Information We Collect and How We Use It
We collect and store information, including information by which you can be personally identified (‘Personal Information’), such as name, postal address, e-mail address, and phone number. This information is voluntarily supplied to us by you when registering or when using the Services. Some such information, such as your e-mail address credentials is required in order for you to register as a user of the Services. You can choose not to provide Embark with certain information, but by doing so, you may not be able to take advantage of many of our Services.
We also collect and store information that is automatically generated when you use the Services, including through the use of ‘cookies’ or other tracking technologies. A cookie is a piece of alphanumeric data stored on a visitor’s hard drive or device to help us improve your access to our Services and identify repeat visitors to our Site or Embark Applications. Cookies enable us to customize and enhance the user experience on our Site or Apps. Information collected automatically may include details of your visits to our website and use of our Services, information about your computer and internet connection, including IP address browser type, referring domains, pages visited, your mobile carrier, device and application IDs, and the nature of your use of the Services. The information we collect automatically may include Personal Information or we may associate it with Personal Information we collect in other ways or receive from third parties.
In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We use the information we collect to deliver the Services and relevant information to you, including advertising, to improve our Services, and to develop analytics and aggregated data that allow us to utilize and enhance our Services and make future marketing efforts more efficient.
Disclosure of Information to Third Parties
We may disclose aggregated information about our users and information that does not identify any individual without restriction.
We may share your Personal Information the following situations:
- With your consent.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
If we believe it is necessary to investigate potential violations of our terms and conditions applicable to the Services, to enforce those terms and conditions, to comply with law or to protect ours or others rights, property, or safety.
- To Service Providers, or authorized agents who are employed by us to perform tasks on our behalf and need to share information with them to provide products and services to you. Unless we communicate with you differently, our authorized agents do not have the right to use any Personal Information we share with them beyond what is necessary to work with us.
- To third-party partners (“Partners”) that assist us with our marketing efforts, and, subject to your right to opt-out, with other marketers whose products or services may be of interest to you. We may collect your email address via cookies and pixels on the Website through the use of trusted third party partners. These partners may also combine your email information with other information they have access to such as a mailing address so that we may serve relevant marketing offers to you via email and direct mail. If you prefer that we do not share your name and address with other marketers, please email us at email@example.com.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may also provide non-personally identifiable information, or aggregated information that does not identify you, to other parties, such as Google Analytics, for analytics, marketing, advertising, or other uses.
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company [has/ has not] disclosed personal information for a business purpose[ to the categories of third parties indicated in the chart below].
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|A: Identifiers.||Service Providers||Partners|
|B: California Customer Records personal information categories.||Service Providers||Partners|
|C: Protected classification characteristics under California or federal law.||None||None|
|D: Commercial information.||Service Providers||Partners|
|E: Biometric information.||None||None|
|F: Internet or other similar network activity.||Service Providers||Partners|
|G: Geolocation data.||None||None|
|H: Sensory data.||None||None|
|I: Professional or employment-related information.||None||None|
|J: Non-public education information.||None||None|
|K: Inferences drawn from other personal information.||None||None|
Your Rights and Choices
Residents of certain jurisdictions have specific rights regarding their personal information. Embark has made it company policy to extend those same choices to all of its users. This section describes these rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you (also called a data portability request).
[We do not provide a right to know or data portability disclosure for B2B personal information.]
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
Emailing us at firstname.lastname@example.org
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, the authorized agent must first provide a copy of either (a) a letter signed by the customer authorizing the agent to submit a request on his or her behalf, or (b) a valid power of attorney. An authorized agent must email one of these documents to email@example.com and include a phone number where the agent may be reached during regular business hours.
You may also make a request to know or delete on behalf of your child by following this same process.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
Date of Birth
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact firstname.lastname@example.org.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by e-mailing email@example.com.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Embark is committed to protecting the security and privacy of your Personal Information. Embark uses commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and thus we cannot guarantee the absolute security of your Personal Information or any other information you provide to us.
Our Services are not directed to people under 18 years of age. If you become aware that your child has provided us with Personal Information without your consent, please Contact Us at firstname.lastname@example.org. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we take steps to remove that information and terminate the applicable account.
Third-Party Links, Websites, and Apps
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, financial account information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through the Site or Apps or otherwise to us. You should provide financial information only to the third party payment processor that we utilize on our Site.
Terms of Service
Please also note that your use of our Services and products is subject in all respects to the terms and conditions of service as we may require of our users from time to time, including limitations on liability and agreement to arbitrate. The current terms of service may be viewed at https://embarkvet.com/tos