This Privacy Policy was last updated on February 21, 2021.

Thank you for joining the world’s largest online learning store. At Vets Pharma and (“Vets Pharma”, “we”, “us”, “us”), we respect your privacy and want you to understand how we collect, use and share data about you. This Privacy Policy addresses our data collection practices and describes the user’s rights to access, correct or restrict our use of the user’s personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy will apply when you visit or use the Vets Pharma website, mobile applications, APIs or related services (the “Services”).

By using the Services, you agree to the terms of this Privacy Policy. You should not use the Services if you do not agree to this Privacy Policy or any other agreement governing your use of the Services.

1. What data we collect

We collect certain information from you directly, such as information you enter on your own, such as information about your participation in courses. We also collect some information automatically, such as information about your device and the parts of our Services that you interact with or spend time using.

1.1 Data you provide to us

We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.

When you create an account and use the Services, including through a third party platform, we collect data that you provide directly to us, including:

Account Data	In order to use some features (such as enrolling in a course), the user has to create a user account. When creating or updating the user’s account, we collect and store data that the user provides to us, such as email address, password, phone number, occupation, skill interests, gender, race, ethnicity, age, date of birth, and account settings, and assign a unique identification number (“Account Data”) to the user.
Profile Data	You may also choose to provide profile information, such as a photo, title, biography, language, website link, social media profiles, or other information. The User’s Profile Data will be publicly visible to other users.
Shared Content	Some parts of the Services allow the user to interact with other users or share content publicly, for example, by posting reviews on a course page, asking or answering questions, sending messages to students or instructors, or posting photos or other work that the user uploads. Such shared content may be publicly visible to other users depending on where it is posted.
Course Data	When you register for and take courses, we collect some data, such as courses, assignments and exams you have started and completed; course credits and purchases; subscriptions; course certificates; your exchanges with instructors, teaching assistants and other students; and assignments, answers to questions and other items submitted to fulfill course requirements. If the user is an instructor, we store course content that may contain data about the user.
Student Payment Data	If the user makes purchases, we collect some data about the purchases (such as the user’s name and zip code) as necessary to process the order. The user must provide some payment and billing information directly to our payment processing partners, such as the user’s name, credit card information, and zip code. For security reasons, Vets Pharma does not collect or store sensitive cardholder data, such as all credit card numbers or card authentication data.
Data about the user’s accounts on other services	We may obtain certain information through the user’s social networks or other online accounts if they are connected to the user’s Vets Pharma account. If you log in to Vets Pharma through Facebook or another third party platform or service, we will request your permission to access certain information about that other account. For example, depending on the platform or service, we may collect the user’s name, profile picture, account ID number, login email address, location, physical location of access devices, gender, birthday, and list of friends or contacts. These platforms or services make the information available to us through their APIs. The information we receive depends on the information the user (through their privacy settings) or the platform or service chooses to provide to us. If you access or use our Services through a third party platform or service, or click on any third party links, the collection, use and sharing of your data will also be subject to the privacy policies and other agreements of those third parties.
Sweepstakes, Promotions and Surveys	We may invite you to take a survey or participate in a promotion (such as a contest, sweepstakes or challenge), either through the Services or a third party platform. If you participate, we will collect and store any information you provide to us as part of your participation, such as your name, email address, mailing address, date of birth or phone number. Such data will be subject to this Privacy Policy, unless otherwise stated in the official rules of the promotion or other privacy policy. The data collected will be used to administer the promotion or survey, including to inform winners and distribute rewards. In order to receive a reward, you may be required to allow us to post some of your information publicly (such as on a winner’s page). When we use a third party platform to administer a survey or promotion, that third party’s privacy policy will apply.
Communications and Support	If you contact us for assistance or to report a problem or concern (whether or not you have created an account), we will collect and store your contact information, messages and other information about you, such as your name, email address, messages, location, Vets Pharma user ID, rebate transaction ID, and any other information you provide to us or that we collect through automated means (which we discuss below). We use this data to respond to you and to investigate your question or concern in accordance with this Privacy Policy.

We store the data listed above and associate it with the user’s account.

