Privacy Policy

Last Updated and Effective: August 15, 2022 

We at the Pet Sustainability Coalition, a US-based 501(c)(3) (“PSC”, “us”, “our”, or “we”), are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your personal information, as well as how you can manage the personal information we collect. This Privacy Policy applies to your interactions with us or your use of or interactions with our website (www.petsustainability.org), social media pages, services, features, or other branded digital properties, either online or offline (collectively, our “Services”).

For the purposes of EU and UK privacy laws, PSC is the data controller of your personal data. 

By using our Services, you acknowledge the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Services. If you do not understand, or if you have questions about, this Privacy Policy, please contact us before using, or continuing to use, our Services.

We reserve the right to change our Privacy Policy from time to time by posting the changes here. If we choose to amend this Privacy Policy, we will revise the Last Updated date at the top of this Privacy Policy when we post the updated version. We may also provide you with notice by prominently posting on our website, via email or both, if we make any significant changes to this Privacy Policy. We may also highlight those changes at the top of this Privacy Policy and provide a prominent link to it for a reasonable length of time following the change. Your use of our Services after we have informed you in one of these ways that we made changes to our Privacy Policy will mean that you have accepted those changes.

Table of Contents

• TYPES OF INFORMATION WE COLLECT
• HOW WE USE PERSONAL INFORMATION
• WHY WE USE PERSONAL INFORMATION
• HOW WE SHARE PERSONAL INFORMATION
• HOW WE PROTECT PERSONAL INFORMATION
• INTERNATIONAL DATA TRANSFERS
• CHILDREN’S PRIVACY
• YOUR CALIFORNIA PRIVACY RIGHTS
• YOUR CHOICES
• THIRD PARTY WEBSITE AND APPS
• EUROPE
• CONTACT US

TYPES OF INFORMATION WE COLLECT

We collect two basic types of information from you when you provide it to us or when you use or interact with our Services: personal information and non-personal information.

Personal information includes all information that relates to you or which are opinions about you personally and either identifies or may be used to identify you personally (collectively, “personal information”). We may only collect limited types of personal information from you depending upon the device you are using and how you interact with us or use or interact with our Services. For example, we may receive personal information in several ways, including, for example:

• Information that we collect through use of our Services: device-related information (operating system, unique device identifiers, mobile network system, etc.), hardware and browser settings, date and time of requests, requests made, pages visited, search engine terms you used to reach our Services, and IP address. We will retain this information for a reasonable length of time not exceeding 3 years to allow us to understand how people use our website and any technical issues they may have.
• Information when you communicate or interact with us in anyway, either online or offline: contact details (this may include a social media account if that is the way the individual communicated with us), details of the communications with us, and the details of the messages exchanged. We will retain this information: (a) if you are a member of a PSC program, for the duration of your membership; (b) if you area a subscriber, for the duration of your subscription; or (c) if you are neither, for the length of any contract between us or a reasonable amount of time not to exceed three years to understand how people interact with us and any technical issues that may require improvement.
• Information when you subscribe to our Direct Marketing communications: contact details (name, email, address, etc.), payment details (if there is a donation or membership payment), expressed interests and preferences, preferences based on interactions with us including which electronic communications have been clicked or opened, any other details provided to us. We will retain this information for a reasonable length of time not exceeding three years to allow us to understand how people use our marketing communications and any technical issues they may have.
• Information about the way our Services are used: when and where you subscribed to us and downloaded our materials, things subscribed under or downloaded from us, timing and amount of any donations, whether electronic communications from us were opened, comments left on our Services or engaged with us on social media, and clicked links in electronic communications from us. We will retain this information for a reasonable length of time not exceeding three years to allow us to understand how people use our Services and the impact of any changes we make. 
• Information you provide on your Pet Sustainability Coalition membership application form: name and other identity data, email, phone number, entity information, and generalized and non-tracked location data. We may also collect special categories of data as described in Section 11 below. We retain this information for as long as the individual is a member of a Pet Sustainability Coalition program.
• Information that we collect from third-party partners: contact and donor information from charitable giving database providers, contact and donor information from event organizers or commercial partners if there is consent to have data shared with us in this way, data about state/local/parliamentary constituency, characteristics of local area, organizational directorships, estimations of your wealth or potential interest in legacy giving, Royal Mail’s National Change of Address and BT Operator Services Information System (OSIS) file, and (depending on social media account settings) contact information from social networks when individuals sign up with a social media account. We retain (a) information relating to payments or anti-fraud measures for the length of the contract between us and six years after, in case there are any issues; and (b) information relating to statistical analysis for a reasonable length of time not exceeding two years to help us better understand our subscriber and member base over time.
• Information that we collect incidentally from other sources or public sources: information available in the media, information presented on our social media platforms, information collected by internet search engines, and publicly available information collected by the US Treasury Department and other government entities. We retain (a) information relating to media awareness and social media for as long as the information is publicly available; (b) information collected incidentally by security systems for as long as reasonable; (c) information relating to fundraising for as long as the information is publicly available; and (d) information relating to our legal obligations for as long as reasonably required to provide a record of compliance with the law.
• Information that we collect from you representing other organizations or entities: contact details of individuals working for organizations or entities, details related to our interaction with those individuals, and other business-related personal information regarding such individuals. We retain this information for the duration of our relationship with the relevant organization unless we are made aware that the individual no longer works for the organization.
• Information when making a purchase or payment: contact details (name, email, address, etc.), payment details, the product purchased, and information about such items. We retain this information for the length of the contract between us and up to six years after in case there are any issues.

