PRIVACY STATEMENT (AS OF 01.03.2024)
In accordance with Art. 12, 13, 14 and 21 of the General Data Protection Regulation (GDPR) and § 13 of the German Tele Media Act (TMG) we inform you below how your personal data are handled when using our website www.clipmyhorse.tv.
OWNER
Owner in the sense of data protection law is:
ClipMyHorse.TV Operations GmbH
Wandersmannstr. 68
65205 Wiesbaden
E-Mail: dataprivacy@clipmyhorse.tv
Via these contact data, you will reach our Data Protection Officer Gina Bleckmann from Fresh Compliance GmbH or another contact with data protection responsibility. Please feel free to contact us at any time if you have any concrete questions about your data, data erasure, or your rights.
PURPOSE AND LEGAL BASIS FOR DATA PROCESSING
General
The purpose of data processing and the corresponding legal basis is detailed in the following.
Insofar as data processing takes place between you and an event host (e.g. regarding the recording of participants’ lists, collecting data about the owners of the horses), the circumstances of data processing and - if applicable - consents or other legal bases are
governed exclusively by the event hosts’ data protection regulations.
USING OUR WEBSITE FOR INFORMATION PURPOSES ONLY
You can visit our website without disclosing personal data. If you use our website for information purposes only, i.e. without registering, logging in or otherwise transmitting personal data, we will not collect any personal data except the data transmitted by your browser to allow for your visit to our website, and information transmitted to us via the cookies used.
Technical provision of the website
For the purposes of the technical provision of the website, we need to process certain automatically transmitted information from you so that your browser can display our website and you can use the website. With each access to our website, this information is collected automatically and saved to our server log files. This information relates to the computer system of the computer calling up our website. The following information is collected in this process:
● IP address:
● Browser type/version (e.g.: Internet Explorer 6.0);
● Browser language (e.g.: German);
● Operating system used (e.g.: Windows XP);
● Internal resolution of the browser window;
● display resolution;
● Java script activation;
● Java on / off;
● Cookies on / off;
● colour depth;
● time of access.
We furthermore use cookies to make our website available for your use. Cookies are text files that are stored in the Internet browser or by the Internet browser on your computer system when you access a website. A cookie contains a characteristic sequence of characters allowing for unique identification of the browser when accessing the website the next time. We use these
cookies to make our website with its technical functions available to you. Using cookies is mandatory for some of the functions of our website; for this reason, these cookies are strictly necessary for the operation of our website. These cookies store the following information and transmit it to us:
● cookie ID;
● session information;
● declaration of consent for the use of the cookie.
● On our website, we use three types of cookies:
● Strictly necessary cookies (we need these, for example, to display the website correctly for you and to cache certain settings)
● Preference cookies (these enable our website to store information that changes the behavior or appearance of the website, e.g. your preferred language or the region you are in)
● Functional and performance cookies (these help us, for example, to evaluate technical data from your visit to ClipMyHorse.TV and thus avoid error messages)
● Advertising and analytics cookies/marketing cookies (these register your previous search, for example for riding shoes, and will accordingly show you advertisements for riding shoes when you next access our website)
You can configure, block and erase cookies in your browser settings. If you erase all cookies from our website, some functions of the website may not be displayed correctly. The Bundesamt für Sicherheit in der Informationstechnik (German Federal Office for Information Security) provides helpful information and instructions for the most common browsers: https://www.bsi-fuer-buerger.de/BSIFB/DE/Empfehlungen/EinrichtungSoftware/EinrichtungBrow
ser/Sicherheitsmassnahmen/Cookies/cookies_node.html
Data recipient
In keeping with the descriptions and purposes described above, we share your data with the following recipients that are vital for our providing our offer to you and communicating with you:
Sentry
We use the service provider Sentry (Sentry, 1501 Mariposa St #408, San Francisco, CA 94107, USA) to improve the technical stability of our service by monitoring the system stability and detecting code errors. Sentry is used exclusively for these goals and does not evaluate data for promotional purposes. Users’ data such as information on the device or time of an error are collected anonymously and erased afterwards. The data processing takes place in the USA. For more information, refer to Sentry’s privacy statement: https://sentry.io/privacy/. Consent may only be given by users over the age of 16. If you are younger, please ask your
parents or legal guardian for permission.
