MyRacehorse Limited (“MyRacehorse“, “we“, “our“, or “us“) is committed to protecting and respecting your privacy.
OUR APPROACH TO PRIVACY
MyRacehorse Limited (company no. 13682188) is the data controller of the personal information we hold about you.
Our registered and postal address is 5th Floor 10 Finsbury Square, Finsbury, London, United Kingdom, EC2A 1AF.
We are registered as a data controller with the Information Commissioner’s Office under data protection registration numberZB298377.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
More generally, we:
- collect personal information that you voluntarily submit to us, such as your name and contact details, when you register with us, use our Site and our services, or otherwise interact with us in the course of our business activities;
- collect personal information about you from third parties, such as social networks, public databases (where permitted by law), our advertising partners and our other business partners where we carry out joint business activities; and
- may also collect certain personal information automatically, including in relation to how you access and use the Site, technical information regarding the device you use to access the Site [and the way in which you interact with our newsletters (such as whether you open these).
We use the information we collect about you to correspond with you, perform our agreements with you, carry out marketing activities and our day-to-day business activities and operations (as described in greater detail in Annex 1).
We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
We will indicate to you where the provision of certain personal information is required in order for us to provide you certain services. If you choose not to provide such personal information, we may not be able to provide the services you have requested.
We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Site and developing new products and features. We may also share such anonymised information with others.
We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 in accordance with our legal obligations and legitimate business interests.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.
RECIPIENTS OF PERSONAL INFORMATION
We may share your personal information with the following categories of recipients (as required in accordance with the uses set out in Annex 1):
- Service providers: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing marketing, payment processing, courier, web hosting or analytics services.
- Professional advisors: we may share your personal information with our lawyers, accountants, insurers and other professional advisors to the extent we need to (for example, to defend ourselves against legal claims).
- Trainers, stables and racetracks: we will share your personal information with horse trainers, stables, racetracks and such other third parties as necessary to allow you to exercise your privileges in relation to racehorses, in each case, as necessary to provide our services.
- Other users: if you choose to post on the Site, your personal information will be shared with other users of the Site.
- Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
- Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law (including with relevant horse racing authorities) or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of MyRacehorse, its users or others.
- Other members of the MyRacehorse group: we may share your personal information with our affiliates, including Experiential Squared, Inc. and MyRacehorse No 1, where they provide services on our behalf or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.
STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
Security. We implement appropriate technical and organisational measures, including encryption, to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers.
International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the UK and European Economic Area (“EEA”) where:
- Our group members are located. For example, we share personal data with our parent company, Experiential Squared, Inc., which is located in the USA and a member of the MyRacehorse group, MyRacehorse No 1, which is located in Australia.
- Our third party service providers have operations, including in the USA and [Australia].
In the event we need to transfer your personal data to a country which is not recognised by the UK government or EU Commission (as applicable) as ensuring an adequate level of protection for personal data, we shall ensure that appropriate safeguards are in place to ensure adequate protection for your personal data (for example, by entering into standard contractual clauses with the recipients of your personal information).
Further details regarding the relevant safeguards we implement can be obtained from us on request at email@example.com.
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
In accordance with data protection law, you have the following rights in respect of your personal information that we hold:
- Right of access. You have the right to obtain access to your personal information.
- Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to object. You have a right to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive or contacting us using the details set out below.
- Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent at any time (without affecting the lawfulness of our processing carried out before this point).
Please note that not all of the above rights are absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.
You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, information on how to contact the Information Commissioner is available at www.ico.org.uk. If you are resident in the EEA, you can find details regarding your local data protection regulator here.
SESSION RECORDING INFORMATION
We may use session recording via software or a third party to create reenactments of user behavior based on data collected from the website’s or app’s server (such as mouse or mobile gestures or keyboard inputs). We use this information to help optimize the My Racehorse user experience. Session recording tools do not actually record users’ screens and never record personally identifiable information. Passwords and sensitive data, like payment credentials are obscured from view and can’t be tracked via the software.
COOKIES AND SIMILAR TECHNOLOGIES
LINKS TO THIRD PARTY SITES
The Site may, from time to time, contain links to and from third party websites, including those of our business partners, advertisers, news publications 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 their policies. Please check the individual policies before you submit any information to those websites.
CHANGES TO THIS POLICY
NOTICE TO YOU
If you are resident in Ireland, you can also contact our EU representative as follows:
Kate Hardy, firstname.lastname@example.org
ANNEX 1 – PERSONAL INFORMATION WE COLLECT