Walker’s Touch Massage is the data controller and responsible for the processing of your personal data (“Walker’s Touch Massage” and “we”).. Protecting your privacy is our priority and we are therefore committed to ensuring that the personal data you provide is treated with the utmost confidentiality and in accordance with the requirements as stipulated in the General Data Protection Regulation (GDPR) and other relevant data protection laws. This Privacy Policy describes how Walker’s Touch Massage collects and processes personal data. 
 [California] residents – please refer to “Privacy Policy for [California] Residents” below. 

Collection of your Personal Data
We will collect your personal data based on the following legal grounds: 
Performance of an agreement - The processing of personal data is necessary for the performance of an agreement with you, or for taking measures upon your request before the conclusion of the agreement. 
Consent - You have given permission for the processing of your personal data for one or more specific purposes. 
Legitimate interests - The processing of your personal data is necessary to pursue our legitimate interest, provided that our legitimate interest in each case is not overridden by your interests or rights and freedoms. 
Compliance with legal obligations -  The processing of your personal data is necessary in order for Walker’s Touch Massage to comply with applicable laws. 

For example, you may be required to provide certain personal data to us when you elect to use certain products or services available on or accessible by the website. These may include: (a) registering for an account on the website; (b) entering a contest sponsored by Walker’s Touch Massage or one of the Walker’s Touch Massage brands; (c) sending us an email message; (d) submitting your credit card or other payment information when ordering and purchasing products and services on the website. 

Purpose of Personal Data Collection
We process your personal data for the following purposes: 
To provide you with goods and services and for contractual purposes; 
To process your payment; 
To communicate with you in relation to services and/or products you have requested from us; 
To inform you of any changes in our services and products; 
To offer you the opportunity to create an account; 
To send you newsletters, marketing emails and other electronic messages (if you have subscribed to them); 
To analyze your user behavior on a Walker’s Touch Massage or Walker’s Touch Massage brand website and your preferences, for more relevant marketing emails (with the appropriate permission); for website improvement and to personalize our products and services based on your preferences; 
To implement and manage loyalty programs if applicable; 
To determine the need for the development of new or changed product and services offers and the communication about these; 
Receiving and processing complaints and other feedbacks; 
Statistical evaluations, e.g., to evaluate information about our customers’ interactions with us on a non-personal basis. 

Below is an overview of the personal data that we collect and process: 
First and last name; 
Job title / role; 
Vet practice name(s) and address(es); 
Domicile and shipping address(es);  
Country of residence; 
Gender; 
For workshop management: Scrub size, specific diet or allergy information (e.g., latex allergy), emergency contact; 
Telephone number; 
Email address; 
VAT or EORI number; 
Professional information: Education status, history, and procedures performed; 
Information about attendance at workshops, webinars, etc.; 
Data submitted through our forms: complaints, feedback forms, webinar registrations, workshop registrations, support requests, surveys; 
Purchase history / behavior; 
Contractual data; 
Payment information (currency, credit card); 
Information about your activities on the Walker’s Touch Massage or Walker’s Touch Massage brand website(s), Walker’s Touch Massage webstores or other marketing channels; 
Information about your user behavior across the Walker’s Touch Massage or Walker’s Touch Massage brand website;  
Information about your user behavior within emails (opens, clicks); 
Communication data (emails, phone calls): Content of the communication as well as contact details (e.g., name, email address, telephone number); 
Information about joining of applicable loyalty programs, e.g., Annual Ordering Program (AOP);  
Activities / behavior on the Walker’s Touch Massage Education Platform, e.g., online course progress; 
Internet browser, device type and device information; 
IP address; 
Photos or videos of workshops and webinars (with explicit consent obtained beforehand). 

Children Under Thirteen
Walker’s Touch Massage does not knowingly collect personal data from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website. 

Sharing Information with Third Parties
Walker’s Touch Massage may contact you about a particular offering that may be of interest to you. In those cases, your personal data (such as email, name, address, telephone number) is transferred to the relevant group companies.  
Walker’s Touch Massage will not share or disclose any personal data with third parties other than when statutorily required, at your specific request, or with third-party suppliers with which we have engaged to carry out certain tasks. Such third-party suppliers may be engaged to provide e.g., hosting services, IT administrators services, email and mail services, and marketing and analytical services, e.g., Google Analytics, HubSpot). All such third-party suppliers are prohibited from using your personal data except to provide these services to Walker’s Touch Massage, and they are required to maintain the confidentiality of your personal data.
Your personal data may be transferred to a country outside the EU/EEA which may not provide an adequate level of protection for personal data. In that case, we will take measures to protect your personal data in connection with such a transfer, e.g., by entering into agreements with the recipients in order for us to ensure that your personal data is processed appropriately. 