We strive to uphold data minimization principles and only seek to collect personal information from you for the purposes described in this Privacy Policy. You can always refuse to provide your personal information, but please note that some personal information is necessary to provide our Services.

Non-personal information includes information that does not personally identify you or information that has been anonymized (collectively, “non-personal information”). When we combine non-personal information with personal information, we treat the combined information as personal information.

Cookies

When you visit our Website, your browser may save a tiny piece of information (called, a “cookie”) on your computer, mobile phone or other device. This information personalizes and improves your experience online, including allowing us to tailor your experience on our Website according to the preferences you have specified or based on your actions on the site. 

We may also use other tracking technologies, such as web beacons, pixels, gifs, tags and other technologies that collect information to personalize your experience, facilitate your browsing on the Website and improve the quality of the Website. We may also use these technologies in e-mails (for example, to track open rates for our mailings). This practice helps us determine which web pages and mailings appeal most to our users. We may use the information collected through pixel tags, tracking links and similar technology in combination with your personal information.

The tracking technologies allow us to display targeted content and advertisements to you on our Website or on other digital properties based on your past visits to the Website and non-personal information collected over time, and to determine the effectiveness of and optimize the content and advertisements, analyze your interactions with the content and advertisements you are presented with, and how those interactions relate to your visits to the Website.

Cookie Opt-out. You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies, if you opt-out from cookies, or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal. 

Online Analytics

We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

Offline Interactions and Other Sources

We also may collect personal information from other sources, such as our partners or third party service providers, or from our offline interactions with you for the purposes listed in the How We Use Personal Information section below, including to enable us to verify or update information contained in our records and to better customize the Services for you. For example, if you apply for a position with us, we may collect information from former employers, employment/recruiting agencies, credit reference agencies, or other background check agencies.

Social Media Integration

Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter, and when you do, we may collect additional information from you, including the information listed above. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated, and your browser will directly connect to that provider’s servers. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.

HOW WE USE PERSONAL INFORMATION

We primarily use personal information to provide, maintain, and improve our Services, but we may also use personal information to do any or all of the following:

• facilitate your interactions and transactions with us, such as requests for support or additional Services;
• respond to your requests, communications, suggestions, comments, inquiries, and requests (including your feedback about our Services);
• administer our relationship with you and your membership with us;
• develop new products, features, and services;
• better understand the preferences of our members;
• provide personalized Services, including content and ads;
• provide you with, and improve, relevant marketing offers or information from us or relevant third parties;
• ensure our systems and premises are secure;
• develop and manage relationships with our business partners;
• respond to legally binding requests from law enforcement, regulatory authorities, or other third parties;
• defend, protect or enforce our rights or applicable terms of service or to fulfill our legal or contractual obligations;
• manage any dispute and accidents and take legal or other professional advice;
• to prevent fraud or the recurrence of fraud;
• assist in the event of an emergency;
• comply with applicable law; or
• any other purpose with your consent.

We may also combine your personal information collected through various sources, including information collected through our Services, and develop a member profile that will be used for the purposes above. 

Except as otherwise permitted or required by applicable law, we only retain personal information for as long as we need to use the information for the purposes listed above, including, for legal, regulatory, backup, archival, accounting, and/or audit purposes. 

