US, UK, AND EU CONSUMER PRIVACY POLICY ADDENDUM
This US, UK, and EU Privacy Policy Addendum (this “Addendum”) supplements our Privacy Policy (available here) and, except as otherwise noted herein, or as otherwise provided under applicable law, applies solely to (i) California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia consumers under applicable state laws (including, as applicable, the California Consumer Privacy Act (CCPA), California Online Privacy Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Indiana Consumer Data Protection Act, Iowa Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Data Privacy Act, New Jersey Data Privacy Act, Oregon Consumer Privacy Act, Rhode Island Data Transparency and Privacy Protection Act, Tennessee Information Privacy Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act and Virginia Consumer Data Protection Act, and their respective implementing regulations), and (ii) individuals in the European Economic Area under the EU General Data Protection Regulation (EU GDPR), and United Kingdom under the UK General Data Protection Regulation (UK GDPR), as applicable. Please read this Addendum carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
Under applicable laws, we may collect, use, and be responsible for certain personal information about you. For example, if we offer goods and services to individuals in the European Economic Area (EEA), we may be subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we may be subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). Where applicable, we are responsible as a “controller” of that personal information for the purposes of the GDPR and we are responsible for your personal information as a “business” under the CCPA/CPRA.
- Key Terms.It would be helpful to start by explaining some key terms used in this Addendum:
| Term(s) | Meaning |
| CuraCore, we, us, our | CURACORE VET, PLLC, doing business as “CuraCore,” and any of our affiliated group companies (if any) |
| Our representative |
Dr. Narda Robinson 905 S Summit View Dr. Fort Collins, CO, 80524, US |
| Our Data Protection Officer |
Dr. Narda Robinson 905 S Summit View Dr. Fort Collins, CO, 80524, US |
| Personal information | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation. |
| Sensitive Personal Information | Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status |
| Biometric Information | An individual’s physiological, biological, or behavioral characteristics, including information about an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information |
- Personal Information We Collect About You.We may collect and use the below-listed personal information, including sensitive personal 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. However, inclusion of a category in the list below indicates only that we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all website or service visitors or users. As noted elsewhere, we may share the below categories of information with our third-party service providers.
| Categories of Personal Information | Specific Types of Personal Information We May Collect (as applicable) |
| Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | We may collect information concerning your name; home address; billing address; shipping address; phone number; email address; IP address; professional license number; and account name and details |
| Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information | We may collect information concerning your name; home address; billing address; shipping address; phone number; email address; IP address; professional license number; education history; payment card information, transaction details, form of payment, payment confirmation and other payment details; and account name and details (including if paying by check) |
| Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
We, or our payment processors, may collect information concerning your account name; password; security questions and answers; home address; billing address; shipping address; phone number; email address; and debit, credit, or payment card information, financial account information, transaction details, form of payment, payment confirmation and other payment details.
To the extent the collection and processing of your debit, credit, or payment card information may be considered collection of sensitive personal information (“SPI): while, to our knowledge, credit, debit, and payment card information is never stored on our servers, it may still be collected and processed to complete applicable transactions and stored on our payment processor’s servers. In such event, it is our intent that use of such information is strictly limited to the purpose for which it was originally collected: to provide the goods or services you requested. For California residents, you may have the right to limit the use and disclosure of such SPI (or other SPI). For more information on how to exercise such rights, please see Section 10 “California Consumers: Your Rights Under the CCPA/CPRA” below. |
| Characteristics of protected classifications under California or federal law | We do not intentionally collect any information concerning your (i) race, color, ancestry, citizenship, or national origin; (ii) sex, gender, gender identity, and gender expression; (iii) sexual orientation or marital status, (iv) religious creed, (v) physical or mental disability, (vi) medical conditions or genetic information, or (vii) military or veteran status. However, we may inadvertently collect such information directly from you if you share it with us, such as, for example, if you choose to upload a profile photo or video content. |
| Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | We may collect information concerning items you view, put in your cart, or purchase, return, exchange or cancel and your past transactions |
| Biometric information | We do not intentionally collect any biometric information. However, to the extent audio or video constitutes Biometric information, we may inadvertently collect such information directly from you if you share it with us, such as, for example, if you choose to upload a profile photo or video content |
| Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement) | We may collect information concerning information about your device, browser, or network connection; your IP address and other unique identifiers; and your interactions with the Website or Services, including how and when you interact with or navigate the Website or Services |
| Geolocation data | We may collect information concerning your home address; billing address; shipping address; and general geographic location |
| Audio, electronic, visual, thermal, olfactory, or similar information | We may collect audio, electronic, visual, or similar information directly from you if you choose to upload videos, pictures, audio or similar content to us or our websites or services |
| Professional or employment-related information | We may collect information concerning your current employment; past employment; education; and professional licenses |
| Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) | We don’t intentionally collect any non-public education information |
| Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Not applicable |
| Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status | We don’t intentionally collect any information concerning your racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status |
| Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication | We only collect mail, email, and text message information you share with us |
| Genetic data | We don’t intentionally collect genetic data |
| Processing of biometric information to uniquely identifying a consumer | We don’t intentionally collect or process biometric data |
| Health information | We don’t intentionally collect any heath information |
| Sex life or sexual orientation | We don’t intentionally collect data regarding your sex life or sexual orientation |
If you do not provide personal information required to provide CuraCore products and/or services to you, it may delay or prevent us from providing such products or services to you.