Google Analytics
For static analysis of how our website is used, we use the service provider Google Analytics (Google Ireland Ltd. headquartered in Gordon House Barrow Street Dublin 4 Ireland) to place cookies that permit us to analyze your surfing behavior, comparable to audience rating in television. This helps us to improve the quality of our website and contents. We learn how the website is used so that we can continuously optimize our web offer. Depending on your location, your data will either be processed in the European Union or in the USA. For more information, please refer to Google’s privacy statement. This website uses Google Analytics with the extension “_anonymizeIp()”.
As a result, IP addresses are further processed in abbreviated form, so that direct personal references can be excluded. You can find more information on the terms of use and data protection of Google Analytics at http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/.
Hotjar
This website uses Hotjar, a analysis software of Hotjar Ltd. (“Hotjar”) (http://www.hotjar.com, Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta, Europe). Hotjar allows us to measure and evaluate how users behave on our website (clicks, mouse movements, scrolling heights, etc.). The information about your visit to our website generated by the "tracking code" and "cookie" is transmitted to the Hotjar servers in Ireland and stored there.
You can prevent the collection of data by Hotjar by clicking on the following link and following the instructions: Hotjar Opt-out
With your consent, we use cookies to distribute our content on the internet, i.e. to display the content of our website on other web pages or on social media.
Google AdWords and Google Conversion Tracking
We use the online promotion program “Google AdWords” and, in the frame of Google AdWords, Conversion Tracking. Google Conversion Tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). When you click on an ad placed by Google, a Conversion Tracking cookie is placed on your computer. These cookies become invalid after 30 days, do not comprise any personal data and thus cannot be used to identify individual persons. The information collected via Conversion cookies is used to generate Conversion statistics for AdWords customers who chose to use Conversion Tracking. The customers learn the total number of users who clicked on their ad and were redirected to a website fitted with a Conversion Tracking tag. However, they will not receive any information that allows them to identify individual users.
Google Tag Manager and Google Publisher Tags
Our website uses the Google Tag Manager. The Google Tag Manager is a solution that allows marketers to manage website tags via an interface. The Google Tag Manager service triggers other tags, which in turn may collect data. Depending on your location, your data will either beprocessed in the European Union or in the USA. For more information, please refer to Google’s privacy statement.
Facebook Pixel and links to social media sites
Facebook Pixel can track the behavior of users who have been redirected to the provider’s website after having clicked on a Facebook ad. This process evaluates the efficacy of Facebook ads for statistics and market research purposes and can help to optimize future advertising measures. The data are collected anonymously and do not allow us to draw any conclusions on the users’ identity. However, Facebook saves and processes the data so that a connection to the respective user profile is possible; also, Facebook can use the data for its own promotional purposes in compliance with the Facebook regulations on use of data (https://www.facebook.com/about/privacy/). You can enable Facebook and its partners to place advertisements on and outside of Facebook. A cookie may also be stored on your computer for these purposes.
Consent to the use of visitor action Pixel may only be given by users over the age of 16. If you are younger, please ask your parents or legal guardian for permission. Please click here to revoke your consent: LINK or send an e-mail to support@clipmyhorse.tv
Our website does not use any social plug-ins. We only place a link to the respective social media website (e.g. www.facebook.com) and to our presence there.
Reviews via Trustpilot
We use the Trustpilot rating tool to receive and publish customer reviews. These reviews are on
a voluntary basis. To permit the use of Trustpilot, we will disclose your email address, your
name, your language settings and our internal booking number to Trustpilot A/S, Pilestræde 58,
5,1112 Copenhagen, Denmark. If you participate in this rating system (prior registration is
required for this), your rating will be published on our website and on the websites of Trustpilot
and its partners in accordance with Trustpilot's requirements. For reviews via the Trustpilot
review service, the terms and conditions and data protection provisions of Trustpilot apply.