1.2 Data We Collect by Automated Means

When you access the Services (including browsing courses), we collect some data through automated means, including:

System Data	Technical data about your computer or device, such as IP address, device type, operating system type and version, unique device identifier, browser, browser language, domain and other system data, and platform types (“System Data”).
Usage Data	Usage statistics about user interactions with the Services, such as courses accessed, time spent on pages or the Service, pages visited, features used, search queries, clickstream data, date and time, referrers, and other data related to use of the Services (“Usage Data”).
Approximate Geographic Data	An approximate geographic location, including information such as country, city and geographic coordinates, calculated based on IP address.

The above data is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. We store them and associate them with the user’s account.

2. How we collect data about you

We will use tools, such as cookies, web beacons and similar tracking technologies to collect the above data. Some of these tools offer the ability to opt-out of data collection.

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files that your browser stores to collect, store and share data about your activities on websites, including on Vets Pharma. They also allow us to remember things about the user’s visits to Vets Pharma, such as language preference, and to facilitate use of the site. For more information about cookies, please visit https://cookiepedia.co.uk/all-about-cookies.

2.2 Why We Use Data Collection Tools

Vets Pharma uses the following types of Data Collection Tools for the purposes described below:

• Strictly Necessary: These Data Collection Tools enable the user to access the site, provide basic functionality (such as logging in or enrolling in courses), protect the site, protect against fraudulent logins, and detect and prevent misuse or unauthorized use of the user’s account. They are necessary for the Services to function properly, so if you disable them, some parts of the site will not function or be unavailable.
• Functional: These Data Collection Tools remember information about the user’s browser and preferences, provide additional features to the site, customize content to make it more relevant to the user, and remember settings related to the appearance and behavior of the Services (such as preferred language or video playback volume level).
• Performance: These Data Collection Tools help measure and improve the Services by providing performance and usage data, visit counts, traffic sources or where the application was downloaded from. These tools help us test different versions of Vets Pharma to find out what features or content users prefer and determine which emails are opened.
• Social Networking: These Data Collection Tools enable the operation of social networks, such as sharing content with friends and networks. These cookies may track a user or device on other sites and create a profile of the user’s interests for targeted advertising purposes.

You can set your web browser to alert you to attempts to place cookies on your computer, to limit the types of cookies you allow, or to refuse cookies altogether. If you do so, you may not be able to use some or all of the features of the Services, and your experience may be different or less functional. For more information about how to manage the Data Collection Tools, see Section 6.1 (User Choices Regarding Use of Your Data) below.

3. What we use user data for

We use user data to do things like provide our Services, communicate with you, troubleshoot problems, protect against fraud and misuse, improve and update our Services, analyze how people use our Services, deliver targeted advertising, and as required by law or as necessary for security and integrity.

We use the data we collect through your use of the Services to:

• Provide and administer the Services, including facilitating course participation, issuing course completion certificates, displaying personalized content, and facilitating communication with other users;
• Process requests and orders for courses, products, specific services, information or features that you make;
• Communicate with you about your account by:
  • Sending you push notifications to your wireless device to provide updates and other relevant messages (which you can manage on the options page);
  • Sending you information, via email or text messages, about your progress in courses, rewards programs, new services, new features, newsletters and other available courses (which you can opt out of at any time);
  • Send you administrative messages and information, such as notifications of changes to our Service and updates to our agreements;
  • Respond to your questions and concerns;
• Manage your account and account preferences;
• Facilitate the technical operation of the Services, including troubleshooting, securing the Services, and preventing fraud and misuse;
• Solicit feedback from users;
• Market and administer surveys and promotions administered and sponsored by Vets Pharma;
• Obtain more information about you by linking your data with additional data through third party data providers or analyzing data with the help of analytics service providers;
• Identify unique users across devices;
• Tailor ads across devices;
• Improve our Services and develop new products, services and features;
• Analyze trends and traffic, and track purchase and usage data;
• Advertise the Services on third-party websites and applications;
• As required or permitted by law; or
• If, in our absolute discretion, we deem it necessary to ensure the safety or integrity of our users, employees, third parties, the public or our Services.

