Last Updated: July 31, 2018
Oxbow Animal Health (“OAH”) collects Personal Data (as defined below) in the context of providing services (as defined below). OAH respects your privacy and is committed to protecting your Personal Data.
If you use our services, this Notice describes how we will collect, hold, store, protect, and use your Personal Data. Depending on the Service, we may provide additional or different privacy statements or notices for specific interactions you have with us or to highlight how we use your Personal Data for specific services. Where we do this, it will be clear which statements apply to which interactions and services. For example, if you use one of our mobile apps, we may provide you a separate notice in relation to a particular data type collected through that app.
If you are a “Data Subject” under the EU General Data Protection Regulation (the “GDPR”), this is a required notice to you. OAH is a “Data Controller” for purposes of this Notice. This means that we are responsible for deciding how we collect, hold, and process your Personal Data. It is important that you read this Notice, together with any other privacy notice we may provide on specific occasions, when we are collecting or processing your Personal Data.
1. Sites Covered By This Statement
This Online Privacy Statement covers the collection and use of data on the www.oxbowanimalhealth.com web site in the United States. This privacy statement also applies to any affiliated websites or sub-websites within oxbowanimalhealh.com (including, but not limited to, oxbowvetconnect.com.)
2. What Information We Collect
The information we collect on our site generally falls into the following two categories: Personally Identifiable Information and Non-Personally Identifiable Information.
Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. The Personally Identifiable Information we collect when you use our Site may include your name, mailing address, phone number, e-mail address, employer, and job title. We request Personally Identifiable Information when you participate in certain promotional activities, fill out surveys, and correspond with us. We also collect Personally Identifiable Information when you ask that we send products or information directly to other people; in these cases, we will collect the information you submit about the recipient. It will be clear when you are on a part of our site that requires personal information, because we will ask you for it and you will have a choice about how we use that information.
Non-Personally Identifiable Information: This refers to information that does not by itself identify a specific individual. The Non-Personally Identifiable data we collect when you visit our site may include the Uniform Resource Locator (“URL”) of the Web site that you visited directly prior to coming to our site, which pages you visit on our site, which URL you visit next, which browser you used to enter our site, your Internet Protocol (“IP”) address, and any search terms entered on our site.
We do not associate the Personally Identifiable Information with the Non-Personally Identifiable Information collected on our site.
3. Why We Collect Your Information
Our primary goals in collecting information are to provide customers with superior service and to give all visitors a smooth, efficient, and personalized experience while using our site. For example, if you request information on our site, we use your Personally Identifiable Information to supply the requested information. We use Non-Personally Identifiable Information on an aggregated basis to analyze customer behavior to help us understand how visitors use our site and to measure interest in the various pages. We use this information to improve the content of our site, to make it easier to use, and to customize our advertising.
We may need to request specific information from you to help us confirm your identity and make sure you can exercise any of your rights hereunder. This is a security measure to ensure that Personal Data 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 may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
4. How We Collect and Use Your Information
We gather and use information in a number of ways, including the following:
Surfing: We collect certain Non-Personally Identifiable Information when you visit our site for products and services. We collect this information to help run our site more efficiently, to gather broad demographic information, to monitor the level of activity on our site, and to evaluate the effectiveness of our advertising.
Technical Support: We may collect certain information when you request technical support for your products. This information is necessary to identify your systems, understand the configuration of your products, and provide solutions.
Online Surveys and Polling: We collect Personally Identifiable Information from those customers who volunteer to complete surveys or participate in polls. We use this information to improve our site as well as our product offerings and services.
Promotional Activities: We collect Personally Identifiable Information from you when you engage in one of our promotional programs or activities. We use this information to administer the program or activity, to send you promotional e-mails, notify winners, and make the winners’ list publicly available pursuant to certain states’ laws.
Newsletters and Promotional E-mails: We collect Personally Identifiable Information when you ask to receive newsletters, promotional e-mails, and other information. We use this data to provide you with the information that you request.
Contact Information: If you contact us, we may keep a record of your correspondence or comments, including Personally Identifiable Information, in a file specific to you. We use this information to help us provide better service in the event you contact us again.
Web Beacons: Our services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages or opened an email and for other related Service statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
Contractual Necessity. Where we need to perform a contract we are about to enter into or have entered into with you.
Legitimate Interests. Where it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests (for example, providing and improving our services, administering our relationship with you and our business, marketing and growing our business, and in order to exercise our rights and responsibilities).
Compliance with Law. Where we need to comply with a legal or regulatory obligation (for example, preventing and detecting crime, and assisting police and other authorities with their investigations).
Vital Interests. Where it is necessary to protect your vital interests or those of another person (for example, where we know or have reason to believe that you or another person may suffer harm).
In circumstances where you have a genuine choice as to whether we should process your Personal Data, we will ask you for your consent. The method used to obtain your consent will depend on the scope and context of the processing that we propose.
Where we need to process your Personal Data either to comply with law or to perform the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. For example, we may not be able to provide you with the functionalities of the services (e.g., setting up your account) or we may not be able to respond to or fulfill a request you make of us (e.g., for demonstration of the services). In this case, we may have to stop you from using our services, but we will notify you if this is the case at the time.