Please refer to https://legal.trustpilot.com.
We process your personal data to send invitation emails for ratings on the basis of your consent
in accordance with Art. 6 para. 1 lit. a) GDPR.
We only disclose such data as are required to execute the mutual contract, or in accordance
with your consent granted for example in the frame of our Newsletter or cookie banner. If no
contract has been concluded yet, we disclose the data in certain cases in the frame of our
justified interests. This is applicable for example also when you wish to visit our website or to
contact us. When you visit our website, it is in our mutual interest to provide access to our offer
and the chance to communicate with each other.
We also concluded data processing agreements with all external recipients in order to comply
with European legal requirements. Depending on your location, some of the above-mentioned
service providers – if specified accordingly – will also transfer your data to the United States or
other third countries. The European Court of Justice decided that the United States have an
equivalent level of data protection. To meet all the requirements, we concluded additional
contracts on data processing, the so-called standard contractual clauses. Furthermore, weinvestigate every service provider in cooperation with our Data Protection Officer and ensure
that additional safety measures are available, for example powerful data encryption.
Active use of the website
In addition to the pure use of our website for information purposes, you can also actively use our
website in order to come into contact with us or to register either for the free-of-charge and
restricted services or for the fee-based and more extensive services and to use them as a
registered user. In addition to the processing of your personal data in a use for information
purposes as detailed above, we then collect and process further personal data from you which
we require for the processing of your registration, for invoicing, for the provision of the
registration-based services and, in the case of a contact enquiry, for the response to your
enquiry.
User enquiries
To handle inquiries sent to us via contact form or message to our email address and to reply to
them, we will process your personal data disclosed to us in this context. This generally includes
your first name, surname and e-mail address in order to send you a reply, as well as any other
information that you disclose to us in the frame of your message. The purpose of the data
requested is to contact you or communicate with you, which is why the data is only used for this
purpose.
Depending on the inquiry, we will process your personal data for the execution of
pre-contractual measures pursuant to Art. 6 para. 1 lit. b) GDPR or for safeguarding our
legitimate interests pursuant to Art. 6 Abs. 1 lit. f GDPR; our legitimate interest lies in the proper
replying to customers’ inquiries.
Newsletter
If you wish to subscribe to our newsletter, you need to specify the email address to which our
newsletter should be sent. For mailing our newsletter, we use the “Mailjet” service from Mailjet
(13-13bis, rue de l’Aubrac, 75012 Paris, France). In the context of this service, only the data
disclosed by you in order to receive the newsletter will be processed (e.g. email address,
surname, first name). For Mailjet’s privacy statement, refer to
https://www.mailjet.de/privacy-policy/.
Consent to the newsletter is given according to the so-called "double opt-in" procedure, i.e. first
you activate a checkbox on our site that confirms that you wish to receive the newsletter, then
you receive a confirmation email. Only clicking on the corresponding link in this confirmation
email will include you in the list of newsletter recipients.
Of course you can unsubscribe from the newsletter at any time and revoke th previously granted
consent for the future. To do this, please click on the respective button in the newsletter mailed
to you, send a email to support@ClipMyHorse.tv, or click on the button at
www.clipmyhorse.tv/newsletter/unsubscribe.
We process your personal data for the purpose of receiving the newsletter on the basis of your
consent in accordance with Art. 6 para. 1 lit. a) GDPR.
Participation in a surveyWe will process your personal data (name, email address, user history) also for the purpose of
direct marketing and to ask you every now and then on clipmyhorse.tv to participate in surveys
(e.g. on your favorite riding discipline). This includes the mailing of information on our latest
campaigns and the request to participate in surveys so that we can adjust the clipmyhorse.tv
service portfolio better to your requirements as a customer. To carry out the surveys, we use the
“Typeform” service. Your data will be processed on the basis of our legitimate interest in the
direct marketing and in the surveys pursuant to Art. 6 para. 1 lit. f) GDPR.
