Privacy policy

1. What this privacy policy governs.

This privacy policy (hereinafter — the Policy) shall apply to all information, including personal data within the meaning of applicable law (hereinafter — «Personal information»), which Marketnet Technologies - FZCO and/or its affiliates (hereinafter — "Booking Administrator"), may receive about you, while using the service for searching and booking crafted tours (hereinafter — «the Service»), the details of which you can find on the website https://horseridingtours.com/ (hereinafter — «the Website»), as well as when executing Booking Administrator and its affiliates of any agreements and contracts entered into with you on the use of the Service.

2. Who processes the information.

To ensure your use of the Website and the Service, your Personal information shall be collected and used by Marketnet Technologies - FZCO, registered under the laws of United Arab Emirates at the following legal address: Dubai Silicon Oasis, Dubai Digital Park, IFZA Dubai Building A1 – Dubai 342001 UAE, Registration number DSO-FZCO-17046, License number 18482 (hereinafter – "Booking Administrator").

3. What is the purpose of this Policy.

Protection of your Personal information and your privacy is of the utmost importance to Booking Administrator. Therefore, when using the Website and the Service, Booking Administrator shall protect and process your Personal information in strict accordance with applicable law.

In keeping with our responsibility to protect your Personal information, we would like to be as transparent as possible in this Policy about the following points:

• why and how Booking Administrator uses (“processes”) your Personal information when you use the Website and/or Service;
• what is the role and responsibilities of Booking Administrator as the legal entity deciding why and how to process your Personal information;
• what tools you can use to reduce the amount of your Personal information Booking Administrator collects;
• what are your rights in relation to the processing of Personal information.

4. Your Personal information Booking Administrator collects.

Booking Administrator shall not verify the Personal information you provide and cannot judge its accuracy or whether you have sufficient legal capacity to provide your Personal information. However, Booking Administrator expects you to provide accurate and sufficient Personal information and keep it up to date.

Booking Administrator may collect the following categories of your Personal information during your use of the Website and Service:

• Personal information provided by you when registering (creating an account) or interacting with Booking Administrator via a phone conversation, such as your name, phone number, email address, social media account addresses, address, age and identity document details, as well as any other information necessary for the quality provision of services and the purposes specified in clause 5; if it is technically possible, the conversation between the operator and the user might be recorded;
• electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information);
• information about you that we receive from our Partners under the terms of the agreements concluded between you and the relevant Partner, and agreements concluded between Booking Administrator and the Partner;
• information about interaction with the Service, employees and affiliates of Horse Tours Club, including audio recordings of phone conversations when using the Service.

Booking Administrator also uses cookies and web beacons (including pixel tags) to collect Personal information and associate it with your device and web browser (see section 11 of this Policy).

5. What is the legal basis and purposes of processing your Personal information.

Booking Administrator may not process your Personal information without sufficient legal grounds. Therefore, Booking Administrator shall only process your Personal information if:

• processing is necessary to fulfill Booking Administrator contractual obligations to you, including the operation of the Website and Service;
• processing is required to comply with legal obligations;
• when required by applicable law, the processing is necessary for the legitimate interests of Booking Administrator if such processing does not significantly affect your interests, your fundamental rights and freedoms. Please, note that when processing your personal information on this basis, Booking Administrator shall always strive to keep a balance between its legitimate interests and the protection of your privacy;
• for specific purposes, we may request your separate consent to process your Personal information.

Booking Administrator shall always process your Personal information for specific purposes and only the Personal information that is relevant to achieve such purposes. In particular, we process your Personal information for the following purposes:

• providing you with access to the Website;
• communicating with you to send you notices, requests and information related to Website operation, to fulfill agreements with you and to process your requests and applications;
• providing advertisements and offers based on Personal information about you available to Booking Administrator;
• protection of your rights and the rights of Booking Administrator;
• collecting, processing and presenting statistical data.

6. How Booking Administrator protects your personal information.

In most cases, Personal information is processed automatically without access to it by any of the Booking Administrator employees. Should such access be required, it may only be granted to those Booking Administrator employees who need it to perform their tasks. To protect and keep data privacy, all employees shall comply with internal policies and procedures for processing Personal information. They shall also follow all technical and organizational security measures in place to protect your Personal information.

Booking Administrator has also implemented sufficient technical and organizational measures to protect Personal information from unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access, and other unlawful forms of processing. These security measures have been implemented regarding the state of the art, the cost of their implementation, the risks related to the processing and nature of Personal information.

7. Who else has access to your Personal information and to whom it may be shared.

Booking Administrator may share information about you with its employees and affiliates within the Booking Administrator group for the purposes specified in section 5 of this Policy;

Booking Administrator may also transfer Personal information to third parties to achieve the purposes specified in section 5 of this Policy. Such third parties may include:

• Partners, such as website and application owners, advertisement networks and other partners providing Booking Administrator services related to the placement and display of ads on websites, programs, products or services owned or controlled by such partners;
• advertisers or other Partners displaying ads for you on the Booking Administrator website, as well as Partners such as information service providers or consultants.

