PRIVACY POLICY
Kingsmoor Holdings Limited (“Kingsmoor”, “we” or “us”) takes the privacy of your personal information seriously as your privacy is important to us. This privacy policy (“Privacy Policy”) explains what personal information we collect from you, through our interactions with you on this website, and how we use that personal information.
The Privacy Policy applies to this website (“Website”). By providing your consent to this Privacy Policy in the manner prescribed below, you indicate that you understand, agree and consent to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use this Website and any content, services or products contained in or available from this Website for which you need to provide personal information. You further agree that such collection, use, storage and transfer of the Data shall not cause any loss or wrongful gain to you or any other person.
- Definitions
In this Privacy Policy, the following definitions are used:
1.1 “Data” means any information that relates to an identified or identifiable natural person, including but not limited to personal information you submit to Kingsmoor via the Website or services, or that we collect automatically. This may include, where applicable and as defined by relevant laws in the United Kingdom or your jurisdiction.
1.2 “Cookies” is a small file placed on your computer by this Website when you either visit, or use certain features of, the Website. A cookie generally allows the website to “remember” your actions or preference for a certain period of time.
1.3 “User” or “you” or “your” means the natural person who accesses the Website.
2. Data Collected
We may collect the following categories of Data or pieces of Data that could allow you to be identified, including:
(a) your name;
(b) email address;
(c) address;
(d) PIN code or postal/ZIP code;
(e) credit card or debit card details;
(f) password, your occupation, interests, and any other information that you voluntarily provide during your interaction with the Website;
(g) government issued identification (Passport or international equivalents, as permitted under applicable law);
(h) location, IP address, browser/device type; and
(i) information collected through cookies and analytics tools, including website usage patterns.
3. Manner of collection of Data
We collect Data in the following ways:
(a) Data is given to us by you when you access, register for, or interact with any Kingsmoor Services (online or offline);
(b) Cookies, server logs;
(c) Data is collected automatically pursuant to your visit to the Website; and
(d) Third-party integrations such as payment gateways or service providers (subject to appropriate contractual safeguards and applicable law).
4. Manner shared by you
Kingsmoor may collect your Data in several ways from your use of the Website. For instance:
(a) when you contact us through the Website (through any form, e-mail address, hyperlink or social media address posted therein);
(b) when you register with us for our membership programs, attend Kingsmoor events, or sign up for newsletters;
(c) when you fill out surveys, feedback forms, or participate in competitions or promotional offers;
(d) when you enter a competition or promotion;
(e) when you elect to receive any communications (including any newsletter, promotional offers) from us;
(f) through website interaction logs and session analytics when you browse our webpages.
5. Data that is Collected Automatically
(a) We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address and the way you use and interact with its content.
(b) Our web servers or authorised service providers who provide analytics and performance enhancement services collect IP address, operating system details, browsing details, device details and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed and similar information. Kingsmoor uses this information to measure the site usage, improve content and to ensure safety and security, as well enhance performance of the Website.
(c) We may collect your Data automatically via Cookies, in line with the cookie settings on your browser.
(d) For more information about Cookies, please see the section below, titled ‘Cookies’.
6. Our Use of Data
6.1. Any or all the above Data may be required by us from time to time to provide information relating to Kingsmoor and to work on the experience when using the Website. Specifically, Data may be used by us for the following reasons:
(a) providing you with the services, products and privileges for which you have subscribed including digital content, event access, exclusive offers, and merchandise purchases;
(b) improvement of the Website, our products or services, as well as those of Kingsmoor’s affiliates or subsidiaries in other jurisdictions;
(c) contact for survey or feedback;
(d) to enable our group entities and authorised representatives to reach out to you in relation to their programmes;
(e) to process your requests (such as replying to your queries);
(f) administering or otherwise carrying out our obligations in relation to any agreement you have with us;
(g) internal record keeping; and
(h) to execute other activities promotional activities or communications for which consent is taken appropriately.
6.2 If you make payments to Kingsmoor via any bank account specified by us, we may be required to retain certain personal information (including your name, address, nationality, and other KYC details) in order to comply with applicable banking and customer due diligence obligations. This is in addition to any verification mandated under applicable data protection or financial laws. Your data will be collected and processed with due safeguards in accordance with the data protection regulations in jurisdictions where Kingsmoor operates.
6.3 By attending Kingsmoor events (online or in-person), you acknowledge and agree that you may be photographed, filmed, or recorded. These images or recording may be used by Kingsmoor and its affiliates for promotional, informational, or commercial purposes in print, digital, or social formats. If you do not wish to be included in such materials, you should not attend the event. By attending, you waive any rights or claims to media usage, including rights to inspect, approve, or receive compensation. If you wish to object to such use after the event, you may contact the Grievance Officer, and we will assess reasonable take-down or redaction requests where feasible.
6.4 We may use your Data for the above purposes if we deem it necessary to do so for our legitimate business interests in compliance with applicable law. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below). We may use your Data to show you advertisements and other content on other websites. If you do not want us to use your Data to show you advertisements and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).