We will save your data as long as we have an interest in the marketing activity, or until you
object to the use of your personal data. In this case, your data will be erased or, if legal retention
periods apply, blocked for further processing. You have the right to object to the processing of
your personal data for direct marketing purposes at any time. If you object, we will no longer use
your data for direct marketing and surveys. To execute your right to object, please contact us at:
dataprivacy@clipmyhorse.tv
Log-in for using services subject to registration
Registration and provision of the services
Clipmyhorse.tv and certain free videos are available free of charge and without registration for
(limited) use. Alternatively, you can register for purchase of a fee-based access for unlimited use
of all services available on clipmyhorse.tv. By using our fee-based performance following
registration, other services and functionalities of our website will be activated for you. If you are
accessing our website from a mobile end device (e.g. tablet or smartphone), free use of
clipmyhorse.tv is possible for a limited time only; after that, you need to purchase a fee-based
access for continued use to the services.
In the context of your registration for the selected services and the rendering of our
performance, we will process the following data:
● E-mail address
● Form of address
● First name and surname
● Company if applicable
● Street address
● Additional address information if applicable
● P.O. code
● Town
● Federal state/cantonif applicable
● Country
● VAT tax ID if applicable
● Telephone no. if applicable
● Legal age
● An additional delivery address if applicable
● Bank data (IBAN, BIC, bank, account holder’s name)
We will then ask you to select the payment method and provide the relevant data, which we will process for the purpose of providing the fee-based services.Once you have fully concluded the registration and payment—which is necessary for fee- based services–has been transacted, the services selected by you will be activated and remain in this state until you cancel the services.
We process your personal data for the performance of the services requiring registration for the fulfillment of a contract or for the implementation of pre-contractual measures in accordance with Art. 6 para. 1 lit. b) GDPR.
Payment
We use the following payment service providers for payment handling:
● PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg
● Stripe Payments Europe, Limited (SPEL), 1 Grand Canal Street Lower, Grand Canal Dock Dublin, D02 H210 Ireland
● CHARGEBEE B.V., Piet Heinkade 55, 1019GM Amsterdam For payment handling, we transmit the following data:
● IBAN
● BIC
● Country
● First name, surname
For more information, please go the respective privacy statements at:
● Privacy Policy PayPal
● Privacy Policy Stripe
● Privacy Policy Chargebee
We process your personal data for the performance of the services requiring registration for the fulfillment of a contract or for the implementation of pre-contractual measures in accordance with Art. 6 para. 1 lit. b) GDPR.
Legal age
When you register for a membership account with clipmyhorse.tv, we ask you to answer the question whether you are of legal age by checking a box; we do not ask you to enter your date of birth. If you complete this mandatory step by checking the respective box, we only save the information that you are of legal age, but not your date of birth or your actual age.
We process your personal data for the performance of the services requiring registration for the fulfillment of a contract or for the implementation of pre-contractual measures in accordance with Art. 6 para. 1 lit. b) GDPR.
Playing videos and live streams and using the media library
When you use the services on clipmyhorse.tv, in particular when you watch the videos that have been activated for you, we collect data that cannot be traced back to individual users as part of the analysis tools described above, and the user profile we have created about you is enriched with the information generated by your use of the services (e.g. which videos were watched by the user, in which order, etc.). In this case, no cookies are generated. We process your personal data for the performance of the services requiring registration for the fulfillment of a contract or for the implementation of pre-contractual measures in accordance with Art. 6 para. 1 lit. b) GDPR.
