Privacy Policy
Last updated: 11/02/20
Protecting your private information is our priority. So Fear Free, LLC (“we”, “us”, or “our”) has provided this Privacy Policy to disclose how we collect, use, share, and store your (“you”, “your”, or “member”) personal information and how you can control how we use and share that information. This Privacy Policy applies to our websites (currently located at fearfreepets.com; fearfreehappyhomes.com; and fearfreeshelters.com) (“Sites”); the content, including without limitation, Sites content, course content, audio content, video content, text, publications, photos, images, blogs, resources, tools, special offers, online store, code, and any other materials to which we offer you access and otherwise make available on the Sites as well as email, text, or other electronic messages between you and us (“Content”); and other related services that we provide (collectively, the “Services”).
Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites or our Services. By accessing the Sites, receiving Content or engaging with our Services, you agree to the terms of this Privacy Policy.
- Personal Information/Personal Data
Personal information/personal data (“personal information”) is information that identifies or is reasonably capable of being associated with an identifiable individual. Personal information does not include information about an individual that is publicly available nor does it include deidentified, anonymized, or aggregate information.
- Personal Information We Collect and How We Collect It
We Collect Personal Information You and/or a Member Provides to Us
We collect personal information from individuals who directly register with us or otherwise voluntarily provide us with personal information. We also receive personal information from the businesses who register to obtain a membership with us. For example, veterinary professionals and pet professionals provide personal information about the individuals they designate to be eligible to take our courses, download resources and participate in-person and online presentations offered by us. We treat personal information provided by members registering others to with access to our Services the same way we treat personal information provided to us directly by the individual him or herself.
Registration Data: When you register, we ask you to provide certain information, which includes name, business name, business address, email, and job title for professionals. For pet owners, we collect email (this information about professionals and pet owners is “Registration Data”), as well as a password for your account. We collect this information so that we may provide you with access to the applicable Content and Services, monitor members’ compliance with our Sites and community forum policies, send communications to you about your registration, and for other purposes set out in this Privacy Policy.
Purchase Information/Third-Party Payment Processing: If you subscribe to the Services or purchase other products or services, we may collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to provide the Services to which you subscribed or other products or services that you purchased. Payment information, such as your credit or debit card information and other financial data that you provide to process your payment is collected directly by the third-party payment processors with which we work and is never collected or accessed by us and is not stored on our website.
Course Activity: When you use the Services to which you have subscribed, we keep track of your course activity, which may include your course completion dates, test scores, course access, drop-off times, and additional courses selected and consumed so that we may provide the Services to you, improve our Content and Services, and for other purposes set out in this Privacy Policy.
Other Services Activity: When you participate in other Services we provide through our Sites, such as our member forums, surveys, or other activities, we collect the information that you voluntarily submit so that we may provide the Services and Content to you, improve our Content and Services, monitor members’ compliance with our Sites and community forum policies, and for other purposes set out in this Privacy Policy.
Contact Information: If you choose to visit us at our booth at events or otherwise communicate with us (including personal correspondence such as emails or any other activity through which you identify yourself), you may provide us, and we may collect, your contact information, including your name, mailing address, email address, and phone number (“Contact Information”). We collect Contact Information in order to send communications to you, improve our Content and Services, and for other purposes set out in this Privacy Policy.
- How We Use Your Information
Generally: In general, we may use your Registration Data, Contact Information and/or other information or data we receive or collect from you or other sources, as well as data we derive or infer from combinations of the foregoing, for a variety of purposes, such as:
- to present our Sites and Content to you;
- to provide the Services to you;
- to facilitate the creation of and secure your account on the Services;
- to customize and personalize the Content we deliver to you on the Services;
- to allow you to participate in interactive features on our Sites or Services;
- to measure and analyze Services usage and enhance the member experience on our Services;
- to improve the content of our Sites or our Services, including our marketing;
- to fulfill your requests for certain products and services, such as distributing electronic newsletters and enabling you to participate in and renew paid services, surveys, and public forums;
- to provide you with products or Services that you have purchased;
- to provide you with information about our Services that you request from us;
- to register you for email notifications, which will keep you up to date on your account status and upcoming renewal dates;
- to register you for email newsletters to receive updates on new courses, products, services, events, and other offerings of interest to our members;
- to alert you to the latest developments and features on our Services, events, and activities and to notify you of administrative information, such as security or support and maintenance advisories;
- to ask you questions about your interests and your experience on the Sites;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- for identity management, security, and auditing;
- for any other purpose for which you provide it; or
- in any other way we may describe before we collect your information.
