Privacy Policy

Last Updated: October 2018

This Privacy Statement explains how user information is collected, used and disclosed by Gula (also referred to as “we” or “us”). This Privacy Statement applies to information collected when you use our website and mobile application (the “Services”) or when you otherwise interact with us.

This Privacy Statement may be altered from time to time. We will notify you by revising the date at the top of the Privacy Statement. We will notice you or obtain consent regarding material changes to this statement as may be required by law.

Collection of Information

We collect information about you in various ways when you use our Services, including information you provide directly and information collected automatically. Information about you is collected and processed with your consent and/or as necessary to provide the products and services you use, operate our business, meet our contractual and legal obligations, and protect the security of our systems and our customers.

Information You Provide to Us

We collect information when you create an account, make a payment, write a review, or participate in any other interactive feature of the Gula. This consists of basic user information (such as your name, email address, address, phone number, photos, gender, and date of birth); pet information (such as breed, age, photos, veterinarian, and immunization status); and any other information you choose to provide.

Limited payment information may also be collected and stored, such as payment card type, expiration date and a part of your payment card number; however, we do not store full payment card numbers as all transactions are processed by our third-party payment processors. If you are a Service Provider, we and our third-party payment processors may also collect certain payment disbursement information to pay you for the Services you provide via Gula.

If you are a Service Provider, we and our third-party service providers may also collect certain personal information from you for purposes of verifying your identity or conducting a background check.

Information We Collect Automatically When You Use the Services

We automatically collect the following information about you when you access or use Gula:

  • Log Information: type of browser you use, access times, pages viewed and your IP address.
  • Device Information: computer or mobile device you use to access our Services, including the hardware model, operating system and version.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to operate our website, including cookies and web beacons (collectively, “Cookies”). Most browsers are set to accept cookies. Please read the Cookie Policy for details about how we use Cookies and how to manage your preferences.

Other Sources

If you create or log into your account through a social media site or email service, we will have access to certain information from that site, such as your full name and email address, in accordance with the authorization procedures determined by such social media site.

Use of Information

We may use information about you for various purposes, including to:

  • Provide, maintain and improve our Services;
  • Facilitate and process payments and their respective confirmations;
  • Enable communications between you and other users of Gula;
  • Send you technical notices, updates, security alerts and support messages;
  • Provide customer service;
  • Monitor and analyze trends, usage and activities related to Gula;
  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Gula and others.

Sharing of Information

We may share with third parties information about you, including your personal data and communications, as follows:

  • When you make or receive a video consultation, certain information is shared between the pet owner and vet, including names, pet information and any other information you choose to share through the Services;
  • Certain information about you may be displayed to other users, such as your name and photo;
  • Consultants or service providers may require such information to carry out work on our behalf;
  • In response to a request for information in accordance with, or required by, any applicable law or legal process;
  • In connection with any merger, sale of company assets, acquisition, divestiture, financing, bankruptcy, dissolution, or other transaction or proceeding involving sale, transfer or divestiture of all or a portion of our business or assets to another company;
  • Between and among Gula and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
  • With your consent or at your direction.

Security

Gula takes reasonable measures designed to help protect information about you from loss, theft, misuse and unauthorized access, use, disclosure, alteration and destruction.

Transfer and Location of Information

The information we collect may be stored and processed in your region, or in any other country where we or our affiliates, or service providers maintain facilities. The locations are chosen to ensure efficient operations, improve performance, and to create back ups.

We transfer information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections.

Retention of Information

Information is kept as long as necessary to provide the products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different information types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the information, the availability of automated controls that enable users to delete information, and our legal or contractual obligations.

Your Choices

Account Information

You may request to update, correct or delete information about you at any time by logging into your online account. If you cannot do so from your account, you may contact us. We may decline requests that are unreasonable, excessive, prohibited by law, could adversely affect the privacy or other rights of another person, where we are unable to authenticate you as the person to whom the information relates, or are not required to be honored by applicable law. We may also retain cached or archived copies of information about you for a certain period of time.

Mobile Push Notifications/Alerts

With your consent, we may send push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. If you are a Service Provider, however, certain features may require that you accept mobile app push notifications or alerts. If you do not want to receive these push notifications or alerts, then, in addition to adjusting the notifications in your mobile device, you must withdraw from providing such services or using such features. Further information about required acceptance of push notifications and alerts by Service Providers can be found in the Terms of Service applicable to your location (or as communicated to you elsewhere via the Gula Service).

Text Messages

As permitted by applicable law, we may send marketing and/or service-related text messages to your mobile device. You may opt out of receiving some or all of these messages by updating your “Notifications” preferences under “Account Settings” in your online Gula profile. If you are a Service Provider, however, certain features may require you to receive service-related messages by text. If you do not want to receive these service-related text messages, then, in addition to adjusting your Notifications preferences, you must withdraw from providing such services or using such features. Further information about required acceptance of text messages by Service Providers can be found in the Terms of Service applicable to your location (or as notified to you elsewhere via the Gula Service).

European Data Protection Rights

If the processing of information about you is subject to European Union data protection law, you have certain rights with respect to that information:

  • You can request access to, and rectification or erasure of, information;
  • If any automated processing of information is based on your consent or a contract with you, you have a right to transfer or receive a copy of your information in a usable and portable format;
  • If the processing of information is based on your consent, you can withdraw consent at any time for future processing;
  • You can object to, or obtain a restriction of, the processing of information under certain circumstances.