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Pimbury Apps - ‘Pimbury App’ Privacy Policy

The first part of this privacy policy explains how Pimbury Apps Ltd processes your personal data as processor when we are providing services to your equine dental provider (our customer) through the Pimbury App.

The second part of this privacy policy explains how we process your personal data when we have collected it as controller, such as when you download and register to use our myPimbury App or when you use our website (https://www.pimbury.app), including any data you may provide when you register with us, sign up to our newsletter..

Neither our website nor the Pimbury App are intended for children and we do not knowingly collect data relating to children.

 

Controller 

Pimbury Apps Ltd (company number: 09000133, registered office address: April Green Old Common, Minchinhampton, Stroud, Gloucestershire GL6 9EH) is the controller and responsible for your personal data (referred to as "Pimbury", "we", "us" or "our" in this privacy policy).

“Personal data” means any information about an individual from which that person can be identified.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section of this policy.

 

When we act as processor

We provide services to equine dental providers through Pimbury App. Those services enable equine dental providers to manage their practices and keep detailed digital records of each of their equine patients, and their owners. When we host and process the personal data your equine dental provider inputs into our system, we do so as processor under a contract for services between us and your equine dental provider, and on your equine dental provider’s instructions.

For example, the equine dental provider will decide what information to provide to us about their patient and the patient’s owner, and whether to send you a report of the information from your latest visit, by email. This means that we act as a data processor of that personal data, and the equine dental provider is the data controller.

As the equine dental provider is the data controller, the equine dental provider ultimately decides how we use personal data to provide the services to them. The equine dental provider is responsible for explaining those uses to you and you should contact your equine dental provider to find out how personal data is used in your particular case. We only share your personal data where your equine dental provider allows us to.

We use a small amount of the personal data we hold about you for purposes that are not part of the services we provide to equine dental providers. When we use data for those other purposes we act as a data controller. This policy also explains how we use personal data as a data controller.

 

The types of personal data we collect about you as controller

We have grouped the types of personal data we may collect, use, store and transfer as controller together as follows:

  • Identity Data: first name, last name, password and email address(s).
  • Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Profile Data: your username and password.
  • Usage Data: information about how you interact with and use our website, products and services.
  • Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific app feature in order to analyse general trends in how users are interacting with our app to help improve the app and our service offering.

 

How we collect your personal data as controller

Where we act as controller, we use different methods to collect data from and about you including through:

  • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • create an account on our app;
    • subscribe to our newsletter(s);
    • request marketing to be sent to you; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website and myPimbury App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy [LINK] for further details. 

How we use your personal data as controller

 

Lawful basis

The law requires us to have a lawful basis for collecting and using your personal data. We may rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

 

Purpose/Use Type of data Legal basis [and retention period]
To register you as a new user of the myPimbury App IdentityProfile [Necessary for our legitimate interests (to provide the app to you)]
To manage our relationship with you which will include:(a) notifying you about changes to our terms or privacy policy(b) dealing with your requests, complaints and queries IdentityProfileMarketing and Communications [Necessary for our legitimate interests (to provide the app to you)]Necessary to comply with a legal obligation
To administer and protect our business, our apps and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) IdentityTechnicalUsage Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)Necessary to comply with a legal obligation
To deliver relevant website and app content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you IdentityProfileTechnicalUsage

Marketing and Communications

 Necessary for our legitimate interests (to study how users use our website and apps, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, apps, customer relationships and experiences and to measure the effectiveness of our communications and marketing TechnicalUsage Necessary for our legitimate interests (to keep our website and apps updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data IdentityTechnicalUsageProfile

Marketing and Communications

 Consent, having obtained your prior consent to receiving direct marketing communications
To carry out market research through your voluntary participation in surveys IdentityProfileMarketing and Communications Necessary for our legitimate interests (to study how users use our apps and to help us improve and develop our products and services).

 

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

 

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes [for example relating to updates to our Terms of Use, checking that your contact details are correct].

 

Cookies

[For more information about the cookies we use and how to change your cookie preferences, please see [LINK TO YOUR COOKIE POLICY].]

 

Disclosures of your personal data as controller

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

  • your equine dental provider, to let them know that you have registered to use the [NAME OF APP] and to request for them to release your horse’s details to you.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

International transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that one of the following safeguards are in place:

  • the person we are transferring it to is in a country that has been deemed by the UK to provide an adequate level of protection for personal data;
  • specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy, please contact us; or
  • we have your explicit consent to the transfer.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data retention (where we are the controller)

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

Third-party links

Our website or the myPimbury App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your legal rights where we are controller

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

  • object any time to the processing of your personal data for direct marketing purposes 
  • withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • if you want us to establish the data's accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the details at the end of this policy.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address:
  • Postal address: Pimbury Apps Ltd, April Green Old Common, Minchinhampton, Stroud, Gloucestershire GL6 9EH

 

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 01/04/2026. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.