SUPPLEMENTAL PRIVACY NOTICE FOR RESIDENTS OF

CALIFORNIA, COLORADO, TEXAS, AND UTAH

Last Updated On: June 30, 2024

Certain states, including require additional information regarding our privacy practices and your privacy rights. Depending on whether you are a resident of those states (“Consumer” or “you”), we provide you additional notices about our privacy practices and consumer rights relating to your personal information or personal data, as defined under those laws (“Personal Information”). Veterinary Growth Partners (“Company” or “we”) provide this Supplemental Privacy Notice for Residents of California, Colorado, Texas, and Utah (the “State Privacy Notice”) to supplement the information contained in the Veterinary Growth Partners’ Privacy Policy.  Where we specifically identify certain states, these additional disclosures apply to residents in those states.

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. For job applicants, please see here. For employees, please refer to the company’s intranet site.

INFORMATION WE COLLECT

We collect Personal Information as identified under applicable consumer privacy laws, including information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

Under Colorado law, Personal Information also excludes information that you have lawfully made available to the general public.

Under Texas and Utah law, Personal Information also excludes information that publicly available, including from sources other than government records.

In particular, we have collected and/or processed the following categories of personal information from consumers:

Category	Examples	Collected
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, professional license identification numbers and related information, 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.	YES
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.	YES
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 obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.

Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

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.

Sharing Personal Information

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, the Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

In the preceding twelve (12) months, Company has sold personal information as noted below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	service providers (i.e. third parties that perform services to support our core business functions and internal operations), third party partners (such as advertising and analytics providers), advertising networks, and social media networks.	Yes
B: California Customer Records personal information categories.	service providers, third party partners, advertising networks and social media networks	Yes
C: Protected classification characteristics under California or federal law.	None	None
D: Commercial information.	Service Providers, Third Party Partners, advertising networks, and social media networks	Yes
E: Biometric information.	None	None
F: Internet or other similar network activity.	Service Providers, Third Party Partners, advertising networks, and social media networks	None
G: Geolocation data.	Service Providers and Third Party Partners	None
H: Sensory data.	Service Providers who help administer customer service and fraud or loss prevention services	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

We may disclose personal information to our corporate affiliates, including our parent company, sister companies, and subsidiaries including Pathway Vet Alliance LLC d/b/a Thrive Pet Healthcare and Vetspire LLC, either with your consent or as permitted or required by applicable law. Such corporate affiliates may process personal information on our behalf as our service providers, where necessary to provide a product or service that you have requested or in other circumstances.

Your Rights and Choices

State consumer privacy laws provide specific rights regarding their residents’ Personal Information. This section describes those rights and explains how to exercise those rights.

If you are a Colorado resident, applicable law provides the following rights:

1. To confirm whether or not a controller is processing your Personal Information and to access such Personal Information;

2. To correct inaccuracies in the your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information;

3. To delete Personal Information provided by or obtained about you;

4. To obtain a copy of your Personal Information that you previously provided to the Company in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and

5. To opt out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

If you are a California resident, applicable law provides you with the following 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, 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).

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, 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.

1. 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.

2. 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.

3. 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.

If you are a Texas resident, applicable law provides the following rights:

1. To request that a business confirms whether it is processing your personal data and to access any such personal data.

2. To correct inaccuracies in your personal data.

3. If the data is available in a digital format, to obtain a copy of your personal data in a portable, and to the extent possible, readily usable format that allows you to transmit the data to another controller without hindrance.

4. To opt out of the processing of your personal data for pruposes of targeted advertising, the sale of personal data, or profiling in furtherance o fa decision that produces a legal or similarly significant effect.

If you are a Utah resident, applicable law provides the following rights:

1. To confirm whether or not a controller is processing your Personal Information and to access such Personal Information;

2. To delete Personal Information provided by or obtained about you;

3. To obtain a copy of your Personal Information that you previously provided to the Company that, to the extent technically feasible, is portable; to the extent practicable, is readily usable; and  allows you to transmit the data to another controller without impediment, where the processing is carried out by automated means; and

5. To opt out of the processing of your Personal Information for purposes of (i) targeted advertising, or (ii) the sale of personal data.

Exercising Your Rights to Know or Delete

Residents of California, Colorado, Texas, or Utah can exercise their rights to know or delete described above, by submitting a request by either:

• Calling us at +1.833.452.1839

Emailing us at privacy@vgpvet.com

If you are a Texas resident and you wish to appeal a decision by us to take action on a request for information, you may contact us by any of the methods listed above.  

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by contacting us via the methods above.

Your request must specify the right you intend to exercise.

If you are a Colorado resident, you may exercise your right to confirm whether we are processing your Personal Information and to access your Personal Information at no charge to you up to 2 times per calendar year.  If you make a request more frequently than 2 times per calendar year, we may charge you a reasonable fee to cover the administrative costs of complying with your request or we may decline to act on the request.  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.

If you are a California or Texas resident, you may only submit a request to know twice within a 12-month period.  For California and Texas residents, 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.

If you are a Utah resident, the Company may charge a fee for information in response for a request if you have made a previous request within the last 12 months.  The Company may also charge a reasonable fee to compensate it for the administrative cost of responding to a request or refuse to act on a request if:    (a) the request is excessive, repetitive, technically infeasible, or manifestly unfounded; (b) the Company reasonably believes the primary purpose in submitting the request was something other than exercising a right; or (c) the request, individually or as part of an organized effort, harasses, disrupts, or imposes undue burden on the resources of the Company’s business.

If you are a resident of California, Colorado, Texas, or Utah 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:

• submitting the request through our password-protected account.
• Applicable verification requirements as communicated to you by us.
• Parents or guardians submitting the request on behalf of a minor child must sign a verification form under penalty of perjury and return it to Veterinary Growth Partners via postal mail, facsimile, or electronic scan.

• 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.

.

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 privacy@vgpvet.com

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.

If you are a California resident, 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.

If you are a Colorado or Utah resident, If we decide not to take action on your request, we shall inform you within forty-five (45) days of the reason for that decision. You may appeal that decision by sending an email to privacy@vgpvet.com with “Data Request Appeal” in the subject line, and attach or reference the decision you’re appealing.

For data portability requests by residents of California, Colorado, or Utah 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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are a California resident 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 visiting the following Internet Web page link:

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at privacy@vgpvet.com.

If you are a resident of Colorado or Utah, you may opt out of the processing of your personal data for the purposes of (i) targeted advertising or (ii) the sale of personal data.  Additionally, if you are a resident of Colorado, you may also opt out of the processing of your personal data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.  

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by:

• Calling us at +1.833.452.1839
• Emailing us at privacy@vgpvet.com

To exercise your opt-out rights under California, Colorado, or Utah law, 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.

Non-Discrimination

If you are a California resident, 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@vgpvet.com

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Veterinary Growth Partners collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone:         +1.833.452.1839

Email:                 privacy@vgpvet.com

Postal Address:

Veterinary Growth Partners
Attn: Privacy Statement
211 Walter Seaholm Drive, Suite 200
Austin, TX 78701

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@veterinarygrowthpartners.com.