Reviewed March 2019
Implemented March 2018
Introduction to the Hooves Group Privacy Policy
At The Hooves Group we are committed to ensuring that your personal information is
protected and never misused.
Our privacy policy explains what personal information we collect, why we collect it, how we
use it, the control you have over your personal information and the procedures we have in
place to protect your personal information. It applies to personal information we collect
through our Hooves websites, through Hooves apps, E-bay and Etsy and in person at our
Hooves retail stores or warehouse or stands and events.
By sharing your personal information with us, and by continuing to use our websites, apps, Ebay
and Etsy you confirm that you have read and understood the terms of this privacy policy.
We take responsibility for the personal information we collect about you, and we aim to be
transparent about how we handle it, and give you control over it.
In this privacy policy, when we refer to "Hooves", "us", "we" or "our", we mean the The
Hooves group company or companies which provide you with the Hooves websites, apps or
any personal information collected about you, are available in the Contacts at the end of this
privacy policy titled In this privacy policy, when we refer to the "The Hooves Group", we
mean all Hooves group companies.
If you have any questions, comments or concerns about any aspect of this privacy policy or
how Hooves handles your information, please email our Privacy Team at
sales@thehoovesgroup.com
Privacy principles
Privacy policies can be complicated. We have tried to make ours as clear and as accessible as
possible. To help, we have also summarised how we handle your personal information at
Hooves in our privacy principles below. These principles demonstrate our commitment to
protecting your privacy and handling your personal information in the right way and as you
would expect it to be handled.
At The Hooves Group we:
1. Will only ask for or collect the personal information we need to provide
and improve the service, products and experiences our customers
expect.
2. Give you control over the personal information we hold about you to
ensure it is accurate and reflects your preferences.
3. Make sure your personal information is always secure and protected.
4. Are fair and transparent about how we use the personal information
we hold.
5. Only ever use your personal information for the purpose that you
trusted us to use it for.
6. Will never sell your personal information and only share it as outlined in
our privacy policy or when you ask us to.
7. Respect your choices and will inform you if there are important
changes that affect your personal information or how we use it.
8. Take responsibility for the personal information that we hold about you.
What personal information do we collect?
We are not interested in collecting every personal detail about you. Our main reason
for collecting your personal information is to provide and improve the service,
products and experiences that you and our customers expect from us.
Personal information is defined slightly differently across the world. To guarantee
your privacy and the protection of your information, we define it as any information
that could be used to identify you or another individual.
We collect personal information about you in a number of different ways. In this
section, we explain the different ways we collect personal information about you and
the ways in which that information will be used. For more detail on how we use your
personal information, please see the section titled "How do we use your personal
information?".
Information you share with us
We collect personal information that you share with us when you contact us or
interact with us through our website, apps, email, phone, in person at our stores,
stands and events, or otherwise.
For example, you will provide information to us when you contact our customer
service teams, place an order, complete a survey, competition or questionnaire, update
your preferences and account information, connect through a Hooves app or book us
for a saddle fitting or order an item of bespoke clothing.
Through these interactions you may share with us: your name, address, e-mail
address, contact number and payment information, location of your horse(s) and
personal measurements. In some circumstances, we will need that information to be
able to provide you with a product or service that you have asked for; for example, we
need your payment information when you buy a product, and your address to deliver
it to you.
Information from your online interactions
We collect and store limited personal information and some anonymous, aggregate
statistics from all visitors to our websites and users of our apps, whether you actively
provide us with that information or merely browse our websites or use our apps. The
information we collect includes, the date and time of access to our website and
information on how you use our websites or apps.
We use this information so that we can see how well our websites and apps are
working, how they are used and what users look at most.
Cookies
We do not use cookies or similar technologies to monitor or collect information about
you.
Email Communications
As a user of our products or services, we will send you support communications by email.
As long as you are happy for us to do so, we would also like to keep you posted
on anything that's happening at Hooves which we think you might like to know about;
whether it’s our latest product announcements, owner offers or upcoming events, we
want to make sure you’re happy with the communications you receive from us. You
can find out how to update or change whether you would like to hear from us, or stop
us contacting you, in the section below titled ‘How can you change the way that we
contact you?'
We collect information about how you engage with our e-mails; including whether
they are delivered to you, whether you open them, whether you choose to learn more
about what's happening at Hooves (for example, by clicking on a link in our e-mail)
We use that information by itself and in combination with your customer record (the
information you share with us) to make sure that we stop sending you support or
marketing communications when you ask us to. We also use it to make our e-mails as
interesting as possible by providing you with content and experiences that we think
you will be interested in based on how you have engaged with our previous e-mails;
you have the right to object to our use of your information for this purpose (see the
section below titled 'Your controls and choices').
