1. Why this Privacy Policy?

Any person (hereinafter referred to as the "User" or "You") visiting and/or using our various websites related to Tipaw services (hereinafter referred to as the "Site") or using our Tipaw services, discloses a number of personal data. Personal data are information that allows us to identify you directly or indirectly as a natural person.

We collect and process your personal data in accordance with the Belgian Law of 30 July 2018 on the protection of privacy with regard to the processing of personal data ("Privacy Law") and the European Regulation of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("Regulation" or "GDPR").

By using the Site or our services, the User declares to have read this Privacy Policy and expressly accepts the collection and processing of your personal data as described in this document.

We reserve the right to make changes to our Privacy Policy at any time.

2. Who processes your personal data?

2.1. Data Controller

Flipaw is the data controller and determines the personal data that are collected, the purposes and means of the processing.

2.2. Processor(s)

Flipaw may use processors. The processor is the natural or legal person who processes your personal data at the request and on behalf of the data controller. The processor is required to ensure the security and confidentiality of your data and always acts on the instruction of the data controller.

Flipaw uses the following categories of processors: Hosting companies, CRM, social networks (Facebook for advertising), Amazon Web Services, Google Calendar, IT maintenance, password management software.

3. On what legal grounds are my data processed?

In accordance with the Privacy Law and the GDPR, we process your personal data on the following legal grounds:

Based on the performance of the contract to which you are a party or on contractual measures taken at your request for the use of our Site and the provision of our services.
Based on our legal obligations for all aspects concerning the management of the contractual relationship, including billing.
Based on our legitimate interest in sending information and newsletters to our customers.
Based on your explicit consent for sending promotional offers (direct marketing).

4. What personal data are collected?

The processing of your personal data is limited to what is strictly necessary to achieve the purposes pursued by Flipaw. Below are the categories of data concerned by the processing:

Personal identification data (name, first name, address, identifiers, VAT number, breeder approval numbers, CVs of veterinarians, photos)
Contact details (phone number and email address)
Financial identification data (banking details)
Electronic identification data (IP address, location, cookies)
Personal details (gender, age, date and place of birth, marital status, nationality)

Flipaw may obtain personal data through various means:

When you register and use our Site and/or services;
By filling out questionnaires (e.g., when you provide feedback or use our support function);
When you communicate with a breeder;
Via social networks (e.g., when you contact us on Facebook);
When connecting devices or third-party services to Flipaw (only when you have given explicit and prior consent), e.g., Google Calendar when making appointments via the Tipaw site;
By placing cookies (see our Cookie Policy).

In addition, we use cookies to recognize the User and provide a personalized user experience, remember choices, and detect and correct any errors on the Site. For more information on how we use cookies, please refer to our Cookie Policy.

5. What are the purposes pursued?

Flipaw collects your personal data to provide you with an optimal, personalized, and secure user experience. Therefore, the processing of your personal data is essential for the proper functioning of the Site and the provision of our services. If data is missing, incorrect, or incomplete, Flipaw reserves the right to suspend or cancel certain operations.

Flipaw undertakes to process your personal data exclusively for the following purposes:

Verification of the professional qualifications of breeders and veterinarians;
Customer management: customer administration, appointment scheduling, billing, solvency monitoring, providing support, handling complaints, and sending newsletters;
Allowing you to make appointments with one of our partner providers via Google Calendar;
Dispute management;
Protection against fraud and offenses;
Personalized marketing and advertising if you have expressly consented. In this case, you are free to withdraw your consent at any time.

By visiting our Site, certain data is collected for statistical purposes. This data allows us to optimize your user experience. By visiting the Site, you expressly agree to the collection of this data for statistical purposes.

6. Who receives your personal data?

Your personal data are intended for internal use. However, Flipaw reserves the right to sell, transmit, or disclose your personal data to third parties. By using our Site or services, you expressly consent to such potential transfer of data.

The data is stored on Flipaw's servers in Frankfurt, Germany, using Amazon Web Services. It can only be read by Flipaw and/or its employees who have the correct key.

Some of your data (name, first name, email address, phone number) is also sent to Google via the Google Calendar service. We use this service to allow you to quickly schedule appointments with our partner providers.

