1.1 We are committed to safeguarding the privacy of our TB-Ed website visitors and users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refers to the Thoroughbred Breeders’ Association (the TBA) who own and operate the TB-Ed website at www.TB-Ed.co.uk. For more information about the TBA, see Section 11.
2. How we use your personal data
In this Section 2 we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
2.2 We process your TB-Ed account registration data (“account data). The account data includes your name, company name (if applicable) and email address. If you are a member or associate of the TBA, we will also process your TBA/Associate membership number to validate any e-learning course fee discounts available to members and associates. The account data may be processed for the purposes of operating our website, ensuring the security of our website, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate business interests, namely the provision of the TB-Ed website, to which you have registered.
2.3 We process your personal data that are provided in the course of your use of the TB-Ed website (“service data “). The service data may include the account data specified above plus any courses you have previously purchased and CPD progression data. The service data is processed for the purposes of operating our website, providing the e-learning courses to you, ensuring the security of the TB-Ed website, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of the contract for the TB-Ed services which you have paid for.
2.4 We process information contained in any enquiry you submit to us regarding TB-Ed (“enquiry data“). The enquiry data are processed for the purposes of offering and marketing relevant TB-Ed services to you. The legal basis for this processing is our legitimate business interests, namely responding to enquiries in an efficient and helpful manner.
2.5 We process information relating to transactions that you enter into with us as a result of your purchase of e- learning courses via the TB-Ed website (“transaction data“). We use a secure third-party payment provider to process transaction data. The transaction data includes your contact details, your card details and the transaction details. The transaction data are processed for the purpose of providing the e- learning courses to you and keeping proper records of those transactions. The legal basis for this processing is the performance of the contract between you and us for the provision of the e- learning courses and/or taking steps, at your request, to enter into such a contract.
2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent to receive such email notifications and / or newsletters. This consent may be express consent from you to receive email notifications and/ or newsletters collected via the TB-Ed website; opt- out consent when you purchase similar products or services from us; or such notifications/ newsletters may be provided as part of your registration to the TBA.
2.7 We process information contained in or relating to any communication that you may send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of the TB-Ed website and communications with our users.
2.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.11 Please do not supply any other person’s personal data to us, unless you have permission from that person to do so.
3. Providing your personal data to others
3.1 Transaction data is collected by Stripe, Inc, who are our secure payment processor. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy. Please see section 4 below for more details.
3.2 The TB-Ed website is hosted by Platform.sh S.A.S, a company located in France.
3.3 Inviqa Limited assist the TBA with developing and providing support and maintenance for the TB-Ed platform. If we require technical support, we may need to pass your personal data onto Inviqa Limited as our data processor.
3.4 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 We do not transfer your information outside of the European Economic Area save as set out below:
- The Rocket Science Group LLC d/b/a MailChimp, located in the United States.
- https://stripe.com/gb/privacy, located In the United States.
Transfers to the United States will be protected by the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from; https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
4.2 You acknowledge that personal data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c ) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 There are exclusions to the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.5 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.6 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.7 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
that are made on the website.
more generally. This cookie is strictly necessary for the performance of the website so does not require your advance consent.
10. Managing cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11. Our details
11.1 This website is owned by The Thoroughbred Breeders Association.
11.2 We are registered in England and Wales under registration number 07073259, and our registered office is at Stanstead House, 8, The Avenue, Newmarket, Suffolk, CB8 9AA.
11.3 Our principal place of business is at the registered address above.
(a) by post, to the postal address given above;
(b) using our website contact form;
(c ) by telephone, on 01638 661321; or
- by email, using the email address published on our website from time to time or firstname.lastname@example.org
12.5 If you have any questions about the TB-Ed website please click here: https://tb-ed.co.uk. If you cannot find the information you are looking for, you can contact the TBA:
- by post, to the postal address given above;
- by telephone: 01638 661321; or
- by email, to email@example.com
30 April 2021