1. Who we are
The Thoroughbred is operated by Diablo Aquila Ltd, a private limited company registered in England and Wales under company number 17010899. Our registered office is 12 Rosehip Lane, Tunbridge Wells, United Kingdom, TN2 3XU.
Diablo Aquila Ltd is the controller of the personal information described in this notice. Privacy enquiries and data-protection requests can be sent to support@thethoroughbred.co.uk.
2. What this notice covers
This notice applies to The Thoroughbred public website and mobile application, including the invite-only Android beta, registered accounts and account-linked features made available through the service such as Free features, My Stable, Race Days, Wallet, notifications and racing research. It also applies to The Thoroughbred Elite where and when that service is offered.
When you follow a link to a third-party website, racecourse, retailer, travel provider, Apple App Store, Google Play or another external service, that third party may process information under its own privacy terms.
3. Information we process
Depending on how you use The Thoroughbred, we may process the following information.
Account and profile information
If you create a registered account, this can include your email address, account identifier, authentication and session information, display name, account status and information you choose to add to your profile. It can also include age band, racing-knowledge level, racing-code preferences, optional coarse departure-area information and your marketing choice where those features are used.
Authentication credentials are handled through our authentication infrastructure. We do not need access to your password in readable form.
Information you save in the product
Registered-account features can store information you choose to save, such as followed horses, trainers or jockeys; lists, tags, notes and alert preferences; Race Day plans; travel, accommodation and itinerary information; Wallet booking metadata and documents you choose to upload; notification read state; and, where offered, private Elite organisation and research information.
Please avoid placing unnecessary highly sensitive information in free-text notes or uploaded documents.
Device, app and notification information
To operate and secure the mobile app we may process limited technical information such as app version, operating system, platform, installation or device-related identifiers, request and error information and security or diagnostic records.
If you choose to enable push notifications, we process a device installation identifier, push-notification token, platform, notification preferences and delivery-related information needed to send and manage those notifications. Push notification delivery uses Expo and the relevant Apple or Google notification service.
The core service does not require precise GPS location. You may save a coarse departure area for Race Day planning and nearby-racecourse discovery. In Discover, you may also choose Use current location. Only after you choose that option does the app request foreground device-location permission. The coordinates returned by your device are used transiently to calculate which racecourses are near you and are not saved to your Thoroughbred account. You can use your saved coarse area instead, and device-location permission can be refused or changed in your operating-system settings.
Elite subscription information
Elite is not currently offered for purchase. If Elite is offered in future and you start, restore or hold a subscription, we process the information needed to administer access. This can include your Thoroughbred account identifier, the relevant app store, subscription product or package identifier, purchase and renewal status, entitlement status, cancellation or expiry state, billing-retry or grace status where reported by the store, revocation or refund state and transaction-related identifiers supplied through the subscription infrastructure.
Apple App Store or Google Play processes the store transaction and payment method. The Thoroughbred does not receive or store your full Apple or Google payment-card details.
If Elite subscriptions are introduced using a specialist subscription or entitlement provider, that provider may receive an app-user identifier linked to your Thoroughbred account and the purchase/subscription information needed to track and reconcile entitlement status. Any provider introduced for this purpose will be reflected in this notice before live processing begins.
Website, launch-list and contact information
If a launch or product-updates list remains available, we may process the email address you submit, signup source, time of consent and limited anti-abuse information. If you contact us by email, we process the information you provide so we can respond and maintain an appropriate business record.
Website and service logs
Our hosting, database and delivery providers may process routine technical data needed to provide and protect the service, such as IP address, browser or device information, requested pages or endpoints, timestamps, response status and security or diagnostic logs.
4. Why we use personal information and our lawful bases
We use personal information only where we have an appropriate lawful basis. Depending on the processing, this includes:
- Providing an account and the requested product features: performance of our contract with you or steps taken at your request before entering into that contract.
- Saving your private preferences, plans, follows, notes, Wallet information and other account-linked data: performance of the service you have requested and our legitimate interests in providing a useful, reliable account experience.
- Providing and verifying Elite access if offered: performance of our contract with you and our legitimate interests in preventing entitlement errors, misuse and fraud.
- Operating, securing, debugging and protecting the website and app: our legitimate interests in running a secure and reliable service and protecting users, our systems and our rights.
- Push notifications you choose to enable: providing the notification feature you request and our legitimate interests in delivering relevant service alerts. Your device permission can be changed through the app or operating-system settings.
- Direct marketing or launch communications where consent is required: your consent. You can withdraw that consent at any time without affecting earlier lawful processing.
- Responding to business, support or other enquiries: our legitimate interests in responding to people who contact us and, where relevant, steps requested before entering into a contract.
- Legal, regulatory, fraud-prevention and claims purposes: compliance with legal obligations and, where appropriate, our legitimate interests in establishing, exercising or defending legal rights.