Social Media
We love interacting with you on social media. You may use social media to contact us
about your Hooves products, or to let people know what you think about your Hooves
product. We review publically available social media and online sites to get a better
understanding of what people are saying about us, and our products, technology and
services and to assist consumers who prefer to contact us through social media.
The information we collect from social media and online sites, including Facebook,
YouTube, Twitter, Pinterest, Line and Snapchat, sometimes includes personal
information that has been put online and is publically available. We make sure any
information we use is properly credited to its source or is made anonymous.
These online and social media sites typically have their own privacy policies
explaining how they use and share your personal information. You should carefully
review those privacy policies before you use these sites to make sure that you are
happy with how your personal information is being collected and shared.
Information we collect at our stores, stands and events
You may share personal information with us when you visit us in person at our store,
warehouse, stands and events; such as your name, contact details and payment
information (see the section above titled "Information you share with us").
We will also collect personal information about you through our use of CCTV,
filming and photography. CCTV cameras are primarily used for security purposes; in
some of our stores, warehouse,and stands at shows and events they will also help us to
measure traffic (that means, how many people come in and out of our stores). We will
film and take photographs at some of our events and exhibitions (such as equine
shows and exhibitions); we use film and photographs for our business purposes (for
example, to post on our social media pages). We will display notices at those of our
stores, stands and events where we use CCTV, or where we intend to film or take
photographs, to let you know that we will collect personal information about you. .
How do we use your personal information?
Our main reason for collecting and using your personal information is to provide and
improve the service, products and experiences that you expect from us.
Information you share with us
We use the personal information you share with us in the following ways:
o To respond to your queries and requests;
o To communicate with you;
o To provide services and support for our products;
o For customer satisfaction surveys to enable us to identify where service and
product improvements can be made and to allow us to improve your
experience should you need support from one of our experts;
o To provide updates to you about any changes to Hooves policies, terms and
conditions and any other matters which we may need to tell you;
o As long as you are happy for us to do so, to tell you about our other products
and services;
o To customise and improve the way that you shop with us in the future; for
example, by showing you products and offers that we think you might like,
both on our websites and apps and on certain third party websites (including
on social media platforms).
Information from your online interactions
We use the personal information from your online interactions, by itself and in
combination with other personal information that we collect about you to identify any
part of our websites or apps that aren't working as well as they should be – so that we
can fix things and make our websites and apps better for you and other users;
We also want to be able to monitor your use of our websites and apps, and how you
engage with our promotional campaigns and advertising online, so that we can:
o Customise and improve the way that you shop with us in future (for example,
by showing you products and offers that we think you might like); and
o (as long as you are happy for us to do so) send you more relevant and
interesting marketing communications.
You have the right to object to our monitoring of your use of our websites and apps,
and how you engage with our promotional campaigns and advertising online for these
purposes. For more information on how to exercise your right to object, see the
section below titled 'Your controls and choices'.
Other potential uses of your personal information
We use your personal information:
o To assist in any disputes, claims or investigations relating to your Hooves
product or warranty matters;
o To detect and prevent fraudulent transactions;
o To comply with our legal obligations.; and
o For profiling and statistical analysis. As part of this activity we combine
different categories of personal information that we collect about you. For
example, we combine personal information from your online interactions,
information you share with us, for the profiling and statistical analysis of
product popularity, of your behaviour when you use our website or apps or of
how our products are used. You have the right to object to the processing of
personal information in this way. For more information on how to exercise
your right to object, see the section below titled 'Your controls and choices'.
What is our justification for handling your personal information in this way?
Data protection and privacy laws in some countries require us to have what's called a
"legal basis" or "lawful ground" for handling personal information. Broadly, that
means that we have to have a legal justification for handling your personal
information. For the most part, we need to handle your personal information to be
able to:
o provide you with the products or services that you have asked for; and
o for our products, websites and apps to be able to work properly and to do all
the things that you expect them to.
Sometimes, our use of your personal information is not strictly necessary for us to be
able to provide you with our products and services, or for them to work properly. In
those circumstances, we have what's called a "legitimate interest" in handling your
personal information; our "legitimate interest" may be to:
o detect and prevent fraud;
o keep our websites, apps, products and IT systems secure;
o ensure that our own processes, procedures and systems are as efficient as
possible;
o analyse and enhance the information that we collect;
o determine the effectiveness of our promotional campaigns and advertising;
and
o customise and improve the way that you shop and engage with us in future.