We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose. 

WHY WE USE PERSONAL INFORMATION

We may use personal information for a number of reasons:

• to fulfill our contractual obligations to you, including to provide our Services to you;
• the individual has given consent for a particular purpose (for example, where an individual has given us consent to send them electronic marketing);
• when using the information is necessary for our legitimate interests or those of a third party, provided we have balanced these against the individual’s rights and interests; and
• in order to comply with a legal obligation (for example, responding to government or law enforcement information requests).

Our legitimate interests for using personal information are:

• to effectively administer and manage our organization;
• to ensure effective administration and management of the individual’s relationship with us, including providing our Services;
• to understand how our members use our Services and to manage our Services;
• to carry out research and analysis on what Services or products our members want or how they would like us to improve our Services and products;
• to understand how our members use our Services and identify any issues in how the Services are used and how we can improve the member’s experience;
• to tell our members about the various products and Services we can offer;
• to understand and respond to inquiries and feedback;
• to better tailor and personalize the promotions and benefits that we can offer to our members;
• to ensure our systems and premises are secure;
• to develop relationships with business partners;
• to ensure debts are paid;
• to operate suppressors to exclude you from direct marketing if you unsubscribe;
• to share data in connection with acquisitions and transfers of our organization;
• to manage our relationships with business partners;
• to prevent, detect, or investigate unauthorized use of our Services and ensure we comply with the law and our policies; and
• to manage any dispute and accidents and take legal or other professional advice.

HOW WE SHARE PERSONAL INFORMATION

We only share personal information in limited circumstances. For example, we may share personal information with our third party service providers, suppliers, vendors, professional advisors and business partners, which may include IT service providers, financial institutions and payment providers, member relationship management vendors, other cloud-based solutions providers, lawyers, accountants, auditors and other professional advisors. We contract with such vendors and advisers to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information. We share personal information with these third parties to help us:

• with the uses described in the How We Use Information section above;
• in the operation, management, improvement, research and analysis of our Services;
• with our marketing and promotional projects, such as sending you information about products and services you may like and other promotions (provided you have not unsubscribed from receiving such marketing and promotional information from us); and
• comply with your directions or any consent you have provided us.

We may share personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:

• responding to a subpoena, court order, or other legal processes;
• defending, protecting, or enforcing our rights;
• assisting in the event of an emergency; and
• complying with applicable law.

In accordance with applicable law, we may also transfer or assign personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose personal information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

We share non-personal information with third parties as reasonably necessary to meet our business needs.

HOW WE PROTECT PERSONAL INFORMATION

We are dedicated to ensuring the security of your personal information. We use physical, electronic, and administrative security measures appropriate to the risks and sensitivity of the personal information we collect. We aim to provide secure transmission of your personal information from your devices to our servers. We have processes to store personal information that we have collected in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your personal information, please contact us immediately.

INTERNATIONAL DATA TRANSFERS

We are a global organization. As such, the personal information we collect from you may be transferred to and stored by our IT vendors and other service providers (as specified in How We Share Personal Information above) who operate on our behalf. We also transfer information to a number of providers of business applications as well marketing service providers. These providers are primarily located in the United States, but may also be located in other jurisdictions.

In certain cases, there may not be an adequacy decision by the European Commission and/or United Kingdom authorities in respect of those countries. Adequacy of data protection is instead ensured by Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation, or any equivalent clauses approved by the authorities in the United Kingdom including any additional safeguards as required by EU / UK data protection laws that we have in place with that third party. A copy may be requested by contacting our Data Protection Officer.

CHILDREN’S PRIVACY

Our Services are not for children or those under the age of 16. We do not knowingly collect personal information from children or other persons who are under 16 years of age. Individuals who are children or those under the age of 16 should not attempt to provide us with any personal information. If you think we have received personal information from children or those under the age of 16, please contact us immediately.

YOUR CALIFORNIA PRIVACY RIGHTS

If you reside in California, you have the right to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our Services. Please be mindful that this would not ensure complete removal of the content posted by you on our Services. To make any request pursuant to California privacy law, please contact us.

YOUR CHOICES

We offer you certain choices in connection with our Services.

Access to your personal information

You may request to access or review the personal information that we have collected about you. To submit a request, please contact us using the information below.

