Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights and Enforcement Act (“CPRA”) (CCPA and CPRA collectively, the “CCPA”), Rockway, Inc., its parent company and affiliates (“Rockway”) are providing the following Privacy Statement to explain how Rockway collects, uses and discloses Personal Data that we collect from individuals who are residents of California, including but not limited to users who visit our websites or consumers who receive goods or services directly from MAI.

For purposes of this California Privacy Statement, Personal Data is information that identifies, relates to, or could reasonably be linked with a particular California resident or household and has the same meaning as under the CPRA Section 1798.140(v): information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern or information that has been de-identified or aggregated. “Sensitive personal information” has the same meaning as under the CPRA Section 1798.140(ae). Sensitive personal information does not include information that is publicly available.

Rockway respects your right to privacy and recognizes our responsibility for protecting the privacy and security of the personal information we receive from you. We are committed to securing the confidentiality and integrity of your personal information.

Collection, Disclosure, and Sharing of Personal Data

The following details which categories of Personal Data we collect and process, which categories of third parties may have access to your Personal Data for operational business purposes, as well as which categories of Personal Data we “share” for purposes of cross-context behavioral advertising, including within the 12 months preceding the date this Privacy Statement was last updated.

Sources of Personal Data

We collect this Personal Data actively (e.g. direct input from individuals) or passively (e.g. website cookies) from you. Additionally, we may also collect Personal Data from third-party sources, such as our affiliates, business partners, and service providers, listed above where applicable.

Purposes for the Collection, Use and Sharing of Personal Data

Rockway uses your Personal Data for the following Business Purposes and objectives:

Detailed Description of Categories of Third Parties

Third Parties that Rockway may disclose your Personal Data are as follows:

(a) Service Providers/Subcontractors
Rockway may share your Personal Data with our subcontractors for certain business purposes. This information is provided for them to provide us with services such as payment processing, advertising services, marketing partners, web analytics, data processing, IT services, customer support and other services such as for the purpose of auditing and fraud investigations.

(b) Related Entities
Rockway may share Personal Data between and among Rockway, its parent company and affiliated companies for purposes of management and analysis, and other business purposes. For instances, Rockway may share your Personal Data with our parent company and affiliated companies to expand and promote our product and service offerings.

(c) Law Enforcement/Legal Authorities
Rockway may be required to disclose your Personal Data to third parties including law enforcement agencies when required to protect and defend our legal rights, protect the safety and security of users of our Services, prevent fraud, respond to legal process, or a request for cooperation by a government entity, as required by law

(d) Corporate Transactions
In the event of sale, transfer, merger, reorganization, or similar event, Rockway may transfer your Personal Data to one or more third parties as part of that transaction with the business entities or people involved in the deal negotiation or transfer.

(e) With Your Consent
Rockway may share Personal Data about you with other third-party companies if you give us permission or direct us to share the information. Rockway will share Personal Data with authorized agents that you authorize Rockway to communicate to.

We do not sell and have not sold Personal Data, including your Sensitive Personal Data, in the preceding 12 months. Without limiting the foregoing, we do not sell Personal Data, including the Sensitive Personal Data, of minors under 16 years of age. We do not knowingly “share” the Personal Data, including the Sensitive Personal Data, of minors under 16 years of age.

Sources of Personal Data

We collect this Personal Data actively (e.g. direct input from individuals) or passively (e.g. website cookies) from you. Additionally, we may also collect Personal Data from third-party sources, such as our affiliates, business partners, and service providers.

Purposes for the Collection, Use and Sharing of Personal Data

Rockway uses your Personal Data for the following Business Purposes and objectives:

(a) Business Purposes for processing Personal Data pertaining to consumers. Personal Data pertaining to consumers with whom Rockway has a business relationship may be processed as needed:

(1) To provide the information, product, or service requested by the individual, and as would be reasonably expected by the individual given the context in which the Personal Data was collected, and the information provided in the applicable privacy statement given to the individual (such as for personalization, remembering preferences, or respecting individual rights);

(2) For due diligence, including verifying the identity of the individual, as well as the eligibility of the individual to receive information, products, or services (such as verifying age, employment, or account status);

(3) To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training materials, and service updates);

(4) To manage the individual’s account, such as for customer service, finance, and dispute resolution purposes;

(5) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets;

(6) For security management, including monitoring individuals with access to the website; applications, systems, or facilities, investigation of threats, and as needed for any data security breach notification; and

(7) To anonymize or de-identify Personal Data. Where we maintain or use de-identified information, we will continue to maintain and use such information only in a de-identified fashion and will not attempt to re-identify such information.