- How Your Personal Information is Collected.We may collect personal information from you and from other categories of sources such as:
- You, directly in person, by telephone, text, email and/or via our website and apps;
- Private and publicly available third party sources;
- Our affiliates;
- Our customers, including organizations with which you may be employed or affiliated;
- Advertising networks;
- Internet service providers;
- Data and data analytics providers;
- Government entities;
- Operating systems and platforms;
- Social networks;
- Data brokers;
- Publicly accessible sources (e.g., property records);
- Cookies on our website; and
- Our IT and security systems, including:
o Door entry systems and reception logs; and
o Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email, and instant messaging systems.
- How and Why We Use Your Personal Information.We only use your personal information if we have a proper reason for doing so, for example:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we may use (process) your personal information (including, if applicable, sensitive person information (but subject to your consent where required by applicable law)) for and our reasons for doing so:
| What we may use your personal information for (as applicable) | Our reasons (as applicable) |
| To provide products and/or services to our customers | For the performance of our contracts with you or our other customers |
| To prevent and detect fraud against you, our customers, or us | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
| Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for our customers |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to our customers |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us, our customers, and/or for you To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For the performance of our contract with our customers or you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services to: • Existing and former customers • Third parties who have previously expressed an interest in our services • Third parties with whom we have had no previous dealings |
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services |
| External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.
- Who We Share Your Personal Information With.We may share personal information with:
- Our affiliates, including companies within the CuraCore group;
- Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses, and delivery companies;
- Other third parties we use to help us run our business, such as marketing agencies or website hosts;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Credit reporting agencies;
- Our insurers and brokers;
- Our bank;
- Veterinary continued education associations, such as American Association of Veterinary State Boards Registry of Approved Continuing Education (AAVSB RACE); and
- Our customers.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may also, where applicable, impose contractual obligations on service providers to help ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. If appropriate, we will attempt to anonymize information, but this may not always be possible. The recipient of the information will be bound by applicable confidentiality obligations.
- Personal Information We Sold or Shared.We do not sell your personal information. In the preceding 12 months, we may have shared the following categories of personal information with the parties identified in Section 5 above:
- Identifiers, such as your name, postal address, IP address, email address, or account name, with our payment processors and/or service providers.
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, address, telephone number, education, employment, employment history, veterinary licenses, credit card number, debit card number, or any other financial information, with our payment processors, services providers, and veterinary continued education associations such as AAVSB RACE.
- Commercial information, such as products or services purchased, with our payment processors and service providers.
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement), with our service providers and website hosts.
- Geolocation data, with our service providers and website hosts.
- Professional or employment-related information with our services providers and veterinary continued education associations such as AAVSB RACE
- Categories of Personal Information We Disclosed for a Business Purpose.In the preceding 12 months, we may have disclosed the following categories of personal information for a business purpose:
- Identifiers, such as your name, postal address, IP address, email address, or account name, with our payment processors and/or service providers.
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, address, telephone number, education, employment, employment history, veterinary licenses, credit card number, debit card number, or any other financial information, with our payment processors, services providers, and veterinary continued education associations such as AAVSB RACE.
- Commercial information, such as products or services purchased, with our payment processors and service providers.
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement), with our service providers and website hosts.
- Geolocation data, with our service providers and website hosts.
- Professional or employment-related information with our services providers and veterinary continued education associations such as AAVSB RACE
- How Long Your Personal Information Will Be Kept.We retain your personal information for as long as necessary to provide our services, including to fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, carrying out our legitimate interests, including meeting our contractual obligations, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. The criteria used to determine retention periods includes the legal limitation of liability period, agreed contractual provisions, applicable regulatory requirements, and industry standards.
