1. Welcome to Horse Monkey.
Horse Monkey enables people in the UK to plan, promote, and sell entries and services to any equestrian event (“Events”). Horse Monkey makes it easy for everyone passionate about horses to discover Events, and to share the Events they are attending with the people they know. We do this through our website.
2. We are committed to protecting your privacy and security.
This policy explains how and why we use your personal data, to ensure that you remain informed and in control of your information.
3. Because of the nature of the services that we provide, any information that you provide or linked to your account may be provided to event organisers (“Organisers”), and your profile information may be publicly available.
1. About Us
1. We are Horse Monkey Limited, a company incorporated in England and Wales with Company Number 8227088. Our registered office address is at 1 Gleneagles Drive, Brockhall Village, Old Langho, Lancashire, BB6 8BF, but our main trading address is at Old Dairy, Clifton Fields, Lytham Rd Clifton, Preston, PR4 0XG. Our VAT registration number is 151 6571 17. We are registered at the Information Commissioner’s Office with data controller number ZA111172. Details of how to contact us can be found www.horsemonkey.com.
1. What information we collect
1. Personal data provided by you.
1. When you create a profile on Horse Monkey then you will be asked to provide certain personal information including but not limited to name, email address, and details about your membership of various organisations, together with information on the horses and riders that you wish to be covered by your account.
2. You do not need to provide all of this information, but you may find functionality of the Service is limited if you haven’t provided us with certain information. Some information is compulsory, and unless you are willing to provide this information then you will not be able to use the Service.
3. When you register for an Event on Horse Monkey, the relevant Organiser may request additional information beyond that requested when you set up your account. This data is shared with us under the terms of our agreements with Organisers, and our General Terms and Conditions of Use with you.
1. Information created by your use of Horse Monkey.
1. Information from third parties.
1. Event Organisers provide us with certain information from time to time which may include personal information about you. This will include the results of any Events that you have attended where applicable.
2. Many Event Organisers use Horse Monkey to administer their Events and even if you do not use Horse Monkey to register your place, they may ask you for your details and whether you have a Horse Monkey account and if so, if wish to use it for the Event registration. In such circumstances they may update your profile with the information that you give them. We aim to notify you of any such updates so that you can verify the accuracy of such changes, but you should check your profile information from time to time to ensure that it is correct and up to date.
3. Sometimes an Event attendee will not have a Horse Monkey account, but the Event Organiser will create one for them in order to administer their Event through Horse Monkey. In such circumstances the account will not be a public account.
1. Sensitive personal data.
Sensitive data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not require any sensitive data to be provided through Horse Monkey, although an Event Organiser may request such information in order to administer their Event. We do not act as the data controller of any sensitive information and do not use it for any purpose other than those instructed to us by the Event Organiser, which is usually only to administer their Event. Please see the relevant Organiser’s own privacy notice about how they will handle this sensitive data.
We do not accept registrations from children under the age of 18, but we do allow users to register under 18s for Events and so their personal details will be contained within the Event administration details, and included in any results published by the Organiser.
1. Disclosing and sharing data
1. Sharing with Event Organisers.
1. Event Organisers are able to search profiles on Horse Monkey so that they can register entrants to Events themselves. Organisers are not allowed to use this information for any other purpose without your permission.
2. When you register for an Event, then we share your personal data with the Event Organiser so that they can administer and manage the Event. Event Organisers are only granted personal data in respect of the Events you have attended with that Organiser, and not with other Organisers. We require that all Organisers publish their own privacy notice on their Event and Organiser pages on Horse Monkey and you should read these notices carefully to ensure that you agree with them.
3. Event Organisers may share your personal data in respect of Events with us. Please see Section 3.3(b).
1. Payment Providers.
1. Where you make a payment through Horse Monkey this is usually handled by our preferred third party payment service provider Stripe Inc. (“Stripe”). We do not have access to your payment details and no records are retained on our servers. For details as to how Stripe handle your details, please see their privacy notice and terms and conditions which can be found here.
2. Occasionally an Organiser may use an alternative payment provider, and again we will not have access to your payment details. The Organiser should identify who the payment provider is, and how they will use your information.
1. Suppliers and sub-contractors.
1. We use third party suppliers to provide various IT and system administration and such parties may have access to your personal data (acting as processors). We restrict such access to their employees that need such access to perform the relevant service and impose obligations on them not to use it for any other purpose, to ensure its security and to keep it confidential.
2. Our servers are all EEA based with market-leading providers.
3. All our suppliers and sub-contractors are based in the EEA and we do not permit transfers outside of the EEA unless specific measures are put in place to protect your personal data.
1. Our group companies.
We may share your personal information with our group of companies for administration purposes, but also as part of our internal research and analysis into product and service development.
1. We may have to share your personal data with professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accountancy services.
2. We may share your personal data with third parties to whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
3. We may be required by law to share your data with HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) who require reporting of processing activities in certain circumstances.
1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
1. How we use information
1. Your information is used by us to administer your Horse Monkey account. This will include registering you for Events and passing your details to the relevant Event Organiser.
2. We will also use your personal data to provide support or to try to resolve complaints where necessary.
1. If you have given us consent to do so, we will send you marketing information from time to time about other Events being promoted and administered through Horse Monkey, and/or on behalf of third parties who offer goods or services that in each case we think may be of interest to you. You can opt out of receiving such communications by amending your marketing preferences in your account details, by clicking on the unsubscribe link on all such communications, or by contacting us. If you opt out of receiving these marketing messages, we will still be able to contact you in respect of the Events that you have registered for.
2. We may from time to time use targeted marketing to display relevant adverts or messages on the site based on your account details and Event attendance.
3. You may receive marketing material from an Event Organiser under the terms of their contract with you, and this should be dealt with in the relevant Organiser’s privacy notice. We are not responsible for how an Organiser handles your personal data, but please do [contact us] if you think you are receiving inappropriate messages as we may be able to help.
1. Internal research and analysis.
We strive to improve every day, and as a result we look at how you use Horse Monkey, and how we can make it better for you, Organisers and ourselves. This is generally done by way of aggregate and anonymised data, but may involve looking at individual user data.
1. Aggregated and anonymised data.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature, or the number of users registering for certain types of Events. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
1. How we protect your personal information
1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
1. We will keep all your personal data contained in your account for so long as your account is active, and then for an additional period not exceeding [six years]. This is because we may need it to deal with any disputes or insurance claims. Once your account is deactivated, the personal information contained within it will not be available to Organisers.
2. Please note that your information may be retained within Event documentation as to attendees, competitors and results and this information will not be automatically deleted as it has historical and statistical value.
1. Your rights
1. Request access to your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
1. Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
1. Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
1. Object to processing of your personal data.
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms you may object to our processing of your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
1. Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
1. if you want us to establish the data's accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
1. Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
1. Withdraw consent at any time.
Where we are relying on consent to process your personal data you may withdraw this consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
1. How to exercise your rights.
1. If you wish to exercise any of the rights set out above, please contact us. If you are submitting a data subject access request it would be helpful if you could complete a copy of our subject access request form which can be found here. This will enable us to identify and deal with your request much more quickly.
2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
4. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
1. Your right to complain to the Information Commissioner’s Office.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
© Horse Monkey Limited 2018
Version: 2.0 Issued: 21 May 2018