Data Privacy Notice

This privacy notice is relevant to all clients of My Home Vet (‘Client Relationship”).

In this Notice certain other defined terms appear, whose meaning is as follows:

• A Client Relationship or a Vendor Relationship shall be a “Business Relationship”;
• “Business Relationship Contract” shall mean a fee agreement (between My Home Vet and its client) or a vendor agreement (between My Home Vet and its vendor); and
• “Data Subject” refers to the natural person to whom the Personal Data relates.

The Cayman Island introduced the Data Protection Law in 2017. Under this law, My Home Vet is considered to be a controller in the course of its business.

This Notice outlines My Home Vet’s data protection obligations, and your data protection rights as they relate to your Business Relationship with My Home Vet.

Below is My Home Vet policy statement of how it complies with the Data Protection Law in relation to such Personal Data.

In the usual course of My Home Vet’s business, it collects and uses certain personal information which constitutes Personal Data. This includes, but is not restricted to, data such as name, residential address, email address, telephone number, and payment information. Email correspondence may also be maintained to support the ongoing delivery of services to your pet.

My Home Vet will only collect, store and use this Personal Data for lawful purposes including, in particular:

(i) Where this is necessary for the performance of the Business Relationship Contract;

(ii) Where this is necessary for compliance with any legal obligation to which My Home Vet is subject; or

(iii) Where this is necessary for the purposes of the legitimate interests of My Home Vet and such legitimate interests are not overridden by your interests, fundamental rights or freedoms.

Analysing Personal Data for quality control, business and statistical analysis, tracking fees and costs, training and related purposes are considered legitimate interests for using your Personal Data. Any such use of your

Personal Data in this way is subject to any relevant overriding prohibitions or restrictions in such use by My Home Vet in the Business Relationship Contract.

My Home Vet may use your Personal Data for such purposes as described above, provided that it is acting in a fair, transparent and accountable manner and has taken appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such use, as discussed below.

My Home Vet is required to use your personal data to fulfill its obligations defined in the Business Relationship Contract, and under the provisions of the Cayman Islands Data Protection Law, My Home Vet is not required to obtain your consent to do so. Should My Home Vet wish to use your Personal Data for other specific purposes that require your consent, then My Home Vet will contact you to request this.

My Home Vet do not sell or distribute any personal information to third parties for the purposes of direct marketing.

It may be necessary for My Home Vet to transfer Personal Data for processing to agents, delegates, subcontractors or other representatives of My Home Vet to carry out sub-processing activities on behalf of My Home Vet (each a “Permitted Processor”) under an appropriate agreement between the Permitted Processor and My Home Vet. A list of the My Home Vet Permitted Processors is available on request.

My Home Vet may only transmit Personal Data:

• To Permitted Processors with the prior consent of the counterparty to the Business Relationship Contract (“Counterparty”); or
• Where required to do so under applicable law.

In addition, it may be necessary for My Home Vet to transfer Personal Data to certain third parties, upon the instruction of the Counterparty, whose involvement is necessary to carry out all or part of My Home Vet’s duties and obligations defined in the Business Relationship Contract. In these cases, the third party will not be a Permitted Processor of My Home Vet and will instead be engaged directly by the Counterparty as a processor.

Where My Home Vet is required to transfer Personal Data to a legal, or regulatory authority under applicable law any such transfer shall not constitute the engagement of a Permitted Processor by My Home Vet.

Subject to applicable provisions of the Cayman Islands Data Protection Law, the Personal Data shall not be shared other than has been described here.

My Home Vet operates an Information Security Policy framework that includes a specific policy on Data Protection. All My Home Vet employees attend annual training to ensure compliance with these policies.

My Home Vet shall apply and shall contractually obligate Permitted Processors to apply appropriate information security measures to protect Personal Data from unauthorised access by third parties or any form of computer corruption.

My Home Vet shall notify you of any Personal Data breach affecting you that is likely to result in a high risk to your rights and freedoms.

You have certain rights regarding My Home Vet’s use of your Personal Data such as:

• the right to access your Personal Data (in an easily readable form);
• the right to examine and correct your Personal Data;
• the right to restrict the use of your Personal Data;
• the right to withdraw any consent given to the processing of your Personal Data (where applicable);
• the right to receive information regarding any entities My Home Vet discloses your Personal Data to;
• the right to lodge a complaint with the Cayman Islands Ombudsman, in accordance with the law.

These rights may be restricted either by local legal obligations or to safeguard the fundamental rights and freedoms in a democratic society.

My Home Vet or Permitted Processors may retain your Personal Data following the conclusion of your Business Relationship with My Home Vet for such minimum period as may be required by applicable laws.

As My Home Vet does not control or process Personal Data on a large scale, My Home Vet is not required to designate a data protection officer. However, an individual has been designated as a Responsible Person for each of:

• The receipt of any queries relating to data protection or in the event a Data Subject wishes to discuss his/her data protection rights with My Home Vet (“General Queries”); and
• Communicating with the relevant supervisory authorities (“Regulatory Communications”).

The Responsible Person for My Home Vet can be contacted at the following email address dataprotection@myhomevet.ky