Welcome to SOULFUL EQUINE’S privacy policy. SOULFUL EQUINE respects your privacy and is committed to protecting your personal data.
1. Introduction
This privacy policy tells you how SOULFUL EQUINE uses your personal data when you visit our website, interact with us, and buy our goods and services.
It also tells you about your privacy rights and how the law protects you.
It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.
This privacy policy was last updated on 24th of May 2018 and historic versions can be obtained by contacting us.
If you have any questions or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact SOULFUL EQUINE about privacy below.
2. Soulful Equine’s website
Our website soulfulequine.com is owned and operated by SOULFUL CREATURES™ LLC (DBA SOULFUL EQUINE), a Texas company, hereafter referred to as SOULFUL EQUINE. SOULFUL EQUINE maintains this site for your personal education and information, as well as sales of books, digital downloads, and services which are aimed at individuals who desire to or own a horse. This website is not intended for children and we do not knowingly collect data relating to children.
SOULFUL EQUINE is the data controller responsible for this website and any handling of personal data carried out by or on behalf of SOULFUL EQUINE. SOULFUL CREATURES LLC is a data controller for any handling of personal data carried out by or on behalf of SOULFUL CREATURES LLC.
SOULFUL EQUINE and SOULFUL CREATURES LLC work collaboratively to bring great products and services to SOULFUL EQUINE customers all over the world, and they may sometimes be acting as joint data controllers. When we mention “SOULFUL EQUINE”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company SOULFUL EQUINE responsible for processing your data. When we mention “Our Site” in this privacy policy, we are referring to soulfulequine.com.
3. Personal data which 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 collect a variety of information about our wonderful customers (you!) and visitors to the Soulful Equine website. This personal data falls into these categories:
Identity Data includes first name, last name, username or similar identifier and your login/password. If you interact with us through social media, this may include your social media username.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
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 and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.
Any of the information we collect from you may be used to either handle transactions or to send periodic e-mails either about your order or upcoming promotions. We promise that we will never sell, trade or rent your telephone or email information to third party marketers.
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 offenses.
Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.
4. 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 and Financial Data by filling in forms or by corresponding with us by post, phone, email or through chat or social media.
This includes personal data you provide when you:
- Sign up to receive the Soulful Equine Newsletter
- Make inquiries or request information be sent to you
- Create an account on our website
- Order our products or services
- Ask for marketing to be sent to you
- Engage with us on social media
- Enter a competition, promotion or survey
- Contact customer services; or
- Leave comments or reviews on our products or services
5. How we use your personal data
Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
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. For example, when we carry out fraud screening as part of the check-out process.
Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.
See below, “Explaining the legal bases we rely on to process personal data” to find out more about the types of lawful basis that we will rely on to process your personal data.
6. Explaining the legal bases we rely on to process personal data
The table here shows you a description of all the ways we plan to use 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.
We do not carry out any automated decision making.
If you ever have any questions about this, all you have to do is ask. See How to contact SOULFUL EQUINE about privacy below.
7. Anti spam policy. Can-Spam Act Compliance
SOULFUL EQUINE is dedicated to ensuring compliance with the “Can-Spam Act,” which took effect January 1, 2004. You may receive email from SOULFUL EQUINE in the following circumstances:
- Advertisements for our products, services, changes in services, new product availability
- Advertisements for third party products and services where we have determined that such product or service may be of interest to our customers
- Thanking you for your valued business
To ensure compliance with the Can-Spam Act, SOULFUL EQUINE has implemented the following guidelines for email delivery:
- All emails sent to you by SOULFUL EQUINE will clearly identify SOULFUL EQUINE as the sender. FROM / SENDER: realperson@soulfulequine.com (NOTE: The actual sender will alter from department to department, but all from addresses will end with @soulfulequine.com)
- Any email from soulfulequine.com will include the ability to unsubscribe from future email messages
- Unsubscribing will ensure the customer is removed from ALL lists at soulfulequine.com; this excludes customer service emails regarding the processing and status of a current product
- All emails sent to you directly by soulfulequine.com include valid postal address information in the footer
- All third party marketing partners are required to comply with the Can-Spam Act
- Emails sent to you directly by soulfulequine.com will include an email address and physical address where you can send suggestions, complaints or other correspondence.
8. Advertising, marketing and your communications preferences
We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.
We may carry out direct marketing by email, phone, text or post. For example, you might have the Soulful Equine Newsletter hit your inbox or a nice promotion sent to your mailbox.
On our website, we always try hard to make it clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the Soulful Equine Newsletter or as part of creating an account or for a purchase – you have a right at any time to change your mind and say no thank you and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.
There are many different ways you’ll see adverts for SOULFUL EQUINE, and not all of these are based on using personal data – sometimes we just buy good old-fashioned advertising space in the real world and websites and social media. If you see SOULFUL EQUINE’s adverts on websites and in social media, these may not be directed specifically at you, we might just have bid for the space. But here are some things we may do that may be specifically directed at you:
- Emails, for example, the Soulful Equine Newsletter
- Text messages, for example with discount codes
- Promotions by post, such as discounts on shipping offers
- Phone calls, to tell you something that might be relevant to you and your business
9. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.
We may share personal data with the following categories of third parties:
- Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
- SOULFUL EQUINE group companies
- Auditors and professional advisers like bankers, lawyers, accountants and insurers; and
- Government, regulators and law enforcement
Any of the information we collect from you may be used to either handle transactions or to send periodic e-mails either about your order or upcoming promotions. We promise that we will never sell, trade or rent your telephone or email information to third party marketers.
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.
10. Payment information
SOULFUL EQUINE uses third party payment processors, such as PayPal, to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors – SOULFUL EQUINE never (ever!) sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.
11. International transfers
Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
- The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.
We share your personal data within the SOULFUL EQUINE Group, which will involve transferring your data outside the European Economic Area. We do this using the EU Model Clauses.
Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
12. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
13. 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 policy of every website you visit.
14. Data retention
We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
15. Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
- The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that is in this privacy policy)
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for a copy of the personal data we hold about you
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate
- The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it)
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data
- The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file)
- The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
- Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.
If you wish to exercise any of the rights set out above, please contact us (see How to contact SOULFUL EQUINE about privacy).
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 may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details in How to contact SOULFUL EQUINE about privacy below.
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority 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.
16. How to contact SOULFUL EQUINE about privacy
If you have any questions about this privacy policy or would like to exercise any of your rights, contact us — click here to go to our contact form — or write to us with your letter addressed to: Data Privacy Manager, SOULFUL EQUINE, PO Box 436, Tioga, TX, 76271.
If you need help with our products and services, or this website generally, please contact us here.
17. A little request from SOULFUL EQUINE to you
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. You can do this by updating your account. Thank you.
18. Our right to contact you
We reserve the right to contact you regarding your account status and changes to subscriber agreements, privacy policy, or any other policies or agreements relevant to you.
19. Changes to this privacy policy
The General Data Protection Regulation is new and the ICO is still issuing new bits of guidance about how businesses should follow it. So, you may see little updates to our privacy policy over the coming months. Be sure to check in and read it every now and then. Thank you.