1. What is this privacy policy about?

VetProcure AG, Kernserstrasse 17, 6060 Sarnen (Switzerland) (hereinafter also “VetProcure”, “we” or “us”) processes personal data in different ways and for different purposes. “Personal data” means all information relating to an identified or identifiable natural person, and “processing” means any operation with it, such as collecting, using, and disclosing it. This privacy notice explains our processing of such data (hereinafter referred to as personal data or data) when

• you visit our website (https://vetprocure.com, “Website”),
• you use our sales platform for veterinary supplies (“Services”) which is accessible via our Website,
• you are otherwise associated with us by contract,
• you contact us via email, letter, on social media, by text message, via a contact form, etc.,
• you register for our newsletter,
• you deal with us in the context of all other data processing related to our offers.

Please take the time to read this privacy notice to learn how and why VetProcure processes your personal data, how VetProcure protects your personal data and what rights you have in this context. If you have any questions or would like further information about our data processing, please do not hesitate to contact us (section 2).

We have aligned this privacy notice with both the Swiss Federal Act on Data Protection (FADP) and the European General Data Protection Regulation (GDPR). However, whether and to what extent the GDPR is applicable depends on the individual case.

2. Who is responsible for processing your data?

For the data processing according to this privacy notice, the following company is the “controller”, i.e. the party primarily responsible under data protection law unless otherwise communicated in individual cases (e.g. in further privacy notices, on forms or in contracts):

VetProcure AG
Kernserstrasse 17
6060 Sarnen
Switzerland
Email: support@vetprocure.com

If you have any questions regarding data protection, please feel free to contact us at the following address so that we can process your request as quickly as possible: dataprotection@vetprocure.com

3. What personal data do we process?

We process different categories of personal data depending on the situation and purpose. You will find the most important categories below, whereby this list cannot be exhaustive.

For contracting parties that are companies, we process fewer personal data because the applicable data protection law generally only covers data of natural persons. However, we do process data of the contact persons with whom we are in contact, e.g. name, contact details, professional details and details obtained from communications, details of members of management, etc. as part of the general information about companies with which we work.

You disclose much of the data mentioned in this section yourself (e.g. via forms, when communicating with us, in connection with contracts, when using the Website or the Services, etc.). If you wish to enter into contracts with us or claim services, you must provide us with data as part of your contractual obligation under the relevant contract, in particular, master data and contract data.

You may provide us with data that relates to other individuals, such as work colleagues, superiors etc. If you do submit data concerning third parties, we understand that you confirm this data is correct and that you are authorised to provide us with this data. We ask you to inform these third parties about our processing of their data (for example, by a reference to this privacy policy).

3.1. Master data

Master data is the basic data that we need to process our business relationships or for marketing and advertising purposes and that relates directly to your person and characteristics. For example, we process the following master data:

• account information such as surname, first name, e-mail address and login credentials
• information on the company you are working for
• company address, company contact details such as e-mail address, further company information such as clinic registration numbers
• language preference declaration
• company order history

We usually obtain this master data from you directly but possibly also from other persons who work for your company.

3.2. Communication data

Communication data is information in connection with our communication with you, for example, when you contact us via contact form or via other means of communication. Communication data are, for example:

• name and contact details such as e.g. postal address, e-mail address and telephone number;
• content of correspondence (e.g. of e-mails, written correspondence, chat messages, etc.);
• responses to customer and satisfaction surveys;
• information on the type, time and, if applicable, location of the communication and other peripheral data of the communication.

3.3. Technical data

Technical data is generated in connection with the use of our website. This includes, for example, the following data:

• The IP address of the end device and device ID;
• information about your device, the operating system of your end device or language settings;
• information about your internet provider;
• accessed content or protocols in which the use of our systems is recorded;
• date and time of access to the website and your approximate location;
• details of the content accessed while using our Services;
• information that is required for using our Services, such as sending an access code via push message for logging into your user account via our Website.

We may also assign an individual code to you or your end device (e.g. by means of a cookie; see section 5.1). This code is stored for a certain duration, often only during your visit. We cannot usually deduce who you are from technical data unless, for example, you register for the newsletter on our website. In this case, we can link technical data with master data – and thus with your person.

3.4. Behavioural data

To tailor our Services to you or your company in the best way possible, we try to get to know you better. For this purpose, we may collect and use certain data on your behaviour. Behavioural data is, in particular, information about the use of our Website or our Services. It may also be collected based on technical data. This includes, for example, information on your use of electronic communications (e.g. whether and when you opened an e-mail or clicked on a link, especially when sending newsletters). We may also use your other interactions with us as behavioural data, and we may link behavioural data with other data (e.g. with anonymous information from statistical offices) and evaluate this data on a personal and non-personal basis.

