile information to manage your account, pet profiles and related services. - To personalise your experience on our services, including managing your privacy settings for you and your pet profile. - We collect analytics to help us understand how users interact with our website, app and content. This information helps us to improve functionality, website performance and optimise our services. - We may collect device properties to enforce our Terms and Conditions, comply with the law and prevent illegal activities, such as fraud. - We collect your shipping information to deliver your ordered tag. - We collect payment method information to process your payments, including shipping fees and periodic subscriptions. - We collect transaction information to carry out our legal obligations, including keeping records for disputes, tax and accounting purposes. - We collect your email address and phone number to send notifications about activities relating to your pet, send promotional content and emails (where you consent), authenticate your account and provide general support services.

4. Third-Party Access To Your Information

The following third parties may access your information for the purposes described: - Our group companies. We may share personal information within the Crumb group of companies, including branches, regional and head office offices (if applicable). Such disclosure may be with respect to internal analytics, support services and development. - Third-party service providers (data processors). We may share personal information with the third parties we hire to handle certain services on our behalf. This may include shipping companies for tag delivery, payment processors for processing shipping fees and subscriptions and marketing third parties for promotional emails and adverts. - We ensure these parties use your information for the purposes defined by entering a Data Processing Addendum (DPA) agreement and other relevant mechanisms that prevent them from using your information for any other purpose. - Public individuals. Subject to your privacy settings, information such as your physical address and pet profile will be available to anyone who scans the QR code attached to your pet. - Law enforcement. We may share your information with competent authorities (statutory bodies, regulatory authorities, authorised bodies who have a role laid out by law) in response to legal requests, such as a court order, subpoena and other legal summonses. - Other organisations. Where we are legally obligated to disclose your personal information (such as requests made in the prevention and detection of crime) or where the disclosure is necessary to protect the property, rights and safety of Crumb and our staff or to comply with any law, regulation or governmental or judicial warrant, rule, order or subpoena - Entities involved in a business transfer. We may share your information with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your information in the same way as set out in this Policy. - Other companies in product testing. Where we are trialling products and services which we consider may improve our offering to customers and/or our business processes, we may share information about you with the concerned entities. - Other third parties at your consent. In other instances, we may share information about you with third parties where you have given your express consent or where we reasonably believe the third party is acting on your behalf

5. Marketing Practices

We may engage in marketing and advertising practices that relies on the information we have gathered about you through our services a. Promotional Emails (email marketing). Where you consent and subscribe to receive promotional emails to your email address, we will send periodic emails containing promotions, deals and offers we think match your interest. You will continue to receive promotional emails (marketing emails) until you exercise your rights to opt out. You can always opt out of promotional emails by using the “unsubscribe” link at the bottom of any email you receive from us. We use Fortifi for our email marketing practices. b. SMS Marketing. By providing your phone number when signing up to use our services, you consent to receive SMS notifications from Crumb, including promotional offers and service updates. This communication is optional, and you may opt out at any time by following the unsubscribe instructions in the message or by contacting us at [email protected]. Crumb complies with all applicable privacy laws; therefore, your phone number will be used solely for the purposes specified at the time of collection. c. Interest-Based Advertising (behavioural advertising). We may work with ad networks and marketing companies like Google Ads and Meta Ads (aka Facebook Ads). We may allow these parties to set cookies, pixels, beacons and similar tracking tools on our website to gather anonymous behaviour, and we may share aggregated, de-identified log and analytics information with them (for example, Google may use Google Analytics and Meta may use Meta Pixel). They may then combine this information with those they gathered about you across other websites, apps and services and use it to display relevant ads that are based on your behaviour and interest. For example, if you visit our website or other website related to pets, they may display our tag and pet services to you across their platform and other websites. You have the right to opt out of interest-based advertising since it involves using your behaviour on our website. This may include: - visiting Google’s Ad Settings to adjust your preference or opting out of personalised ads from Google by installing the Google Analytics Opt-out Browser Add-on on each browser you use; - adjusting Meta’s ad preference here; - visiting self-regulatory platforms such as NAI and DAA; - blocking analytics and marketing cookies.

