This policy explains what personal data we collect when you use the PCE website, the PCE app, the national pet register and our other services, why we collect it, who we share it with, how long we keep it and what rights you have. It also explains the particular position that applies to a pet microchip database, which is required by law to disclose keeper details to certain people.
1. WHO WE ARE
Sandbox Corp Limited is the controller of the personal data described in this policy. We are registered in England and Wales under company number 17485326 and our registered office is at 21 Ellis Street, London, England, SW1X 9AL, United Kingdom. We trade as Pet Care Essentials and as PCE.
We are registered with the Information Commissioner's Office under registration number [ZA000000].
You can reach our data protection contact at [privacy@pce.org.uk], or by post at the registered office marked for the attention of the Data Protection Lead.
2. THE DATA WE COLLECT
| Category | What it includes |
|---|---|
| Identity and contact data | Your full name, postal address, email address and telephone number. The Regulations require the keeper's full name and address to be recorded. |
| Pet data | Microchip number, species, breed, colour, sex, name, date of birth, date of implantation, neutering status, and whether the pet is a certified working dog. Where you are a licensed breeder, your local authority licence number. |
| Account data | Your username, password in hashed form, account settings and communication preferences. |
| Payment data | The last four digits of your card, the card type and expiry, and the payment reference. Full card numbers are handled by our payment provider and are not stored by us. |
| Location data | Where a Smart Tag is active, the location of the device over time. Because the device is on your animal and the animal is usually with you or at your home, this is personal data about you as well as information about your animal. |
| Pet Wallet content | Documents you upload, which may include vaccination records, insurance policies, licences and veterinary history. |
| Community data | Your profile, messages, reviews, play date arrangements and posts in local threads. |
| Usage and device data | IP address, device type and identifiers, operating system, app version, pages viewed and features used. |
| Communications | Your correspondence with us, and recordings of calls to the reunification line and to customer services. |
| Enquiry records | A log of every search of the register, who made it, when, and on what basis. |
We do not knowingly collect special category data. If you tell us that your animal is an assistance dog, that may reveal information about your health or disability. Where that happens we treat the information as special category data and rely on your explicit consent under Article 9(2)(a) of the UK GDPR. You do not have to tell us.
Information about your animal's health is not personal data about you, because an animal is not a data subject. It is still treated as confidential and handled under this policy.
3. WHY WE USE IT AND OUR LAWFUL BASIS
| Purpose | Lawful basis |
|---|---|
| Creating and maintaining a microchip registration, and giving you access to it | Performance of a contract with you, Article 6(1)(b). |
| Recording the details required by regulation 6 of the Microchipping of Cats and Dogs (England) Regulations 2023, and meeting the operator conditions in regulation 7 | Compliance with a legal obligation, Article 6(1)(c). |
| Disclosing keeper details to a person entitled to them under the Regulations | Compliance with a legal obligation, Article 6(1)(c). Where a disclosure is not strictly required but is made to reunite a found animal, our legitimate interests and yours in the safe return of the animal, Article 6(1)(f). |
| Providing PCE Membership and the services within it | Performance of a contract with you, Article 6(1)(b). |
| Operating Smart Tag location, movement and escape alerts | Performance of a contract with you, Article 6(1)(b). |
| Operating Search and Rescue and alerting people near the last known location | Performance of a contract with you, Article 6(1)(b), and the legitimate interests of keepers, finders and animal welfare, Article 6(1)(f). |
| Operating the Pet Nanny directory and community features | Performance of a contract with you, Article 6(1)(b). |
| Taking payment and keeping accounting records | Performance of a contract, Article 6(1)(b), and compliance with a legal obligation for tax records, Article 6(1)(c). |
| Sending you service messages, including compliance alerts and renewal notices | Performance of a contract, Article 6(1)(b), and compliance with a legal obligation, Article 6(1)(c). |
| Sending you marketing about PCE products and partner offers | Your consent, Article 6(1)(a), or our legitimate interests in marketing similar products to existing customers, Article 6(1)(f), in each case subject to the Privacy and Electronic Communications Regulations 2003. |
| Preventing and investigating fraud, misuse of the register and unauthorised searching | Our legitimate interests in protecting the register, keepers and animals, Article 6(1)(f), and compliance with a legal obligation, Article 6(1)(c). |
| Improving our services and understanding how they are used | Our legitimate interests in running and improving our business, Article 6(1)(f). |
| Establishing, exercising or defending legal claims | Our legitimate interests, Article 6(1)(f). |
Where we rely on legitimate interests we have carried out a balancing assessment. You may ask for a summary of it and you may object to that processing. See section 9.
4. THE STATUTORY DISCLOSURE POSITION
A pet microchip database exists so that a lost animal can be reunited with its keeper. The Regulations therefore require us to make recorded details available to certain people. This is the single most important thing to understand about how your data is used.
We will disclose your name, address and telephone number to a person entitled to receive it under the Regulations. In practice that means a veterinary surgeon or veterinary nurse, a local authority officer including a dog warden, a police officer, and an authorised rehoming or welfare organisation, in each case where they have scanned your animal or are otherwise entitled to the information.
We operate a system to check whether a person requesting information is entitled to it. We record every enquiry and we audit them.
A member of the public who finds an animal is not entitled to your details. Where a member of the public contacts us we will take their details and contact you, so that you can decide whether to contact them.
We make available to other database operators the information they need in order to work out which microchip numbers are recorded with us rather than with them. This is a number range check. It does not involve disclosing your personal data to them.