- EEA Data Subjects: Promotional Communications.If you are an EEA Data Subject: We may use your personal information to send you updates (by email, text message, telephone, or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and will never knowingly sell it with other organizations outside the CuraCore group for marketing purposes.
You have the right to opt-out of receiving promotional communications at any time by:
- Contacting us at info@curacore.org;
- Using the “unsubscribe” link in emails or “STOP” number in texts; or
- Updating your marketing preferences in your account.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
- California Consumers: Your Rights Under the CCPA/CPRA.Where applicable: if you are a California consumer, and depending on your relationship with us and the nature of our business, you may have the following rights (free of charge) under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable:
| Disclosure of Personal Information We Collect About You |
You have the right to know, and request disclosure of:
Please note that we are not required to: |
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| Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose |
In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. |
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| Right to Limit Use of Sensitive Personal Information |
You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. |
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| Right to Deletion |
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is reasonably necessary to: |
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| Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. | ||
| Protection Against Retaliation |
You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things, retaliate against you by:
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
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It is our policy to extend at least equal rights to those listed above to all of our consumers, regardless of your location.
- UK And EEA Data Subjects: Your Rights Under the EU and UK GDPR.Where applicable: if you are a EEA or UK consumer, and depending on your relationship with us and the nature of our business, you may have the following rights:
| Right to Be Informed | The right to know or be notified about the collection and use of your personal information |
| Right to Access | The right to be provided with a copy of your personal information (the right of access) |
| Right to Rectification | The right to require us to correct any mistakes in your personal information |
| Right to be Forgotten | The right to require us to delete your personal information—in certain situations |
| Right to Restriction of Processing | The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data |
| Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations |
| Right to Object | The right to object: • At any time to your personal information being processed for direct marketing (including profiling) • In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests |
| Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the EU General Data Protection Regulation.
- General Rights. In general, and in addition to any other rights you might have, you may request to know whether we process your personal information and to access such personal information. You may request to correct inaccuracies in your personal information. You may request to receive a copy of your personal information, including specific pieces of personal information, including, where applicable, to obtain a copy of your personal information in a portable, readily usable format. You may request that we delete your personal information, subject to certain exceptions and our contractual rights or rights under applicable law. You may request to “opt-out” of your personal information being sold to certain third parties, as defined by applicable law. This right may be exercised by contacting us as detailed below. If applicable, our use of tracking technologies through some of our websites may be considered a sale or sharing of your personal information for cross-context behavioral advertising or targeted advertising under certain U.S. consumer privacy laws. You may request to opt-out of such tracking technologies by utilizing the “Cookie Settings” link on our websites or by sending an opt-out preference signal supported by your device or browser. In such circumstances, your use of an opt-out preference signal will apply only to your device or browser and not to other personal information that is not linked to your device or browser. We will not retaliate against you because you exercise any of your rights under applicable law. We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.
- How to Exercise Your Rights.If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by contacting us via phone at 970-818-0851; email at info@curacore.org; or mail to CURACORE VET PLLC, 905 South Summit View Drive, Fort Collins, CO, 80524, United States. Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact us, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address, and customer or matter reference number);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right(s) you want to exercise and the information to which your request relates
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
- EEA Data Subjects: Where Your Personal Information is Held.Where applicable: Information may be held at our offices and those of our group companies, third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). Some or all of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”
- EEA Data Subjects: Transferring Your Personal Information Out of the EEA.Where applicable: To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, e.g.:
- With our offices outside the EEA;
- With your and our service providers located outside the EEA;
- If you are based outside the EEA;
- Because we are based outside the EEA; or
- Where there is an international dimension to the services we are providing to you.
These transfers may be subject to special rules under European and UK data protection law. If you would like further information, please contact us (see “How To Contact Us” below).
- Keeping Your Personal Information Secure.We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and, if applicable, subject to a duty of confidentiality. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- EEA Data Subjects: How to File a GDPR Complaint.Where applicable: We hope that we can resolve any query or concern you raise about our use of your information. The GDPR may also give you the right to lodge a complaint with a supervisory authority, in the EEA state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authorities for EEA states are listed here: Our members | European Data Protection Board.
- Changes to This Privacy Addendum. We may change this Addendum from time to time. Any changes will be posted on this page with an updated revision date.
- How to Contact UsPlease contact us by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below:
CURACORE VET PLLC
905 South Summit View Drive,
Fort Collins CO 80524, United States
970-818-0851
info@curacore.org