Additionally, Flipaw transfers adopters' contact details (name, first name, email address, phone number) to its partners.

Flipaw does not transfer your data outside the European Union.

7. How long are your data retained?

Your data is kept for as long as necessary to achieve the purposes pursued. It will be erased from our database as soon as it is no longer needed for the intended purpose or if you have validly exercised your right to erasure.

8. What are your rights?

8.1. Guarantee of fair and lawful processing

Your personal data is always processed in accordance with the legitimate purposes explained in point 5. It is collected and processed appropriately, relevantly, and not excessively, and is not kept longer than necessary to achieve the purposes pursued.

8.2. Right of access

If you can prove your identity, you have the right to obtain information about the processing of your data. You have the right to know the purposes of the processing, the categories of data concerned, the recipients or categories of recipients to whom the data are disclosed, the criteria used to determine the data retention period, and the rights you can exercise over your data.

8.3. Right to rectification

Inaccurate or incomplete personal data can be corrected either directly by the User on their user profile or by making a written request to us at info@tipaw.com.

8.4. Right to erasure (or "right to be forgotten")

You have the right to obtain the erasure of your personal data in the following cases:

Your personal data is no longer necessary for the purposes;
You withdraw your consent to the processing, and there is no other legal ground for processing;
You have validly exercised your right to object;
Your data has been unlawfully processed;
Your data must be erased to comply with a legal obligation.

8.5. Right to restriction of processing

In certain cases, you have the right to request the restriction of the processing of your personal data, especially if you contest the accuracy of the data, if the data is necessary for legal proceedings, or the time needed for Flipaw to verify that you can validly exercise your right to erasure.

8.6. Right to object

You have the right to object at any time to the processing of your personal data for direct marketing purposes, profiling, or for the legitimate interests pursued by the data controller. Flipaw will cease processing your personal data unless it demonstrates compelling legitimate grounds for the processing which override your right to object.

8.7. Right to data portability

You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. Upon your request, this data can be transferred to another provider, unless it is technically impossible.

8.8. Right to withdraw your consent

You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.

9. Security measures

In accordance with the Data Privacy Law and GDPR, Flipaw undertakes to implement technical and organizational measures ("security measures") to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, and against all other unlawful forms of processing or use.

These security measures ensure a level of security appropriate to the risk associated with the processing. To determine adequate security measures, Flipaw considers the state of the art, implementation costs, the nature, scope, context, and purposes of processing as well as the risks to the rights and freedoms of individuals.

Flipaw makes every reasonable effort to ensure that its processing systems and services meet ongoing confidentiality, integrity, availability, and resilience requirements, considering the state of the art and implementation costs.

10. Notification of a data breach

Under the Data Privacy Law and GDPR, Flipaw notifies the User of any personal data breach without undue delay and no later than 24 hours after becoming aware of it. This notification is accompanied by any relevant documentation to enable the User, if necessary, to notify this breach to the data protection authority and/or the individuals concerned. Flipaw provides the User with the following information: the nature of the personal data breach, the categories and approximate number of data subjects concerned, the categories and approximate number of personal data records concerned, the likely consequences of the data breach, and the measures taken or proposed to remedy the data breach or mitigate its possible adverse effects.

Flipaw notifies the data breach on behalf and for the account of the User to the supervisory authority without undue delay and, where feasible, not later than 72 hours after becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of individuals.

Flipaw notifies the data breach on behalf and for the account of the User to the individuals concerned without undue delay, if the breach is likely to result in a high risk to the rights and freedoms of individuals.

The decision to notify the data protection authority and/or individuals concerned of a data breach rests with Flipaw.

11. How to exercise your rights

To exercise your rights, you must send us a written request and proof of identity by registered mail to FLIPAW S.A., Avenue de la sapinière 51B -1180 Uccle or by email to info@tipaw.com. We will respond as soon as possible, and no later than one (1) month after receiving the request.

12. Right to lodge a complaint

If you are not satisfied with the processing of your personal data by Flipaw, you have the right to lodge a complaint with the Data Protection Authority (https://www.autoriteprotectiondonnees.be/).

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