A) Who is using your personal data?
The Horse Writers and Photographers Association is the “data controller” for the information that we collect when you visit the website. This means that we decide how to use it and are responsible for looking after it in accordance with the GDPR.
Access to your personal data within the company will be provided to those staff who need to view it as part of their work in connection with the operation of the website. It will also be shared with the third parties described in Section E.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We may update this policy at any time.
Where we refer in this policy to your ‘personal data’, we mean any recorded information that is about you and from which you can be identified. It does not include data where your identity has been removed (anonymous data).
Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, deletion or retention.
C) Types of data we collect about you
technical information, for example, the type of device (and its unique device identifier) you use to access our site, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform;
and information about your visit to our site including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
D) How we use your data
We process your data for purposes arising from your use of the website, for example, to ensure that we understand who uses our site and how our site is used and to improve our site and ensure it is secure. This processing occurs because it is necessary to meet our legitimate interests in operating and improving the website, analysing its use, and ensuring its security.
We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.
E) Sharing your data with third parties
We may share your data with third parties who provide services on our behalf, such as those who help us to operate the website. All our third-party service providers are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
Where your data is shared with third parties, we will seek to share the minimum amount necessary.
F) Where we store or use your data
We may store data collected by the website manually or electronically. The data is stored on our secure servers and/or in our premises within the UK.
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 data transmitted to the website and any transmission is at your own risk.
G) Third party websites
Our site may contain links to and from various third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
H) Retaining your data
We will only retain your data for as long as we need it to fulfil our purposes, including any relating to legal, accounting, or reporting requirements.
I) Your rights
Under certain circumstances, by law you have the right to:
- Request access to your data (commonly known as a “subject access request”). This enables you to receive a copy of your data and to check that we are lawfully processing it.
- Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
- Request erasure of your data. This enables you to ask us to delete or remove your data under certain circumstances, for example, if you consider that there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see below).
- Object to processing of your data where we are relying on our legitimate interests (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.
- Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your data to another party.
Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. Further information on your rights is available from the Information Commissioner’s Office (ICO).
If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, you should contact the HWPA Compliance Team at email@example.com. The same email address may be used to contact the company’s Data Protection Officer. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If you remain dissatisfied, you have the right to lodge a complaint with the ICO at https://ico.org.uk/concerns/.
K) Changes to this policy