Last updated: 23 May 2018
At Together for the Tote we commit to using any personal data you give to us responsibly and in accordance with all applicable laws and data privacy regulation.
The purpose of this policy is to give you a clear explanation about how Together for the Tote collects and uses the personal information you provide to us and that we collect, whether online, via telephone, email, in letters or in any other correspondence or from third parties.
Who we are
Together for the Tote is powered by Alizeti Capital Limited, a company backed by a group of racehorse owners and breeders who are passionate about the sport of racing and determined to bring the industry together to secure the future of the Tote. If you need it, our company number is 11119798 and our registered office is 77 Limerston Street, London, United Kingdom SW10 OBL. Alizeti Capital Limited is the controller of your personal information, and is responsible for your personal information. All references in this policy to "our", "us" or "we" refer to Alizeti Capital Limited,. All references in this policy to "our website", refer to the website owned by Alizeti Capital Limited at www.togetherforthetote.com.
Who this policy applies to
- Visitors to our website www.togetherforthetote.com;
- Supporters of our campaign;
- Subscribers to our Together for the Tote campaign newsletter.
How we collect information
- Information you give to us. For example, when you sign up for our email lists, engage with our social media or otherwise provide us with personal information.
- Information we get from your use of our website and services. We collect information about the services you use and how you use them, for instance when you watch our videos, visit our websites or view and interact with our digital advertising and website or social media content. We, like all organisations, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer.
What information we collect
The information we may collect from you, either directly or indirectly, may include:
- Email address
- Telephone number
- information provided when you correspond with us;
- any updates to information provided to us;
- personal information we collect about you or that we obtain from our third party sources;
- the following information created and recorded automatically when you visit our website:
- Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages;
- Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads;
- Your location
Why we collect your information
We hold and process personal data for a number of reasons:
- To send you marketing information about our latest activities, news and opportunities, where we have your consent or are otherwise allowed to do this;
- To take part in campaigns or activities for which we would require personal information to register your interest;
- For administrative purposes (for example, relating to the data we hold about you in your personal user account);
- To analyse and improve the content and operation of our website and our internal business processes;
- to ensure the security of our website;
- To tailor communications presented to you and to other people who may have similar interests or other characteristics to yours on the internet according to your interests, preferences and other characteristics (as described below);
- To ensure we do not send unwanted information to individuals who have informed us they do not wish to be contacted.
- to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
What is your legal basis for collecting and using my personal information?
When we collect and use your personal information, we will make sure this is only done accordance with at least one of the legal grounds available to us under Data Protection law.
Our legal basis for sending you email marketing messages or informational updates is that we have obtained your specific consent to use your information for this purpose. You may withdraw your consent by contacting us at email@example.com and we will stop using your personal information in this way.
In all other cases, our use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
- run, grow and develop our business;
- carry out marketing, market research and business development;
- for internal group administrative purposes.
If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details in this policy.
We are careful to balance our legitimate interests against your rights as an individual and ensure that we only use your personal information in a way or for a purpose that you would reasonably expect in accordance with this policy, and that does not intrude on your privacy or previously-expressed marketing preferences.
How long will you keep my information?
We will retain your information for as long as you have an active relationship with Together for the Tote. If you cease to have an active relationship with us or request to receive no further contact, we will retain only the basic information required in order to avoid sending you unwanted materials in the future, and to ensure that we don’t accidentally duplicate information. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Will you use my social media data?
We may use the personal data you share with us to match to your account on Facebook, Twitter, Instagram, LinkedIn or other social media sites in order to show you Together for the Tote content while you are using these services. We may also use publically-available information such as a Twitter handle to show you Together for the Tote while using that platform. Your personal data is kept secure at all times. We may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites who we believe would be interested in Together for the Tote, and we may then show them Together for the Tote content.
Information on how to stop this use of your data is given by each of the individual social media platforms in your user preferences. For example, in Twitter the privacy settings are on this page.
How to stop or change how we communicate with you
If at any time you wish to stop or change how we communicate with you, or update the information we hold, please email firstname.lastname@example.org.
You can opt out of our emails by clicking on the unsubscribe link at the bottom of our messages.
We want to make sure that the personal information we hold for you is accurate and up to date. If your contact details have changed or you think any information we have about you is incorrect or incomplete, you can always update or correct the information we hold about you by contacting us at email@example.com.
How and why we share your personal information with others
We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
We will share your personal information with the following third parties or categories of third parties:
- Squarespace who host our website. Squarespace will also share your personal information with us;
- we may share anonymised and aggregated statistical information with our suppliers to demonstrate what interest there has been in any marketing campaigns we have assisted our suppliers in carrying out;
- our other service providers and sub-contractors, including payment processors, utility providers, suppliers of technical and support services, insurers, logistic providers, and cloud service providers;
- public agencies and the emergency services;
- companies that assist in our marketing, advertising and promotional activities, such as the marketing automation platform MailChimp and marketing services firm Edmonds Elder Ltd;
- analytics and search engine providers that assist us in the improvement and optimisation of our website
We will also disclose your personal information to third parties:
- where it is in our legitimate interests to do so to run, grow and develop our business:
- if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
- if substantially all of our or any of our affiliates' assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- to protect our rights, property, or safety, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.
We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
Where we may transfer your personal information
Your personal information may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or suppliers. Further details on to whom your personal information may be disclosed are set out above.
- in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
- in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at firstname.lastname@example.org at any time.
Complaints and contacting us
In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
For detailed information on the cookies we use and the purposes for which we use them, please refer to the Squarespace cookies policy here https://www.squarespace.com/cookie-policy.
Risks and how we keep your personal information secure
The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures.
In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Rights of individuals
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at email@example.com at any time. You have the following rights:
· Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area ("EEA").
· Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
· Right delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details above. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, by emailing firstname.lastname@example.org.
· Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details above. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details above.
· Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
· Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
· Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.