Booking Administrator may also transfer Personal information to third parties outside the Booking Administrator group:

• third parties, in respect of which the assignment of rights or obligations has been made, or novation under the relevant agreement;
• to any national and/or international regulatory body, law enforcement, central or local executive authorities, other official or state bodies or courts in respect of which Horse Tours Club is required to provide information under applicable law upon request;
• to third parties, if you have expressed your consent to the transfer of your Personal information or of the transfer of Personal information is required in order to fulfill a certain agreement or contract with you.

If a third party that received personal data under this Privacy policy does not take sufficient measures to protect them, and, as a result, personal data was used by it or other persons for personal purposes or for purposes not provided for in this Privacy policy, as well as for purposes not stipulated by the agreement between Booking Administrator and a third party, Booking Administrator shall be entitled to recover damages from that third party.

8. Where is your Personal information stored and processed?

Your Personal information will be stored and processed in United Arab Emirates. By processing Booking Administrator means recording, systematizing, accumulating, clarifying (updating, changing), extracting personal data of the users.

9. How long do we keep your Personal information.

Booking Administrator shall keep your Personal information for as long as necessary to fulfill the purpose it was collected for or to comply with legal and regulatory requirements.

If you wish to have any part of your Personal information removed from Booking Administrator databases, you may delete the required Personal information from your account.

10. Your rights.

1. What rights do you have.

   When required by applicable law, you may access your Personal information processed by Booking Administrator under this Policy.

   If you believe that any of your information, kept by Booking Administrator, is incorrect or incomplete, you may log in to your account and correct your Personal information yourself.

   If this is provided for by applicable law, you have the right to:

   • request the removal of your Personal information;
   • require restrictions on the processing of your Personal information;
   • object to the processing of your Personal information, if this is provided for by applicable law;
   • Booking Administrator shall comply with these requests under applicable law.

   In cases provided for by applicable law, you may also have other rights not specified above.

2. How can you exercise your rights.

   To exercise the above rights, please, log in to your account, and if there is no special interface function, contact Booking Administrator.

   If you are not satisfied with the way Booking Administrator processes your Personal information, please, let us know and we will consider your complaint. If you are not satisfied with Booking Administrator response, you may file a complaint with the competent authority.

11. How do we use cookies and other similar technologies on the Website or when you use the Service.

1. What are cookies and what does Booking Administrator use them for?

   Cookies are small text files placed on the device that you use to access the Website. They contain information that is collected on your device and sent back to the Website each time you visit it to remember your actions and preferences after time.

   The Website uses the following types of cookies:

   • strictly necessary cookies/technical cookies: these cookies are essential for Website operation and Service provision to you; among other things, they allow Booking Administrator to identify your hardware and software, including your browser type;
   • statistical/analytical cookies: these cookies allow recognizing users, counting their number and collecting information such as your activities on the Website, including information about the web pages you visit and the content you receive;
   • technical cookies: these cookies collect information about how users interact with the Website, which allows identifying errors and testing new features to improve the performance of the Website and Service;
   • functional cookies: these cookies allow certain features to be provided to facilitate your use of the Website, for example, by storing your preferences (such as language and location);
   • (third-party) tracking files/advertising cookies: these cookies collect information about users, traffic sources, pages visited and advertisements displayed to you, as well as the one that led you to the advertised page. They allow displaying ads that may interest you based on the analysis of your Personal information collected. They are also used for statistical and research purposes.

2. How long are cookies stored on your device.

   Booking Administrator uses the information from cookies only for the purposes described above, after which the collected data will be stored on your device for a period that may depend on the type of cookies, but not exceeding the period necessary to achieve their purpose, after which they will be automatically removed from your system.

3. Who else has access to the information contained in cookies.

   Personal information collected from cookies on your device may be transferred to and available to Booking Administrator and/or third parties specified in section 7 of this Policy. The use of Personal information outside the Website for advertising purposes, if any, may be subject to separate user agreements available on third-party websites. Booking Administrator and/or third parties may also provide you with the opportunity to opt out of receiving personalized advertising, which may be subject to the laws and regulations applicable to such products and offers.

   The first time you visit the Website, your consent to the use of cookies may be requested. If, after you have approved the use of cookies, you want to change your mind, you can do this by deleting the cookies stored in your browser (this can usually be done in the browser settings - please, refer to the browser manual or the website of its developer). After that, a pop-up window asking for your consent may be displayed again, and you will be able to make a different choice. If you refuse to use cookies, this may result in some Website features not being available to you and may affect your ability to use the Website. You may also change your browser settings to accept or decline by default all cookies or cookies from certain websites, including the Booking Administrator website.

   Booking Administrator may also use web beacons (pixel tags) to access cookies previously on your device for the following purposes:

   • determining your actions on the Website and when using the Service by accessing and using cookies stored on your device;
   • collecting statistical information related to the performance of the Website or Service.

12. Updating this Policy.

This Policy may be amended. Booking Administrator may make changes at its sole discretion, including, but not limited to, in cases where the changes are related to applicable law, as well as when the changes are related to the operation of the Website and Service.

Booking Administrator shall not make significant changes, not impose additional encumbrances or restrictions on your rights established by this Policy without notice to you. You will be notified of such changes. Relevant notifications can be displayed on the Website (for example, through a pop-up window or banner) before such changes take effect, or they may be sent to you via other communication channels (for example, by email if you have provided us with your contact details).