Privacy Policy

Your privacy is important to SURGE DVM, LLC. Please read this privacy notice carefully as it contains
important information on who we are, how and why we collect, store, use, and share personal information,
your rights in relation to your personal information and on how to contact us or supervisory authorities in
the event you have a complaint.

By using our website or any other domain operated by SURGE DVM, LLC, you
signify your consent to the terms of our Privacy Policy. If you do not agree with any terms of this Privacy
Policy, please do not use this website, or submit any personal information to us.

1. Who We Are
SURGE DVM LLC (“SURGE”) and operating at collects, uses, and is responsible
for certain personal information about you.

2. Children’s Online Privacy Protection Act
This website and any products and services offered herein are not intended for persons under the age of
thirteen (13). SURGE does not knowingly collect information from anyone under thirteen (13) years of
age. SURGE prohibits children under the age of thirteen (13) from using all interactive portions of this
website, including leaving any comments, filling out forms, or otherwise submitting information. SURGE
will not knowingly collect personally identifiable information from children under thirteen (13). If
SURGE learns it has any information or content from anyone under the age of thirteen (13), it will delete
that information.

3. The Personal Information We Collect and Use
a. Information Collected by Us
SURGE may collect, use, and is responsible for certain personal information that you provide when
you voluntarily sign up for emails, free gifts or resources, register for a class or presentation, leave
comments, order a service or product, fill out any type of form, access private membership pages, or
otherwise contact SURGE via an online form or email. The information collected may include your
name, email, practice name, address, phone number, billing information, and any other information
you submit to SURGE, whether through SURGE’s website or membership program, including your
preferences, interests, and favorite items. You are not required to provide any personally identifiable
information to merely access or visit this website.

SURGE may collect domain information, your numerical IP address, referring website addresses, the
type of browser you use, which pages you view, and the files you request. We may also use “cookies”
(small files saved on your hard drive by your web browser) to analyze website and advertisement
performance, track user patterns, save information from your previous visits and customize your

If your browser sends a “Do Not Track” signal, only a generic cookie will be placed on your device
while the website is accessed.

We will ask for your consent to allow us to use cookies. SURGE or its third-party vendors may collect
nonpersonal information through the use of these technologies. Nonpersonal information might
include anonymous demographic information, which is not unique to you, such as your ZIP code, the
browser you use, the type of computer you use and technical information about your means of
connection to this website such as the operating systems and the Internet service providers utilized and
other similar information. SURGE’s systems may also automatically gather information about the
areas you visit and search terms you use on this website and about the links you may select from
within this website to other areas of the Internet.

If you are located in the European Economic Area (“EEA”), we are regulated under the General Data
Protection Regulation which applies across the European Union, and we are responsible as controller
of that personal information for the purposes of those laws.

If you are located in the United Kingdom (“UK”), we are regulated under UK data regulations known
as “UK GDPR.”

b. Information Collected from Other Sources
We also obtain information from other sources, such as SurveyMonkey. The information collected
may include your name, practice name, email, address, phone number, preferences, interests, favorites,
and financial data.

c. How we use your personal information
SURGE collects such information in order to send emails, fulfill orders, deliver services and products,
complete customer transactions, oversee contests and promotions, inform you of other products or
services available from SURGE and SURGE’s sponsor partners (“Partners”), conduct surveys about
current or potential new services, and improve website performance and customer service.

d. Who We Share Your Personal Information With
SURGE respects your privacy and will never sell, trade, or transfer your personally identifiable
information to third parties (beyond what is necessary for fulfilling a customer transaction or for the
basic functionality of an online service) without your consent.

We do, however, share your name, practice name, and delivery address details with our third-party
suppliers, credit card processors or shipping companies. If you have enrolled in the SURGE
Membership, you have also provided your consent in the SURGE Membership Terms and Conditions
of Use for SURGE to share your name, practice name, email, and delivery address with our Partners
for their marketing purposes.

This data sharing enables us to process transactions, perform statistical analysis, provide support, and
deliver goods and services to you. It also allows our Partners to share their products and services
directly with you and allows you to enroll in any rebate programs they may offer based on purchases
you make with them. Those third-party recipients are based outside the European Economic Area or
the UK — for further information including on how we safeguard your personal data when this
occurs, see Transfer of your information out of the EEA, UK below.

SURGE may release personal information to enforce its Website Terms and Conditions of Use, other
Terms and Conditions, manage its business, protect users or the general public, or to otherwise comply
with legal obligations.

If you give SURGE your permission, it may also use personal identification information for internal or
external marketing and promotional purposes.

On occasion, SURGE may collect personal information from you in connection with optional contests,
special offers or promotions. SURGE will share such information with necessary third parties for the
purpose of carrying out the contest, special offer or promotion. SURGE will ask for your consent to
such disclosure and use of such information, prior to your participation in the contest, special offer or

We reserve the right to transfer personal information in the event that we merge with or are acquired
by a third party. We also may disclose your personal information for any other purpose permitted by
law or to which you consent.