6. How We Protect Your Information

- General. Crumb has security measures in place to protect your information against loss, misuse and alteration. Personal information provided to us is stored in secure facilities with access restricted to authorised personnel only. Although we make good faith efforts to store personal information we collect in a secure operating environment that is not accessible to unauthorised users, we cannot guarantee complete security - Secure Payments. If you choose to subscribe to our services, your payment card information is sent to us using SSL (Secure Socket Layer) encryption, an industry-standard method for protecting data as it travels over the Internet, or a similar encryption technology that may become accepted as an industry standard, or a better encryption method, in the future

7. The Retention of Your Information

Your information is collected and used for the reasons set out in this Policy and will not be stored for longer than necessary for those purposes. Generally, we store your information for no longer than the time you have an account with us. Once you request the deletion of your account and information, we take steps to delete it within 30 days (for example, unless you request that we remove your payment method as a subscribed member, we will retain it to facilitate your subscription payments). We may retain certain information, such as transactions for longer periods as required by law and to keep records for tax, accounting and dispute purposes. Information about your device and other analytics is de-identified and retained with us to satisfy our legitimate interest, including for research and marketing.

8. The International Transfer of Your Information

We operate our services in the UK and use your information in accordance with the GDPR law and any other laws that apply to your location. However, we may transfer personal information to some of our third-party service providers in locations that have little variations in privacy laws. In connection with such transfers, we rely on approved data transfer mechanisms by the European Commission (EC), which may include the following: - Adequacy decision. We may transfer data to countries that the EC has deemed to have adequate data protection laws. This means that we may transfer your data to such locations without putting anything in place. For example, we can transfer personal information from the EU/EEA/UK to Canada and vice versa without additional safeguards, as both regions have been recognised as having adequate data protection. - Standard Contractual Clauses (SCCs). For transfers to countries without an adequacy decision, we use Standard Contractual Clauses approved by the EC to ensure the data is protected - EU-US Privacy Shield. We also use some data processors who have the EU-US Privacy Shield certificate. For example, Google US has submitted to the EU-US Privacy Shield. - Other Safeguards. In certain cases, we may rely on additional safeguards, such as such third parties are bound by corporate rules; obtaining your explicit consent for the transfer; and de-identifying or aggregating such data before they are transferred. You have the right to request information on the safeguards we have implemented and copies of relevant transfer agreements by contacting us at [email protected].

9. Your Data Protection Rights

You have the following rights with respect to how we use your information: - Request access to your personal data (also known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Please contact us at [email protected]. - Request to correct your information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You can request to correct most of your information via your Crumb account profile area. For specific information, you may contact us at [email protected]. - Request the erasure of your information. You may request the deletion of any of your information by using the account deletion button in your profile (where provided). You may also reach out to us at [email protected]. Note that the deletion of your information is subject to our information retention policy as described above in section 7. - Request restriction of processing of your information. You can reach out to us at [email protected] to request that we restrict the processing of your information. This enables you to ask us to suspend the processing of your information in the following scenarios: (i) if you want us to establish the information’s accuracy; (ii) where our use of the information is unlawful but you do not want us to erase it; (iii) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it - Request the transfer of information to you or to a third party. Upon request at [email protected], we will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you - Withdraw consent at any time. As already highlighted, you have the right to withdraw your consent at any time where the processing of your information is based on your consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent - Right to complain. If you consider that the processing of any of your information is in breach of any applicable privacy laws, you have the right to submit a complaint to a supervisory authority in your jurisdiction. For example, UK users can report to the Information Commissioner’s Office; users in Canada can complain to the Office of the Privacy Commissioner of Canada; and US users can report to the Federal Trade Commission. - Right to object. You can object to the processing of your information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes as described in the marketing section above. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms - Opt out of the sale of personal information. We do not engage in the traditional practices of selling or sharing personal information for monetary consideration. However, our sharing of your behavioural and analytics information with ad networks in connection with marketing our services may be considered a sale of personal information for advertising purposes. You can opt out of such sale by using the cookie consent banner to opt out of advertising. Certain laws, such as Nevada law, give its residents the right to opt out of any future sale of their information to a third party for monetary consideration. You will not have to pay a fee to access your information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it

10. How We Respond To Do Not Track Signals

Our website does not respond to "Do Not Track" (DNT) signals from web browsers. DNT is a browser setting that allows users to communicate their preference not to be tracked across websites and services. However, because there is no industry-wide consensus on how to interpret or implement DNT signals, we do not alter our data collection or use practices when we receive such signals. For more information about DNT, please visit https://fpf.org/thank-you-for-visiting-allaboutdnt-com/