3.5. Preference data

Preference data tells us which needs you are likely to have, and which Services or information might meet your interest or the interest of your company. We therefore also process data regarding your interests and preferences. For this purpose, we can link behavioural data with other data and evaluate this data on a personal and non-personal basis. This allows us to draw conclusions about characteristics, preferences, and anticipated behaviour.

3.6. Other data

We may also collect data from you in other situations. In connection with official or judicial proceedings, for example, data (such as files, evidence, etc.) incurs that may also relate to you.  

4. For what purposes do we process your personal data?

We use the personal data we collect primarily for collaboration with you. If you have subscribed to our newsletter, we use your e-mail address for sending it. In addition, we also process your personal data, to the extent permitted and deemed appropriate, for other purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

• For communication purposes, i.e. to contact you and to stay in contact with you. This includes answering inquiries and contacting you in case of queries, e.g. by e-mail. For this purpose, we especially process your communication and master data.
• For customer care and marketing purposes to offer you targeted information about new offers according to your personal interests and preferences, for example, through the newsletter and personalised advertising. For this purpose, we especially process technical data, master data, communication data and behavioural data.
• To develop and license anonymous, aggregated market insights that support the functionality and continuous improvement of the Platform and ensure its economic sustainability. For this purpose, we process order and usage data and apply safeguards (k-anonymity ≥10, rounding/noise, suppression of rare combinations) and take measures to prevent re-identification or competition concerns. These insights do not contain personal data (no clinic or buying-group identities; no individual prices or volumes).
• To ensure IT security and for prevention: we process personal data to monitor the performance of our company, in particular IT, our Website, applications, and other platforms, for security purposes, to ensure IT security, to prevent theft, fraud and abuse, and for evidence purposes. This includes, for example, the evaluation of technical records of the use of our systems (log data), the prevention, defence and investigation of cyber-attacks and malware attacks, analyses and tests of our networks and IT infrastructures, system and error checks.
• To maintain the internal rules and other measures for IT, building and facility security and for the protection of our employees and other persons and assets belonging to or entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone records).
• To protect our rights: we may also process personal data to enforce claims in or out of court and before authorities in Switzerland and abroad, or to defend ourselves against claims. For this purpose, master data and communication data may be processed.
• To comply with legal requirements: this includes, for example, the processing of complaints and other notifications, compliance with orders of a court or an authority, measures to detect and investigate abuses, and generally measures that we are obliged to take by applicable law, self-regulation, or industry standards. For this purpose, we may especially process your master data and communication data.
• For administration and support: to shape our internal processes efficiently, we process data as far as necessary for the administration of IT, for accounting or for archiving data. For this purpose, particularly communication and behavioural data as well as technical data may be used.
• We may also process data for other purposes. These include company management, including business organization and company development, other internal processes and administrative purposes (e.g. management of master data, accounting and archiving), training as well as educational purposes and the preparation and processing of purchase and sale of business units, companies or parts of companies and other transactions under company law and the associated transfer of personal data, as well as measures for business management and the protection of other legitimate interests.

If we ask for your consent for certain processing activities, we will inform you separately about the corresponding purposes of the processing. You can revoke your consent at any time by written notice.

5. What online tracking and online advertising techniques do we use?

On our website, we use various techniques to let us and third parties consulted by us recognise you when you use our Website and, in some cases, track you across multiple visits. The use of such techniques is regulated separately. The following section provides information on this topic.

5.1. How and for what purpose do we use cookies and similar technologies?

We use third-party services for our Website to measure and improve the user experience of the Website and online advertising campaigns. For this purpose, we may embed third-party components on our Website, which may in turn use cookies. When we track you or use similar technologies, the core purpose is to enable us to distinguish access by you (via your system) from access by other users so that we can ensure the functionality of the Website and perform statistical analyses. We do not want to identify you in this process. The technology used is designed to recognise you as an individual visitor each time you access the Website, for example, by having our server (or the servers of third parties) assign a specific identification number to you or your browser (so-called cookie).

Cookies are files that your browser automatically stores on your end device when you visit our website. Cookies contain a unique identification number (an ID) that allows us to distinguish individual visitors from others, but usually without identifying them. Depending on the purpose use, cookies contain further information, for example, on accessed sites and the duration of the visit to a site. On the one hand, we use session cookies, which are deleted again when the browser is closed, and on the other hand, we use permanent cookies, which remain stored for a certain duration after the browser is closed and are used to recognise visitors on a subsequent visit.

