1 General
This privacy policy (”Privacy Policy”) describes how Aktiebolaget Djursjukvård i Sverige AB, org. no. 559299-9113, (hereinafter referred to as ”VetAtHome”) processes your personal data. VetAtHome is the data controller for personal data relating to your user account for our IT platform, hereinafter referred to as ”the Platform”. The Privacy Policy explains, among other things, which categories of personal data we process, for which purposes we process them and what legal basis we support the processing on. We also explain who may have access to and process the data, the principles for filtering, which third parties we may share the personal data with, where the personal data is processed and your rights as a data subject in the form of the right to information, correction and deletion, etc. It may happen that we need to update or change the Privacy Policy from time to time. If the changes are material, we will inform you in an appropriate manner and ask you to take note of the changes that have been made. The latest version of the Privacy Policy can always be found on our website (
www.vetathome.se). We hope that this Privacy Policy answers your questions about our processing of your personal data. If you have any further questions or concerns, you are always welcome to contact us at VetAtHome, Attn: Data Protection Officer, Box 55997, 102 16 STOCKHOLM, or by contacting us or our Data Protection Officer at
data protection officer@vetathome.se.
2 How we process your data
How we collect your information
We collect your information directly from you when you download the Platform and create an account or otherwise use our digital healthcare services (the ”Services”). If you consent, we may also access your medical records from another healthcare provider through consolidated medical records. The purpose of this is to be able to provide your animal with the correct diagnosis and care and to avoid repeating your animal’s medical history. You always have the right to object to consolidated medical records. When you register, we may also retrieve your information via the electronic identification service you use or the population register.
Purposes of processing, legal basis and retention period
Your personal data will not be used in a manner incompatible with the purposes for which the data was collected. We process your data for the purposes set out below.
Provide you with your user account
In order to provide you with our Services, you need to create a user account. We use your information to verify your identity, provide you with your user account, and communicate with you about your issues you create with us. To do this, we need the following personal information that belongs to you (“User Data”).
- Name, social security number, address and other contact information, including email address and telephone number;
- Your use of our Platform, including personal settings and preferences, such as whether you wish to receive marketing from us.
The legal basis for processing your personal data for this purpose is that it is necessary for us to perform our obligations under our contract with you. We process your personal data for this purpose for as long as you have an account with us.
Provide care and fulfill our legal obligations as healthcare providers
We also use your personal data, including your User Data, to provide your animal with medical care and make medical diagnoses and to keep records. When you have opened a case with us, we ask you questions to make medical assessments of your animal and provide you with advice. For these purposes, you can provide symptom descriptions and other information about your animal's health, including photographs of the animal's ailments. We also process your personal data in order to be able to send an invoice. The legal basis for the processing of personal data for this purpose is that it is necessary to be able to provide you with animal care and for us to be able to fulfill our legal obligations as a healthcare provider. After your case has been closed, information about your animal care is transferred to your medical record. Correspondence in the Platform is saved for 48 hours and then deleted.
Communicate with you about our business
We use your User Data for the purpose of sending you direct marketing and information regarding our Services and important events with us. Direct marketing refers to all types of outreach marketing measures, such as mailings by post, email and text message. You have the right to object free of charge to your data being used for such purposes and each electronic mailing from us for marketing purposes contains an opportunity to unsubscribe, so-called opt-out. The legal basis for the processing of personal data for this purpose is that it is necessary to fulfill our legitimate interest in marketing our services to you as a customer with us during our contractual relationship. We process your personal data for this purpose as long as you have an account with us and for a further year after you have closed your account with us. You can unsubscribe from such mailings at any time.
Provide support
We also use your User Data to assist you if you contact us for support matters, e.g. if you have questions regarding our Services or your account. We use your personal data to identify you, communicate with you regarding your questions, and investigate any complaints or support matters. The legal basis for processing personal data for this purpose is that it is necessary to fulfill our and your legitimate interest in providing you with support. We process your personal data for this purpose for as long as the support matter is ongoing and we delete the data thereafter.
Improve our Services
We process your User Data to improve our Services. When we use your data for this purpose, we use it in aggregate form (i.e. studying overall usage patterns using de-identified data) to the extent possible. We process the data by producing statistics on how you use our Services. We may do this, for example, by conducting user satisfaction and market surveys or by analyzing your use of the Services. We also use your data to make the Services more user-friendly, e.g. to troubleshoot, fix bugs, change the interface so that you can easily access the information you are looking for or highlight features in our Services that are frequently used by our users. For this purpose, we may also process your IP number. The legal basis for the processing of personal data for this purpose is that it is necessary for our legitimate interest to continuously improve the Services. We process your personal data for this purpose for two years from the date the data was collected.
Prevent abuse
Your personal data may also be used to prevent misuse of our services or to prevent, prevent or investigate crimes against us. Abuse includes, but is not limited to, fraud, spam, harassment, attempts to gain unauthorized access to user accounts, and other actions that are prohibited by our terms and conditions or by law. The legal basis for processing personal data for this purpose is that it is necessary for our legitimate interest in preventing misuse of our services or to prevent, prevent or investigate crimes against us.
Fulfill legal obligations
We may also process your personal data in order to comply with our legal obligations under law, court orders or regulatory decisions. The legal basis for processing personal data for this purpose is that it is necessary for us to comply with our legal obligations or necessary to provide veterinary care.