11. Children’s Privacy

Our website and services are not intended for use by individuals who cannot enter a legally binding contract. Accordingly, Crumb does not intentionally gather any personal information about individuals who are under the age of eighteen (18). If you are under eighteen (18) years of age or otherwise lack the capacity to enter into a binding contract, do not use our services. If we become aware that we have collected personal information from someone under 18 years of age, such information will be deleted immediately

12. Third Party Links and Services

We may provide links to third-party websites as a convenience to you (collectively, the “Third Party Websites”). Please exercise care when visiting any Third Party Websites. The Third Party Websites have separate and independent privacy policies, notices and terms of use which govern your use of such websites and their use of any information they collect. We recommend you read these policies carefully. Crumb expressly disclaims all liability for personal information you provide to any Third Party Websites

13. California Privacy Rights

If you are a California resident using our services, you are entitled to additional privacy rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). a. Your Rights under the CCPA/CPRA - Right to know. You have the right to request that we disclose the categories of personal information we collect, the sources from which we collect them, the business purposes for collecting or sharing them and the categories of third parties with whom Crumb has shared or sold them to. This applies to the past 12 calendar months. - Right to access. You may request a copy of the specific personal information we have collected about you over the past 12 calendar months - Right to opt-out of sale or sharing. As we participate in interest-based ads with information about your use of our services, you can opt out of such sharing by using the “Do Not Sell or Share My Personal Information” link on our website - Right to limit our use of sensitive personal information. If applicable, you can limit how we use your sensitive personal information. We provide additional security for information categorized as sensitive personal information, including de-identifying and anonymising it. - Right to non-discrimination. We will not discriminate against you for exercising your privacy rights. We will not deny you goods or services, charge you a different price, or provide a different level of service if you exercise these rights b. Categories of Personal Information We Collect In the past 12 months, we have collected the following categories of personal information about you: - Identifiers, such as your name, email address, postal address, phone number, location and unique device identifiers - Commercial information, such as your payment method, products paid for, purchase history, transaction information, billing address and payment information - Internet or network activity, including your browsing history, interaction with our website and device information (IP address, browser type, etc.) - Geolocation information, including your pet’s precise location when their tag is scanned. - Audio, visual and media, including photos, videos and files shared during vet consultation and general support. - Sensitive personal information, including your payment method information, transaction information and billing address. - Health information, including pet health details. - Inferences like your preferences, interests and behaviour based on interactions with our website We have collected the categories of information above directly from you (e.g., when you fill out your pet profile); automatically from your interactions with our website (e.g., via cookies and tracking technologies); and from third-party service providers such as our third-party payment processor c. Our Business Purposes for Collecting Personal Information We collect and use your personal information for the following business and commercial purposes: - To process transactions, deliver your tag and provide customer support - To improve, personalize and maintain our website and services - To communicate with you regarding your tag order, your pet and promotional offers - For marketing and advertising purposes, including displaying relevant ads - To detect and prevent fraud, protect the security of our website and comply with legal obligations - To perform analytics and improve user experience on our website d. Sharing and Selling of Personal Information In the past 12 months, we have disclosed certain categories of personal information for business purposes to third parties, including service providers and marketing partners. We “do not sell” your personal information for monetary consideration. However, some sharing for interest-based advertising may be considered a "sale" under the CCPA/CPRA definitions The categories of third parties with whom we have shared your personal information in the past 12 calendar months include (i) third-party service providers, (ii) advertising and analytics providers, and (iii) individuals who have scanned your pet tag

Changes to this Policy

We may modify this Policy from time to time to reflect changes in, or requirements of, the law or modifications or updates to our services. We will notify you if such change materially affects your rights under this Policy. Changes will not apply retrospectively and, unless the change is required immediately for legal reasons, notice of the modified terms will be provided a reasonable period prior to the changes taking effect. If you do not accept and agree to this Policy after any changes to this Policy, then you must stop using our services.

Crumb Contact Information

If you have any questions or comments, please contact us at [email protected] or at the address listed below: Crumb LLC d.b.a Crumb

256 Champan Road STE 105-4
Newark
Delaware
19702
United States