It’s your right to…

How?

Be informed

Be informed of the personal data we process about you and how we process it.

We inform you:

• through this Policy
• through information provided to you as you use the HAESTR Service
• by answering your specific questions and requests when you contact us

Know/Access

Request to know and access the personal data we process about you.

To request a copy of your personal data from HAESTR, please contact us

Correction

Request that we amend or update your personal data where it’s inaccurate.

You can edit your User Data under ‘Edit profile’ in your account or by contacting us.

Deletion

Request that we delete certain of your personal data.

Please note there are situations where HAESTR is unable to delete your data, for example when:

• it’s still necessary to process the data for the purpose we collected it for
• we have an overriding interest in continuing to process the data, for example where we need the data to protect our services from fraud
• HAESTR has a legal obligation to keep the data, or
• HAESTR needs the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account

There are several ways you can delete personal data from HAESTR:

• to remove content from your account select the relevant content and choose to remove it. For example, you can remove horses from your account, or remove a workout from your calendar
• to request deletion of your other personal data from HAESTR (and thus close your account), follow the steps under ‘edit profile’ inside the mobile application. This data includes your User Data, Usage Data and other data listed in Section 3 ‘Personal data we collect about you’
• you can also contact us to request deletion

Right to Opt-Out

Request to opt out of the processing of your personal data for ‘sharing’ or ‘targeted advertising’ purposes, as defined under certain privacy laws.

For more information about our processing for these purposes, see the section ‘Tailored advertising controls’ below.

There is no targeted advertising in the application, so no user has to take action to opt out. In the future when targeted advertising will be implemented, an option to opt out will be included in the user’s account settings.

Data portability

Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.

For information about how to exercise the right to portability, contact us.

Not be subject to automated decision making

Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

HAESTR does not carry out this type of automated decision making in the HAESTR Service.

Withdrawal of consent

Withdraw your consent to us collecting or using your personal data.

You can do this if HAESTR is processing your personal data solely based on your consent.

To withdraw your consent, you can:

• adjust the relevant control on HÆSTR application
• contact us

Collected when you sign up for the HAESTR Service or when you update your account

Categories

Description

User Data

Personal data that we need to create your HÆSTR account and that enables you to use the HAESTR Service.

The type of data collected and used depends on how you create your account, the country you are in, and if you use third party services to sign in. This may include your:

• profile name
• email address
• password
• phone number
• date of birth
• gender
• street address (see further details below)
• country

We receive some of this data from you e.g. from the sign up form or account page.

We also collect some of this data from your device e.g. country or region.

Street Address Data

We may ask for and process your street address for the following reasons:

• to deliver notices which are required by law
• to deliver support options
• for billing and tax administration
• to deliver physical goods or gifts which you have requested

In some cases, we may use a third party application to help you verify your address, such as Google Maps.

Collected through your use of the HAESTR Service

Categories

Description

User Data

Personal data collected and processed about you when you’re accessing or using the HAESTR Service.

There are a few types of information this includes, listed in the following sections.

Information about how you use HAESTR

Examples include:

• your actions with the HAESTR Service (including date and time), such as:
  • search queries
  • feed history
  • horses you create
  • your feed library
  • browsing history
  • account settings
  • interactions with other HAESTR users
  • your use of third party services, devices and applications in connection with the HAESTR Service

• inferences (i.e., our understanding) of your interests and preferences based on your usage of the HAESTR Service
• content you provide when participating in HAESTR promotions, such as contests or sweepstakes
• content you post to any part of the HAESTR Service. For example: images, audio, text, titles, descriptions, communications, and other types of content

Your technical data

Examples include:

• URL information
• online identifiers such as cookie data and IP addresses
• information about the devices you use such as:
  • device IDs
  • network connection type (e.g. wifi, 4G, LTE, Bluetooth)
  • provider
  • network and device performance
  • browser type
  • language
  • information enabling digital rights management
  • operating system
  • HÆSTR application version

• information which enables us to discover and connect with third party devices and applications. Examples of this information are the device name, device identifiers, brand and version. Examples of third party devices and applications are:
  • devices on your wifi network (such as speakers) which can connect to the HAESTR Service
  • devices your operating system makes available when connecting via Bluetooth, plugin, and installation
  • HAESTR partner applications to determine whether the application is installed on your device

Your general (non-precise) location

Your general location includes country, region or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency.

We need this to:

• meet geographic requirements in our agreements with the owners of content on the HAESTR Service
• deliver content and advertising that’s relevant to you

Your device sensor data

Motion-generated or orientation-generated device sensor data if needed to provide features of the HAESTR Service that require this data. This is data which your device collects about the way you move or hold your device.