We do not use the current service to make solely automated decisions about you that produce legal or similarly significant effects.
5. Free and Elite subscription processing
The core Thoroughbred service is not currently charging for Elite. Elite is planned as a separate optional paid service and is not currently offered for purchase.
If Elite subscriptions are introduced through the mobile app, purchases will be processed through the Apple App Store or Google Play. Those stores manage the payment transaction, renewal and store-account billing relationship under their own terms and privacy information.
If Elite launches with a specialist subscription or entitlement provider, that provider may receive and reconcile store subscription information and help determine whether an authenticated Thoroughbred account has a valid entitlement. A successful store transaction would not require us to receive your full card details, and store billing would remain separate from your Thoroughbred account.
7. International transfers
Some service providers may process information outside the United Kingdom, including in the United States. Where UK data-protection law treats a transfer as a restricted transfer, we rely on an applicable UK adequacy regulation or recognised safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another lawful transfer mechanism, as appropriate.
You can contact us for more information about safeguards relevant to your information.
8. Younger users
The Thoroughbred is a racing-information product and is designed with a high-privacy approach for younger users.
Users under 13 are not permitted to create a registered Thoroughbred account; the current product boundary provides guest access instead. Users aged 13–17 may use a registered account subject to the age-appropriate controls applied to the service.
For 13–17 users, we do not require a real name or full home address, we do not use the account for behavioural advertising or gambling targeting, and account-linked personal information is private by default except where a feature is expressly designed to show a pseudonymous public result or similar limited public output.
Elite is planned as a racing-analysis and research service. It is not a bookmaker, does not accept bets and is not designed to profile younger users for gambling products.
If you are under 18 and do not understand this notice, ask a parent, guardian or trusted adult to read it with you. A parent or guardian can contact us at support@thethoroughbred.co.uk with a privacy question.
9. How long we keep information
We keep personal information only for as long as reasonably necessary for the purpose for which it is used.
Account and account-linked product data is normally kept while the account remains active. Where applicable, subscription state and entitlement records are kept for as long as needed to administer the subscription, reconcile access, handle disputes, prevent fraud and meet applicable legal obligations. Contact correspondence and security records are retained according to the nature of the enquiry or incident and any legitimate record-keeping requirement.
Marketing-list information is retained until you withdraw consent, unsubscribe or the purpose of the list has ended, subject to keeping a minimal suppression record where necessary to respect an opt-out.
After account deletion, limited information may be retained where genuinely required for security, fraud prevention, legal compliance, accounting, dispute resolution or the establishment, exercise or defence of legal claims. Any such retention is limited to what is necessary for that purpose.
Apple, Google and other independent services may retain store-account, transaction or other information under their own legal obligations and retention policies. Deleting a Thoroughbred account does not delete your Apple ID or Google account.
10. Deleting your Thoroughbred account
Registered users can permanently delete their account from within the mobile app through the Account area. Users who cannot access the app can use the public Account Deletion route or contact support@thethoroughbred.co.uk from the email address associated with the account. We may need to verify identity before acting on an external request.
When a Thoroughbred account deletion is completed, we delete the authentication account and account-linked personal data under our control that is no longer required, including private account/profile information and private saved product data. The deletion workflow also removes private Wallet documents associated with the account.
Elite is not currently available for purchase. If app-store subscriptions are introduced in future, deleting a The Thoroughbred account will not by itself cancel Apple App Store or Google Play billing. Store subscriptions must be managed through the store account that purchased them.
If future subscription infrastructure holds account-linked entitlement data, that information will be handled in accordance with this notice, applicable retention requirements and the relevant provider arrangements in force at that time.
11. Your data-protection rights
Depending on the circumstances, UK data-protection law may give you rights to request access to your personal information, correction, deletion, restriction, portability or to object to certain processing.
Where we rely on legitimate interests, you have the right to object to that processing. We will stop the relevant processing unless we have compelling legitimate grounds to continue or the information is needed for the establishment, exercise or defence of legal claims.
Where processing is based on consent, you can withdraw that consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
To exercise a right, contact support@thethoroughbred.co.uk. We may need to verify your identity.
You also have the right to raise a concern with the UK Information Commissioner's Office (ICO) at ico.org.uk.
13. Security
We use technical and organisational measures designed to protect personal information, including authenticated access controls, server-side authorization, private storage controls and encrypted network connections. No internet service can guarantee absolute security, but we design the product so private account information is not intentionally exposed as public data.
14. Changes and contact
We may update this notice when The Thoroughbred, Elite, our providers or our legal obligations change. The date at the top identifies the current version.
Company no. 17010899
12 Rosehip Lane
Tunbridge Wells
United Kingdom
TN2 3XU