HorseWorld Privacy Notice
HorseWorld Trust (‘We’, ‘us’ and ‘our’) are committed to protecting and respecting your privacy and personal data.
This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purpose of applicable data protection legislation, the data controller is HorseWorld Trust of Delmar Hall, Keynes Farm, Staunton Lane, Whitchurch, Bristol, BS14 0QL. We have appointed a representative who is responsible for overseeing data protection at HorseWorld, our representative can be contacted using the contact information provided at the bottom of this policy.
INFORMATION WE COLLECT FROM YOU
We collect the following categories of information about you:-
• Identity data: including name, title, address, date of birth, sex and/or gender;
• Contact data: including billing address, delivery address, telephone number, and email address;
• Financial and transactional data: including debit, credit card or bank account information, details about payments to and from you, whether you are a tax payer; details of transactions you carry out through our website and of the fulfilment of your orders. We do not store your credit or debit card information once the transaction is complete. For further information visit: https://www.pcisecuritystandards.org/pci_security/.
• Technical data: including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, traffic data, weblogs and other communication data;
• Usage data: includes anonymous statistical data about our users' browsing actions and patterns and use of our site;
• Marketing and communications data: includes your preferences in receiving marketing contact from us and our third parties and your communication preferences;
• Special category data: as part of our Discovery programme, we may collect health data, criminal offence data and racial or ethnic origin where this is relevant to being involved in the programme;
• Pictures and Video: as part of taking part in our Discovery programme we may ask you if we can take pictures and/or videos of your participation.
HOW WE COLLECT INFORMATION FROM YOU
We may collect and process the following data from direct interactions.
• Your identity, contact, and financial and transactional data, when you:- fill in forms on our website www.horseworld.org.uk (our Site), this includes information provided at the time of registering to purchase goods from our Site, - correspond with us at events such as Open Days, or by post, phone, email or otherwise, - make donations,- enter into competitions, promotions, surveys, or support petitions, - give us feedback, or request further information,
• Your identity, contact and marketing and communications data, when you: - request marketing to be sent to you (such as subscribing to our newsletter or registering for Horse Alerts to find out what we at HorseWorld have been up to and how your donations help us care for horses),
• Your identity, contact, special category data, pictures and videos when you:- volunteer with us or otherwise take part in our Discovery volunteering programme. We may collect and process the following data from automated technologies or interactions.
• Your technical and usage data, when you:- interact with our website,- accept certain cookies and other similar technologies, - interact with other websites employing our cookies. Please see our cookie policy for further information.
LAWFUL BASES FOR USE OF THE INFORMATION
We will only use your personal data for the purposes for which we collected it. We use information held about you in the following ways:
• Identity data, contact data, financial and transactional data: Where we need to perform the contract we are about to enter into or have entered into with you,
• Identity data, contact data, technical data, usage data, financial and transactional data: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as research and profiling supporters to raise funds for HorseWorld’s mission.
• Identity data, contact data, financial and transactional data: Where we need to comply with a legal obligation,
• Identity data, contact data, marketing and communications data, special category data, pictures and video and technical and usage data: With your consent. You have the right to withdraw your consent to marketing at any time by contacting us using the contact information at the bottom of this policy.
RESEARCH AND PROFILING OF SUPPORTERS
It’s vital that our fundraising efforts are as effective as they can be. By developing a better understanding of our supporters through researching them using publicly available sources we can tailor and target our fundraising events and communications (including volunteering opportunities) to those most likely to be interested in them. This allows us to be more efficient and cost-effective with our resources, and also reduces the risk of someone receiving information that they might find irrelevant, intrusive or even distressing.
We undertake in-house research and may engage third party organisation to help us identify people who may be able to support us with a larger gift. We use existing information you have given us from our database and combine this with information from publicly available sources such as the electoral register, land records, ‘rich lists’, Who’s Who publications , public social media accounts and Companies House records. We only use reputable sources, where someone would expect their information may be read by the public.
You’re free at any time to opt out of this data processing.
Please contact 01275 893023 or email info@horseworld.org.uk
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers within the United Kingdom or a country which the UK Government has confirmed has adequate data protection standards. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We have set retention periods for all personal information and will take reasonable steps to destroy or anonymise personal information at the end of the retention period. In some circumstances you can ask us to delete your data: see Your Rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries as defined in section 1159 of the UK Companies Act 2006 in order to fulfil the purpose your information was collected for. We may disclose your personal information to the following third parties for the following reasons:
• Gemini Print Group, who fulfil the mailing of our newsletter,
• Giant Digital who manage our website,
• Shopify who processes our online shop orders,
• Sterling Management Centre Limited, t/a Unity Lottery who administers our lottery
• Chorus Global Limited, who maintains our IT equipment and security, and
• Internal contractors who for example, send out our newsletter and sponsorship updates.
• Research and profiling companies such as Factory or Prospecting for Gold to better understand you and your philanthropic priorities so that we can be measured in who we might approach for substantial support. (see Research and Profiling of Supporters)
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 and any such new owner may use your personal data in the same way as set out in this privacy policy. 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.
INTERNATIONAL TRANSFERS
We share your personal data with the above third parties. This may involve transferring your data outside the UK. Whenever we transfer your personal data out of the UK, we ensure that appropriate safeguards are in place which afford you a similar degree of protection, such as ensuring we have carried out appropriate due diligence on our sub-processors, and having protective contractual arrangements in place with them.
DATA SECURITY
HorseWorld will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 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. 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. Any payment transactions will be encrypted. 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.
YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
• You have the right to be informed that we hold your personal data and how we use it.
• You have the right of access to know what personal data we have for you and to check that we are processing it lawfully.
• You have the right to update and correct your personal data. We may need to verify the accuracy of new data you provide to us.
• You have the right to request removal of your data. Please be aware that we may have to keep some of your data to comply with the law or for HMRC purposes but we will evaluate your request within applicable data protection laws.
• You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by not opting in to marketing. You can also exercise the right at any time by contacting us using the contact information at the bottom of this policy
• You have the right to object to automated individual decision-making and profiling.
• You have the right to lodge a complaint about our handling of your personal data with the Information Commissioner’s Office (ICO) but we would appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details at the bottom of this privacy policy. Address: UK Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: +44 (0) 01625 545745 Website: www.ico.org.uk
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to: info@horseworld.org.uk for the attention of the Data Management Officer or by post, addressed to: Data Management Officer, HorseWorld Trust, Delmar Hall, Keynes Farm, Staunton Lane, Whitchurch, Bristol, BS14 0QL
Revised January 2024