Privacy Policy

Introduction

Horse Racing Ireland ("HRI") is committed to protecting privacy and takes our responsibility regarding the security of your information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.

This Policy sets out the following:

• What personal data we collect and process about you in connection with your relationship with us and through your use of our website, mobile applications and online services;
• Where we obtain the data from;
• What we do with that data;
• How we store the data;
• Who we transfer/disclose that data to;
• How we deal with your data protection rights;
• And how we comply with the data protection rules.

All personal data is collected and processed in accordance with Irish and EU data protection laws.

Data Controller

“HRI” (referred to as “we”, “us”, “our” or “HRI” in this policy) in this policy primarily refers to Horse Racing Ireland and, where appropriate, to other companies within the HRI group or other entities over which HRI exercises management control.

These include Irish Thoroughbred Marketing Limited, Tote Ireland Limited and corporate entities in relation to our racecourses at Fairyhouse, Leopardstown, Navan, Tipperary & Leopardstown Golf Centre.

HRI is the “data controller” of all personal information that is collected and used about HRI customers. HRI is a body established by statute having its primary place of business at Ballymany, The Curragh, Co Kildare.

This Policy applies to our services, websites, any mobile services or apps and telephone and / or online betting.

What Personal Data We Collect

Personal data means any information relating to you which allows us to identify you, such as your name, contact details, client or customer number, horse details, payment details and information about your access to our website and / or apps.

We may collect personal data from you when you engage with us – including but not limited to your participation in racing, purchase of tickets or hospitality, when you avail of our services or supports, carry on betting, use our website and / or apps and other websites accessible through our website and / or app, participate in a survey or competition, or when you contact us.

Specifically, we may collect the following categories of information:

• Name, home address, e-mail address, telephone number, passport or other recognized personal verification details, credit/debit card or other payment details;
• Information about any horses in which you have an interest whether for racing or breeding purposes;
• Communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media;
• Your telephone conversations - these may be recorded both to assist us in training and in quality management, and to allow for the speedy resolution of queries;
• CCTV footage, when you visit our premises;
• Our business activities and your areas of interest;
• Information relating to your subscription to, receipt of or interest in any of our mailing lists or newsletters, or registration to access any of our restricted content;
• Entry details for competitions or promotions;
• Your betting, payments and other account transactions - these may be routinely analysed so as to assist us in improving the services we provide to you;
• Employment applications including your personal information;
• Education and training information;
• Technical information relating to the device that you use to access our services;
• Information we collect using cookies stored on your device about how you use our websites and / or apps - for more information on cookies please refer to Cookies section below;
• Location, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP Address, along with Wi-Fi hotspot and cell tower locations, if you use location-based features and turn on the location services settings on your device and computer.

Some personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “sensitive” personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary, or you have deliberately made it public.

It’s important to highlight that our services are generally not intended for individuals under the age of 18 and we do not knowingly record or retain any personal information from such individuals. In the event that we inadvertently gather personal information in relation to a minor, we will take reasonable measures to remove any records where possible, other than such information as will allow us to identify and prevent future access from such individuals.

What Do We Use Your Personal Data For, Why And For How Long

Your data may be used for the following purposes:

• Providing products and services you request: we use the information you give us to perform our services;
• Contacting you about the services you have asked for and any changes to such services. Some of these communications may not be made for marketing purposes and, as such, cannot be opted-out of;
• Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
• Administrative or legal purposes: we use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or in order to deal with a dispute or claim. Note that we may perform data profiling based on the data we collect from you for statistical and marketing analysis purposes. Any profiling activity will be carried out with your prior consent only and by making best endeavours to ensure that all data it is based on is accurate. By providing any personal data you explicitly agree that we may use it to perform profiling activities;
• Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
• Provide tailored services: we use your data to provide information we believe is of interest to you and to personalise the services we offer to you including ascertaining the platform or mobile devices which you use;
• Racing and race card information: we use your data in relation to your participation in racing including details of any horses in which you have an interest;
• Marketing: from time to time we may contact you with information regarding promotions and ancillary services via e-communications. You will be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material;
• Security, administrative, crime prevention/detection: we may use your information, including geo-location services to ensure compliance with territorial limits where applicable. We may pass your information to government authorities or enforcement bodies for compliance with legal requirements.

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.

We may also process your personal data for one or more of the following:

• To comply with a legal obligation;
• You have consented to us using your personal data;
• Where it is in our legitimate interests;
• Inviting you to events, seminars, webinars and meetings;
• Managing and administering our relationship with our business contacts and with our customers.

We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

Security Of Your Personal Data

We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.

All payment details are transmitted over SSL across dedicated network infrastructure (Multiprotocol Label Switching-MPLS) and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).

We may disclose your information to trusted third parties for the purposes set out in this Privacy Notice. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Irish and EU law on data protection rules.

