INTRODUCTION

The EU General Data Protection Regulation (GDPR) includes rules on giving privacy information to data subjects. These are more detailed and specific than in the Data Protection Act (DPA) and place an emphasis on making privacy notices understandable and accessible. Data controllers are expected to take ‘appropriate measures’.

The GDPR says that the information you provide to people about how you process their personal data must be:

• Concise, transparent, intelligible and easily accessible

• Written in clear and plain language, particularly if addressed to a child

• Free of charge.

These requirements are about ensuring that privacy information is clear and understandable for data subjects.

Understand Horses shall comply with the GDPR requirements by ensuring our privacy statement includes:

• Identity and contact details of Understand Horses and the data protection officer

• Purpose of the processing and the lawful basis for the processing

• The legitimate interests of Understand Horses or third party, where applicable

• Categories of personal data/ any recipient or categories of recipients of the personal data

• Details of transfers to third country and safeguards

• Retention period or criteria used to determine the retention period

• The existence of each of data subject’s rights

• The right to withdraw consent at any time, where relevant

• The right to lodge a complaint with a supervisory authority

• The source the personal data originates from and whether it came from publicly accessible sources

• Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

• The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences

Responsibilities

The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Understand Horses collecting/processing their personal data. All Employees/Staff of Understand Horses who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

PRIVACY STATEMENT

Identity and contact details

If you would like to discuss anything in this privacy notice, please contact: The Data Protection Officer at

Understand Horses
The Stables, 16 Fernhill, Wallasey, CH45 5AW
Email: info@understandhorses.com

Purpose of the processing

Understand Horses take your privacy seriously and will only use your personal information to administer your account, personalise your use of the website, and to provide the products and services you have requested from us.

In order for ‘users’ to use some of our online services and to respond to enquiries we need to collect and process various personal data. Users may be asked to complete an online form(s) which request, name, address, e-mail and telephone number. The personal data we collect is used to process your request for our services.

All information provided will be treated as confidential and will only be used for the purpose intended. Anyone can contact Understand Horses to correct or update personal information in our records.

What information do we collect?

We collect information that you provide to us via our website www.understandhorses.com. For example, the information you provide if you subscribe to our membership services, newsletters, notifications, enter a promotion, complete a survey, request information, or purchase goods or services via our website. if you contact us, we may keep a record of that correspondence.

The sort of information we hold includes your application form; references; contact details; bank details, photo identification; learner cards and certificates; information needed for equal opportunities monitoring.

What do we use personal information for?

We may use the information we hold about you in the following ways:

• to send newsletters and/or notifications to you if you have signed up to receive them;

• to provide you with information about our products, services, and upcoming events if you have consented to be contacted for such purposes;

• to notify you about any important information about, or changes to, our products and services

• to provide you with products and services requested by you;

Corrections/Accuracy

We will endeavour to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify Understand Horses of any changes to information held about them.

The lawful basis

Understand Horses will process data for the specific and lawful purpose for which it is collected and not further process the data in a manner incompatible with this purpose.

We collect and use information for general purposes where:

• the data subject has given consent to the processing of his or her personal data for one or more specific purposes

• processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

• the data subject has given explicit consent to the processing of those personal data for one or more specified purposes

Categories of personal data

We will ensure that the reason for which it collected the data originally is the only reason for which it processes those data, unless the individual is informed of any additional processing before it takes place. We will ensure that the data is adequate, relevant and not excessive in relation to the purpose for which it is processed.

Personal data

We may collect ‘personal data’ relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This may include the data subjects name, identification number, location data or online identifier.

Sensitive Personal Data

We may, from time to time, be required to process sensitive personal data. Sensitive personal data includes photographic images of learners and data relating to gender, religion, race, sexual orientation, and criminal records and proceedings.

Disclosure to third parties

We will not sell or license your personal information to any third party. However, we may disclose your personal information:

• to any member of Understand Horses

• contractors engaged by us to provide services on our behalf;

• in order to provide you with any products or services you have purchased or requested;

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation to do so.

Details of transfers to third country

We will not transfer your personal information to countries outside of the European Economic Area that do not have adequate data security law.

Retention period

Understand Horses may retain data for differing periods of time for different purposes as required by statute or best practices.

Data subject’s rights

You have the right to request access to information about you that we hold. You also have the right to:

• object to processing of personal data that is likely to cause, or is causing, damage or distress

• prevent processing for the purpose of direct marketing

• object to decisions being taken by automated means

• in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed

Any data subject wishing to access their personal data should put their request in writing to the Data Protection Officer at info@understandhorses.com who will endeavour to respond to any such written requests as soon as is reasonably practicable and, in any event, within 40 days.

The right to withdraw consent

Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.

• We make it easy for individuals to withdraw their consent at any time.

• We act on withdrawals of consent as soon as we can.

• We don’t penalise individuals who wish to withdraw consent.

You may withdraw consent at any time by putting your request in writing to the Data Protection Officer at info@understandhorses.com who will endeavour to respond to any such written requests as soon as is reasonably practicable and, in any event, within 40 days.

The right to lodge a complaint

Data subjects are able to complain to Understand Horses about:

• how their personal data has been processed

• how their request for access to data has been handled

• how their complaint has been handled

• appeal against any decision made following a complaint.

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance by emailing the Data Protection Officer ADD EMAIL. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/

The source the personal data

All personal information provided to us is either stored on our secure servers located in the UK, or on the secure servers of sub-contractors that we have engaged to provide services on our behalf.

Statutory or contractual requirements

We will make you aware if we need to collect data for the purpose of statutory or contractual requirements. We will keep this data and use it to enable us to run our business and manage our relationship with you effectively, lawfully and appropriately.

Automated decisions

We do use automated decision making (including profiling) in limited circumstances.

Unsubscribing

You may unsubscribe from our marketing communications at any time by putting your request in writing to the Data Protection Officer at info@understandhorses.com.

Websites and cookies

This section applies to anyone accessing the Understand Horses website.

A cookie is a small file, typically of letters and numbers, downloaded on to your device (e.g. your PC) when you access Understand Horses website. Cookies allow the website to recognise your device and so distinguish between the different users that access the site.

Session cookies will remember your selections as you browse the site. These cookies are for the browsing session and not stored long term. No personal information is collected by these cookies.

Google Analytics cookies help us to make the website better for you by providing us with user statistics, for example: which pages are the most visited; how a user navigates the site. No personal information is collected by these cookies.

You may delete or control the use of cookies through your browser settings, but this may limit the functionally of the website. The site and our computer systems have security measures in place with the aim of protecting the loss, misuse or alteration of the information ‘users’ provide to us.

To find out more about cookies and what cookies might be stored on your device, visit www.aboutcookies.org or www.allaboutcookies.org