- Sharing Your Information With Others
Except as disclosed in this Privacy Policy, we do not share, rent, or sell personally identifiable information you have given us to any third party without your permission. As part of our services, we make public the directory information of our professional members. We do not sell or give personal contact information of individuals resident in the EEA or Switzerland to other companies for their own marketing purposes without their permission. We supply Registration Information and Contact Information of all other members to our Corporate Program Members. We do not provide personal information about you to others unless you are registered by a business or organization in which case the person(s) designated as team administrator(s) for the account will see your certification completion status as well as a list of all of the Fear Free Continuing Education you have completed.
We may provide your personal information to service providers or contractors to perform functions on our behalf, including, but not limited to, communicating news; performing Sites or Services development or maintenance; providing functionality or other services for our Sites and our Services; sending postal mail, email, or other communications; removing outdated and repetitive information from our lists; measuring and analyzing our Services usage and our data; developing, enhancing, marketing, or providing any of our Services; processing payments; or assisting us with other marketing and support functions. These companies are authorized to use your personal information only as necessary to provide these services to us. They are not authorized to use your personal information for their own unrelated purposes.
We may also disclose an individual’s personal information:
- if you elect to take advantage of certain features or services provided jointly by us and third parties to enable them to communicate with you directly, to enable the Services on their platforms, or for research purposes;
- in situations where sharing or disclosing your information is required in order to provide you with information that you have requested;
- to a person or company who in our reasonable judgment is seeking the information as an authorized agent of the individual;
- if, in our reasonable judgment, it is necessary enforce compliance with our internal policies or the agreement for our Services or to protect or defend our legal rights or property, or the legal rights of our business partners, employees, agents, and contractors;
- to protect or defend our Sites or Services or protect the safety and security of our users or members of the public, including acting in urgent circumstances;
- to protect against fraud or to conduct risk management;
- to comply with the law, legal process, or legal requests, including, without limitation, a court order or subpoena;
- in response to a law enforcement agency’s request;
- to another entity as part of a merger, bankruptcy, a sale of assets or all or part of a business, or any other corporate change or re-organization; or
- to a third party or parties, where the individual consents to such disclosure or disclosure is required or permitted by law.
- Managing Your Information
Modification of Your Registration Data: We provide you with the ability to modify your Registration Data, which you may do through the settings section of our Site or by contacting customer support.
Retention of Your Registration Data: We will keep your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it (and whether we can achieve those purposes through other means), and the applicable legal requirements.
In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case it is no longer personal information.
Upon expiration of the applicable retention period, we will securely destroy your personal information in accordance with applicable laws and regulations.
Cancellation or Deactivation of Accounts: If you would like to request the cancellation or deactivation of your account, you should contact our customer support team for assistance. If you elect to have your user account deleted from our database, all of your data will effectively be removed, will no longer be available to us, and we will no longer be able to provide it to you if you decide later to become a member with us again. You can reach us at wags@fearfreepets.com to deactivate your account.
Rights to “Opt Out”: If you are receiving emails, texts, or similar online communications from us, it is because we understood from your registration on our Sites or your information request that you were interested in receiving ongoing information from us. If at any point you no longer wish to receive such communications, you may at any time “unsubscribe” from these communications by following the “opt out” directions to be found at or near the end of the communication. Even if you “opt-out” of these email communications, we will continue to communicate with you about your account and other administrative matters relating to our provision of services to you. If you have any questions about the opt-out process, you can contact us at wags@fearfreepets.com. Please note that if we have already shared your personal contact information with one of our Corporate Program Members or partners, unsubscribing from our communications list will not prevent these third parties from continuing to email or text you. You will have to send an opt-out request to those third parties directly. Opportunities to “opt out” from receiving emails and texts are usually found on these companies’ websites or at the end of their emails or texts. If you do not wish to have your personal contact information shared with our Corporate Program Members or partners, then you can request that we stop such sharing by emailing us at wags@fearfreepets.com.
- Security and Content From Other Websites
Protection of Data From Loss: We have implemented security measures designed to reasonably protect against the loss, misuse, and alteration of the personal information we collect. However, despite our efforts, no security measures are perfect or impenetrable, and we cannot guarantee the security of our databases nor that information you supply will not be intercepted while being transmitted to us over the Internet.
Data Integrity: We will take steps to ensure that all personal information collected, processed, and/or stored is protected from destruction, corruption, or use in a manner inconsistent with the purpose for which we received it.
Third Party “Linked-To” Websites: The Sites may contain links to third-party websites which are neither operated nor controlled by us. This Privacy Policy does not address the information practices of those third-party websites (including social media websites), and we encourage you to read the legal notices posted on such websites, including their Terms of Use and Privacy Policies. To be clear, Fear Free has no responsibility or liability for your experience with, and the data collection and use practices of, such third-party websites. All inquiries concerning the terms and policies of third-party websites should be addressed to the third party hosting the respective website.
- Do Not Track
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers nor is there a common agreement about how to implement these features or interpret user intent. Our Services are not currently set up to respond to those signals.