(b) Business-necessary processing activities. Rockway may process Personal Data as needed (i) to protect the privacy and security of the Personal Data it maintains, such as in connection with advanced security initiatives and threat detection; (ii) for treasury operations and money movement activities; (iii) for compliance functions, including screening individuals against sanction lists in connection with anti-money laundering programs; (iv) for business structuring activities, including mergers, acquisitions, and divestitures; and (v) for business activities, management reporting, and analysis.

(c) Development and improvement of products and/or services. Rockway may process Personal Data to develop and improve its products and/or services, and for research, development, analytics, and business intelligence.

(d) Relationship management and marketing. Rockway may process Personal Data for relationship management and marketing. This purpose includes sending marketing and promotional communications to individuals who have not objected to receiving such messages, such as product and service marketing communications, investor communications, Client communications (e.g., product updates, and training opportunities and invitations to Rockway events), customer satisfaction surveys, supplier communications (e.g., requests for proposals), corporate communications, and Rockway news.

(e) Operational purposes. Additionally, Rockway uses your Personal Data for purposes such as: (i) disaster recovery and business continuity; (ii) internal audits or investigations; (iii) implementation or verification of business controls; (iv) statistical, historical, or scientific research; (v) dispute resolution; (vi) legal or business counseling; (vii) compliance with laws and company policies; and/or (viii) insurance purposes.

Purposes for the Collection and Use of Sensitive Personal Data

Subject to your consent where required by applicable law, we may use Sensitive Personal Data for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, servicing accounts, providing customer service, verifying customer information, processing payments, and activities relating to quality or product improvement.

保持期間

We retain Personal Data for as long as needed or permitted considering the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

(a) The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Data to address issues that may arise;

(b) Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them); or

(c) Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation or regulatory investigations).

カリフォルニア州消費者の権利

If you are a California resident you may make the following requests, subject to applicable law:

(a) Right to Access and Know – You may request that we disclose to you the following information covering the 12 months preceding your request:

(1) The categories of Personal Data we collected about you and the categories of sources from which we collected such Personal Data;

(2) The specific pieces of Personal Data we collected about you;

(3) The business or commercial purpose for collecting or sharing Personal Data about you;

(4) The categories of Personal Data about you that we shared (as defined under the applicable privacy law) and the categories of third parties with whom we shared such Personal Data; and

(5) The categories of Personal Data about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Data (if applicable).

(b) Right to Request Correction of your Personal Data – You may request to correct inaccuracies in your Personal Data;

(c) Right to Request Deletion of your Personal Data – You may request to have your Personal Data deleted; and

(d) Right to Opt-out of Sharing for Cross-Context Behavioral Advertising – You may request to opt out of the “sharing” of your Personal Data for purposes of cross-context behavioral advertising.

We will not unlawfully discriminate against you for exercising your rights under the CCPA.

How to submit a California Rights Request

To make a privacy request, please contact us by emailing us at privacy@estrotect.com. We will verify and respond to your request consistent with applicable law, considering the type and sensitivity of the Personal Data subject to the request. We may need to request additional Personal Data from you, such as your name and email address, to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Data. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Data.

To request to opt out of any future sharing of your Personal Data for purposes of targeted advertising, please go to estrotect.com and click the Cookie Preferences – Do Not Share My Data link at the bottom of the page and toggle off advertising cookies.

Authorized Agents Submitting a Request on Behalf of a Consumer

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Agents may be asked to provide proof of their status as an authorized agent. Once a request has been submitted by an authorized agent, we may require additional information from you to verify your identity as described in the section entitled “How to Submit a California Rights Request” or confirm that you provided the agent permission to submit the request. Authorized agents emailed privacy@estrotect.com リクエストを送信します。

Changes to this California Consumer Privacy Statement

We may change or update this Privacy Statement from time to time. When we do, we will communicate updates to this Privacy Statement by posting the updated Statement on this page with a new “Last Updated” date.

お問い合わせ

If you have any questions regarding this California Consumer Privacy Statement, please contact us at privacy@estrotect.com.

最終更新日：1年2024月XNUMX日

European Union, European Economic Area, Switzerland, and United Kingdom

This EEA and UK Privacy Policy applies to you only if are in a member state of the European Union, the European Economic Area, Switzerland, or the United Kingdom.