There will be certain personal information that you share with us which we specify as
being optional (for example, when you update your account information). We will
explain how we use that information and if you choose to provide it to us, you are
agreeing to our use of your information in that way. You can ask us to delete that
information at any time by contacting Hooves customer service or by e-mailing our
global privacy team at sales@thehoovesgroup.com
Finally, in some, relatively limited circumstances we will need to handle your
personal information in a certain way to be able to comply with our legal obligations;
for example, if we are requested to disclose your personal information to regulatory
bodies or law enforcement authorities.
Ultimately, the reason we handle your personal information in the way we do is so
that we can directly or indirectly, improve our products, services and your overall
experience of Hooves as a business. Whatever our justification for handling your
personal information (whether it is necessary for us to provide you with a certain
product, or it is in our "legitimate interests"), we make sure that we take steps to
honour our commitment to protect your privacy.
Hooves contact promise
We love to keep you posted, whether it’s on our latest product announcements or
upcoming events.
We do this in various ways, including e-mail, post, SMS, in-app and push
notifications, via social media platforms and by phone, but only if you are happy for
us to do so. Ultimately, we want to make sure you’re happy with the communications
you receive from us.
We therefore promise to:
o Only send you marketing communications when you have told us it is ok to
do so;
o Only allow another Hooves Group company to send you marketing
communications if you have told us it is ok to do so;
o Never pass your personal information to anyone outside the Hooves Group for
them to use for their own marketing purposes; and
o Give you the option to stop receiving support or marketing communications at
any time.
.
If your details change, please let us know so that we can continue to stay in
touch.
How can you change the way that we contact you about our products, services and
support?
We will only send you marketing communications when you have told us that you are
happy for us to do so.
You can change the way that we contact you in the following ways:
Opt-In/Start Contacting Me
If you hadn’t previously asked us to send you marketing communications, you can ask
us to start contacting you (sometimes called an "opt-in") by:
o Contacting Hooves customer service and stating that you would like to receive
communications from us, or
o Logging onto your account on our website and changing your preferences and
information.
Changing your preferences
If you have previously said that you would like us to contact you ("opted-in") but
would like to change or update the way that we do so, you can update your
preferences by:
o Contacting Hooves customer service and stating that you would like to change
or update the way that we contact you; or
o Logging onto your account on our website and changing your preferences and
information.
Opt-Out/Stop Contacting Me
If you want to stop receiving marketing or support communications from us
(sometimes called "opting out"), you can do so at any time by:
o Contacting Hooves customer service stating that you no longer wish to receive
such communications;
o Logging into your account on our website and changing your preferences and
information.
o Emailing our global privacy team at sales@thehoovesgroup.com
o
What personal information does Hooves share with third parties?
Most importantly, we never sell your personal information to anyone and only share it
as outlined in this privacy policy or when you ask us to.
Sharing within the The Hooves Group
Most of Hooves processes, procedures and systems are shared across the Hooves
Group, which means that we need to share your personal information between us. We
make sure that access to your personal information is limited to those of our staff who
need it, and that all staff understand how and why we protect your personal
information.
Third party service providers
We share your personal information with certain third party service providers. They
only have access to the personal information they need to perform those services.
They are required to keep your personal information confidential and may not use it
other than as we ask them to and always in accordance with this privacy policy. Those
third party service providers fall into the following categories:
o Those helping us to deliver products to you;
o Third parties that help us with mailing services, product services and repairs,
processing product purchases, financial services, audit services, administrative
services, IT technologies (e.g. data storage), security services and insurance
claims; and
o Third parties that help us to provide services and responses to you.
We will also share limited personal information with:
o social media platforms (such as Facebook), who serve our advertising on their
platforms and
o third party data providers and analytics companies, who perform data
matching and/or data analysis on our behalf.
Other third parties
We will also share your personal information if we are required to do so by law,
including in response to a legal process, such as a court order or warrant, or to comply
with other national or local laws.
If you would like more information on how we share your personal information,
please email our Privacy Team at sales@thehoovesgroup.com. .
Links to third party websites
We may provide links to other websites which are not operated and controlled by
Hooves. We have no control over and are not responsible for the content of those sites
or how the third parties responsible for them collect and use your personal
information. We do not endorse or make any representations about third party
websites.
Third party websites usually have their own privacy policies explaining how they use
and share your personal information. You should carefully review those privacy
policies before you use these websites to make sure that you are happy with how your
personal information is being collected and shared.
How long do we keep your personal information?
We only keep your personal information for as long as we need to, to be able to use it
for the reasons given in this privacy policy, and for as long as we are required to keep
it by law. The actual period for which we store your personal information will vary
depending on the type of personal information and how it is used..