Additional data you may choose to give us

Categories

Description

Payment and Purchase Data

If you make any purchases from HAESTR or sign up for a paid Service Option or a trial, we will need to process your payment data.

The exact personal data collected and used will vary depending on the payment method. It will include information such as:

• name
• date of birth
• payment method type (e.g. credit or debit card)
• if using a debit or credit card, the card type, expiration date, and certain digits of your card number. Note: For security, we never store your full card number
• ZIP/postal code
• mobile phone number
• details of your purchase and payment history

Survey and Research Data

When you respond to a survey or take part in user research, we collect and use the personal data you provide as described in the survey or research.

Third party sources that we receive your data from

Categories of third parties

Description

Data categories

Authentication partners

If you register for or log into the HAESTR Service using another service, that service will send your information to us. This information helps create your account with us.

User Data

Third party applications, services and devices you connect to your HÆSTR account

If you connect your HÆSTR account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible.

These third party apps, services or devices may include:

• social media
• devices including:
  • audio (e.g. speakers and headphones)
  • smart watches
  • heart rate sensors
  • televisions
  • mobile phones and tablets
  • automotive (e.g. cars)
  • games consoles

• services or platforms such as voice assistants or content platforms

We’ll ask your permission before we collect your information from certain third parties.

User Data

Usage Data

Technical service partners

We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g., country or region, city, state).

This makes it possible for HAESTR to provide the HAESTR Service, content, and features.

We also work with security service providers who help us protect user accounts.

User Data

Usage Data

Payment partners and Merchants

If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners.

This allows us to:

• send you invoices
• process your payment
• give you what you’ve purchased

If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to a rider’s merchandise store on a third party platform or to a third party ticketing website.

Receiving this data allows us to:

• calculate any commissions owed to us
• analyze the effectiveness of our partnership with these merchant partners
• understand your interests

Payment and Purchase Data

Advertising and marketing partners

We receive inferences from certain advertising or marketing partners. These inferences are the partners’ understanding of your interests and preferences.

This allows us to deliver more relevant ads and marketing.

Usage Data

Acquired companies

We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.

User Data

Usage Data

Purpose for processing your data

Categories of personal data used for the purpose

To provide the HAESTR Service in accordance with our contract with you.

For example, when we use your personal data to set up an account and personalize the account to make the SeeMe-function function properly. 

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data

To provide further parts of the HAESTR Service.

For example, when we use your personal data to enable you to share a link to HÆSTR content with someone else.

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data

To provide certain additional voluntary features of the HAESTR Service. When this is the case, we will clearly ask for your consent.

• User Data
• Usage Data
• Survey and Research Data
• Payment and Purchase Data

To diagnose, troubleshoot, and fix issues with the HAESTR Service.

• User Data
• Usage Data

To evaluate and develop new features, technologies, and improvements to the HAESTR Service.

For example:

• we use personal data to develop and improve our personalized recommendation algorithms
• we analyze how our users react to a particular new feature and see whether we should make any changes

• User Data
• Usage Data
• Survey and Research Data

To gather information on feeding practices, for example:

• Commonalities between different groups of people
• Commonalities in feed consumption in different geographical areas

• User Data
• Street Address Data
• Usage Data

For marketing or advertising where the law requires us to collect your consent.

For example, when we use cookies to understand your interests or the law requires consent for email marketing.

• User Data
• Usage Data
• Survey and Research Data

For other marketing, promotion and advertising purposes where the law does not require consent.

For example, when we use your personal data to tailor advertising to your interests.

• User Data
• Usage Data
• Survey and Research Data

To comply with a legal obligation that we are subject to.

This might be:

• an obligation under the law of the country / region you are in
• Norwegian law (because of our headquarters in Norway), or
• EU law that applies to us

For example, when we use your date of birth when required for age verification purposes.

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data
• Survey and Research Data

To comply with a request from law enforcement, courts, or other competent authorities.

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data
• Survey and Research Data

To fulfill contractual obligations with third parties.

For example, when we provide pseudonymized data about our users’ listening because we have an agreement with a HAESTR rightsholder to do so.

Pseudonymized data means that your data is identified by a code rather than your name or other directly identifying information.

• User Data
• Usage Data
• Payment and Purchase Data

To take appropriate action with reports of intellectual property infringement and inappropriate content.

• User Data
• Usage Data
• Payment and Purchase Data

To establish, exercise, or defend legal claims.