Deleting your personal information

You may request that we delete the personal information that we have collected about you. Please note that we may retain an archived copy of your records as required by applicable law or to enforce our rights. To submit a request, please contact us using the information below.

Updating your personal information

The accuracy of the personal information we have about you is very important and you may request to update or correct your information. To submit a request, please contact us using the information below.

Email Communications / Direct Marketing

You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your email address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these necessary emails, if lawful and appropriate, even if you unsubscribe from our optional marketing communications.

Cookies / Beacons

If you wish to minimize information collected by cookies or beacons, you can adjust the settings of your device or browser. You can also set your device or browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some Services may not work properly if you reject cookies. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests. For more information about how our Services use cookies, please see our Cookie Notice.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt-out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page or through the Digital Advertising Alliance Opt-Out Tool. Please note that even if you choose to remove your personal information (opt-out) you will still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt-out of certain online behavioral advertising, please visit http://www.aboutads.info.

Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Do Not Track

Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit.

Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.

THIRD PARTY WEBSITES AND APPS

Our website and Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

EUROPE / UNITED KINGDOM

This section provides additional information to individuals who are a resident of a member state of the European Union (EU), the United Kingdom, or the European Economic Area (EEA).

If you have questions or concerns regarding the use of your personal information, please contact us.

Automated Decision Making

We do not make solely automated decisions based on your data. If you have any questions about this, please contact us at support@petsustainability.org.

Your Privacy Rights

You may have – in accordance with applicable data protection laws – the following rights when it comes to our handling of your personal information. Please note that many of these rights are not absolute, and we may have grounds for refusing to comply with your request to exercise them (for example, where we are (a) required or permitted by law to process your personal data in a way that is incompatible with your request, or (b) able to rely on exemptions under data protection law which entitle us to process your personal data in a way that is incompatible with your request). Where such circumstances apply, we will inform you of this at the time you make a request to exercise your rights.

Your right	How to use it
Right of access – you may have the right to request a copy of the personal information we have about you and to request supporting information explaining how the personal information is used.	You can email your request to us at support@petsustainability.org.
Right of rectification – you may have the right to request that we rectify inaccurate personal information about you.	You can email your request to us at support@petsustainability.org.
Right of erasure / to be forgotten – you may have the right to request that we erase personal information about you.	You can email your request to us at support@petsustainability.org.  It may not always be possible for you to use this right if, for example, if it is still necessary for us to perform the contract or we need to keep the information by law or because of a legal dispute.
Right to restrict processing – in some situations, you may have the right to request that we do not use the personal information you have provided (for example, if you believe it to be inaccurate).	You can email your request to us at support@petsustainability.org.
Right to data portability – you may have the right to receive your personal information in a structured, commonly used and machine-readable format and to transmit such information to another controller.	You can email your request to us: support@petsustainability.org.
Right to withdraw consent – where we process your personal information based on consent (including direct marketing consents), you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal we may continue to use your personal information as permitted or required by law.	You can email your request to us at support@petsustainability.org. To remove your consent for particular uses, you can email your request to us at support@petsustainability.org.  To remove your consent for any use and be forgotten, you can email your request to us at support@petsustainability.org.
Right to object – where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your personal information where we can demonstrate that we have compelling legitimate grounds to process your information (which override your rights and freedoms), or where continuing to process your personal information is relevant to the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.	You can email your request to us at support@petsustainability.org.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information, or access someone else’s personal information on their behalf (or to exercise any of the other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is complex or you have made a number of requests. In this case, we will notify you and keep you updated. Should we be unable to comply with your request, we will provide an explanation.

Data Protection Officer Contact Information

You may contact our Data Protection Officer with any issues or questions you have regarding our processing of personal information.

EMAIL –dcastellucci@petsustainability.org
POSTAL ADDRESS –104 Bohn Ct, Lyons, CO, 80540, USA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (Tel: 0303 123 1113 or at www.ico.org.uk). Alternatively, you can also make a complaint to the supervisory authority in the Member State of the EU or EEA in which you are resident. We would however appreciate the chance to deal with your concerns before you approach the ICO or a supervisory authority, so please contact us in the first instance.

CONTACT US

We welcome requests, questions, comments, and feedback on this Privacy Policy and our management of personal information. If you have requests, questions, concerns, or feedback, you can always contact us in the following ways. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.

Email	support@petsustainability.org
Mail	104 Bohn Ct Lyons, CO 80540