We will not share your personal information with any other third party.

e. Whether Information Has to Be Provided by You and Why
The provision of your name, email, practice name, phone number, address, and/or billing information
is required from you to join the SURGE Membership or sign up for free resources.
We do not require you to provide any personal data in order to access the public areas of our website.
We will inform you when we collect it whether you are required to provide the information to us.

f. How Long Your Personal Information Will Be Kept
We will hold all client and customer personal data in our files for six years.
We will hold all non-client personal data until you let us know you would like for us to delete it or
unsubscribe from our marketing contacts, which you are free to do at any time.

g. Reasons We Can Collect and Use Your Personal Information
SURGE collects and uses your personal information to send emails, fulfill orders, deliver services and
products, complete customer transactions, oversee contests and promotions, inform you of other
products or services available from SURGE and our Partners, conduct surveys about current or
potential new services, and improve website performance and customer service.

4. Use and Transfer of Your Information Out of the EEA, UK
This website is operated in the United States and third parties with whom we might share your personal
information as explained above are located in the United States and the United Kingdom. If you are
located in the EEA, the UK, or elsewhere outside of the United States, please be aware that any
information you provide will be transferred to the United States.
By using this website, participating
in any of its services and/or providing your information, you consent to this transfer.

These countries do not have the same data protection laws as the EEA or UK. While the European
Commission has not given a formal decision that the United States provides an adequate level of data
protection similar to those which apply in the EEA, any transfer of your personal information will be
subject to the derogation in Article 49 permitting non-repetitive transfers that concern only a limited
number of data subjects, as permitted by Article 49 of the General Data Protection Regulation that is
designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of
your personal information.

If you would like further information, see “How to contact us” below. We will not otherwise transfer your
personal data outside of the EEA or UK, or to any organization (or subordinate bodies) governed by
public international law or which is set up under any agreement between two or more countries.

5. Your Rights

If you want to unsubscribe from receiving emails from SURGE, you may do so at any time by emailing Each email from SURGE includes instructions for unsubscribing from these email communications.

If you are covered by the General Data Protection Regulation, or other relevant privacy regulations, you
have a number of important rights free of charge. In summary, those include rights to:

  • Fair processing of information and transparency over how we use your use personal
  • Access to your personal information and to certain other supplementary information that this
    Privacy Policy is already designed to address
  • Require us to correct any mistakes in your information which we hold
  • Require the erasure of personal information concerning you in certain situations
  • Receive the personal information concerning you which you have provided to us, in a
    structured, commonly used and machine-readable format and have the right to transmit those
    data to a third party in certain situations
  • Object at any time to processing of personal information concerning you for direct marketing
  • Object to decisions being taken by automated means which produce legal effects concerning
    you or similarly significantly affect you
  • Object in certain other situations to our continued processing of your personal information
  • Otherwise restrict our processing of your personal information in certain circumstances

You may also have the right to claim compensation for damages caused by our breach of any data
protection laws.

For further information on each of those rights, including the circumstances in which they apply, visit;; or

If you would like to exercise any of those rights, please:

  • Email, call, or write to us
  • Provide us enough information to identify (e.g., first and last name and email address)
  • Provide us proof of your identity and address (a copy of your driver’s license or passport and
    a recent utility or credit card bill)
  • Provide us with the information to which your request relates including any account or
    reference numbers, if you have them

6. Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally
lost, used, or accessed in an unauthorized way. We limit access to your personal information to those who
have a genuine business need to know it. Those processing your information will do so only in an
authorized manner and may be subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and
any applicable authorities of a suspected data security breach where we are legally required to do so.
It is important to understand that no security measures are absolute. We cannot guarantee the safety of any
information you provide to us.

Please note that any comments or information that you post on the website, including the SURGE
Membership website and social media pages or groups, become public and third parties may use your
information. SURGE is not responsible for any unauthorized uses by third parties in such context. You
disclose such information at your own risk.

7. Links to Other Sites
You may see advertising or other content on this website that links to the sites and services of our
Partners, suppliers, advertisers, sponsors, licensors, vendors, affiliates or other third parties. Any products
or services reached through a third-party link are subject to separate privacy policies. SURGE is not
responsible for or liable for any content on or actions taken by such third-party websites.

8. How to Complain
We hope that we can resolve any question or concern you raise about our use of your information.
If you are covered by the General Data Protection Regulation or UK GDPR, you may lodge a complaint
with a supervisory authority, in particular in the UK or European Union (or European Economic Area)
state where you work, normally live, or where any alleged infringement of data protection laws occurred.

9. Changes to This Privacy Notice
We may change, modify, or update this Privacy Policy at any time and will notify you of any fundamental
changes by email or postal mail. Otherwise, we will reflect any such modifications to this Privacy Policy
on our website. We suggest that you periodically consult this Privacy Policy. Your continued use of our
website after any such changes constitutes your acceptance of this Privacy Policy, as revised.

10. How to Contact Us
If you have any questions or concerns about this Privacy Policy, the information we hold about you, or
you wish to change your personal information in our records, please contact:
234 W. Bandera #140
Boerne, TX 78006

11. Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us
(see “How to contact us” above).

Policy Last Updated and Effective Date: December 19, 2022