4. Security

We will use appropriate security measures depending on the type and confidentiality of the data being stored. As with any system with an Internet connection, there is always a risk of unauthorized access, so it is important that you protect your password and that you contact us if you suspect unauthorized access to your account.

Vets Pharma takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal data that we collect and store. These measures vary depending on the type and confidentiality of the data. Unfortunately, however, no system can be completely secure, so we cannot guarantee that communications between you and Vets Pharma, the Services or any information provided to us in connection with data we collect through the Services will be free from unauthorized access by third parties. The user’s password is an important part of our security system, and it is the user’s responsibility to protect it. You should not share your password with any third party, and if you believe that your password or account has been compromised, you should change it immediately and contact our support team with your concerns.

5. User Rights

You have certain rights regarding the use of your data, including the ability to opt out of promotional emails, cookies and the collection of your data by certain third parties. You may update or cancel your account from within our Services, and you may also contact us to make individual rights requests about your personal data. Parents who believe that we have inadvertently collected personal information about their minor children should contact us to help us delete such information.

5.1 User Choices Regarding Use of Your Information

You may choose not to provide us with certain information, but you will not be able to use some features of the Services.

• To opt-out of receiving promotional communications from us, you may opt-out by using the unsubscribe mechanism included in the promotional communication you receive, or by changing your email preferences in your account. You should note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, such as administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• Your browser or device may allow you to control cookies and other local data storage. For more information on cookie management, please visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control the collection or sharing of location or other data.
• To opt out of allowing Google Analytics, use of your data for analytics or enrichment, the user can refer to the Google Analytics Opt-out Browser Add-on.
• Apple iOS, Android OS and Microsoft Windows provide their own instructions on how to control personalized in-app advertising. For other devices and operating systems, the user should review their platform privacy settings.

If you have any questions about your data, our use of your data, or your rights, please contact us at esantiago@kironmexico.com.

5.2 Accessing, updating and deleting the user’s personal data

The user can access and update his personal data that Vets Pharma collects and maintains as follows:

• To update the data that the user provides directly, you must log in to your account and update your account at any time.
• To cancel your account:
  • User should be aware that even after terminating User’s account, some or all of User’s data may still be visible to other users, including, but not limited to, data (a) that User or others have copied, stored or disseminated (including in course comments); (b) that User or others have shared or disseminated (including in User’s shared content); or (c) that has been posted on a third party platform. Even after terminating the user’s account, we will retain your data for as long as we have a legitimate purpose for doing so (and in accordance with applicable law), for example, to assist with legal obligations, resolve disputes, or enforce our agreements. We may retain and disclose such data in accordance with this Privacy Policy following termination of the user’s account.
  • If you are having trouble terminating your account, please contact our support team.
  • If you are a student, you should visit your profile settings page.
• To request access to, correct or delete the user’s personal data, please use our online form. You can also send an email to esantiago@kironmexico.com or write to us. It may take up to 30 days for a response. To protect you, we may ask you to submit the request using the e-mail address associated with your account, and we may need to verify your identity before processing the request. The user should note that we will retain some data if legally justified, for example, for mandatory record keeping and to carry out transactions.

6. Updates and Contact Information

When we make any material changes to this policy, we will inform users by email, in-product notice, or other mechanism required by law. Changes will be effective the day they are posted. You may contact us by email or by postal mail if you have any questions, concerns or disputes.

6.1 Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material changes to it, we will inform you by email, through a notice posted on the Services or as required by applicable law. We will also include a summary of the major changes. Unless otherwise stated, changes will be effective on the day they are posted.

To the extent permitted by applicable law, if you continue to use the Services after the effective date of any change, your access and/or use will be deemed an acceptance of (and an agreement to comply with and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

6.2 Interpretation

Capitalized terms that are not defined in this policy are defined as specified in the Vets Pharma Terms of Use. Any version of this Privacy Policy in a language other than English is provided for the convenience of the user. If there is any conflict with a version in another language, the user agrees that the English version prevails.

6.3 Questions

If you have any questions, concerns or disputes regarding our Privacy Policy, you may contact our privacy team (including our specific personal information protection officer) by sending an e-mail to esantiago@kironmexico.com.

