Privacy Policy
Highclere Thoroughbred Racing Australia Ltd are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be used, stored, processed, and/or transferred by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it and your rights with respect to it.
By visiting www.highclereracing.com.au you are accepting and consenting to the practices described in this policy.
For the purposes of the General Data Protection Regulations, the data controller is Highclere Thoroughbred Racing Australia Ltd. The Data Protection Officer is Tony Fleiter.
What personal data we collect from you
We will collect and process the following data about you:
Personal data you give us
This is data about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes data you provide when you register to use our site, subscribe to our service, subscribe to receive information from us, search for a product, enter a competition, promotion or survey, contact us via the enquiry option and when you report a problem with our site. The data you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
Personal data we collect about you
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, operating system and platform;
analytical information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
Personal data we receive from other sources
This is data we receive about you from people already connected to us or known to us and from our advertising and marketing campaigns. This data includes your name, address, e-mail address and phone number and personal description.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
How we use the personal data collected
We use data held about you in the following ways:
Personal data you give to us
We will use this data:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar
to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.
Personal data we collect about you
We will use this data:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Data we receive from other sources
We will combine this data with data you give to us and data we collect about you. We will use this data and the combined information for the purposes set out above (depending on the types of data we receive).
Our Legal Basis for processing your personal data
It is necessary for us to process your personal data for performance of the contract between us in relation to the product and service we provide as racing managers and syndicate providers.
In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of sending you marketing communications, making you aware of products and/or services which are related to or similar to those we provide
When we rely on our legitimate interests in order to collect and use your personal data including for the purposes of automated decision making and profiling we must consider whether those legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue only if we decide that your interests, rights and freedoms do not override our legitimate interests.
We have considered these matters, and where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not use your personal data unless there is another legal basis for us to do so (either that it is necessary for us to perform our contract with you, or on the basis of your consent).
Disclosure of your personal data
You agree that we have the right to share your personal data with:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Selected third parties including:
business partners, suppliers and sub-contractors who act on our behalf for the performance of any contract we enter into with you or for the purpose of communicating with you;
analytics and search engine providers that assist us in the improvement and optimisation of our site;
credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal data to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Highclere Thoroughbred Racing Australia Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Highclere Thoroughbred Racing Australia Ltd our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights
You have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from ??
The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this Notice.
The right of access
You have the right to obtain access to your personal data (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice) free of charge, except where your requests are manifestly unfounded or excessive, particularly if it is repetitive, in which case we may charge a reasonable fee or refuse to respond. If we refuse, we will write to you explaining why.
We will provide the data within one month of receipt of your request, except where the request is complex or numerous. In this case we will respond to you within one month advising you of this.
This right is to allow you to be aware of and verify the lawfulness of the processing.
The right to rectification
You are entitled to have your personal data rectified if it is inaccurate or incomplete. We will respond within one month of receipt of your request for rectification, unless the request is complex. If we refuse to rectify your personal data, we will write to explain why.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data. This is not a general right to erasure; it only applies in these specific circumstances:
The personal data is no longer necessary in relation to the purpose for which it was original collected;
When you withdraw consent;
When you object to the processing of your personal data and there is no overriding legitimate interest to continue the processing;
The personal data was unlawfully processed;
The personal data has to be erased in order to comply with a legal obligation; and
The personal data is processed in relation to the offer of information society services to a child.
In addition there are exceptions which include where the personal data is processed for the following reasons:
To exercise the right of freedom of expression and information;
To comply with certain legal obligations;
For public health purposes; and
Exercise or defence of legal claims.
The right to restrict processing
You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but will not process it. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future. We will inform you if we decide to lift a restriction on processing.
The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This only applies if your data is processed by automated means, and is technically feasible with our IT systems. It is provided free of charge. We will respond to such request within one months, unless the request is complex.
The right to object to processing
You have the right to object to processing for direct marketing (which we do only with your consent) and also to processing which is carried out for the purposes of our legitimate interests.
The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with the Information Commissioner’s Office.
The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.
Changes to our privacy policy
We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time.
Contact
Questions, comments and requests regarding this privacy policy should be addressed to racing@highclereracing.com.au. If you no longer wish to receive such or certain communications, you can let us know by contacting us at racing@highclereracing.com.au. You may also update your preferred contact details at any time by contacting us at the above address.
If we have your consent, we will contact you by post, e-mail, SMS text messages, telephone or other means including other electronic means such as Facebook and social media applications for marketing purposes, and only using such contact details as you provide to us from time to time.