Your controls and choices
Where possible, we give you control over the personal information we collect about
you, to ensure it is accurate and reflects your preferences. You have the right to
access, update and amend personal information that we hold about you; you can do
that in relation to some of your personal information in your account. If you would
like to change the way that we contact you, see the section above titled 'How can you
change the way that we contact you about our products, services and support?'
In certain circumstances, you can also:
o Object to our use of your personal information for certain purposes;
o Ask us to limit or restrict our use of your personal information;
o Ask us to correct, remove or delete personal information about you; or
o Ask us to provide your personal information to a third party provider of
services.
Please note that those rights do not always apply and there are certain exceptions to
them. We will also need to confirm identity before acting on certain requests.
If the law in your country allows us to impose a fee for giving you access to your
personal information, or to exercise any of your other rights in relation to your
personal information, we will let you know.
If you would like to exercise any of your rights in relation to your personal
information, please email sales@thehoovesgroup.com
How do we protect your personal information?
We are committed to protecting your personal information. We use appropriate
technical and organisational measures, including encryption, to protect your personal
information and privacy, and review those regularly. We protect your personal
information using a combination of physical and IT security controls, including access
controls that restrict and manage the way in which your personal information and data
is processed, managed and handled. We also ensure that our staff are adequately
trained in protecting your personal information. Our procedures mean that we may
occasionally request proof of identity before we share your personal information with
you.
In the unlikely event that we do suffer a security breach which compromises our
protection of your personal information and we need to let you know about it, we will
do so.
Data transfers, storage and the global handling of your personal information
The relevant Hooves group company or companies will collect personal information
from you in the country in which you live. We, and those third parties that we share
your personal information with, then host, store and otherwise handle that information
in the UK (at our headquarters), in the countries within the European Economic Area
(EEA) listed in the Contacts or in any country outside of the EEA, including those
listed in the Contacts.
We will make sure that any transfers of your personal information from one country
to another comply with those data protection and privacy laws which apply to us.
European data protection laws, in particular, include specific rules on transferring
personal information outside the EEA.
When transferring personal information outside the EEA, we will:
o include standard data protection clauses approved by the European
Commission for transferring personal information outside the EEA into our
contracts with those third parties (these are the clauses approved under Article
46.2 of the General Data Protection Regulation (GDPR)); or
o ensure that the country in which your personal information will be handled has
been deemed "adequate" by the European Commission under Article 45 of the
GDPR.
In any case, our transfer, storage and handling of your personal information will
continue to be governed by this privacy policy. If you would like further information
about the global handling of your personal information, please contact us at
sales@thehoovesgroup.com
Children
Hooves websites, apps and products are not directed at children. We do not
knowingly collect any personal information from children.
If you are a child, please do not attempt to become a registered user of our websites,
apps or products or otherwise provide us with any personal information. If we learn
that we have inadvertently obtained personal information from a child, we will delete
that information as soon as possible.
If you are aware of a child who has provided their personal information to us, please
contact us at sales@thehoovesgroup.com
Changes to this privacy policy
We will review and update this privacy policy at least once a year and will note the
date it was last updated below.
If we change our privacy policy, we will post the details of the changes below. If we
have your e-mail address, we may also e-mail you with information on those changes.
If we need to, we will also ask you to confirm that you are happy with those changes.
This privacy policy was last reviewed and updated in May 2018.
Previous changes to this privacy policy
May 2018
We updated our Global Privacy Policy to comply with the requirements of new
European data protection laws (specifically, the General Data Protection Regulation).
.
Contact us
If you have any questions, comments or concerns, or would like to make a complaint
about how we use the personal information we hold about you, please email , or write
to, our Privacy Team, or contact the relevant Data Protection Officer for your country
as set out in the Contacts.
You can also contact the relevant regulator or authority in your country that is
responsible for handling complaints about the use of personal information.
Information about the relevant regulator or authority in your country, and that
organisation's contact details, are set out in the Contacts.
You can contact our Privacy Team at any time by email at
sales@thehoovesgroup.com or in writing at C/O The Privacy Team, The Hooves Group. 188A Oxford
Road, Gomersal, Cleckheaton, BD18 4HA West Yorkshire, United Kingdom [You
can also contact the relevant Data Protection Officer(s) in your country using the
contact details set out in the Contacts]. We will get back to you as soon as possible.
Contacts
The Hooves Group, including, Hooves Equestrian, Hooves Western,
Hooves on the Move, Hooves Creations contact
customersevices@thehoovesgroup.com, address 188A Oxford Road, Gomersal,
BD19 4HA, telephone +44 (0)1274 653533
The regulatory authority for the United Kingdom - https://ico.org.uk/Introduction to the Hooves Group Privacy Policy