Sally Newcomb t/a Hereford Equestrian understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our website, herefordequestrian.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account”Means an account required to access and/or use certain areas and features of Our Site;
“Cookie Law”Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data”Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 or EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)
“We/Us/Our” Means Sally Newcomb trading as Hereford Equestrian, of the address Gadling, Hooks Lane, Upleadon, Gloucestershire, GL18 1EL.
“Data Subject”Means ‘you’ the reader of this document who is affected by this policy
2. Information About Us
2.1 Our Site is owned and operated by Sally Newcomb trading as Hereford Equestrian, of the address Gadling, Hooks Lane, Upleadon, Gloucestershire, GL18 1EL.
2.2 Our Data Protection Officer is Sally Newcomb, and can be contacted by email at firstname.lastname@example.org, by telephone on 01531 828350, or by post at Gadling, Hooks Lane, Upleadon, Gloucestershire, GL18 1EL.
3. What Does This Policy Cover?
This Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data we hold about you
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 13 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.3 Email address;
5.4 Telephone number;
5.5 Mobile Number;
5.6 Business name;
5.7 Job title;
5.8 Mobile Number;
5.9 Information about your preferences and interests;
5.10 IP address;
5.11 Web browser type and version;
5.12 Device operating system;
5.13 A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Act 1998 or GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.1 Providing and managing your account.
6.2.2 Supplying our services to you. Your personal details are required in order for us to enter into a contract with you, and successfully process entries made by you for auction or to process purchases made by you at one or more of our auctions
6.2.3 Disclosures and exchange of information (to process entries made by you for auction)
6.2.4 Communicating with you. Replying to emails from you
6.2.5 Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by either; email – click on unsubscribe in the footer of the email, postal – please contact us using the details provided in Part 11)
6.2.6 Compliance with legal, regulatory and corporate governance obligations and good practice
6.2.7 Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
6.2.8 Operational reasons, such as providing information to you about Hereford Equestrian and its activities and undertakings
6.2.9 Security vetting, investigating complaints and allegations of criminal offences
6.2.10 Statistical analysis
6.2.11 To allow you to participate in interactive features included on our website
6.2.12 Market research
6.2.13 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience
6.3 With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Act 1998 or GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.5 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
7. How and Where Do We Store Your Data? We need to consider the data Protection law as this is too simplified
7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 or GDPR
7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through Our Site.
8. Do We Share Your Data?
8.1 We will not share any of your personal data with any third parties for any purposes, subject the following important exception.
8.2 In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
8.3 We may sometimes contract with the following third parties to supply products services to you on our behalf. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law. These may include payment processing, delivery, and marketing.
• Encrypted payment portal
• Auction partners – in order to process your auction entries and transfer ownership of animals
8.4 We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
9. What Happens If Our Business Changes Hands?
9.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. You will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
11. Your Right to Withhold Information
12. How Can You Access Your Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 13.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request. You will be kept fully informed of our progress.
The Hereford Market Auctioneers Subject Access Request Form is available for download as an Adobe PDF document here.
13. Contacting Us
V1.0 – Updated 30th May 2018