How we share your information
We do not share your information with any third parties except as described below.
Other healthcare providers in case of coherent record keeping:
If you seek veterinary care from a healthcare provider other than us, they may, during an ongoing patient relationship with you, gain access to your animal's medical records that we have through integrated medical records. The purpose of this is to be able to provide you with the correct diagnoses and veterinary care and to avoid repeating your medical history. In order for your healthcare provider to be able to access your personal data through integrated medical records, you need to give your consent to your healthcare provider. You always have the right to object to integrated medical records and to have us block your medical records from being included in integrated medical records.
Our suppliers:
We may use third parties to manage one or more aspects of our business, including our processing of personal data. We may share personal data with these third parties in order for them to perform services on our behalf, such as sending you messages and marketing communications, storing our data and providing other IT services to us. When we use suppliers under this section, we will establish data processing agreements and take other appropriate measures to ensure that your personal data is processed in a manner consistent with this Privacy Policy.
Sale or transfer:
We may transfer or disclose your personal information to a buyer or prospective buyer in the event of a sale, assignment or other transfer of all or part of our business or assets. In the event of such a transfer, we will take reasonable steps, such as using confidentiality and assistance agreements, to ensure that the receiving party processes your information in a manner consistent with this Privacy Policy. We may also share your personal information with, for example, the police, tax authorities or other authorities when we are required to do so by law.
3 How we protect your information
We take appropriate safeguards and maintain security standards to protect your personal data against unauthorized access, unauthorized disclosure and misuse by, among other things, using authorization restrictions for access to your data. Your personal data is stored in files that are only accessible to our employees, agents and service providers who need the data for the performance of their duties. We use technical tools such as firewalls and passwords, and we ensure that our employees are trained in the importance of maintaining security and confidentiality in relation to the personal data we process and ensure that confidentiality agreements are in place. As a healthcare provider, we are also obliged to maintain confidentiality for personal data stored in your patient record. Only our employees who need the data to participate in your care or for their work in healthcare are allowed to see it.
4 Where we process your personal data
We always process your data within the EU/EEA. We aim to always process your other personal data such as your User Data within the EU/EEA where all of our own IT systems are located. However, such personal data may be shared with suppliers to us who are either themselves or through subcontractors established or store information in a country outside the EU/EEA. In such a case, we will take all reasonable legal, organizational and technical measures required to ensure that the level of protection for the processing corresponds to that within the EU/EEA. Such a level of protection exists, among other things, if the country in question already ensures an adequate level of protection according to a decision from the EU Commission or by us using other appropriate protective measures such as standard contractual clauses or approved codes of conduct in our agreements with such suppliers. You can read more about which third countries the EU Commission has assessed as ensuring an adequate level of data protection at
https://ec.europa.eu/info/law/law-topic/data-protection_sv.
5. Your rights
This section describes the rights you have as a data subject. You can always exercise these rights by contacting us at
data protection officer@vetathome.se.
The right of access, your medical record and information about accessing your personal data
If you would like to receive information about what personal data we process about you, you can request access to the data. The information will then be provided in the form of a register extract stating what personal data we process, for what purposes we process it, where the data has been obtained from, which third parties the data has been transferred to and how long the data will be stored. You also have the general right to access your animal's medical records. You also have the right to receive information about access to your personal data in your medical record, including what direct access and other electronic access to your medical record has occurred.
The right to rectification
You have the right to have incorrect information about you corrected without delay. You also have the right to complete incomplete information.
The right to block
You have the right to block information in your medical record, which means that no other healthcare provider can access it, e.g. in the case of consolidated medical records.
The right to erasure
You have the right to have your personal data erased by us under certain circumstances, if the personal data is no longer necessary to fulfil the purposes for which it was collected or processed, if the personal data processing is based on your consent and you withdraw this, if you have objected to the processing of personal data and we do not have a legitimate interest that outweighs your interest, if the personal data has been processed unlawfully or if the personal data must be erased for compliance with a legal obligation. However, we have the right to object to the erasure of your personal data in certain cases and we will inform you if this is applicable.
The right to restriction of processing
You have the right to request that we restrict the processing of your personal data in certain cases if you contest the accuracy of the personal data during the time it takes for us to verify whether the data is accurate, if the processing is unlawful and you oppose the erasure of the data and instead request a restriction, if we no longer need the personal data but you need them to establish, exercise or defend legal claims or if you have objected to processing based on our legitimate interest during the time we verify whether our interest outweighs your interests.
The right to object
You have the right to object to the processing of your personal data based on our legitimate interests. If so, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
The right to data portability
If we process your personal data on the basis of a contract with you or your consent, you have the right to receive the personal data you have provided to us and which concerns you in an electronic format that is commonly used, where technically feasible and this can be done by automated means. You have the right to transfer such data to another controller, where applicable (data portability).
The right to file a complaint
The Swedish Data Protection Authority is the authority responsible for monitoring the application of the legislation among companies that process personal data. If you believe that we are processing your personal data incorrectly, you can, in addition to contacting us, file a complaint with the Swedish Data Protection Authority. If you have any questions or comments, please contact us at
data protection officer@vetathome.se.