Rockway, Inc dba Estrotect and its parent company and affiliates (“Rockway”), is committed to protecting the privacy and security of your personal information. This EEA and UK Policy supplements our main Privacy Policy found on our website at Estrotect.com, as it may be updated from time to time, in connection with the personal data of residents of the European Economic Area (“EEA”) and in order to comply with the EU General Data Protection Regulation 2016/679, the UK Data Protection Act 2018, and GDPR as incorporated into UK law by virtue of the European Union (Withdrawal) Act 2018 (“UK GDPR”). In this EEA Privacy Notice, “you” means anyone who uses our website, our products or services, or otherwise communicates with us. “Personal Data,” “processor,” “processing,” and “controller” have the same meanings given as in GDPR. This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the applicable data protection legislation.

お客様のデータ保護の権利

If you are in the EEA or the UK, you have certain rights and protections under the law regarding the processing of your Personal Information.

Subject to certain limitations and exceptions, you have the following legal rights:

• A right to obtain information: You have the right to request information about how your Personal Data is processed.
• A right of access: You have the right to request access to, or a copy of, your Personal Data.
• A right of rectification: You have the right to request correction or supplementation of inaccurate or incomplete Personal Data.
• A right of deletion: You have the right to request deletion of your Personal Data.
• A right to restriction of processing: You have the right to request restriction of processing of your Personal Data, so that such data may be stored but not further processed.
• A right to data portability: You have the right to request your Personal Data in a structured, commonly used, and machine-readable format, and you have the right to transmit such data to another controller without hindrance.
• A right to object to processing: You have the right to request the cessation of processing your Personal Data (for example, when your Personal Data is processed for direct marketing purposes, you have the right to object to the processing of such data at any time).
• A right to revoke your consent: When processing is based on your consent, you have the right to revoke such consent at any time.
• Right to Standard Contractual Clauses: You have the right to review and request standard contractual clauses, which are used as a data transfer mechanism primarily designed to help controllers and processors legally facilitate data transfers to countries outside the EEA and UK.
• The right to file a complaint: You have the right to file a complaint regarding data protection practices with a supervisory authority. If you are located in the EEA, contact details for your supervisory authority are available with the  欧州データ保護委員会（EDPB） opens in new window. If you are in the UK, contact details for your supervisory authority are available with the 情報コミッショナーズオフィス（ICO） opens in new window.

If you make a request, we have thirty (30) days to respond to you. To exercise any of the rights above please contact us at privacy@maianimalhealth.com. We will consider and process your request within a reasonable period. Under certain circumstances, the GDPR may limit your exercise of these rights.

収集するもの

We collect the following personal information about you that you voluntarily supply to us via our website:

• 名前
• メールアドレス
• 電話
• 完全な住所
• 居住国

When you visit the Website, we may also collect “Other Information” that does not reveal your specific identity or does not relate to an identifiable individual. This might include, for instance, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation of the website(s).

In some instance we may also collect:

Human Resources Personal Data: Personal Data may be collected from job applicants, actual or past employees, consultants or independent contractor, to fulfil our Human Resources (HR) functions and administer potential, past or current employment with Rockway. Such Personal Data may be disclosed to Rockway’s agents providing recruitment or employment services on our behalf.

Business Contact Personal Data: Personal Data may be collected from customers, service providers, suppliers, and business partners to discuss prospective business opportunities, Rockway service offerings or provide customer support.

Legitimate Interests – Business Purposes for Processing Personal Data

We may process your personal data where it is necessary for the purposes of our legitimate interests, or a third party’s legitimate interests, such as those of other employees or users, or our corporate partners or those organizations we collaborate with for certain projects or services.

Personal Data may be processed by Rockway in the context of the following legitimate interests related to Rockway’s business operations for one or more of the following Business Purposes:

A. Business Purposes for Processing Personal Data pertaining to Professionals:

1. Business relationship management;
2. Business relationship due diligence;
3. Transactional communications;
4. Account management;
5. Quality control;
6. 危機管理;
7. Security management; and
8. Anonymize or de-identify Personal Data.

B. Business Purposes for Processing Personal Data pertaining to Consumers and other Individuals:

1. Provide requested information, products or services;
2. Due diligence;
3. Transactional communications;
4. Account management;
5. 危機管理;
6. Security management; and
7. Anonymize or de-identify Personal Data.

