PRIVACY POLICY

1. Our commitment to privacy

Thoroughbred Derivatives Australia (TDA) respects the privacy of its members, horse owners, breeders, applicants and website users.

This Privacy Policy explains how TDA collects, holds, uses, discloses and protects personal information in connection with the TDA Studbook, website, member portal, registration services and related activities.

TDA seeks to handle personal information responsibly and, where applicable, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

2. Information we may collect

Depending on how you interact with TDA, we may collect information including:

• your name;
• postal or residential address;
• email address;
• telephone number;
• date of birth where reasonably required;
• TDA account and membership details;
• breeder or stud information;
• information relating to horse ownership or co-ownership;
• registration applications and supporting documentation;
• ownership-transfer information;
• pedigree, breeding and service information submitted to the registry;
• DNA, parentage and other horse verification documentation;
• competition or performance information;
• correspondence with TDA;
• payment and transaction information;
• refund or certificate-replacement requests;
• records of consents and preferences;
• technical information relating to your use of the TDA website and member portal; and
• other information reasonably required to administer the TDA Studbook and associated services.

TDA does not need to store complete payment-card details where payment is processed through an external payment provider.

3. How we collect information

TDA may collect personal information when you:

• create a TDA account;
• purchase or renew a membership;
• register a horse or foal;
• apply to become a registered breeder;
• submit ownership, breeding, pedigree, DNA or performance information;
• transfer ownership;
• submit evidence or supporting documentation;
• purchase a certificate, replacement, directory listing or other TDA service;
• contact TDA;
• submit an enquiry, complaint or dispute;
• use the TDA website or member portal; or
• otherwise provide information to TDA.

Information may also be provided by another person where reasonably necessary for registry administration, such as a co-owner, breeder, previous owner or authorised representative.

4. Why TDA collects and uses information

TDA may collect, hold and use information for purposes including:

• establishing and administering member accounts;
• managing TDA memberships;
• processing horse and foal registrations;
• maintaining the TDA Studbook;
• assessing registration eligibility;
• verifying ownership, ancestry, pedigree and supporting evidence;
• administering DNA and parentage evidence;
• maintaining breeder and stallion directory services;
• recording horse performance;
• processing ownership transfers and disputes;
• issuing and verifying registration certificates;
• administering payments, refunds and replacement requests;
• communicating with members and applicants;
• preventing fraud, misuse and duplicate or inaccurate registry records;
• maintaining audit and historical records;
• improving TDA's services and website;
• meeting legal and regulatory obligations; and
• protecting the integrity of the TDA Studbook.

5. Public registry information

TDA operates a public horse registry.

Certain information relating to a registered horse may therefore be publicly accessible, including registered name, TDA registration number or identifier, registration category, original registration number where applicable, date of birth or foaling information, sex, colour, verified Thoroughbred percentage, pedigree information, verification status, performance records, progeny information, registration status, and QR or other registry-verification information.

Information displayed publicly may change as records are verified or corrected. Historical information may continue to be retained internally even where it is no longer displayed as the current public record.

Personal contact information will not be made public merely because a person owns or registers a horse unless the person has consented to its publication or another lawful basis applies.

6. Breeder and directory information

Where a breeder, stud or stallion directory service is intended to be public, information specifically provided or approved for public display may be published.

This may include a breeder/stud name, region, website, approved contact details and other directory information. TDA may provide controls or seek approval before certain personal contact details are publicly displayed.

7. Payments

Payments may be processed by third-party payment providers.

TDA may receive and retain transaction information such as payment status, amount, transaction or reference number, payment method, payment date, and information necessary for reconciliation, refunds and financial records.

Payment providers handle information according to their own privacy and security practices.

8. Disclosure of information

TDA may disclose personal information where reasonably necessary to service providers assisting TDA with website hosting, data storage, email, payments or other operational services; professional advisers; laboratories or verification providers where necessary and authorised; government, regulatory, law-enforcement or judicial bodies where required or authorised by law; or another person where you have authorised the disclosure.

