Welcome to the British Horse Foundation’s privacy notice.
The British Horse Foundation respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, for example when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HEALTH RELATED DATA
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how the British Horse Foundation collects and processes your personal data including any data you may provide through our website or on the telephone or when you sign up as a Trustee, speaker, guest, sponsor, delegate, volunteer, supporter, make a nomination for an award, or anyone else.
Our websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other such notices, if any, and is not intended to override them.
CONSENT TO TRANSFER OF PERSONAL DATA OUTSIDE THE EEA
Some of our external third parties which provide services to us are based outside the EEA or have operations and service centres based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Further information is provided in section 7 below under the heading ‘INTERNATIONAL TRANSFERS’.
BY THIS PRIVACY NOTICE WE ARE INFORMING YOU THAT YOUR DATA MAY BE PROCESSED OUTSIDE THE EEA AND YOU ARE CONSENTING TO SUCH PROCESSING.
The British Horse Foundation is a Registered Charity No.: 1003290 (England and Wales) and is the controller and responsible for your personal data (collectively referred to as ”British Horse Foundation”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights as a Data Subject under the Data Protection Legislation, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: British Horse Foundation
Name or title of DPO: Jan Rogers
Email address: firstname.lastname@example.org
Registered Office Address: Streethill Farm, Lowesby, Leicestershire, LE7 9DL
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our websites 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 notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, marital status, title, postnominals and images. Maiden name, date of birth and gender might be required for specific events or purposes.
- Background Data includes information about your qualifications, career, and subjects of interest to you such as hobbies and past times which we may collect, for example, when a person applies to be or becomes a volunteer, Trustee, or supporter.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Health Related Data includes information we request in relation to access requirements, for an event, for example.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of tickets you have purchased from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
- Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and products.
- Marketing Communications and Usage Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 website feature. 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.
EXCEPT AS SET OUT BELOW UNDER THE HEADING ‘HEALTH RELATED DATA’, we do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
3. HEALTH RELATED DATA
We may collect health related data in relation to an individual who supplies us with this in relation to their access requirements. We use this information ourselves and may disclose it to a third party organisation if required for access purposes.
EXCEPT AS PROVIDED ABOVE, we will not disclose health related information to any other person unless permitted to do so under the Data Protection Legislation.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Background and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
* apply for our tickets or services;
* subscribe to our service for us to be in touch with you and to provide updates, including opportunities to purchase tickets and become involved in our events;
* apply to take part in a competition or promotion and/or if you take part in any competition or promotion, or make a nomination for an award or provide feedback;
* request marketing or ticketing information to be sent to you;
* making a nomination for an award;
* bidding for an auction item.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
(a) analytics providers including such as Google based outside the EEA;
(b) advertising networks which we may use in the future based inside or outside the EEA;
(c) search information providers based inside or outside the EEA; and
(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Eventbrite some of which may be based inside or outside the EEA.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to including the Data Protection Legislation. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- where we need to comply with a legal or regulatory obligation.
Click https://ico.org.uk/ to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we intend to rely on consent as the legal basis for processing your personal data, however, there may be other ways in which we may lawfully process your personal data where we do not have your consent and we will rely on these where appropriate other than in relation to sending third party direct marketing communications to you via email.
You have the right to withdraw consent to marketing at any time. Please contact us to do so.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity may include||Type of data may include||Lawful basis for processing including basis of legitimate interest includes|
|1||To register you as a Trustee, speaker, sponsor, delegate, volunteer, assistant, supporter, guest, make a nomination for an award, or anyone else||(a) Identity|
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep records of customers and other persons who are involved with the British Horse Foundation)
(d) vital interest
(e) access requirements
|2||To make suggestions and recommendations to you about services that may be of interest to you or opportunities to help and support the British Horse Foundation||(a) Identity|
|Necessary for our legitimate interests (to develop our services and support our charity)|
|3||To process and deliver your order for tickets or pay for an item you have bought from us such as:|
(a) Manage payments, fees and charges
(b) Collect and recover payments due to us
(e) Marketing communications and usage
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to collect payments due to us)
|4||To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey, a prize draw or competition
(c) Process a nomination for an award
(d) Marketing communications and usage
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|5||To administer and protect our charity and its website(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our charity, provision of administration and IT services, network security, to prevent fraud)
(b) Necessary to comply with a legal obligation
|6||To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(d) Marketing communications and usage
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy, to keep our website updated and relevant)|
|7||To record visual images of our event, its attendees, speakers and others in attendance||(a) Identity|
(b) Marketing communications and usage
|Necessary for our legitimate interest (to host an annual assembly of individual who support our charity)|
MARKETING AND PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Background, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have given us consent or have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by emailing email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a ticket purchase, conference attendance or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or we where we are permitted to use it under the Data Protection Legislation.
If you want an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may 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.
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.
7. INTERNATIONAL TRANSFERS
Some of our External third parties which provide services to us are or may be based outside the EEA or have operations and service centres based outside the EEA so their processing of your personal data will or may involve a transfer of data outside the EEA.
The following are some of the main services in relation to which your personal data may be processed outside the EEA:
- Website forms
- Online contracts
- Transaction emails
- Website hosting
- Ticket purchases
We will when we review the third party companies we use and services provided by them seek to ensure where reasonably possible that your personal data is only transferred outside the EEA
- to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- where we use specific contracts which give personal data the same protection it has in EEA.
- where we use providers based in the US, if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the US.
8. DATA SECURITY
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.
9. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
We may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) as required or to enable us to comply with laws, regulations, and obligations imposed by local or national Governments.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may 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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. These rights include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
Please refer to the Glossary for more information about Your Legal Rights. If you wish to exercise any of the rights referred to above, please contact us.
NO FEE USUALLY REQUIRED
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.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
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.
DATA PROTECTION LEGISLATION
Data Protection Legislation means all applicable privacy and data protection laws including the General Data Protection Regulation ((EU) 2016/679) and any applicable national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).
EEA means the European Economic Area.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Service providers who provide various support services such as IT and system administration services in particular Dropbox Inc, Ticket Tailor, Ninja Forms, YouTube, Facebook and Twitter;
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and other services to support us;
- Contracted partners or agents who assist us with providing services for you in line with any contact you have made;
- Financial services providers for payment process such as Ticket Tailor and related services;
- HM Revenue & Customs, Companies House, regulators and other authorities who require reporting of processing activities in certain circumstances;
- CCTV services providers at the venue;
- Event photography website.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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.
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 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.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
Withdraw consent at any time where we are relying on consent to process your personal data. 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.