Privacy Policy

1. Introduction

This Privacy Policy explains how Thoroughbreds AI Pty Ltd ("Thoroughbreds.AI", "we", "us", or "our") collects, uses, discloses, and protects information when you use our horse racing, breeding analytics, sales catalogue, stable management, mobile application, website, and related services (the "Service").

The Service supports sale catalogue review, lot scoring, notes, photos, shortlists, stable records, contacts, reports, and related support workflows.

By using the Service, you consent to the collection and use of your information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Service.

2. Information We Collect

2.1 Information You Provide

We collect information you provide directly, including:

• Account registration information, such as name, email address, mobile number, company name, and account preferences
• Profile information, such as role, address, postal address, and organisation details
• Horse and stable information, including horse profiles, status, ownership details, training and racing history, documents, notes, images, veterinary notes, contacts, and other records you choose to enter
• Sale workflow information, including catalogue markups, scores, comments, insights, shortlists, pass decisions, notes, uploaded images, and related assessment data
• Communications you send to us, including support requests and feedback
• Feedback and survey responses
• Subscription and billing information where applicable outside the iOS app
• DNA sample collection records only where you use a separate DNA-related workflow outside the iOS app, such as sample IDs and associated contact details

The iOS app does not process in-app purchases, card payments, or external checkout flows.

2.2 Information We Collect Automatically

When you use the Service, we automatically collect:

• Device information, such as browser type, operating system, app version, device type, and device identifiers
• Log data, such as IP address, access times, pages viewed, referring URLs, and error logs
• Usage data, such as features used, screens viewed, taps, clicks, workflow interactions, preferences, and product analytics events
• Approximate location inferred from IP address

We do not require precise GPS location for core iOS app workflows.

2.3 Mobile App Permissions

The iOS app may request access to device features where needed for app functionality:

• Camera access, so you can attach horse, lot, field, and stable photos to records
• Photo library access, so you can attach existing images to records
• Photo library add-only access, where supported, so the app can save generated or attached images if you choose to do so

You can manage these permissions in your device settings. Disabling a permission may limit related app functionality.

2.4 Analytics & Diagnostics

We use analytics and diagnostic tools, including PostHog, to understand how users interact with the Service, identify errors, improve performance, and prioritise product improvements.

Analytics may include product interaction data such as screens viewed, features used, workflow steps, clicks, taps, and app events. Diagnostics may include crash data and performance data.

We do not use analytics or diagnostic data for third-party advertising or cross-app tracking.

2.5 Cookies and Similar Technologies

We use cookies and similar tracking technologies to:

• Maintain your session and remember your preferences
• Analyse usage patterns and improve the Service
• Deliver relevant content and features

You can control cookies through your browser settings. Disabling cookies may limit your ability to use certain features of the Service.

3. How We Use Your Information

We use your information to:

• Provide, maintain, secure, and improve the Service
• Create and manage your account
• Enable catalogue review, scoring, notes, shortlists, comparison, and stable management workflows
• Store and retrieve horse, stable, contact, document, image, and note records
• Process transactions and manage your account where applicable
• Send service-related communications
• Respond to your enquiries and provide customer support
• Analyse usage patterns and optimise user experience
• Develop, test, and improve new features and services
• Send marketing communications, with your consent where required
• Comply with legal obligations
• Protect against fraud, abuse, security threats, and technical issues

4. How We Share Your Information

We may share your information with:

4.1 Service Providers

Third parties who assist us in providing the Service, including providers of:

• Cloud hosting and infrastructure
• Database services
• Authentication and identity management
• Email communications
• Analytics and product improvement
• Diagnostics and error monitoring
• Customer support workflows
• File storage
• Payment processing, where applicable outside the iOS app

These providers may be located in Australia, the United States, the European Union, and other jurisdictions where they operate.

4.2 Team Members and Shared Workflows

Information may be visible to other users only where you choose to share it, invite someone into a team, or use a feature that makes information available to that team or recipient.

We do not directly share your private notes, stable records, shortlists, uploaded photos, or horse records with other users or competitors unless you choose to share them or invite others into your team.

4.3 Business Partners

With your consent, we may share information with business partners for marketing or service-related purposes.

4.4 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Thoroughbreds.AI, our users, or the public.

4.5 Business Transfers

In connection with a merger, acquisition, financing, reorganisation, or sale of assets, your information may be transferred to the acquiring entity.

We do not sell your personal information.

5. Data Security

We implement technical and organisational measures designed to protect your information, including:

• Encryption of data in transit and at rest
• Access controls and authentication measures
• Regular security assessments
• Alignment with ISO 27001 and the Australian Essential Eight security framework

While we strive to protect your information, no method of transmission or storage is completely secure. We cannot guarantee absolute security.

6. Data Retention

We retain your information for as long as your account is active or as needed to provide the Service. We may retain certain information as required by law or for legitimate business purposes, including dispute resolution and enforcement of our agreements.

7. Your Rights

7.1 Australian Privacy Rights

Under the Privacy Act 1988 (Cth), you have the right to:

• Access your personal information
• Request correction of inaccurate information
• Complain about a breach of the Australian Privacy Principles

7.2 GDPR Rights (EEA/UK Users)

If you are located in the European Economic Area or United Kingdom, you have additional rights under the GDPR, including:

• Right of access
• Right to rectification
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Rights related to automated decision-making

To exercise these rights, contact us at support@thoroughbreds.ai.

7.3 Opting Out

You can opt out of marketing communications by:

• Clicking the unsubscribe link in our emails
• Updating your account preferences
• Contacting us at support@thoroughbreds.ai

8. International Data Transfers

Your information may be transferred to and processed in countries outside Australia, including the United States and countries where our service providers operate. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable laws.

9. Children's Privacy

The Service is designed for professional and adult users in the thoroughbred industry. It is not directed to children. We do not knowingly collect personal information from children under 13 years of age. If you believe we have collected information from a child, please contact us immediately.

10. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, contact us at:

Thoroughbreds AI Pty Ltd Email: support@thoroughbreds.ai

For privacy complaints, you may also contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.