If the Secretary of State serves a notice under regulation 8 of the Microchipping of Cats and Dogs (England) Regulations 2023, we may be required to provide an electronic copy of the recorded data to the Secretary of State or to another database operator.
5. WHO WE SHARE DATA WITH
| Recipient | Purpose and role |
|---|---|
| Salesforce | Salesforce is the platform on which the register, the customer records and the service workflows are operated. Salesforce acts as our processor under a written agreement meeting Article 28 of the UK GDPR. |
| Payment provider | To take payment and handle card data. The provider is a controller in its own right for fraud prevention and regulatory purposes. |
| Authorised Users under the Regulations | Veterinary practices, local authority officers, police and authorised rehoming organisations. Each is a controller in its own right in respect of what it does with the information. |
| Leashh | Operates elements of the Pet Nanny provider network. Where Leashh receives applicant or provider data it does so under a written agreement. |
| Partner businesses in the voucher and Pet Network programmes | We do not pass your details to a partner unless you choose to claim an offer or contact the business. Where you do, the partner is a controller in its own right. |
| Insurance partners | Only where you choose to take up an insurance offer. The insurer is a controller in its own right and its own privacy notice applies. |
| AI Vet clinical provider | When AI Vet launches, the third party clinical provider will receive the content of your query and relevant pet information. |
| Professional advisers, auditors and insurers | Where necessary for the running of the business or the defence of a claim. |
| Law enforcement, regulators and courts | Where we are required to disclose, or where disclosure is necessary to establish, exercise or defend legal claims. |
| A buyer or successor | If the business or the register is transferred, including under regulation 8. |
We do not sell personal data and we do not share it with third parties for their own marketing.
6. WHERE YOUR DATA IS HELD AND INTERNATIONAL TRANSFERS
Our platform is provided by Salesforce. Where personal data is stored or processed outside the United Kingdom, we put in place one of the safeguards permitted by Chapter V of the UK GDPR. This will be either a decision by the Secretary of State that the destination provides an adequate level of protection, or the International Data Transfer Agreement, or the International Data Transfer Addendum to the European Commission standard contractual clauses.
You may ask us for a copy of the safeguard that applies to a particular transfer.
7. HOW LONG WE KEEP IT
| Record | Retention period |
|---|---|
| Microchip registration and keeper details | For the life of the animal, and for 24 months after we are told that the animal has died, after which the record is anonymised. |
| Transfer of keepership history | For the life of the animal plus 24 months, so that the chain of keepership can be evidenced. |
| Register enquiry and audit logs | 6 years, so that misuse can be investigated and disclosures evidenced. |
| Membership account and billing records | 6 years after the end of the membership, to meet tax and limitation requirements. |
| Smart Tag location history | 13 months rolling, unless a lost pet report is open in which case until the report is closed plus 12 months. |
| Pet Wallet documents | Until you delete them, or 90 days after your membership ends. |
| Community content and messages | 24 months after the account is closed. |
| Call recordings | 12 months, or longer where a complaint or claim is open. |
| Marketing preferences and suppression records | Indefinitely for suppression, so that we do not contact you again after you have asked us not to. |
| Complaint files | 6 years from closure. |
Where a record is retained for a purpose that no longer needs to identify you, we anonymise it rather than keep it in identifiable form.
8. AUTOMATED DECISION MAKING AND AI VET
We do not make decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing.
Smart Tag movement analysis compares an animal's activity against its own baseline and may generate a prompt suggesting that you look into a change. That is a prompt to you. It is not a decision about you.
AI Vet, when it launches, will generate guidance automatically. It will not make a decision about you and it will not diagnose or treat your animal. Additional information about the processing, including the clinical provider involved, will be published before launch.
9. YOUR RIGHTS
You have the right to be informed, to access your data, to have inaccurate data corrected, to have data erased in certain circumstances, to restrict processing, to data portability, and to object to processing based on legitimate interests. You also have an absolute right to object to direct marketing.
There is an important limit on erasure. We cannot simply delete a microchip registration on request, because the record exists to meet a statutory scheme and to enable a lost animal to be returned. Where you ask for erasure we will consider the request, tell you what we can do, and explain why if we cannot do all of it.
To exercise a right, contact us using the details in section 1. We will respond within one month. We may extend that by two further months for complex requests and we will tell you if we do. We do not charge a fee unless a request is manifestly unfounded or excessive.
We may ask you to verify your identity before we act on a request. This protects you.
If you are unhappy with how we have handled your data you may complain to the Information Commissioner's Office at ico.org.uk, by telephone on 0303 123 1113, or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would like the chance to deal with your concerns first.
10. SECURITY
We apply technical and organisational measures appropriate to the risk, including access controls, role based permissions, encryption in transit and at rest, logging of register enquiries, staff training and supplier due diligence.
We have a procedure for dealing with any suspected personal data breach and we will notify the Information Commissioner's Office and, where required, you, in accordance with Articles 33 and 34 of the UK GDPR.
No transmission over the internet is completely secure. You are responsible for keeping your password confidential.
11. CHILDREN
Our services are for adults. You must be at least 18 to hold an account or to be recorded as a keeper with us.
We do not knowingly collect data about children. If you believe a child has given us personal data, contact us and we will delete it.
12. COOKIES
We use cookies and similar technologies on the website and in the app. Our Cookie Policy explains what we use, why we use it, and how you can change your preferences.
13. CHANGES TO THIS POLICY
We review this policy regularly. Where we make a material change we will tell you by email or through the app before the change takes effect.
This version was published on the date shown in the document control table at the front of this policy.