Privacy Policy

Privacy policy

The Owner Breeder Privacy Notice

(Last updated May 5th, 2023)

We are delighted that you have shown interest in our organisation. Data protection is of a particularly high priority for The Owner Breeder (TOB).

This privacy notice explains how we process your personal information when you visit our website and/or if you’re a subscriber to TOB. It explains how we will protect data subjects {your} information and personal data, and the controls and safeguards we provide for this data. This includes understanding, at all times, precisely what data we’re storing for and about you, who (if anyone) can see that data, and whether you give permission for that data to be shared with third-parties.

The processing of personal data, such as the name, address, e-mail address, or telephone number shall always be in line with the General Data Protection Regulation (GDPR), The Data Protection Act 2018 and Privacy and Electronic Communication Regulations (PECR).

By means of this data protection declaration, we would like to inform you of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

Who we are?

The Owner Breeder is the official publication of the Racehorse Owners Association (ROA) and Thoroughbred Breeders’ Association (TBA). Please refer to their websites for their individual/membership privacy policy. TOB is produced monthly and sent to all members of the ROA and TBA and subscribers.

The information we collect about you, why we need it and who it’s safely shared with

• We collect information depending on the relationship we have with you but typically this would be:
• When you apply for, purchase or renew your subscription.
• When you set up a direct debit for subscription payments.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc.
• When you ask one of our team to email you information about a subscription offer.
• When you enter prize draws or competitions.
• When you choose to complete any surveys we send to you.
• When you sign-up to receive our email newsletter.
• When you fill in any forms. For example, feedback forms and newsletter sign-up.
• If you attend our offices at 12 Forbury Road, Reading, RG1 1SB your image may be recorded on our CCTV cameras that are operated for the security of both visitors and staff.
• Photographs and videos of members attending our events.

The personal data we may collect from you and process is:

Personal data type:	Source
Title, First Name & Last Name	On-Line Subscription Application Form, Paper Subscription Application Form, Newsletter Sign-Up
Email	Subscription Newsletter Sign-Up, Online Subscription Application form, Paper Application Form
Postal Address	Online Subscription Application form, Paper Subscription Form
Telephone Number	Online Subscription Application form, Paper Subscription Form
Debit or credit card details	Online Subscription Application form, Paper Subscription Form
Date of Birth	Online Subscription Application form, Paper Subscription Form

The personal data we collect may be used for the following purposes depending on the relationship we have with you:

• Processing a subscription application and ongoing essential subscription related processing
• Sending you information about TOB (and selected relevant partners), our activities and campaigns and for marketing purposes (including via Facebook and other social media channels)
• Processing a purchase that you have made
• Responding to correspondence you have sent to us

In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

The legal basis we use under the General Data Protection Regulation for the processing of personal data:

• Fulfilling our Contractual obligations to you
• Our legitimate interests as Thoroughbred Owner Breeder
• Your Consent
• Any Legal Requirement we may have

Processing to fulfill the membership contract

When you join as a subscriber to TOB, we need to use your personal information to provide the services you have paid for and subscribed to for the lifetime of your subscription. Data we hold will be used confidentially, and to help us run our services and keep you informed – for example, to collect subscriptions and mail out publications.

We will send you your magazines via post but may send other essential subscription service emails by email. Communications will be relevant, timely and not excessive. You can contact us via the details at the bottom of this notice to request a preference for postal communications although we cannot guarantee that all electronic communications can be transferred. Please be aware you are likely to miss out on a number of the essential subscription offers that your subscription has paid for by not allowing electronic communications.

TOB will never sell, trade, rent, exchange or otherwise share your personal information with any other person, company or organisation unless it is necessary to fulfil our contractual responsibilities, we have a legal obligation to do so or without gaining consent to do so. The information you provide will be held securely by us and/or our data processors, whether the information is in electronic or physical format. We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

Processing through use of our Legitimate Interests

Broadly speaking this means that we are processing your personal information if:

• We have a genuine and legitimate reason and we are not harming any of your rights and interests

The legitimate interests we pursue are to fulfil your magazine subscription.

When you provide your personal details to us we use your information for our legitimate business interests to carry out our work. Before doing this, we will carefully consider and balance any potential impact on you and your rights.

Some typical examples of when we might use this lawful basis are for direct marketing, maintaining the security of our system, data analytics, research, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and fundraising.

Direct marketing is generally seen as an important tool, but we want to respect your wishes as the recipients of our marketing. For this reason, we have undertaken a balancing test to compare our legitimate interests versus your interests and indeed fundamental rights and freedoms, which require the protection of your personal data.