- Our Policies Concerning Children
Our Sites are not intended for children under the age of 16. We prohibit registration by, and do not knowingly solicit or collect personal information from, anyone under 16 years of age. In the event we obtain actual knowledge that we have collected personally identifiable information from children under the age of 16, we will take reasonable measures to remove such information from our servers and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law). If you believe that we might have any personal information from a child under 16, please contact our customer support team.
- Your California Privacy Rights
Pursuant to California Civil Code Section 1798.83, this policy sets forth the rights that apply to the sharing of personal information with third-parties that we understand will use the information for their own direct marketing purposes. You may contact us at the email address in Section 10 below to request that we provide you with a list of the categories of personal information that we have shared with third parties for the third parties’ direct marketing purposes during the immediately preceding calendar year and a list of the names and addresses of the third parties that received personal information for the third parties’ direct marketing purposes during the immediately preceding calendar year.
- Additional Notice to Residents of the European Economic Area (EEA) and Switzerland
Legal Bases for Collection and Processing of Information
Our collection and processing of your personal information is supported by a number of legal bases. Set out below are the most relevant ones. Please note that while we may rely on one legal basis for a particular activity, if that is no longer applicable or available then we may be able to rely on another basis.
With Your Consent: We collect and process some of your personal information because we obtain your consent.
To Fulfill a Contract: We collect and process some of your personal information because we need to do so either to enter into or fulfill a contract we have with you. For example, we process your personal information when we provide products or Services to you that you have purchased on our website.
For a Legitimate Interest: We may process your personal information where we or a third party have a legitimate interest in doing so. For example, we have a legitimate interest in understanding how people are using our Services, both to improve them and to market our Services more effectively. Therefore, we may use your personal information to understand and analyze your use of our Services. When we rely on our legitimate interest, we will carry out a balancing test between our legitimate interests and your privacy rights. Our legitimate interests include: understanding how our audience interacts with our Content, our marketing, and our Services; learning about our audience in order to improve our Services for them; developing, delivering, and maintaining relevant and engaging Content and marketing; supporting dissemination of information on topics of interest to individuals and the community; supporting individuals’ rights to receive information; and conducting our business activities and achieving our business goals.
To Comply with Legal Obligations: We will process your personal information when necessary to comply with legal and regulatory obligations or defend claims. For example, we may share your personal information in response to a court order, subpoena, or law enforcement agency’s request.
Your Rights: Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights by contacting at the addresses provided in section 10 below.
Right to Access Personal Information: You are entitled to a copy of the personal information we hold about you and certain details of how we use it. Your information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.
Right to Rectification: We take reasonable steps to ensure that the information we hold about you is accurate. However, if you do not believe this is the case, you can ask us to update or amend it.
Right to erasure: In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or, where we are relying on consent as our legal ground, you withdraw your consent. However your request to erase will be balanced against other factors. For example, we may have legal and regulatory obligations which mean we cannot comply with your request.
Right to Restriction of Processing: In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you believe we no longer need to use your personal information.
Right to Data Portability: In certain circumstances, you have the right to ask that we transfer personal information that you have provided to us to another third party of your choice.
Right to Object: You have the right to object to the processing of your personal data in certain circumstances. You may exercise your right to object to stop us from using your personal information for direct marketing. In other circumstances, you may exercise your right to object, however, whether or not we may continue to process your information will depend on the circumstances.
We may ask you for additional information to confirm your identity and for security purposes before disclosing information requested to you.
Transfer of Information
We are located in the United States and your personally identifiable information that we collect is processed and stored in the United States. We rely on derogations for specific situations as set forth in Article 49 of the General Data Protection Regulation (“GDPR”). In particular, we collect and transfer to the United States personally identifiable information with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Given the lack of a finding of “adequacy”, there may be a risk that the supervisory authority and/or data processing principles and/or data subject rights in the United States might not be sufficiently appropriate or comprehensive safeguards from the perspective of the EU. We strive, however, to apply suitable safeguards to protect the privacy and security of your personally identifiable information and only to use it consistent with your relationship with us and the practices described in this Privacy Policy. Our vendors are either certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks or we use Standard Contractual Clauses that have been provided by the EU Commission or other protective contractual language in our agreements with them.
- Contact Information
We welcome your questions or comments regarding this Privacy Policy, which can be directed to us at:
Fear Free, LLC
2301 Blake Street, Suite 100
Denver, Colorado 80205
Attn: Privacy
Email Address:
wags@fearfreepets.com
Please include the words “Privacy Policy Request” in the subject line of your message
- Changes to our Privacy Policy
We will continue to evaluate this Privacy Policy against new technologies, business practices, and our members’ needs and may make changes to the Privacy Policy accordingly. Please check this page periodically for updates. Use of the Services by you following the posting of a new or updated Privacy Policy on our Sites constitutes your acceptance of the Privacy Policy as modified.
