SCHEDULE 5 DATA PROTECTION AND PRIVACY RULES
We are committed to protecting and respecting Your privacy.
The data controller is The Racing Manager Limited of 39 Long Acre, London, WC2E 9LG.
Our nominated representative for the purpose of the Act is Adrian Ash.
Legal basis for the processing of personal information
TRM bases its processing of Your personal information on one or more of the following grounds, as permitted by data protection law:
- processing based on Your explicit consent to such processing;
- processing based on TRM’s legitimate interests as the operator of a Site aimed to facilitate the ownership and management of racehorses; and
- processing based on the need for TRM to be able to use Your personal information in order to perform obligations required under these Terms and/or due to the need to administer the contract in relation to the Members and to invoice the Members as required under these Terms.
We may collect and process the following data about You:
INFORMATION YOU GIVE US
You may give Us information about You by filling in forms on our Site or by corresponding with Us by phone, email or otherwise. This includes information You provide when You register to use our Site, subscribe to our service, place an order on our Site, use our service, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey, and when You report a problem with our Site. The information You give Us may include Your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
INFORMATION WE COLLECT ABOUT YOU
With regard to each of Your visits to our Site, 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 Site (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 are also working closely with third parties (including, for example, business partners, regulators, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about You from them.
Strictly necessary cookies:these are cookies that are required for the operation of our website. They include, for example, cookies that enable You to log onto secure areas of our website, use the shopping cart or make use of e-billing services.
Analytical/performance cookies:they allow Us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps Us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies:these are used to recognise You when You return to our website. This enables Us to personalise our content for You, greet You by name and remember Your preferences (for example, Your choice of language or region).
Targeting cookies:these cookies record Your visit to our website, the pages You have visited and the links You have followed. We will use this information to make our website and the advertising space on it more relevant to Your interests.
USES MADE OF THE INFORMATION
We use information held about You in the following ways:
Information You give to UsWe will use this information:
- to carry out our obligations to You under these Terms and to provide You with the information and services that You request from Us;
- to provide You with information about other goods and/or services We offer that are similar to those that You have already purchased or enquired about;
- to provide You, or permit selected third parties 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 (email, SMS or app push notifications) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to You;
- to notify You about changes to our service;
- to ensure that content from our Site is presented in the most effective manner for You.
Information We collect about YouWe will use this information:
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site 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 Site 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 Site about goods or services that may interest You or them.
Information we receive from other sourcesWe 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.
- Apart from disclosure of Your personal information to third parties as set out in these Terms including in clause 4.4.3 below, We shall not share or transfer Your personal information to any third parties.
- We may disclose Your personal information to third parties:
- in the event that it is necessary to provide Your personal information to regulators such as the British Horseracing Authority or to third parties who provide verification checks on You such as Contego.com and for related purposes;
- in the event that We sell TRM, in which case We may disclose Your personal data to the prospective buyer of TRM;
- If TRM or substantially all of its assets are acquired by a third party, in which case personal data held by it about its Members will be one of the transferred assets;
- if We are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect our rights or property, or the safety of our Members, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where We store Your personal data
- All information You provide to Us is stored on our secure servers. Any payment transactions will be encrypted when processed by third parties. Where We have given You (or where You have chosen) a password which enables You to access certain parts of our Site, 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 Site; 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.
Retention period for Your personal data
- Whilst We will periodically review and delete any outdated personal data in accordance with our legal requirements, our general policy is to retain all relevant personal data for six years after Your membership is terminated or expires, as information may be relevant for legal reasons for this period.
- If You consider that this period is excessive in any specific circumstances, please contact Us by email at email@example.com.
- You have the right to ask Us not to process Your personal data for marketing purposes. We will always 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. You can also revoke any consent given to Us to process Your date at any time by contacting Us firstname.lastname@example.org.
- In addition, You also have the following legal rights in relation to personal data:
- the right to rectify any inaccuracies in personal information held on You;
- the right of portability – this is the right to require personal data to be provided in a commonly used electronic form (in specified circumstances only);
- the right to object to processing based on legitimate interests;
- the right to erasure (“the right to be forgotten”) – this right is broadly the right to have certain personal data erased in specified situations, normally where the processing fails to meet the requirements of data protection laws;
- the right to object to Your personal data being used for profiling and automated decision-taking.
ACCESS TO INFORMATION
The Act gives You the right to access information held about You. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing You with details of the information We hold about You.
LINKS TO THIRD PARTY WEBSITES
Our Site may, from time to time, contain links to and from the websites of third parties. 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.