Godolphin’s Cookie Policy

Introduction

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

Godolphin respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you either visit our website (regardless of where you visit it from) or interact with us in other ways and tells you about your privacy rights and how the law protects you.

Godolphin collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data Controller Godolphin’s interests are represented worldwide by a number of different companies registered within the geographical regions in which Godolphin operates. These Godolphin group companies are referred to below as “Godolphin”, “we”, “our” or “us”.

Within the European Union

For the purposes of compliance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) data protection laws, a company incorporated in the United Kingdom, Godolphin Management Company Limited (“the Company”) is the Data Controller and responsible for your personal data and adhering to data protection and privacy laws within the European Union.

Outside the European Union

If you are based outside of the European Union and have questions or concerns about our use of your personal data, then you may contact your local Godolphin company, or Godolphin Management Company Limited, whose contact details are listed below.

Godolphin operates several websites to which this Privacy Notice applies and will be published on them.

We have appointed a Data Privacy Manager, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details below.

Worldwide Data Protection and Privacy Contact details

Data Privacy Manager
Godolphin Management Company Limited
Dalham Hall Stud
Duchess Drive
Newmarket, Suffolk CB8 9HE, United Kingdom

Tel : +44 1638 730070
Email: dataprivacy@godolphin.com

You have the right to make a complaint at any time to the appropriate data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns directly, before you approach the relevant authority, so please contact us in the first instance.

Changes to the privacy notice

This version was last updated on 24 May 2018

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data which could include your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data which could include your billing address, delivery address, email address and telephone numbers.
  • Financial Data which could include your bank account and payment card details.
  • Transaction Data which could include your details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data which could include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data which could include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data which could include information about how you use our website, products and services.
  • Marketing and Communications Data which could include your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

  • Direct interactions. You may give us your Identity, Contact, Financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • provide products and services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    1. analytics providers such as Google based outside the EU;
    2. search information providers.
  • Identity and Contact Data from publicly availably sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into, with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Click   to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legiti