We believe that the recipients of our marketing have a reasonable expectation that TOB will store and process their Personal Data in this manner and for this purpose.

It is not always the case that TOB collects personal information directly from the recipients of our marketing. Here we issue fair processing notices within one month of collecting personal data, or at the time of first communication, whichever is the soonest. These fair processing notices adhere to new General Data Protection Regulation and provide a clear and simple mechanism to object to our decision and immediately stop all future processing.

Our assessment has considered the technical and organisational security measures that TOB has implemented and the safeguards being put in place in regards to your privacy and the protection of your personal data.

TOB routinely conducts Data Protection Impact Assessments with outputs that support privacy by design and default and include:

• data minimisation;
• de-identification and anonymisation;
• appropriate technical and organisational security measures;
• adding extra transparency;
• encryption and access control;
• data retention limits;
• restricted access to systems;
• where appropriate, encryption, hashing and salting of data;
• other technical security methods used to protect data;
• organisation wide privacy training;
• the sensitivity of the personal data we have collected and processed;
• whether you’d be likely to object to the processing or find it intrusive;
• that a mechanism exists through which you may challenge our assessment.

The likelihood of impact and the severity of negative impact of our processing on your data has been assessed and deemed to be negligible.

Processing using Consent

There are certain circumstances, particularly in regards electronic marketing communications where we may need consent from you, in order to process your data.

If this is the case we will ensure that the consent that you provide is by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the processing of personal data relating to you.

TOB is monitoring future developments in EU electronic marketing regulation presently under debate in the EU Council and subject to delay and change.

Email Marketing

In relation to any email marketing that you may receive from us, either at your request or in any other circumstances, we may monitor whether you open and/or click on any links in such emails and we uses various tracking techniques to measure the effectiveness of our email campaigns and tailor our communications to your interests

If you elect to receive TOB e-newsletters, we will use your email to send you the requested newsletters. We currently use MailChimp, a US-hosted third-party provider to send out and monitor our communications. For more information, please see MailChimp’s Privacy Policy.

We endeavour to keep all personal data hosted within the EEA. However, if it is essential to transfer your data outside of the EEA, as is the case with MailChimp, we look at this on a case-by-case basis to ensure that robust data-sharing agreements are in place. For example, MailChimp hosts its data in the US and is a member of the Privacy Shield scheme. This scheme has been declared by the EU to provide adequate protection for personal data, and as such we are happy to use it whilst we review their terms and conditions in more detail.

If you no longer wish to receive these emails, you can unsubscribe by emailing or writing to TOB.

We conduct this email marketing in adherence with the Privacy and Electronic Communications Regulation which derive from the European Directive 2002/58/EC.

We’ll always act upon your choice of how you want to receive marketing and communications (for example, by email, post or phone). However, there are some communications that we need to send.

These are essential to fulfil our promises to you as a member, owner, or buyer of goods or services from TOB. Examples are:

• Transaction messaging, such as Direct Debit schedules, purchase confirmations and event booking confirmations
• TOB magazine
• TOB monthly e-newsletter

Who your information is shared with

TOB will share your personal data with third parties only for the purposes of essential sub-contracted processing. We will seek assurances that these contractors/processors have in place appropriate technical and organizational measures to safeguard the security of your data. Where appropriate robust data processing agreements will be in place as per article 28 of the GDPR and mechanisms allowing the monitoring of such safeguards will be agreed.

Our website uses cookies, this is what they do and how you can stop them

You do not have to give us any personal data in order to use this website. However you may provide us with personal data by completing forms on this website or by contacting us by telephone or email.

When you visit this website, we will automatically collect the internet protocol (IP) address of the device used by you to visit this website as well as the type of the device, browser version and time zone setting. This will enable us to identify you as a unique user for analytical purposes and to optimise our website for your device. This data does not allow us to, and we will not attempt to use this data to, identify you.

Cookies

This website uses small text files, called cookies, which are automatically stored on your device when you access and use certain features of this website. As cookies are unique, we can use them to distinguish you from other users. To find out more about cookies, how to refuse them and how to change your device’s cookie settings, you should visit All About Cookies. Please note that if you refuse to accept cookies or change your device’s cookie settings, you may not be able to use all of this website’s features.

Data collected from the use of cookies does not allow us to, and we will not attempt to use this data to, identify you.