C. Business-necessary Processing activities:

1. Protect privacy and security;
2. Treasury operations and money movement activities;
3. コンプライアンス;
4. Business structuring activities; and
5. レポートと分析。

D. Development and improvement of products and/or services; and

E. Relationship management and marketing.

Use for Other Purposes

Personal Data may be processed for a secondary purpose, similar to the legitimate Business Purpose, provided appropriate additional measures are taken. It is generally permissible to Process Personal Data for the following purposes (even if not listed as a Business Purpose), provided appropriate additional measures are taken:

1. Disaster recovery and business continuity, including transferring the Information to an Archive.
2. Internal audits or investigations.
3. Implementation or verification of business controls.
4. Statistical, historical, or scientific research.
5. 論争の解決。
6. Legal or business counseling.
7. Compliance with laws and company policies.
8. Insurance purposes.

機密情報

We ask that you not send us or disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, health, biometrics or genetic characteristics) on or through the website. Rockway shall only collect and use sensitive Personal Data where permitted, and subject to heightened restrictions, under applicable law (and only after obtaining your explicit consent or authorization where so required) and where we have provided you with specific notice of such processing.

What We Do with Your Personal Information

We will process (collect, store and use) the information you provide in a manner compatible with the UK Data Protection Act 2018 (including as amended), UK GDPR, the Swiss Federal Act on Data Protection (FADP), and EU GDPR 2016 ((EU) 2016/679 relevant privacy laws named above (as such apply to you).

Your personal information is processed at our office in the United States. Storage of your information takes place at our hosted service provider located in the United States. No third-party providers or external agencies have access to your personal information, unless specifically required by law.

Security and Confidentiality Requirements

Rockway has implemented commercially reasonable and appropriate technical, physical, and organizational measures to protect Personal Data from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access.

Access to Personal Data will be authorized only to the extent necessary to serve the applicable Business Purposes and Rockway Staff with access to Personal Data will be subject to confidentiality obligations.

Rockway shall investigate all known or suspected Data Security Breaches and shall document the facts relating thereto, their effects and the remedial actions taken. Rockway shall notify Individuals of a Data Security Breach within a reasonable period following determination of such Data Security Breach if (a) the Individual is at a high risk of harm because of the Data Security Breach or, (b) (even if the Individual is not at a high risk of harm), if an applicable breach notification law requires Individual notification.

Direct Marketing

Rockway respects the choices of Individuals and provides Individuals the choice to opt-in and opt-out of direct marketing. Rockway will send direct marketing materials if the Individual has provided opt-in consent or if Applicable Law permits Rockway to send marketing communications without explicit consent based on an existing business relationship.

Transfer of Personal Data to Third Parties and Internal Processors

Rockway may transfer Personal Data to a Third Party and to Internal Processors to the extent necessary to serve the applicable Business Purposes. Rockway will only transfer Personal Data to a Third Party or to an Internal Processor if a written contract has been entered into with Rockway ensuring that the same level of data protection will be applied as described in the Rockway Privacy Code for Business Data.

Transfers of your personal data outside the European Economic Area

Your personal data may be transferred to and stored by persons outside the European Economic Area (the “EEA”) and may be transferred to and stored by affiliates or service providers outside the EEA.

Where personal data is transferred outside the EEA by Rockway, Rockway will take appropriate safeguards with respect to such transfer. You can obtain more details of the protection given to your personal data when it is transferred outside the EEA by contacting the Company at privacy@estrotect.com.

We may transfer your personal data to other jurisdictions where we have facilities or service providers, including the United States, where data protection laws may not provide the same protections as the laws of your home country.

When we transfer personal data of data subjects in the UK or EU to a third country that is not subject to an adequacy decision, we will do so in accordance with all applicable data protection laws. We may rely on standard contractual clauses to provide an adequate level of protection for personal data. “Standard Contractual Clauses” refers to contracts between companies transferring personal data from Europe to third countries that contain standard commitments approved by the European Commission protecting the privacy and security of the personal data transferred.

If you have questions about these international transfers of personal data, please email us at privacy@maianimalhealth.com.

苦情手続き

Individuals covered by this Policy may file a written complaint if they suspect that a member(s) of the Rockway family of companies or affiliates has violated the commitments made in the Rockway Policy. Complaints must be submitted in writing to Rockway. Complaints may be submitted via email to privacy@estrotect.com or Questions@Estrotect.com.

Retention of personal data

How long Rockway holds your personal data will vary. The retention period will be determined by various criteria, including the purposes for which Rockway is using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum retention period).

Changes to Our EEA and UK GDPR Compliance Policy

We reserve the right to change this EEA and UK GDPR Compliance Policy at any time by indicating revisions through the “Last Updated” date at the bottom of the GDPR Compliance Policy. Such changes will be effective upon posting on our website.

お問い合わせ

For more information about Rockway’s Privacy Program, including the Rockway Privacy Code for Business Data, please contact us at privacy@estrotect.com.