Sharing Your Personal Data

Your personal data may be shared with other companies within HRI.

Your personal information may be transferred or disclosed to any company within HRI or, subject to appropriate agreement, to third parties, for the processing of that personal information based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures.

Within HRI

Any HRI entity may use and share, within the group and with its advisors, the information you provide and other information it holds about you for the following purposes:

• Account set up, verification and management;
• Race card information;
• Marketing and events;
• Risk management;
• Legal and regulatory obligations.

Our Third-Party Service Providers & Partners

HRI may, from time to time, retain trusted third parties to process your information to provide us with services, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys. As part of our agreements with our partners, we may be required to share your information.

Third Parties For Legal Reasons

We will share personal information when we believe it is required, such as:

• To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
• To protect our rights, users, systems, and services.

Regulatory Or Sporting Body

Your personal information may also be disclosed to any regulatory or sporting body (with whom HRI has agreements for the sharing of such data in connection with the integrity of racing) such as the Irish Horseracing Regulatory Body. Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.

International Data Transfer

HRI may from time to time engage with businesses in other jurisdictions, some of which are not located in the European Economic Area (EEA), While countries outside the EEA do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with Irish and EU law on data protection. We utilise standard means under EU law to legitimise data transfers outside the EEA.

Use Of Cookies, Tracking Pixels And Web Beacons

A "cookie" is a small data file transferred by a Website to your computer's hard drive. Cookies are typically classified as either "session" cookies or "permanent" cookies.

"Session" cookies do not stay on your computer after you leave our Website or close your browser. The aggregate information collected permits us to analyse traffic patterns on our site. This can enable us over time to provide a better experience on our site by improving content or personalisation and making our site easier to use.

"Permanent" cookies are those that remain on your computer. They are used to facilitate shopping, personalisation and registration services. For example, cookies can keep track of what you have selected to purchase as you continue to shop and allow you to enter your password only once on Web pages where a login is required. "Permanent" cookies can be manually removed by the user.

Most browsers automatically accept cookies by default, but you can usually refuse cookies or selectively accept certain cookies by adjusting the preferences in your browser. If you turn off cookies, there may be some features of our site that will not be available to you and some Web pages may not display properly.

You can find information on popular browsers and how to adjust your cookie preferences at the following Websites:

• Microsoft Internet Explorer: www.microsoft.com/info/cookies.htm

• Mozilla Firefox browser: http://support.mozilla.com/en-US/kb/

• Opera browser: http://www.opera.com/support/tutorials/security/privacy/

• Safari browser: http://www.apple.com/support/safari/

• Google Chrome browser: http://www.google.com/support/chrome/

Which Cookies Do We Use?
The following are the cookies we use on the Website:

Google Analytics

Our websites use Google Analytics to collect information about how visitors use our websites. The cookies used by this product collect information in an anonymous form and are used by many different websites. If you wish to opt out of being tracked by Google Analytics across all websites, please visit http://tools.google.com/dlpage/gaoptout.

Managing Cookies Usage

You may refuse to accept or you may disable cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our websites or unable to avail of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Website. You can find out how to do this for your particular browser by clicking "help" on your browser's menu or by visiting www.allaboutcookies.org.

Web Beacons

A web beacon is an electronic image, called a single-pixel (1x1) or clear GIF. web beacons can recognise certain types of information on a visitor's computer, such as a visitor's cookie number, time and date of a page view and a description of the page where the web beacon is placed. You may render some web beacons unusable by rejecting their associated cookies.

Facebook Conversion Tracking Pixel

Our websites may from time to time use Facebook Advertising, Facebook Pixel Re-Marketing, and communications. This tool allows us to understand and deliver ads and make them more relevant to you. The collected data remains anonymous and we cannot see the personal data of any individual user.

However, the collected data is saved and processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes. Facebook has ultimate control of the information gathered through Facebook Advertising, Facebook Pixel Re-Marketing, and communications. You can opt-out of Facebook’s use of cookies and Facebook Pixel Re-Marketing through settings on your Facebook Account.

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this policy. You have the right to make a complaint at any time to a supervisory authority. The Irish Data Protection Commissioner is the lead data protection supervisory authority for HRI as an Irish data controller.

Your Data Protection Rights

Under certain circumstances, by law you have the right to:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you want to exercise any of these rights, then please contact our Data Protection Officer by email to [email protected] or by post to Data Protection Officer, Horse Racing Ireland, Ballymany, The Curragh, Co Kildare.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Should you have any queries regarding any privacy issues you may have, or should you wish to access\amend\or erase any of your personal details, please contact us.

Changes to Privacy Notice

Our Privacy Notice may change from time to time and any changes to the statement will be communicated to you by way of a notice on our website.