7. Who we share Data with
7.1 We may share your Data with:
(a) Our affiliates, group companies, and Kingsmoor controlled subsidiaries in the United Kingdom or other jurisdictions, to assist them to reach out to you in relation to their programs and to process your query / requests (such as job application);
(b) Our employees, vendors, agents, marketing partners, consultants and professional advisors working on our behalf for the purposes described in this policy statement; and
(c) Service-providers who assist in protecting and securing our systems and provide services to us which require the processing of Data, such as to host your Data or to process your Data for data profiling and user analysis.
We usually do not share your Data collected from the Website with other third parties, unless necessary and permitted under applicable laws.
7.2 In case you are a Kingsmoor Club Member, we may share your personal data with Turf Clubs, Racing Authorities or similar organisations globally. This is essential to enable your access to certain Member benefits, including entry, registration, or participation in events at racetracks or similar venues. Such sharing is conducted in compliance with applicable data protection laws, This does not apply to Kingsmoor World Members.
7.3 However, we may share your Data collected from the Website with other third parties if:
(a) You request or authorize us to do so;
(b) We need to comply with applicable law or respond to valid legal process; or
(c) We need to operate and maintain the security of this website, including to prevent or stop an attack.
8. Keeping Data secure
We will use technical and organisational measures to safeguard your Data and we store your Data on secure servers. Technical and organisational measures include measures to deal with any suspected data breach.
9. Retention of Personal Data
Kingsmoor retains Data for as long as necessary to provide the access to and use of the Website, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly. Data may be retained and processed in accordance with applicable data retention laws in the relevant jurisdiction, and may persist on backup or archival media for audit, legal, tax or regulatory purposes even after it is removed by Kingsmoor.
10. Your Rights
When we process Data about you, we do so with your consent and/or as necessary to provide the Website for your access, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of Kingsmoor as described in the Privacy Policy. We deny all liability and responsibility for the authenticity of the Data provided by you to us. However, you have the right to review and correct, update and/or amend the Sensitive Personal Data or Information provided to us previously for it to be accurate, complete and up to date. Further, you also have a right to withdraw consent for the Sensitive Personal Data or Information you provide to us. However, please note that in a situation where you deny consent or withdraw consent, or provide inaccurate information, you may not be able to avail the entire scope of our services, and in such instance, we reserve the right to not provide you access to our services or any part thereof. Depending on your jurisdiction (for example, the United Kingdom or the European Union), you may also have additional rights such as the right to data portability, the right to object to processing, and the right to lodge a complaint with a supervisory authority. You may exercise the rights mentioned in the Privacy Policy by writing to the Grievance Officer whose details have been set out below.
11. Security of Personal Data
Kingsmoor is committed to protecting the security of your Data. We use a variety of security technologies, encryption protocols and procedures to help protect your Data from unauthorized access, use or disclosure. We regularly review our security practices to ensure a level of protection appropriate to the nature of the Data and the risks associated with its processing.
12. Links to other websites
The Website may, from time to time, provide links to third party websites. We have no control over such websites and are not responsible for the content, privacy policies and practices of these websites. This Privacy Policy does not extend to your use of such third party websites. You are advised to read the privacy policy or statement of other websites prior to using them.
13. Collection and Use of Non-Personal Information
We may also collect and use non-personal information provided to this Website, such as automatically collected information about the type of internet browsers you use or the website from which you linked to our Website, and aggregated information based on data that you have submitted to the Website (such as age, gender, and residency) from which you cannot be identified, for the purposes of assisting us in providing an effective service on this Website. This data helps us better understand Member behaviour, preferences, and geographic distribution in a de-identified manner. We may from time to time supply third parties with this non-personal or aggregated data for uses in connection with this Website.
14. Cross-border Transfers
Kingsmoor may transfer your Data across international borders to jurisdictions where Kingsmoor or its affiliates, group entities, or trusted service providers operate. Such transfers will be carried out in compliance with globally accepted data protection principles, including the United Kingdom General Data Protection Regulation (UK GDPR), where applicable.
15. Cookies
(a) This Website may place and access certain Cookies on your computer. Kingsmoor uses Cookies to improve your experience of using the Website;
(b) Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended;
(c) You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser;
(d) You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings;
(e) It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
16. General
If any court or competent authority finds that any provision of the Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected. Any waiver of rights under this Privacy Policy must be in writing and shall not be deemed a continuing waiver of such rights unless expressly stated.
17. Changes to this Privacy Statement
17.1 Kingsmoor reserves the right to change, modify, or update this Privacy Policy from time to time to reflect changes in applicable law, technology, or business operations.
17.2 Any changes will be effective upon posting the revised version on the Website, with an updated revision date. We encourage you to review this Privacy Policy periodically. Your continued use of the Website following any such changes constitutes your deemed acceptance of the updated Privacy Policy.
18. Grievance Redressal
Any complaints, abuse or concerns with regards to content and or comment or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to “Grievance Officer”. We will make reasonable efforts to address your concerns and respond to your requests in a timely manner.
Grievance Officer
[James O’Donnell]
Email: hello@kingsmoor.com
By entering this website and clicking the “I accept” button (where available), you consent to the terms of this Privacy Policy.