We use the following types of cookies and similar technologies:

• Necessary cookies: necessary cookies are required for the functionality of the Website, for example, to allow you to switch between sites without losing information entered in a form.
• Performance cookies: these cookies collect information about the use of our Website and enable analyses, for example, which sites are most popular. They can thereby simplify the visit to the Website and improve the user experience.
• Functional cookies: functional cookies enable advanced features and can display personalised content.
• Marketing cookies: marketing cookies help us and our advertising partners to target you on our Website and on websites of third parties with advertisements for products or services that may be of interest to you or to display our advertisements during your further internet use after visiting our Website.

We particularly use cookies for the following purposes:

• personalisation of content;
• displaying personalised advertisements and offers;
• displaying ads on third-party websites and measuring their success, i.e. whether you respond to these ads (remarketing);
• save settings between your visits;
• determining whether and how we can improve our Website;
• collection of statistical data on the number of users and their usage habits, as well as to improve the speed and performance of the Website;
• we may process your contact details to target you with advertisement on third-party platforms.

We may also use similar technologies [e.g. [LinkedIn Insight Tags, Pixel Tags or Fingerprints]] to store data in the browser. Pixel Tags refer to small, usually invisible images or a program code that are loaded from a server and thereby transmit certain information to the operator of the server, e.g. whether and when the Website was visited. Fingerprints are information that is collected when you visit our Website via the configuration of your end device or your browser, and which make your end device distinguishable from other devices.

5.2. How can cookies and similar technologies be disabled?

When accessing our Website, you have the option to activate or deactivate certain categories of cookies. You can configure your browser in the settings to block certain cookies or similar technologies or delete existing cookies and other data stored in the browser. You can also enhance your browser with software (so-called plug-ins) that blocks tracking by certain third parties. You can find out more about this in the help pages of your browser (usually under the heading “privacy”). Please note that our Website may no longer fully function if you block cookies and similar technologies.

5.3. Cookies from partners and third parties on our website

We use third-party services to help us measure and improve the user experience of the Website and online advertising campaigns. Third-party service providers may be located outside Switzerland and the EU/EEA, provided that the protection of your personal data is adequately ensured. For example, we use analytical services to allow us to optimise and personalise our Website. The respective third-party providers may record the use of the Website for this purpose and combine their recordings with further information from other websites. This allows them to record user behaviour across multiple websites and end devices in order to provide us with statistical evaluations on this basis. The providers may also use this information for their own purposes, e.g. for personalised advertising on their own website or other websites.

Two of the most important third-party providers are Google and Meta/Facebook. You can find more information about them below. Other third-party providers generally process personal and other data in a similar way.

• Google Analytics, an analysis service of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA, USA) and Google Ireland Ltd. (Google Building Gordon House, Barrow St, Dublin 4, Ireland; jointly “Google”, with Google Ireland Ltd. being responsible for the processing of personal data). Google uses cookies and similar technologies to collect certain information on the behaviour of individual users on or in the relevant website as well as information on the end device used for this purpose (tablet, PC, smartphone, etc.). Google collects information on the behaviour of users on the website and the end device used and provides us with evaluations on this basis, but also processes certain data for its own purposes. We have configured Google Analytics in a way that IP addresses of visitors are anonymised before being forwarded to the USA. You can find information on data protection at Google Analytics here. You can disable Google Analytics by installing a respective browser add-on.
• Meta Pixel, an analytical tool of Meta Platforms Ireland Ltd (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This allows us to control advertisements on Meta and Meta’s partners to be displayed only to users for whom advertisements are likely to be of interest. We can also measure the effectiveness of such advertisements for statistical and market research purposes. We are jointly responsible with Meta for sharing data that Meta receives as a result, for displaying personalised advertisements, improving advertisement delivery, and personalising content. The data is stored on servers in the EU/EEA and the USA. Users may submit information requests and other inquiries directly to Meta/Facebook. Further information on data protection at Meta and corresponding settings options can be found here.

6. To whom do we disclose your personal data?

We disclose the information we collect about you to Vendors, that may have a business relationship with us, whose products you purchase through the Platforms and Services. For example, for orders with Vendors through the Procurement Platform, we may share your account information, including, for example your veterinary license number, to the respective Vendor to process and ship the order, as well as to communicate directly with you for troubleshooting, order issues, errors or other investigations. We may license anonymous, aggregated market insights to Vendors. These insights do not contain personal data (no clinic or buying-group identities, no individual prices or volumes).

We further disclose personal data to service providers as required for their services. This particularly concerns IT service providers, but also consulting companies, analysis service providers, marketing service providers, etc. As far as service providers process personal data as processors, they are obliged to process personal data exclusively according to our instructions and to implement data security measures.

Data may also be disclosed to other recipients, e.g. to courts and authorities as part of legal proceedings and legal information and cooperation duties, to buyers of companies and assets, to financing companies in the case of securitizations, and to collection agencies.

In individual cases, it is possible that we also disclose personal data to other third parties for their own purposes, e.g. if you have given us your consent to do so or if we are legally obliged or entitled to disclose such data.