TDA does not sell member contact lists or personal information for unrelated third-party marketing.

9. Overseas service providers

Some technology, hosting, payment, email or other service providers used by TDA may store or process information outside Australia.

At the date of this Privacy Policy, these service providers and locations are:

• Website, application and database hosting — Hostinger, on a server located in Jakarta, Indonesia.
• File storage (for example registration evidence, DNA reports, certificates and other uploaded documents) — Cloudflare R2, with storage located in the Oceania region. Cloudflare, Inc. is based in the United States.
• Email delivery — Postmark (ActiveCampaign, LLC), which processes email addresses and email content in the United States.
• Payments — PayPal, which may process payment information in Australia, the United States and other countries in line with PayPal's own privacy statement. TDA does not receive or store full card numbers.

TDA will update this section if these service providers or locations change.

10. Data security

TDA takes reasonable measures to protect information from misuse, interference, loss and unauthorised access, modification or disclosure.

Measures may include access controls, authentication, administrative permissions, audit records, secure hosting, backups and other technical or organisational safeguards appropriate to the system.

No internet-based service can guarantee absolute security.

11. Registry history and retention

TDA is a permanent horse registry.

Certain registry records may need to be retained for historical, evidentiary and integrity purposes even after a member closes an account or a horse changes ownership.

These records may include original registration information, registration numbers, previous ownership records, category changes, status changes, pedigree and ancestry records, verification decisions, DNA evidence records, certificate histories, performance corrections and administrative audit records.

Where a registry entry is corrected, TDA may preserve the original historical record and create a correction rather than deleting the original event. This is necessary to maintain the integrity and traceability of the TDA Studbook.

Personal information that is no longer reasonably required and is not required to be retained for legal, registry, financial, security or other legitimate purposes will be handled in accordance with applicable requirements.

12. Access and correction

You may request access to personal information TDA holds about you or ask TDA to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

Corrections to personal information should be distinguished from corrections to historical registry events. TDA may preserve an original registry event while recording a subsequent correction so the historical integrity of the Studbook is maintained.

Requests can be made using the contact details below. TDA may need to verify your identity before processing a request.

13. Cookies and technical information

The TDA website may use cookies and similar technologies necessary for login and authentication, account security, session management, website functionality, analytics, and fraud or security monitoring.

Where required, additional information or consent mechanisms may be provided.

14. Communications

TDA may send operational communications relating to accounts, memberships, registrations, payments, applications, certificates, evidence, ownership matters and other TDA services.

Where TDA sends optional promotional or marketing communications, recipients will be provided with an appropriate method of opting out where required.

15. Children and Family Memberships

Family Membership covers up to two adults and their dependent children under 18 who ordinarily reside in the same household.

Where personal information concerning a minor is required, TDA may require the information or relevant consent to be provided by a parent, guardian or other authorised adult.

TDA will seek to collect only information reasonably necessary for the relevant membership or registry purpose.

16. Privacy complaints

If you believe TDA has mishandled your personal information, please contact TDA using the details below.

Please provide sufficient information for TDA to understand and investigate the matter. TDA will seek to acknowledge and investigate privacy complaints within a reasonable period.

Where the Privacy Act applies, you may also have the right to complain to the Office of the Australian Information Commissioner.

17. Changes to this Privacy Policy

TDA may update this Privacy Policy to reflect changes to its services, technology, information-handling practices or legal obligations.

The current version will be published on the TDA website with its effective or last-updated date. Material changes may also be communicated to members where appropriate.

18. Contact TDA

Thoroughbred Derivatives Australia (TDA)Operated by Kelly Ann DavisABN 18 543 022 130York WA 6302, AustraliaEmail: thoroughbredderivatives@gmail.com

For privacy enquiries, access or correction requests, please use the contact details above.