For example, if we are involved in litigation, we need to provide information to our lawyers in relation to that legal case.

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data
• Survey and Research Data

To conduct business planning, reporting, and forecasting.

For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.

• User Data
• Usage Data
• Payment and Purchase Data

To process your payment.

For example, when we use your personal data to let you purchase a HÆSTR subscription.

• User Data
• Payment and Purchase Data
• Street Address Data

To keep the HAESTR Service secure and to detect and prevent fraud.

For example, when we analyze Usage Data to check for fraudulent use of the HAESTR Service.

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data

To conduct research and surveys.

For example, when we contact our users to ask for your feedback.

• User Data
• Usage Data
• Survey and Research Data

Categories of recipients

Categories of data you can choose to share

Reason for choosing to share

Third party applications, services and devices you connect to your HÆSTR account

• User Data
• Usage Data

To connect your HÆSTR account, or so that you can use the HAESTR Service in connection with third party applications, services or devices.

Examples of such third party applications, services and devices include:

• social media applications
• speaker devices
• smart watches
• heart rate monitors
• televisions
• automotive platforms
• voice assistants

You can see and remove many third party connections under ‘Apps’ in your Apple or Google account.

Other HÆSTR users

• User Data
• Usage Data

To share information about your use of the HAESTR Service with other HÆSTR users. These could include your followers on HÆSTR .

Categories of recipients

Categories of data

Reason for disclosing

Service providers

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data
• Survey and Research Data

So they can provide their services to HAESTR.

These service providers include those we hire to:

• give customer support
• operate the technical infrastructure we need to provide the HAESTR Service
• assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)
• help market HAESTR’s (and our partner’s) products, services, events and promotions
• verify your eligibility for certain types of Service Options

Payment partners

• User Data
• Payment and Purchase Data

So they can process your payments, and for anti-fraud purposes.

Advertising partners

• User Data
• Usage Data

So they can help us deliver more relevant advertising to you on the HAESTR Service, and help measure the effectiveness of ads.

For example, our ad partners help us facilitate tailored advertising.

With respect to HAESTR Service users under the age of 16, we do not disclose personal data to advertising partners by default.

Marketing Partners

• User Data
• Usage Data

To promote HAESTR with our partners. We disclose certain User Data and Usage Data to these partners where necessary to:

• enable you to participate in HAESTR promotions, including trials or other bundled offers
• to promote HAESTR in media and advertising published on other online services
• help us and our partners to measure the effectiveness of HAESTR promotions

Examples of partners include:

• marketing or sponsorship partners
• websites and mobile apps who sell us advertising space on their services
• device, app and mobile partners who also offer HAESTR promotions

Our partners may also combine the personal data we disclose to them with other data they collect about you, e.g. your use of their services. We and our partners may use this information to present you with offers, promotions, or other marketing that we think you’ll find relevant.

With respect to HAESTR Service users under the age of 16, we do not disclose personal data to marketing partners by default.

Ticketing and event partners

• User Data

For every event for which we sell tickets, we will need to disclose your name, email or other order details to our event partners such as ticketing agent or venue box office where the event is taking place so that you can check-in as a verifiable guest who purchased tickets through HAESTR’s ticketing platform.

Academic researchers

• User Data
• Usage Data

For activities such as statistical analysis and academic study, but only in a pseudonymized format.

Other HAESTR group companies, including companies that HAESTR acquires

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data
• Survey and Research Data

To carry out our daily business operations and so we can maintain, improve and provide the HAESTR Service and acquired companies’ services to you.

For example:

• enabling our employees who work for different group companies to develop and improve features for the HAESTR Service
• disclosing data to our measurement companies to measure the effectiveness of ad campaigns that run on the HAESTR Service
• disclosing data to our partner companies to better understand user trends

Law enforcement and other authorities, or other parties to litigation

• User Data
• Usage Data

When we believe in good faith it’s necessary for us to do so, for example:

• to comply with a legal obligation
• to respond to a valid legal process (such as a search warrant, court order, or subpoena)
• for our own or a third party’s justifiable interest, relating to:
  • national security
  • law enforcement
  • litigation (a court case)
  • criminal investigation
  • protecting someone’s safety
  • preventing death or imminent bodily harm

Purchasers of our business

• User Data
• Street Address Data
• Usage Data
• Payment and Purchase Data
• Survey and Research Data

If we were to sell or negotiate to sell our business to a buyer or possible buyer.

In this case, we may transfer your personal data to a successor or affiliate as part of that transaction.