Wick Bidco Ltd trading as Kin Vet Community, Mercer & Hughes LTD,

External Privacy Notice

Last Updated: 13^th November 2023

1. Who we are and what we do

Who we are

We are Wick Bidco Ltd trading as Kin Vet Community, Mercer & Hughes LTD, (“Kin Vet Community]”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 14870035 and we have our registered office at Sidney House, Western Way, Bury St. Edmunds, England, IP33 3SP. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”), in relation to our processing of Personal Data under registration number C1416258.

Our subsidiary companies are registered in England and Wales and trading as:

Company	Limited Company Registration Number	Registered Office Address	ICO Registration Number
Mercer & Hughes Limited	05069848	14 Radwinter Road, Saffron Walden, CB11 3JB	Z9769996
Swayne and Partners Limited	07986290	Western Way, Bury St Edmunds, IP33 3SP	ZA313978
Penrose Veterinary Group Limited	10417267	70 Brinkley Lane, Highwoods, Colchester, CO4 9XE
Kevin Castle (Pet Care) Limited	07863527	355 Bexley Road, Erith, DA8 3EZ	ZB269508

What we do

We are in the business of providing veterinary care and services. We and our subsidiaries and related entities are committed to protecting the privacy and security of the Personal Data we process about you.

Controller

Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

2. Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.

3. Who this privacy notice applies to

This privacy notice applies to you if:

You visit our website or veterinary practices in person
You purchase goods or services from us
You enquire about our products and/or services
You sign up to receive newsletters and/or other promotional communications from us

4. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.

5. Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes & lawful bases’.

6. How we collect your Personal Data

We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website.

However, we may also collect your Personal Data from third parties such as:

reputable companies who provide lead generation contact lists
others to whom you have provided consent
publicly available sources such as social media platforms

7. Purposes & lawful bases

We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:

Categories of individuals	Categories of Personal Data	Purpose of Processing	Lawful Basis
Customer	Name, address, email address, contact telephone number	To provide you with and carry out the services that you request from us, as well as providing you with information relating to the health and wellbeing of your pet.	Contract arrangements & legitimate interests
Customer	Incoming call recording	We use incoming call recording in our practices for training and monitoring purposes	Legitimate interests & legal obligations to retain and share with law enforcement agencies
Customer	Photographic & video production material	If this media contains images of you, we will only make use of it if we have obtained and recorded your consent. We will also let you know what we do with this information (for example, place it on the practice’s website or social media page).	Consent
Customer	CCTV recording within our practices	For the safety of and prevention of any crimes committed against our staff, our clients, our patients, our suppliers and other visitors, our equipment and our properties, not for other monitoring purposes.	Legitimate interests & complying with legal obligations
Employee Candidates	Employment application data, including contact details, CV, past employment information and any information shared through any interview process	For the application and subsequent processing of a role at Kin Vet Community	Consent, legitimate interests & legal obligations
Employee	Personal information such as name, contact information, bank account details, next of kin details, marital status, dependents, gender, copy of photographic ID	To enable us to process you as our employee, worker or contractor including paying you, providing contractual benefits, checking you are legally entitled to work in the UK, conducting performance reviews and managing sickness absence	Contractual arrangements, legal obligations & legitimate interests
Employee	Special categories of personal information including information about your race, religious beliefs, sexual orientation, information about your health and information about criminal convictions	To enable us to process you as our employee, worker or contractor including paying you, providing contractual benefits, checking you are legally entitled to work in the UK, conducting performance reviews and managing sickness absence	Contractual arrangements, legal obligations & legitimate interests

Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

8. Sharing your Personal Data

We may share your Personal Data with our carefully selected third parties, including:

with other veterinary practices or professionals, if your pet requires a particular treatment or if you wish to transfer your pet to another veterinary practice;
with insurance companies, with whom your pet is insured or with whom we or our personnel are insured in the event of any incidents involving you or your pet;
with third party suppliers, who we work with in order to deliver services and treatment for your pet, these include:
data partners that support us with analysis and insights to continuously improve the service that we offer;
- direct marketing companies who enable us to communicate with you;
- social media companies for the purposes of marketing and advertisement as well as receiving and providing feedback on our products, services and operations;
- IT service providers who support our organisation’s IT systems, including our Site and practice management systems; and
- review companies that may invite you to review the service we have provided;
with regulatory bodies, government departments or agencies and law enforcement bodies where we believe that we’re required to disclose such information due to legal or regulatory requirements or to protect your interests or those of any third party;
with our professional advisors including tax, legal, accounting, insurance brokers or other corporate advisors who provide professional services to us;
in the event that we consider selling or buying any business or assets we will disclose your personal information to any prospective sellers or buyers of such business or assets;
with other entities in our group and our investors as part of the administration of our business. For example, we may share personal information as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data; or
with any other third party where you have consented to such disclosure.

9. International Transfers

Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.

We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:

Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or
We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk)).

10. Your rights and how to complain

You have certain rights in relation to the processing of your Personal Data, including to:

Right to be informed

You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

Right to rectification

You have the right to have any incomplete or inaccurate information we hold about you corrected.

Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.

Right to restrict processing

You have the right to restrict our use of your Personal Data.

Right to portability

You have the right to ask us to transfer your Personal Data to another party.

Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.
Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

Right to lodge a complaint

You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:

Or by telephone on 0303 123 1113

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.

11. Children’s Privacy

We do not offer our products and services to children and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If you are a child, you must have your parent’s permission to use our services. If you learn that a child has provided us with their Personal Data without parental consent, you may contact us, as described below, and if appropriate, we will securely and permanently delete it, in accordance with applicable law.

12. How to contact us and our Data Protection Officer

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:

Kin Vet Community

Sidney House,

Western Way (West)

Bury St Edmunds,

Suffolk

IP33 3SP

welcome@kinvet.co.uk

Our DPO can be contacted as follows:

FAO: Data Protection Officer

Kin Vet Community

Sidney House,

Western Way (West)

Bury St Edmunds,

Suffolk

IP33 3SP

welcome@kinvet.co.uk

Please mark your communications FAO the ‘Data Protection Officer’.

13. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 13^th November 2023