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:
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;
we obtain the data from;
we do with that data;
we store the data;
we transfer/disclose that data to;
we deal with your data protection rights;
how we comply with the data protection rules.
All personal data
is collected and processed in accordance with Irish and EU data protection
“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.
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
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.
may collect the following categories of information:
name, home address, e-mail address, telephone number, gender, age range, date
of birth, passport or other recognized personal verification details,
credit/debit card or other payment details;
about any horses in which you have an interest whether for racing or
you exchange with us or direct to us via letters, emails, chat service,
calls, and social media;
telephone conversations - these may be recorded both to assist us in
training and in quality management, and to allow for the speedy resolution
footage, when you visit our premises;
business activities and your areas of interest;
relating to your subscription to, receipt of or interest in any of our
mailing lists or newsletters, or registration to access any of our
details for competitions or promotions;
betting, payments and other account transactions - these may be routinely
analysed so as to assist us in improving the services we provide to you;
applications including your personal information;
and training information;
information relating to the device that you use to access our services;
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;
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.
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:
products and services you request: we use the information you give us to
perform our services;
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;
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;
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;
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;
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;
and race card information: we use your data in relation to your
participation in racing including details of any horses in which you have
from time to time we may contact you with information regarding promotions
and ancillary services via e-communications (i.e. email and SMS) and post.
Your contact details are confidential and only shared with our trusted
data partners for the purposes of market segmentation and communication. You
will be given the opportunity on every communication that we send you to
indicate that you no longer wish to receive our direct marketing material;
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:
comply with a legal obligation;
have consented to us using your personal data;
it is in our legitimate interests;
you to events, seminars, webinars and meetings;
and administering our relationship with our business contacts and with our
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.
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.
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:
set up, verification and management;
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:
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;
protect our rights, users, systems, and services.
Regulatory Or Sporting Body
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.
"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.
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.
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.
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:
| Cookie Name|| Description|
This is a general purpose
platform session cookie, used by sites written with Microsoft .NET based
technologies. It is usually used to maintain an anonymised user session by
This cookie is associated with the Ektron web content management
system, and is used to collect anonymous visitor information to enable
performance measurement and improvement.
This cookie is associated with
the Ektron web content management system. It can contain user identifiers,
language/culture codes, or device information like screen size. This data is
used to perform a range of different functions for the site.
This cookie is used by Google Analytics to distinguish users and
existing __utma cookies exists. The cookie is updated every time data is sent
to Google Analytics.
This cookie is used by Google
Analytics to capture the traffic source or campaign that explains how the
executes and is updated every time data is sent to Google Analytics.
This cookie is used by Google Analytics to determine new
executes and no existing __utmb cookies exists. The cookie is updated every
time data is sent to Google Analytics.
These cookies are used by
Google Analytics to throttle request rate.
These cookies are used by Google Analytics to distinguish users.
These cookies are associated
with the AddThis social sharing widget which is embedded in websites to
enable visitors to share content with a range of networking and sharing
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
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.
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.
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.
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
circumstances, by law you have the right to:
information about whether we hold personal information about you, and, if
so, what that information is and why we are holding/using it.
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
correction of the personal information that we hold about you. This
enables you to have any incomplete or inaccurate information we hold about
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).
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.
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.
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
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.
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.