7. Do we disclose personal data abroad?

Recipients of data are not only located in Switzerland. This applies in particular to certain service providers. These may be located outside the European Economic Area (EEA) and Switzerland (especially in the USA, but also in other regions and countries worldwide. We may transmit data to authorities and other persons abroad if we are legally obliged to do so or, for example, in the context of a company sale or legal proceedings. Not all of these countries currently guarantee an adequate level of data protection according to the standards of Swiss law. We therefore take contractual precautions to contractually compensate for the lower level of legal protection, especially with the standard contractual clauses issued by the European Commission and recognised by the Swiss Data Protection and Information Commissioner (FDPIC).For more information and a copy of these clauses, please visit www.edoeb.admin.ch/edoeb/en/home/data-protection/handel-und-wirtschaft/transborder-data-flows.html.

In certain cases, we may transmit data in accordance with data protection law requirements even without such contracts, e.g. if you have consented to the corresponding disclosure or if the disclosure is necessary for the execution of the contract, for the establishment, exercise or enforcement of legal claims or for overriding public interests.

8. How long do we process personal data?

We store and process your personal data as long as it is necessary for the purpose of the processing (in the case of contracts, usually for the duration of the contractual relationship), as long as we have a legitimate interest in storing it (e.g. to enforce legal claims, for archiving and or to ensure IT security) and as long as the data is subject to a legal retention obligation (for example, for certain data, a ten-year retention period applies). If there are no legal or contractual obligations to the contrary, we will destroy or anonymise your data after the storage or processing period has expired within our normal processes. Where data are used to form anonymized, aggregated insights, we anonymize promptly once the purpose is achieved and thereafter retain only non-personal data.

9. What are the legal bases for data processing?

As the case may be, data processing is only permitted if the applicable law specifically allows it. This does not apply under the FADP, but does apply, for example, under the GDPR as far as it is applicable. In this case, we base the processing of your personal data on the following legal bases:

• on your consent (Article 6(1)(a) and Article 9(2)(a) GDPR),
• that the processing is necessary for the performance of the contract or pre-contractual measures (e.g. the review of a contract proposal; Article 6(1)(b) GDPR),
• that the processing is necessary for the establishment or defence of legal claims or civil proceedings (Article 6(1)(f) and Article 9(2)(f) GDPR),
• that the processing is necessary for compliance with domestic or foreign legal provisions (Article 6(1)(c) and (f); Article 9(2)(g) GDPR),
• that the processing is necessary for a legitimate interest in the data processing, in particular the interests mentioned in section 4 (Article 6(1)(f) GDPR), including our legitimate interest in developing and licensing anonymised, aggregated market insights to sustain and improve the Platform (see section 4).

10. How do we protect your data?

We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data to protect it against unauthorised or unlawful processing and to protect it against the risks of loss, accidental loss or alteration, unauthorised access. However, security risks cannot be completely ruled out; residual risks are unavoidable.

11. What rights do you have?

Under the applicable data protection law, you have certain rights to obtain further information about and influence our data processing. Particularly, these are the following rights:

• Access right: you can request further information about our data processing. We are at your disposal for this purpose. You can also submit a so-called information request if you wish to receive further information and a copy of your data.
• Objection and deletion: you may object to our data processing and request that we delete your personal data at any time if we are not obliged to continue processing or storing this data and if it is not necessary for the contract.
• Correction: you can have incorrect or incomplete personal data corrected or completed or complemented by a note that indicates your objection.
• Data portability: you also have the right to receive the personal data you have provided to us in a structured, common and machine-readable format or to have it transferred to a third party, as far as the respective data processing is based on your consent or is necessary for the execution of the contract.
• Revocation: if we process data based on your consent, you can revoke your consent at any time. The revocation is only valid for the future, and we reserve the right to continue to process data based on another basis in the event of a revocation.

Please note that these rights are subject to legal requirements and restrictions and are therefore not fully applicable in every case. In particular, we may need to further process and store your personal data in order to fulfil a contract with you, to protect our own legitimate interests such as the assertion, exercise or defence of legal claims, or to comply with legal obligations. To the extent legally permissible, in particular to protect the rights and freedoms of other data subjects and to safeguard interests worthy of protection, we may therefore also reject a data subject request in whole or in part (e.g. by redacting certain content relating to third parties or our trade secrets).

If you wish to exercise any rights against us, please contact us in writing. You will find our contact details in section 2. As a rule, we will have to verify your identity (e.g. by means of a copy of your ID card ). You are also free to file a complaint against our processing of your data with the competent supervisory authority. The competent supervisory authority in Switzerland is the Swiss Data Protection and Information Commissioner (FDPIC).