5. Sharing Your Information
We do not sell, trade, or rent to others the Personally Identifiable Information we collect online. Unless we have your permission, we will share the Personally Identifiable Information you provide online only within OAH and/or businesses that provide services to OAH and only for the purposes described above. In situations where OAH engages third parties to perform services on its behalf, we will require them to observe the intent of this Privacy Statement.
On some of our Web pages we may offer you the opportunity to receive information from companies with products or services that may be of interest to you. If you choose to receive such information, OAH may assist those companies in their marketing activities by forwarding their messages to you, but we will not provide these companies with any of your Personally Identifiable Information.
From time to time, we may be required to provide Personally Identifiable Information in response to a court order, subpoena, or government investigation. We also reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful. We may release certain Personally Identifiable Information when we believe that such release is reasonably necessary to enforce or apply our Terms and Conditions or to protect the rights, property, and safety of others and ourselves.
OAH or its related entities could merge with or be acquired by another business entity, or their respective assets could be acquired. Should such a combination or acquisition occur, you should expect that OAH would share some or all of your Personally Identifiable Information to continue serving you and other users of our site.
We may share your Personal Data with both internal parties (i.e., amongst OAH and its affiliates) and external third parties who are based outside the European Economic Area (the “EEA”). We will take commercially reasonable steps to ensure that when we process the Personal Data of individuals based in the EEA or transfer that Personal Data to any third parties outside the EEA, appropriate safeguards are maintained to ensure protection of that Personal Data consistent with the GDPR.
6. Your Choices and Rights
OAH will not use or share the Personally Identifiable Information collected on our site in ways unrelated to the purpose for which you provided the information, including those described above, without giving you a choice whether to permit any such unrelated uses. At the time you provide your information, we will offer you a choice as to whether you want to receive further communications about special offers, product information or other marketing messages. If you choose not to receive these communications, we will not use the information you provide for this purpose. If you have previously given your permission to receive these communications, but then change your mind and do not want to receive further marketing communications from OAH, you can unsubscribe or “opt out” by clicking on the “unsubscribe” link located at the bottom of our emails, or by sending us email at firstname.lastname@example.org, or post mail to Oxbow Animal Health, 11902 S. 150th St., Omaha, NE 68138 USA, Attention: Privacy.
You may have rights under the GDPR and other laws to have access to your Personal Data and to ask us to rectify, erase, and restrict use of your Personal Data. You may also have rights to object to your Personal Data being used, to ask for a transfer of Personal Data you have made available to us, and to withdraw consent to the use of your Personal Data. Further information on how to exercise your rights is set out below.
We will endeavor to honor your rights under applicable data protection laws. You have the following rights under the GDPR and may have similar rights under the laws of other countries:
Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”).
Please contact us at email@example.com if you wish to exercise any of these rights. Note, however, that these rights are not absolute and do not always apply in all cases. OAH may be entitled to refuse any request in certain circumstances and, where this is the case, you will be notified accordingly. In cases of Consent Withdrawal, OAH may not be able to provide some or all of its services to you or the provision of those services may be affected. If you do exercise your right to object, we will still have the right to process your Personal Data to send you Service-related communications, such as emails we may have to send you relating to the management of your account, your use of our Services, updates to this Notice, etc.
7. Protecting Your Information
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees and other staff who have a business need to have such access. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
We will only retain your Personal Data for as long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law
8. Links to Other Websites
Parts of our site may contain links to third-party Websites for your convenience and information. If you use these links, you will leave the OAH Website. When you access a non OAH Website, even one that may contain the OAH Logo, please understand that we do not control the content and therefore are not responsible for the privacy practices of that site. We recommend that you carefully review the privacy policies of each site you visit. This Privacy Statement does not cover the information practices of those Websites linked to our site. Those other sites may send their own cookies to users, collect data, or solicit personal information.
9. Children’s Privacy
OAH believes that protecting children’s privacy online is extremely important, and we encourage parents and guardians to take an active role in their children’s use of the Internet and to spend time online with their children. OAH respects national and international laws, including the Children’s On-line Privacy Protection Act (“COPPA”), which applies in the United States. Accordingly, at our site we do not knowingly collect personal information from children under 13 without parental consent. In the event we develop areas of our site directed at children under age 13, we will implement a special children’s privacy statement that complies with the requirements of COPPA and other relevant laws.
10. Your California Privacy Rights
California Civil Code Section 1798.83 permits users of our services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
11. Changes to This Statement
If there are changes or additions to the terms of this Privacy Statement, we will post those changes here so that you will always know what information we collect online, how we use it, and your choices in providing that information. Please be sure to check this page before proceeding to use our site. Regardless of any changes we make to our Online Privacy Statement, we will always use your Personally Identifiable Information in accordance with the version of the Privacy Statement in place at the time you provided your information, unless you give your express consent for us to do otherwise.
12. Contact Us
If you have any questions or concerns about OAH’s use of your information, or about this Online Privacy Statement, please send an e-mail to email@example.com.