Compliance with legal regulations
On our website, we use affiliate network technologies by CJ Affiliate (https://www.cj.com), a service of Conversant Europe Ltd. The legal basis for this is our legitimate interest (i.e. interest in the economically efficient operation of our online product portfolio in the meaning of Art. 6 para. 1 lit. f. GDPR). If you are redirected to our website via an advertisement from a website that is part of the affiliate network ("network"), this fact is stored in a cookie that the operator of the website places on your computer. The cookie contains a randomly generated ID (pseudonym). If you make a purchase on our website or return to the website within a certain period of time, the network partner can recognize you via the ID and assign the purchase to the network. However, the ID or information on purchases cannot be linked to you individually. We do not combine this information with other personal data and do not pass on any personal data to third parties.
If you do not want information about your behavior to be used by CJ Affiliate as explained above, you can refuse the setting of a cookie required for this – for example, by setting your browser to generally disable the automatic cookie placement – or you can delete the cookie. For details on how CJ Affiliate uses your data and your right to object, please refer to the company’s privacy statement: https://www.cj.com/legal/privacy-policy-services-de?hsLang=en
Categories of Recipients
As explained in the above descriptions and purposes, we disclose your data only to those other
recipients who perform services for us in connection with our website. Here, we limit the
disclosure of your personal data to the minimum necessary to make the services requiring
registration available for your use. In some cases, our service providers receive your personal
data as processors; as such, they are strictly bound by our instructions when handling your
personal data. In some cases, the recipients handle your data disclosed to them independently.
Below, please find the categories of the recipients of your personal data:
● Payment service providers and banks, for payment handling,
● IT service providers for administration purposes and for hosting our website (also refer to the list and description),
● Collection agencies and legal advisers, for asserting our claims. Specifically, we use the following IT service providers for the services described below:
● Zendesk For handling customer inquiries via telephone, we use the ticket system “Zendesk” by Zendesk Inc. (1019 Market St, San Francisco, CA 94103, U.S.A.). When you contact us, the data required for replying to the contact inquiry will be collected (name, first name, telephone number, email). We will use your personal data transmitted for this purpose exclusively for replying to your contact inquiry. For Zendesk Inc.’s privacy statement, refer to https://www.zendesk.de/company/customers-partners/privacy-policy/?_ga=2.91941658.1061004003.1524063401-1063456244.1524063401 .
● Unbounce
We use the “Unbounce” service from unbounce Marketing Solutions Inc. (400-401 West
Georgia Street, Vancouver BC, Canada V6B 5A1) as a host for single, smaller web
pages. When you visit these pages (“landing pages”), your browser communicates with
the service provider. Your IP address will be transmitted to this host, and cookies areplaced (for general information on cookies, refer to 3.2.1.1 above in this Privacy
Statement). For this service provider’s privacy statement, refer to
https://unbounce.com/privacy/.
TRANSFER TO THIRD COUNTRIES
We have also concluded data processing agreements with all external recipients in order to
comply with European legal requirements. Depending on your location, some of the
above-mentioned service providers – if indicated – will also transfer your data to the United
States or other third countries. The European Court of Justice decided that the United States
have an equivalent level of data protection. To meet all the requirements, we concluded
additional contracts on data processing, the so-called standard contractual clauses.
Furthermore, we investigate every service provider in cooperation with our Data Protection
Officer and ensure that additional safety measures are available, for example powerful data
encryption.
STORAGE PERIOD
USING OUR WEBSITE FOR INFORMATION PURPOSES ONLY
If you use our website exclusively for information purposes, we will save your personal data to
our servers only for the duration of your visit to our website. Your personal data will be erased
immediately after your visit. Server log files are generally stored for a period of 365 days.
Cookies installed by us will be placed for a period of 90 days and will be erased automatically
after that.
Deviating from the ninety-days storage period, to cookies listed below will be s tored for the
respectively specified storage periods:
● CookieConsent: 365 days
● _ga: 729 days
● _gads: 729 days
● _gaexp: 64 days
● IDE: 389 days
● fr: 89 days
Generally, you can erase the placed cookies at any time yourself, as described above. Your data will also be blocked or erased if a storage period prescribed by law expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.
