Introduction
This privacy notice is provided in a layered format, so you can click through to the specific areas set out
below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy
notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

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Important information and who we are
Purpose of this privacy notice
Godolphin respects your privacy and is committed to protecting your personal data. This privacy notice will
inform you as to how we look after your personal data when you either visit our website (regardless of where
you visit it from) or interact with us in other ways and tells you about your privacy rights and how the law
protects you.
Godolphin collects and processes your personal data through your use of this website, including any data you
may provide through this website when you sign up to our newsletter, purchase a product or service or takepart in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice
we may provide on specific occasions when we are collecting or processing personal data about you so thatyou are fully aware of how and why we are using your data. This privacy notice supplements the other notices
and is not intended to override them.

Data Controller Godolphin’s interests are represented worldwide by a number of different

companies registered within the geographical regions in which Godolphin operates. These Godolphingroup companies are referred to below as “Godolphin”, “we”, “our” or “us”.
Within the European Union
For the purposes of compliance with the General Data Protection Regulation (GDPR) (Regulation (EU)2016/679) data protection laws, a company incorporated in the United Kingdom, Godolphin
Management Company Limited (“the Company”) is the Data Controller and responsible for yourpersonal data and adhering to data protection and privacy laws within the European Union.
Outside the European Union
If you are based outside of the European Union and have questions or concerns about our use of yourpersonal data, then you may contact your local Godolphin company, or Godolphin Management
Company Limited, whose contact details are listed below.
Godolphin operates several websites to which this Privacy Notice applies and will be published on them.
We have appointed a Data Privacy Manager, who is responsible for overseeing questions in relation to thisprivacy notice. If you have any questions about this privacy notice, including any requests to exercise yourlegal rights, please contact the Data Privacy Manager using the details below.
Worldwide Data Protection and Privacy Contact details
Data Privacy Manager
Godolphin Management Company Limited
Dalham Hall Stud
Duchess Drive
Newmarket
Suffolk
CB8 9HE
United Kingdom2Tel : +44 1638 730070
Email : dataprivacy@godolphin.com
You have the right to make a complaint at any time to the appropriate data protection supervisory authority.
We would, however, appreciate the chance to deal with your concerns directly, before you approach therelevant authority, so please contact us in the first instance.
Changes to the privacy noticeThis version was last updated on 24 May 2018
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 thesethird-party websites and are not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy notice of every website you visit.

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The data 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped
together follows:•

Identity Data which could include your first name, maiden name, last name, username or similar identifier,marital status, title, date of birth and gender.

•

Contact Data which could include your billing address, delivery address, email address and telephone
numbers.

•

Financial Data which could include your bank account and payment card details.

•

Transaction Data which could include your details about payments to and from you and other details of
products and services you have purchased from us.

•

Technical Data which could include your internet protocol (IP) address, your login data, browser type andversion, 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.

•

Profile Data which could include your username and password, purchases or orders made by you, yourinterests, preferences, feedback and survey responses.

•

Usage Data which could include information about how you use our website, products and services.

•

Marketing and Communications Data which could include your preferences in receiving marketing fromus and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as thisdata does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data tocalculate the percentage of users accessing a specific website feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used in accordance with this privacy notice.
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 offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you
fail to provide that data when requested, we may not be able to perform the contract we have or are trying
to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel
a product or service, but we will notify you if this is the case at the time.

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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, Financial data by filling in forms or bycorresponding with us by post, phone, email or otherwise. This includes personal data you provide whenyou:•

apply for our products or services;•

provide products and 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 some feedback.

•Automated technologies or interactions. As you interact with our website, we may automaticallycollect Technical Data about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs and other similar technologies. We may also receive Technical Data
about you if you visit other websites employing our cookies. Please see our Cookie Policy for further
details.

•

Third parties or publicly available sources. We may receive personal data about you from various third
parties and public sources as set out below:••

Technical Data from the following parties:a)analytics providers such as Google based outside the EU;b)search information providers.

Identity and Contact Data from publicly availably sources.

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How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal
data in the following circumstances:•

Where we need to perform the contract, we are about to enter into or have entered into, with you.

•

Where it is necessary for our legitimate interests (or those of a third party) and your interests andfundamental rights do not override those interests.