Intellectual Property Policy

This intellectual property policy was last updated on February 21, 2021.

Vets Pharma is a technology platform that allows anyone to take educational courses anywhere in the world. We host courses in our virtual online learning store. Our online store model means that we do not review or edit courses for legal issues.

Infringing activity is not tolerated on or through our platform.

This policy addresses what we do in the case of copyright infringement by content owners and in the case of trademark infringement claims by brand owners with respect to courses offered on the Vets Pharma platform. The policy also addresses what we do when Vets Pharma instructors’ courses are copied on third party platforms without their consent.

Reporting of Third Party Copyright Infringement

Vets Pharma ‘s policy is to remove courses from our service when they are alleged to be infringing in a copyright infringement notice received from the original content owner. We reserve the right to terminate a student’s account at any time, including when a student posts content that infringes the intellectual property of third parties.

How to file a complaint

If you wish to report a course found on the Vets Pharma platform and you are the owner, or the owner’s designated agent, of the rights to the content that you believe the course infringes.

Before submitting a notice of copyright infringement, remember these important points:

1. Your notice of copyright infringement must be sufficiently substantiated for us to address it. This means:
   1. You must add a statement that says: “I declare, under penalty of perjury, that the information contained in this claim is accurate and that I am the copyright owner or am authorized to act on behalf of the copyright owner and have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.”
   2. You must provide sufficient information for us to locate the allegedly infringing course(s) found on the Vets Pharma website (the URL on our website and the exact name of the course);
   3. You must accurately identify the original copyrighted material or, if multiple copyrighted works are included in your notification, you must provide a sufficiently representative list of such original material (e.g., a URL where the material is located);
   4. If you are submitting a complaint on behalf of an organization, you must include the name of the organization and your relationship to it.
   5. You must provide sufficient information for us to contact you, including your full legal name, an email address, a physical address, and a telephone number (optional).

1. Knowingly submitting a false or misleading infringement claim is illegal and you may be held liable and liable to pay damages as a result. Vets Pharma reserves the right to seek damages from anyone who submits an infringement notification that violates the law.
2. Consider whether the use of your material in the course is a “fair use”. Some copyright laws include a “fair use” exception for certain uses of content that are considered to be in the public interest. Fair use encompasses such things as reviews, commentary, news reports and research. In considering whether a course’s use of your material qualifies as fair use, you should look at:
   1. the effect on the market for your material (whether potential buyers would purchase the course instead of your material).
   2. the portion being used (whether the course uses small, necessary excerpts of your material or substantial portions of it);
   3. the type of copyrighted work being used (whether your work is factual or creative);
   4. the purpose of the use (whether the course is paid or unpaid, whether the course criticizes, parodies or transforms your material);

Before submitting a notice of copyright infringement, make sure that the use of the copied content in the course does not qualify as fair use.

Counter-notification

To be effective, a counter-notification must be made in writing and must include the following information:

• your physical or electronic signature;
• your name, physical address, and e-mail address or telephone number;
• identification of the course that was removed and the location (URL) at which it appeared before it was removed (you can access this information in the copyright infringement complaint that was filed against your course; we always attach a copy when we notify you);
• a statement under penalty of perjury that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled; and
• a statement that you consent to (i) Vets Pharma sharing your name and contact information with the claimant; (ii) receiving service of process for any legal action by the claimant or an agent of the claimant; and (ii) consenting to the jurisdiction of the federal district court for the judicial district in which you reside.

Knowingly sending a false or misleading counter-notification is unlawful and you may be held liable and liable to pay damages as a result.

Vets Pharma reserves the right to seek damages from any party who submits a counter notification of copyright infringement in violation of the law.

Reporting of Third Party Trademark Infringement

Vets Pharma ‘s policy is to remove courses from our service when they are reported to infringe a third party trademark. We also reserve the right to terminate an instructor’s account at any time, including when an instructor posts content that infringes the trademark rights of a third party.

Designated Agent Contact Information

Vets Pharma’ s designated agent may be contacted for infringement reporting notices in the following ways:

• By email: esantiago@kironmexico.com