Certain data may have to be stored for longer for legal reasons. This applies primarily to storage periods stipulated under commercial, trade, or tax law. You can of course request information about the stored data at any time.
ACTIVE USE OF THE WEBSITE
When you actively use our website, we initially store your personal data for the duration of the
response to your inquiry or for the duration of our business relationship. This also includes the
initiation of a contract (pre-contractual legal relationship) and the execution of a contract.
Then, we additionally save your personal data until any legal claims arising from the relationship
with you become statute-barred in order to use it as evidence if necessary. Usually, the limitation
period is between 12 and 36 months, but it can also be up to 30 years.We will erase your personal data when the limitation period expires, unless there is a statutory
retention obligation, for example under the German Commercial Code (Sections 238, 257 (4)
HGB) or the German Fiscal Code (Section 147 (3), (4) AO). The statutory retention obligation
may apply for two to ten years.
UPLOAD OF IMAGES TO HORSE PROFILE PAGES
I confirm that I have permission to use the uploaded photos, and they do not violate any
copyright laws. ClipMyHorse.TV does not accept responsibility for any fines arising from illegal
use. The most recent upload will replace the current profile and cover images. ClipMyHorse.TV
uses the uploaded images to present horses in an appealing way.
YOUR RIGHTS AS A DATA SUBJECT
Pursuant to the statutory requirements, you have the following rights as a data subject that you
can assert against us:
● Right to information
In accordance with Art. 15 GDPR, you are entitled at any time to obtain confirmation
from us as to whether we are processing personal data concerning you; where this is the
case, you are also entitled in accordance with Art. 15 GDPR to receive information about
this personal data and certain other information (including processing purposes,
categories of personal data, categories of recipients, envisaged storage period, your
rights, the origin of the data, the use of automated decision-making and, in the case of
third country transfer, the appropriate safeguards) and a copy of your data.
● Right to Rectification:
In accordance with Art. 16 GDPR, you have the right to obtain from us the rectification of
inaccurate personal data concerning you.
● Right to Erasure:
In accordance with Art. 17 GDPR, you have the right to obtain from us the erasure of
personal data concerning you without undue delay. The right to erasure does not apply
to the extent that processing is necessary (i) for exercising the right of freedom of
expression and information, (ii) for compliance with a legal obligation to which we are
subject (e.g. statutory retention obligations), or (iii) for the establishment, exercise or
defense of legal claims.
● Right to Restriction of Processing:
In accordance with Art. 18 GDPR, you have the right to obtain from us the restriction of
processing your personal data.
● Right to Data Portability:
In accordance with Art. 20 GDPR, you have the right to receive the personal data
concerning you which you have provided to us in a structured, commonly used and
machine-readable format.
● Right to withdraw:
You have the right to withdraw your previously granted consent to processing personal
data at any time with effect for the future.
● Right to Object:
In accordance with Art. 21 GDPR, you have the right object against the processing ofyour personal data so that we have to terminate processing your personal data. The right
to object only exists within the limits specified in Art. 21 GDPR. In addition, our interests
may conflict with the termination of processing, so that we are entitled to process your
personal data despite your objection.
Where your personal data are processed for direct marketing purposes, you have the
right to object at any time to processing of personal data concerning you for such
marketing. Where you object to processing for direct marketing purposes, the personal
data shall no longer be processed for such purposes.
● Right to lodge a complaint with a supervisory authority:
In accordance with Art. 77 GDPR, you have the right to lodge a complaint with a
supervisory authority, in particular in the Member State of your habitual residence, place
of work or place of the alleged infringement if you consider that the processing of
personal data relating to you infringes the GDPR. The right to complain exists without
prejudice to any other administrative or judicial remedy.
The supervisory authority responsible for us is:
Der Hessische Datenschutzbeauftragte
Gustav-Stresemann-Ring 1
65189 Wiesbaden, Germany
AUTOMATED DECISION-MAKING / PROFILING
We do not use automated decision-making or profiling (automated analysis of your personal
circumstances).