Automatically Collected Information
Information about your computer hardware and software may be automatically collected by Walker’s Touch Massage. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain the quality of the service, and to provide general statistics regarding the use of the website.

Links
Walker’s Touch Massage or Walker’s Touch Massage brand websites contain links to websites outside the Walker’s Touch Massage or Walker’s Touch Massage brand websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage you to be aware when leaving our website and to read the privacy policies of any other website that collects personal data. 

Personal Data Retention Periods
We retain your personal data for as long as it is necessary for us to provide you with the proper level of service. We will also keep your personal data for the period in which we deem it relevant to keep your information with regards to our services and our business relationship. The above-mentioned periods apply unless we are statutorily obligated to retain personal data for a longer period. 

Security of your Personal Data
Walker’s Touch Massage secures your personal data from unauthorized access, use, or disclosure. Walker’s Touch Massage uses the following methods for this purpose: 
 – Secure Sockets Layer (SSL) Protocol    
When personal data (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
 
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal data. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this website cannot be guaranteed. 

Viewing, Editing and Deleting Personal Data
You have the following rights: 
Right of access to your personal data – you have the right to obtain confirmation of whether we process your personal data and access to personal data that is being processed. 
Right of rectification – you may request rectification of inaccurate personal data. 
Right to erasure – you may request that your personal data is erased from our records. 
Right to restriction – you may request that the processing of your personal data is restricted. 
Right to object – you may object to the processing of your personal data. 
Right to data portability – you may submit a request to transfer all your personal data in our records via a computer file to another organization of your choosing, provided that we process the personal data based on your consent or as the result of an agreement. 
If you want to exercise any of your rights, you can contact us by email at dataprotection@walkerstouch.com. If you have complaints regarding the processing of your personal data, you may also contact the data protection authority in your country. 
Please note that there may be conditions or limitations on the above-mentioned rights. This depends on the specific circumstances of the processing activity. 

Marketing and Email Communications
From time to time, Walker’s Touch Massage may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. We respect your privacy and will provide you with a link in these types of email to opt-out of receiving further marketing information. You may also opt-out of receiving any further marketing information from Walker’s Touch Massage by contacting us by email at dataprotection@walkerstouch.com. 

Changes to this Policy
Walker’s Touch Massage may from time to time change this Privacy Policy. We will notify you about significant changes in the way we treat personal data by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this page. 

Contact Information
Walker’s Touch Massage welcomes your questions or comments regarding this Privacy Policy. If you believe that Walker’s Touch Massage or one of the Walker’s Touch Massage brands has not adhered to this Privacy Policy, please contact Walker’s Touch Massage at: 
dataprotection@walkerstouch.com.

Place of Jurisdiction
The place of jurisdiction is
• for customers located in the USA, Canada, and South America, in St. Augustine, Florida, USA
• for customers located in Europe and the Rest of the World (RoW) in Zurich, Switzerland. 
You are entitled to make a complaint to the relevant data protection authority in the jurisdiction where the alleged breach occurred, or where you are formally registered. 

Privacy Policy for [California] Residents

Sharing Information with Third Parties
Although rare in incidence, Walker’s Touch Massage may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Walker’s Touch Massage or the site; (b) protect and defend the rights or property of Walker’s Touch Massage; and/or (c) act under exigent circumstances to protect the personal safety of users of Walker’s Touch Massage, or the public. 

 Opt-Out of Disclosure of Personal Information to Third Parties
In connection with any personal data we may disclose to a third party for a business purpose, you have the right to know: 
The categories of personal information that we disclosed about you for a business purpose. 
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information. To opt-out of the disclosure of your personal information, email massage@walkerstouch.com and express your request to be removed from such disclosures. 

Right to Deletion
Please note that we may not be able to comply with requests to delete your personal information if it is necessary to: 
Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; 
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 
Debug to identify and repair errors that impair existing intended functionality; 
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; 
Comply with the California Electronic Communications Privacy Act; 
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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; 
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; 
Comply with an existing legal obligation; or 
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. 
Effective as of 2/7/2023

Privacy Policy