The cookies/trackers/web analytics used by this website are as follows:

Source	Code	Description
Necessary cookies	_GDPR_cookie_banner_shown	Necessary cookies enable core functionality such as page navigation and access to secure areas. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences.
Preference cookies	targeting-or-advertising performance functionality	These cookies are used to remember your preferences.
Session cookies	JSESSIONID	These cookies are used for the website to function and to improve the performance of the website.
Google Analytics	_ga _gat_gtag _gid	These cookies are used to collect information about how you use our website. The information collected includes number of visitors, pages visited and time spent on the website. The information is collected by Google Analytics in aggregated and anonymous form, and we use the data to help us make improvements to the website. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance. Click here for more information about Google Analytics and your privacy.
	__utma	This cookie creates a unique ID when a new visitor browses our website. It helps us to assess the number of new visitors to our site, and also identify whether we are receiving repeat visitors, too.
	__utmb __utmc	These two cookies help us measure a visitor’s session, giving us data on what time visitors arrive and how long they spend browsing our website.
	__utmz	This cookie gives us information about how a visitor got to our site (e.g. Google Search, referral site, social media, direct URL, etc.) and also which pages they viewed after they arrived.
	Double Click	This cookie collects anonymised Ad Views, Analytics, Browser Information, Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction Data, Page Views, Serving Domains)
	Audiences	This cookie collects anonymous data (Ad Views, Analytics, Browser Information, Cookie Data , Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction Data , Page Views , Serving Domains)
Marketing cookies	bkdc bku uuid2 ouid uuid uuidc	These cookies are used to show you relevant and engaging ads.
Social sharing cookies	_atrfs _atuvc _atuvs bt2 di2 loc mus uid uvc vc xtc	We use some social sharing plugins, to allow you to share certain pages of our website on social media. These plugins place cookies so that you can correctly view how many times a page has been shared.
E-commerce cookies	_stripe_mid _stripe_sid woocommerce_cart_hash woocommerce_items_in_cart woocommerce_session m nsr	This site offers e-commerce or payment facilities and some cookies are essential to ensure that the site remembers items and can process your order properly.

These cookies are used by the Google Analytics service to identify unique visitors to this website, where they came from, which pages they visit and how long they spend on it.

Third party links

This Privacy Policy only applies to this website, theownerbreeder.com. This website may include links to third party websites, plugins and applications. We do not control these third party websites and are not responsible for their privacy statements and how they use your data. Example of third party produces include Google Analytics, Google Maps, Google fonts or Adobe fonts.

Further information can be found in the Google Privacy Policy.

Most browsers allow you to refuse to accept cookies; for example:

1. In Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
2. In Firefox (version 39) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
3. In Chrome (version 44), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

You can also delete cookies already stored on your computer; for example:

1. In Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
2. In Firefox (version 39), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
3. In Chrome (version 44), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.

Social buttons

Visitors may use these to bookmark or share our web pages. There are buttons for: Twitter. These work using scripts from domains outside of TOB and it is likely those sites will collect their own information about what you are doing. You should review the policies of each of these sites to see how they use your information and to find out how to opt out, or delete, such information.

Social Media Contact with TOB: We use Twitter. If you intend to post a comment on our Twitter feed, Twitter will require you to set up your own account. Please review the Twitter privacy notice to see how it uses your information and to find out how to opt out, or delete, such information. Direct messages sent to TOB’s Twitter account will be deleted after 1 year.

Your privacy rights explained

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you free of charge
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that TOB refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Other websites

On occasion our website will contain links to other websites. This privacy policy only applies to the TOB website. When you link to other websites you should read their own privacy policies.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on May 22, 2018.

How long we keep your personal data

Any information provided by you will be retained for as long as necessary in connection with the purposes for which it was provided, for example, to respond to your enquiry. In respect of any contact information stored within our customer relationship management (CRM) system, we will delete your details upon request and if we have not had any further communication with you within a period of 2 years.

Any information collected about you or your activity through the use of cookies will be retained for the time periods set out in the above table.

In any case, once we have processed any information about you in connection with the purposes for which it was provided or collected, we will securely delete or anonymise (to the extent such information was capable of identifying you in the first instance) such information upon expiry of the above time periods.

 How to contact us in regards your rights, or to make a complaint

In the event that you wish to make a complaint in regards to how your personal data is being processed by TOB (or the third parties above), please contact TOB’s data protection representative, if you are unhappy with how your complaint has been handled, you have the right to lodge a complaint directly with the ICO.

Email:info@ownerbreeder.co.uk

	Data Protection Representative contact details
Contact Name:	Data Protection Representative
Address line 1:	12 Forbury Road
Address line 2:	Reading
Post Code:	RG1 1SB
Telephone:	0207 152 0210