Crescent Horse Sales GDPR and Privacy Policies
GDPR Overview
The purpose of GDPR is to protect the private information of EU citizens and give them more control over their personal data. Under GDPR, private information is defined as any information that is directly or indirectly identifiable to an individual. This includes information such as social security numbers, location data, online identifiers, pseudonymous data, and genetic or biometric data, such as fingerprints and facial recognition.
Specifically, GDPR grants EU citizens the following means of controls over their personal data:
Transparent information about data processing
Every company that hold and/or process data of any person in the EU is obligated to provide any information relating to processing this data subject
Right of access
Data controllers will be required to fulfil requests from individuals seeking access to their private data or information on how it is being used. Data collectors and processors will have to detail how the personal information was obtained, how and why it is being used, as well as with whom the company is sharing the information. Companies will also be mandated to provide the individual with a copy of their personal records.
Right to be Forgotten
Individuals can decide they no longer want their personal data to be processed and request all of their information to be deleted.
Notice of security breaches
Individuals must be alerted within 72 hours if their personal data has been hacked or otherwise compromised.
Privacy by design
At its core, privacy by design calls for the inclusion of data protection from the onset of the designing of systems, rather than an addition.
Crescent Horse Sales Ltd and GDPR
Crescent Horse Sales Ltd trading as horsesales.ie have thoroughly researched all areas of our product and our business impacted by GDPR. Here are all important points regarding Crescent Horse Sales Ltd and GDPR:
All Crescent Horse Sales Ltd Services
1. Crescent Horse Sales Ltd Live Auction Site – for Mainstream auctioning of horses
(www.horsesales.ie)
2. Crescent horse Sales Ltd Payment Page – for credit card and eft payments
(www.horsesales.ie)
3. Crescent Horse Sales Ltd Landing Page – for public information (www.horsesales.ie)
4. Crescent Horse Sales Ltd Google Sheets (Google G Suite):
Transparent information about data processing
The Article 4 of GDPR defines data controllers and data processors as below:
Controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor – a natural or legal person, public authority, agency or another body which processes personal data on behalf of the controller.
For example, if Crescent Horse Sales Ltd promotes the bloodstock industry and uses Google Mail (GMail) to email trainers, owners, agents etc on their behalf and track their engagement, then, with regard to such email activity data, Crescent Horse Sales Ltd is the data controller, and Google is the data processor.
This distinction is important for compliance. Generally speaking, the GDPR treats the data controller as the principal party for responsibilities such as collecting consent, managing consent-revoking, enabling the right to access, etc. A data subject who wishes to revoke consent for his or her personal data therefore will contact the data controller to initiate the request, even if such data lives on servers belonging to the data processor. The data controller, upon receiving this request, would then proceed to request the data processor remove the revoked data from their servers.
Crescent Horse Sales Ltd as a Data Controller
In the meaning of Data Controller stated above, Crescent Horse Sales Ltd stores the following Personal Information:
1. Crescent Horse Sales Ltd Live Auction Site (www.horsesales.ie):
• User Profile
• Real Name (unless otherwise specified)
• Address
• Telephone number
• Email address
2. Crescent Horse Sales Ltd Payment Page (www.horsesales.ie):
• Credit Card:
o All personal information is entered by you through securitized payment functions i.e STRIPE and PAYPAL. Please visit their privacy policy. No credit card details are stored by Crescent Horse Sales Ltd (www.horsesales.ie)
• EFT Transfer:
o Crescent Horse Sales Ltd do not store online your bank details. In the event you have sold a horse then Crescent Horse Sales Ltd undertake to transfer the selling amount (minus any fees or commission) for our designated Client Account from the successful Purchaser to you. To ensure payment we will ask you to give us your bank details over the telephone or by email. At your consent we will keep a physical (non- online) copy on file for future sales payment transfers but you may elect to destroy this at any time.
3. Crescent Horse Sales Ltd Loading Page (www.horsesales.ie):
o Registration Form (www.horsesales.ie/forms)
o Real Name
o Contact Number
o Address
o Email Address
4. Crescent Horse Sales Ltd Google Sheets (Google G Suite):
• Vendor & Purchaser List
o Real Name
o Contact Number
o Address
o Email Address
In order to create an account in Crescent Horse Sales Ltd, we ONLY accept sign up requests from verified Vendors and Purchasers.
Crescent Horse Sales Ltd will firstly verify the Vendor/Bidder and sign up request. In the case of a Bidder, once verified, Crescent Horse Sales Ltd Team issue a Bidder Number. Created Username and Password will be ONLY stored in Crescent Horse Sales Ltd Google Sheets (Google G Suite).
Crescent Horse Sales Ltd Privacy Policy
Crescent Horse Sales Ltd regard the privacy and security of our customer’s information as an important component of the service that we offer. This policy describes how we use your personal information in your dealings with us. Please take the time to read it carefully. You have a number of rights in relation to your information including the right to object to the processing of your personal information where that processing is carried out for our legitimate interests.
When you purchase a horse through horsesales.ie, we, Crescent Horse Sales Ltd, will be the company responsible for handling your personal information (known as a “controller” under data protection law).
The personal information collected by us includes your name, address, contact information, telephone number, email address, company number (if applicable) and questions regarding your knowledge of Crescent Horse Sales Ltd.