•

Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation
to sending third party direct marketing communications to you via email or text message. You have the rightto withdraw consent to marketing at any time by contacting us.
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 your personal data, andwhich of the legal bases we rely on to do so. We have also identified what our legitimate interests are whereappropriate.
Note that we may process your personal data for more than one lawful ground depending on the specificpurpose for which we are using your data. Please contact us if you need details about the specific legal ground
we are relying on to process your personal data where more than one ground has been set out in the tablebelow.
Purpose/Activity

Type of data

Lawful basis for processing including
basis of legitimate interest

To register you as a newcustomer(a) Identity

Performance of a contract with you

To process and deliver yourorder including:(a) Identity(a) Performance of a contract with you(b) Contact(b) Necessary for our legitimate interests(to recover debts due to us)(a) Manage payments, fees
and charges(b) Collect and recover money
owed to us
To manage our relationshipwith you which will include:(a) Notifying you aboutchanges to our terms or
privacy policy(b) Asking you to leave areview or take a survey(b) Contact(c) Financial(d) Transaction(e) Marketing andCommunications(a) Identity(a) Performance of a contract with you(b) Contact(b) Necessary to comply with a legal
obligation(c) Profile(d) Marketing andCommunications

6(c) Necessary for our legitimate interests(to keep our records updated and to
study how customers use our
products/services)To enable you to partake in a
prize draw, competition orcomplete a survey(a) Identity(a) Performance of a contract with you(b) Contact(b) Necessary for our legitimate interests(to study how customers use our
products/services, to develop them andgrow our business)(c) Profile(d) Usage(e) Marketing andCommunications

To administer and protect ourbusiness and this website(including troubleshooting,data analysis, testing, system
maintenance, support,
reporting and hosting of data)(a) Identity(a) Necessary for our legitimate interests(for running our business, provision ofadministration and IT services, network
security, to prevent fraud and in thecontext of a business reorganisation orgroup restructuring exercise)(b) Contact(c) Technical(b) Necessary to comply with a legal
obligation
To deliver relevant website
content and advertisements toyou and measure orunderstand the effectivenessof the advertising we serve toyou(a) Identity

Necessary for our legitimate interests (tostudy how customers use our
products/services, to develop them, togrow our business and to inform ourmarketing strategy)(b) Contact(c) Profile(d) Usage(e) Marketing andCommunications(f) Technical

To use data analytics to
improve our website,
products/services, marketing,customer relationships andexperiences(a) Technical

To make suggestions andrecommendations to you
about goods or services that
may be of interest to you(a) Identity

Necessary for our legitimate interests (todefine types of customers for our
products and services, to keep our
website updated and relevant, todevelop our business and to inform ourmarketing strategy)(b) Usage

Necessary for our legitimate interests (todevelop our products/services and growour business)(b) Contact(c) Technical(d) Usage(e) Profile

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Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing andadvertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which products, services andoffers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us by subscribing
to our website or purchased goods or services from us or if you provided us with your details when you entereda competition or registered for a promotion and, in each case, you have not opted out of receiving thatmarketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside theGodolphin group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out
links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us
as a result of a product/service purchase, warranty registration, product/service experience or othertransactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or accesscookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible
or not function properly. For more information about the cookies we use, please see [our Cookie Policy.]
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance withthe above rules, where this is required or permitted by law.

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Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the tablein paragraph 4 above.
•

Internal Third Parties as set out in the [Glossary].

•

External Third Parties as set out in the [Glossary].

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

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International transfers
We share your personal data within the Godolphin Group. This will involve transferring your data outside theEuropean Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded
to it by ensuring at least one of the following safeguards is implemented:•

Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe. For further details, see
European Commission: Model contracts for the transfer of personal data to third countries.

•

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 the Europe andthe US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring
your personal data out of the EEA.

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Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to yourpersonal data to those employees, agents, contractors and other third parties who have a business need toknow. They will only process your personal data on our instructions and they are subject to a duty ofconfidentiality.
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.

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Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil 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, andsensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personaldata, the purposes for which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy
which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may anonymise 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.

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Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:•[Request access to your personal data].

•[Request correction of your personal data].

•[Request erasure of your personal data].

•[Object to processing of your personal data].

•[Request restriction of processing your personal data].

•[Request transfer of your personal data].

•[Right to withdraw consent].

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
may 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 rightto 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 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.

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Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us
to give you the best service/product and the best and most secure experience. We make sure we consider andbalance any potential impact on you (both positive and negative) and your rights before we process yourpersonal 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 toby law). You can obtain further information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract
to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary forcompliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIESInternal Third Parties
Other Godolphin companies and organisations acting as joint data controllers or processors and who are based
the UK, Ireland, France, United Arab Emirates, USA, Australia or Japan.
External Third Parties•

Service providers acting as processors based both inside and outside the European Union who provide IT
and system administration services.

•

Companies such as Marketing Agencies, Mailing Houses, Printers, Lawyers, Sales Companies, Debt
Collection Agencies.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data 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. 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 tocomply with local law. Note, however, that we may not always be able to comply with your request of erasurefor specific legal reasons which will be notified to you, if applicable, at the time of your request.

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Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right toobject where we are processing your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your information which override yourrights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processingof your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where
our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data evenif we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected
to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. However, thiswill 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.

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