Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data which you provide in order to operate our website located at www.saracenhorsefeeds.com (the “website”), our webshop at https://saracen-shop.com (the “webshop”) or our account customer portal at https://trade.saracenhorsefeeds.co.uk (the “Trade Portal”), the website, webshop and Trade Portal together being the “Media” which we have grouped together as follows:

· Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, and title.

· Contact Data includes billing address, delivery address, email address and telephone numbers.

· Financial Data includes your payment card details where you make a purchase via the Media.

· Images/videos includes additional supporting information that you may provide to us when you request feed advice via our online feed advice request form.

· Transaction Data includes details about payments to and from you that you carry out through the Media, the fulfilment of your orders and other details of products and services you have purchased from us.

· Technical Data includes 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, device ID and other technology on the devices you use to operate our website located at www.saracenhorsefeeds.com (the “website”).

· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

· Usage Data includes your use of the Media (including, but not limited to, traffic data and location data) whether this is required for our own purposes or otherwise, how you interact with and use our website, products and services, including any content that you submit to our staff via the App, for example through the “Request a Call”, “Request Visit” and “Feed Advice form” functions.

· Marketing and Communications Data if we ask you for your contact details for future marketing use, the contact details you provide to us, and this includes your preferences in receiving marketing from us and our third parties and your communication preferences, although you have the option to opt-out of such use.

If you are providing us with personal information about any other person, you confirm that you have obtained his or her consent and made him or her aware of this policy before providing the information to us.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

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

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• request or purchase our products or 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 feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. For further details please see the ‘cookies’ section below.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

• Technical Data is collected from the following parties:

• Analytics providers (such as Google Adsense and Facebook based outside the UK);

• Equine nutrition, research, and consultation platforms (such as Kentucky Equine Research based outside the UK);

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe based outside of the UK;

• Profile, Identity, Contact, and Usage Data is collected from equine nutrition, research and consultation platforms (such as Kentucky Equine Research based outside the UK, including via the MicroSteed and Gro-Trac software), including reports and outputs generated for feed advice purposes and equine growth-monitoring.

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LEGAL BASIS

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract, we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

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 the various categories of 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.

DIRECT MARKETING

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which product, services and offers may be of interest to you so that we can then send you relevant marketing communications.

THIRD-PARTY MARKETING

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

OPTING OUT OF MARKETING

You can ask us to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations for a product/service warranty registration, appointment reminders, updates to our Terms and Conditions, or checking that your contact details are correct.

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The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (‘UK’) and transferred to any of our distributors and/or partners (for example, Kentucky Equine Research). It may also be processed by staff and contractors operating outside the UK who work for us, our distributors, or our partners.

We will use strict procedures 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 using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Media, you are responsible for keeping it 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 the Media. Once we have received your information, we will use strict procedures and appropriate security features to try to prevent your personal data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We use information we hold in the following ways:

· To ensure that content on the Media is presented in the most effective manner

· To carry out our obligations in connection with any transactions you enter into via the Media

· To allow you to participate in interactive features of our service, when you choose to do so

· To notify you about changes to our service

· To provide you with information and offers that we or selected third parties feel may interest you

We will only contact you by electronic means (email or SMS) with information about goods and services similar to those which were the subject of a previous 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.

If you do not want us to use your data for marketing purposes, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.

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We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, with external third parties and with relevant third parties for the purpose of fraud protection and credit risk reduction, in particular Creditsafe.

We may also share your personal information, with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law we always ensure that a similar degree of protection is afforded to it by ensuring that we use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement, or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers (EU SCCs). To obtain a copy of these contractual safeguards, please contact us at info@saracenhorsefeeds.co.uk.

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You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Where we are unable to comply with your request of erasure for specific legal reasons, these will be notified to you at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes. See the ‘opting out of marketing’ section above.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

We reserve the right to update or alter this Privacy Policy from time to time. Any changes will be posted on this page and where appropriate will be notified to you by e-mail.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

To enhance your experience, the Media use “cookies.” For more information about the cookies, we use and how to change your cookie preferences, please see our cookies policy.

If you have any questions about this privacy policy or about the use of your personal data or you would like to exercise your privacy rights, please contact our data protection lead in the following ways:

Email address: info@saracenhorsefeeds.co.uk

Postal address: Saracen Horse Feeds Ltd, The Forstal, Beddow Way, Aylesford, Kent, ME20 7BT

Telephone number: +44 01622 718487

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. The ICO will expect you to have done this before reviewing your complaint.

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 policy of every website you visit.