Retraining of Racehorses Ltd (We) are committed to protecting your personal data and respecting your privacy.
For the purpose of the General Data Protection Regulation (GDPR), the data controller is Retraining of Racehorses. We are registered with the Information Commissioner’s Office (ICO) as a Data Controller. Our registered number is: Z1303206. Our nominate representative is Di Arbuthnot and our registered address is 75 High Holborn, London. WV1V 6LS.
GDPR requires all organisations that process personal data to have a Lawful Basis for doing so. Our Lawful Basis for processing your information is consent of the data subject and/or for the purposes of performing a contract with a data subject. Where we rely on consent, you have the right to withdraw that consent at any time.
We may also process data under the Legitimate Interest of RoR or a data subject who is not a registered member of RoR, where such interests are not overridden by the interests, rights or freedoms of the data subject. Where we use Legitimate Interest as a legal basis, we have made sure that your information, and your rights in relation to that information, are protected. Examples may include provision of information about RoR and our activities such as newsletters, or to communicate with you to raise awareness, and/or notify you of promotional activities or to invite you to attend specific events.We may also process your information in order to comply with a legal obligation to which we are subject or to protect the vital interests of a data subject or another person.
We may collect and process the following data about you:
Information we may collect from you to administer RoR Competition series and educational events.
– Information you consent to give us. You may give us information about you by filling in forms on our Sites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Sites, subscribe to our services, sign up for our newsletters, provide a donation, sign up for training, search for a product, view adverts, post adverts, enter a competition, promotion or survey (and to receive any prizes), register your horse with us, request to be included in our Retrainer’s Directory and when you report a problem with our Sites. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photographs.
– Information we collect about you
With regard to each of your visits to our Sites we may automatically collect the following information:
· technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
· information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Sites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
– Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers) and may receive information about you from them.
Uses made of the information
We use information held about you in the following ways:
– Information you consent to give to us. We will use this information:
· to send you updates about our activities;
· to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
· to include your details in our Retrainer’s Directory, if you have requested us to include you and we have agreed to that;
· to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
· to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale, negotiations of a sale or provision of a service to you. If you are a new customer, we will contact you by electronic means only if you have consented to this. If you are happy for us to use your data in this way, please opt in by ticking the relevant box situated on the form on which we collect your data (the registration form);
· to notify you about changes to our service;
· to ensure that content from our Sites is presented in the most effective manner for you and for your computer.
You can change your preferences or opt out at any time by contacting firstname.lastname@example.org
– Information we collect about you. We collect information about you under the lawful basis of consent. We will use this information:
· to administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to improve our Sites to ensure that content is presented in the most effective manner for you and for your computer;
· to allow you to participate in interactive features of our service, when you choose to do so;
· as part of our efforts to keep our Sites safe and secure;
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
· to make suggestions and recommendations to you and other users of our Sites about goods or services that may interest you or them.
– Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
If you are advertising a horse for sale on our Sites, we will disclose your email address or telephone number as specified by you to guests and registered users of our Sites. Please note we do not store credit card details.
If you have requested us to include your details in our Retrainer’s Directory and we have agreed to this, we will include the information you specify (such as your name, address and contact details) in our Retrainer’s Directory which is available on our main website, www.ror.org.uk
Otherwise we may share your information with selected third parties including:
· Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
· Analytics and search engine providers that assist us in the improvement and optimisation of our Sites.
We may disclose your personal information to third parties:
· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
· If Retraining of Racehorses or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
· If we are under a duty to disclose or share your personal data in order to resolve a compaint or disciplinary hearing, comply with any legal obligation, or to protect the rights, property, or safety of Retraining of Racehorses, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We do not use automated decision-making in the processing of your personal data.
Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be through Stripe. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
The General Data Protection Regulation gives you specific rights regarding the collection and use of your personal data. You have the right to ask us not to process your personal data for marketing purposes or to specify how you want to receive marketing communications from us. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. If you are happy for us to use your data in this way, please opt in by ticking the relevant box situated on the form on which we collect your data (the registration form); You can also object to the ways in which we use your information and exercise the right to opt out of receiving marketing information from us at any time by contacting email@example.com
Our Sites may, from time to time, contain links to and from the websites of our partner networks, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
GDPR also gives you the right to access information held about you. You can ask us for a copy of your personal information at any time which will be provided within 30 days. You can also ask us to update or correct any inaccuracies with the personal data we hold about you, or to stop sending you direct mail, or emails. You can also ask us to provide your information in a commonly used electronic format for transmission directly to another organisation, or to stop processing or erase your personal data.
The period for which we will keep your information
We retain your personal data for the purposes described in this policy and while you remain an RoR member, employee or volunteer, or a stakeholder unless you ask us to delete it. RoR has an internal Retention and Disposal Policy which explains to our staff how long to retain data and how to dispose of it when it is no longer needed. We will delete your information on request unless:
- There is an ongoing issue, such as a complaint or disciplinary hearing in which case we may share your personal data with our legal advisors or Disciplinary Panel.
- We are legally required to; or
- There are overriding legitimate business or charitable interests