Why we collect this
• We need your Personal Information to create your account, and to provide the services you request.
• We show your Personal Information on your profile page. This profile is accessible by you only.
• We use your Personal Information, specifically your username, to identify you on Crescent Horse Sales Ltd.
• We use your Personal Information to contact you about our services and enable you to buy or sell horses on www.horsesales.ie
The purpose and legal basis for processing your information
We collect your personal information to enter into a contract with you to sell a horse through our platform. It is a requirement of the contract that we enter into with you that you provide all personal information requested on this form. If you do not provide us with contact details we may not be able to perform our contract, for example, we will not be able to call you should a problem arise with your application.
In order to process your personal information for this purpose, the processing is necessary for the performance of the contract to which you are a party.
We may use your personal information for direct marketing purposes to make you aware of auction dates or ad hoc auctions which may interest you or for customer satisfaction surveys where you have not objected to us doing so. As part of our marketing activities, we may also use your personal information to provide you with details of horses which may be of special interest to you. We may do this by phone, post, email, text or through other digital media. Where we do so, we rely on the lawful processing ground of legitimate interest and our legitimate interest is to develop relationships with our existing customers and to assess our performance and standards.
When you purchase a horse through horsesales.ie we may use your personal information to comply with any obligation under anti-money laundering legislation, for the purposes of any statutory audit or for any other legal obligation to which we are subject.
We may also use your personal information to manage our everyday business needs, including accounting and to prevent fraud. Where we do so we rely on the lawful processing ground of legitimate interest and our legitimate interest is in the effective management of our business.
We limit our use of your Personal Information to the purposes listed in our terms and conditions. We do not share, sell, rent, or trade Personal Information with third parties other than those previously stated.
Right of access and Right to be Forgotten
Your Rights
You have several rights under data protection law in relation to how we use your personal information. You have the right, free of charge, to:
• Check what type of personal data we hold about you and what we do with that information. You are also entitled to receive a copy of this information.
• Rectify any inaccurate personal information we hold about you.
• Erase personal information we hold about you.
• Stop us from using your personal information in certain cases, including if you believe that the personal information we hold about you is inaccurate or our use of your information is unlawful. If you exercise this right, we will store your personal information and will not carry out any other processing until the issue is resolved.
• Object to us using your personal information where we rely on our legitimate interests to use your information. We will stop using your personal information unless we can demonstrate an overriding legitimate grounds for the continued processing of this information.
• Receive your personal information in a structured, commonly used and machine-readable format and to have that data transmitted to another data controller.
These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights please contact us info@horsesales.ie. We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will explain why. You also have the right to lodge a complaint to the office of the Data Protection Commission. For further information on data protection see www.dataprotection.ie. This consent can be withdrawn at any time free of charge.
Crescent Horse Sales Ltd doesn’t ask for more personal data from our users than we need to provide our services to you. We provide you the ability to access and delete the data you have given us (e.g. you can remove your profile information at any time).
We have gone through our Privacy Statement to provide more context and transparency, though, so our users understand exactly why we ask for information and what we’ll do with it.
INFO: If you want to get or erase all information that we have about you, please send a request to service@horsesales.ie
Notice of security breaches
Crescent Horse Sales Ltd takes all measures reasonably necessary to protect Personal Information from unauthorized access, alteration, or destruction, maintain data accuracy, and help ensure the appropriate use of Personal Information. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We are committed to announcing any security breaches within 72 hours after we notice this kind of issue.
Privacy by design
Since the very beginning, the application’s architecture and server infrastructure have been designed and chosen specifically to ensure that all user data is safe.
The application and user data are hosted on Siteground servers. You can see how Siteground secures data https://www.siteground.com/privacy.htm
The application is continually updated on monthly basis with the most recent and secure solutions. Critical security patches are provided as needed outside of the regular release cycle and specifically announced with email notifications and via our Twitter channel. We also have a bug bounty program that lets users report vulnerabilities to our dedicated address service@horsesales.ie so reported issues and security holes are fixed with the highest priority.
Tracking
If you do not want online services to collect and share certain kinds of information about your online activity from third-party tracking services, you can set the Do Not Track privacy preference in your browser.
We do not track your online browsing activity on other online services over time and we do not permit third-party services to track your activity on our site with the exception of basic Google Analytics tracking and our other vendors listed below. The tracking data is collected exclusively to improve the UX and performance of the Service and website.
Because we do not share this kind of data with third-party services or permit this kind of third party data collection on Crescent Horse Sales Ltd for any of our users, and we do not track our users on third-party websites ourselves, we do not need to respond differently to an individual browser’s Do Not Track setting. If you wish, you can opt out from Google Analytics tracking here.
Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails.
Our Vendors
We also use the services that already confirmed they met GDPR conditions or are in the final stage of preparations:
• Google G Suite – email communication, School List storage (Ireland)
• Google Analytics – Traffic Analytics (Ireland)
• Google Webmasters – Search Engine Optimizations (Ireland)
• Paypal – Secure payments facility
• Stripe – Secure payments facility
Updates to our T&C and other policies
To achieve compliance with the GDPR and Provacy Laws, we may update our policies to come into alignment with any new law. We will automatically make you aware of any updates to our policies.