Privacy Policy

Update: 09/2025

About this Statement

  1. This Privacy Statement (the "Statement") describes how PMI Group collects, shares, and uses any information that, used alone or in combination with other information, relates to you ("Personal Data") in your capacity as a user of the EQWIN application, trainer, or horse owner ("you" and "your").
  2. PMI Group, registered with the Paris Trade and Companies Register (RCS Paris) under number 983 031 519, with its registered office at 12 rue d'Hauteville, 75010 Paris, France ("PMI Group," "we," or "our"), operates the EQWIN application (the "Application").
  3. This Statement also outlines the rights you have regarding the Personal Data we process about you and how you can exercise them. PMI Group takes its privacy obligations seriously. This is why we have developed this Statement describing the standards that PMI Group applies to protect your Personal Data.
  4. For the purposes of this Statement, PMI Group acts as the controller of your Personal Data. Thus, PMI Group is responsible for ensuring that the processing of Personal Data complies with the applicable data protection legislation, particularly the General Data Protection Regulation ("GDPR").
  5. Please take the time to read this Statement carefully. If you have any questions or comments, please contact us via email at data@eqwin.app.

What Personal Data is Collected by PMI Group and Why?

  1. The categories of Personal Data we collect, and the reasons for processing them are as follows:
Why we collect themTypes of Personal DataLegal Basis
User of the Application
Registration and account creation — Necessary verification for registration (user age, place of residence)Identification data (password, email address); if authentication occurs via Google, Facebook Connect, or Apple: email, name, social network IDContractual necessity
Management of the virtual stable and racesUser email address, data related to the stable, horses, User activities, "Private" or "Socio-professional Category" (in the latter case, existence of accreditation received from federations), points accumulated by the user, ratingContractual necessity
Execution of transactions made with you (purchase of horse shares)Financial data (payment data, data related to your balance and purchases made, sponsorship)Contractual necessity
Horse trainers
Management of "trainers" profiles on the ApplicationIdentification data (name, surname), horses, pedigreeOur legitimate interest in presenting users with an accurate image of the equestrian sector and existing trainers
Socio-professional users
Calculation and management of commission for socio-professional categoriesIdentification data (email, password), data related to the applicable accreditation, data related to EQWIN allowancesOur legitimate interest in remunerating field actors and diversifying their income
General
Administration of the ApplicationN/AOur legitimate interest in ensuring the proper functioning of the Application
Management of complaints and disputesIdentification data, such as name, email, history of exchanges with youOur legitimate interest in safeguarding our rights and interests
To respond to any type of request you may make directly via our ApplicationIdentification data, such as name, email addressContractual necessity if you are a user; our legitimate interest in assisting you if you are not an account holder on the Application
For marketing and communication purposes, such as examining overall customer satisfaction with our products and services, communicating about our activities, services, and productsIdentification data, such as name, email address; marketing preferencesOur legitimate interest in sending commercial communications to our existing clients; consent when you are not an existing client

If we ask you to provide additional Personal Data beyond what is described above, we will specify which Personal Data we are asking for and the reasons we are asking for them at the appropriate time.

  1. We may also automatically collect certain information from your device when you use the Application. Specifically, the information we automatically collect may include data related to your IP address, device type, unique device identifiers, browser type, geographic location broadly understood (e.g., at the country or city level), and other technical information. We may also collect information about how your device interacts with our Application, including pages viewed and links clicked. Collecting this information allows us to better understand our Application users, where they come from, and to determine the content of our Application that interests them. We use this information for internal analysis purposes as well as to improve the quality and relevance of our Application for our users.

  2. We also collect Personal Data (name, first name, horses) regarding trainers, jockeys, and owners through data made public by equestrian federations. We may also verify your accreditation with these federations as a socio-professional. We use this data to provide an accurate portrayal of the equestrian sector within our Application.

Who does PMI Group share your Personal Data with?

  1. We may disclose your Personal Data to the following categories of recipients:
  2. Our third-party suppliers, service providers, and partners who provide us with data processing services or process Personal Data for purposes described in this Statement, or as notified to you when collecting your Personal Data. These suppliers and providers offer us the following categories of services: development, hosting, and maintenance of the Application, user verification processes (Know Your Customer).
  3. To equestrian federations, to verify your accreditation as a socio-professional.
  4. To any competent law enforcement agency, regulator, government agency, court, or other third party where we believe disclosure is necessary (i) under applicable laws or regulations, (ii) to establish or defend our rights, or (iii) to protect your vital interests or those of any other person.
  5. To our auditors, advisors, legal representatives, and similar agents as part of the advisory services they provide to us for legitimate business purposes and subject to a contractual prohibition on using Personal Data for other purposes.
  6. To a potential buyer (and its agents and advisors) in connection with a proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer that they must only use your Personal Data for the purposes described in this Statement.
  7. To any other person where you have given prior consent to the disclosure.

How do we protect your privacy?

In accordance with this Statement, we will process Personal Data as follows:

  1. Fairness — We will process your Personal Data fairly. This means that we are transparent about how we process Personal Data and will process it in accordance with applicable laws.
  2. Purpose limitation — We will process Personal Data for specific and lawful purposes, and we will not process it in a manner incompatible with these purposes.
  3. Proportionality — We will process Personal Data in a manner proportionate to the purposes for which the processing is intended to achieve.
  4. Data accuracy — We take appropriate measures to ensure that the Personal Data we hold is accurate, complete, and, if necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is as accurate, complete, and up to date as possible by informing PMI Group of any changes or errors (e.g., a change of address). As a user of the Application, you can directly modify your Data within your account.
  5. Data security — We use appropriate technical and organizational measures to protect the Personal Data we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
  6. Subcontractors — We may engage third parties to process Personal Data on behalf of PMI Group. We require these subcontractors to process Personal Data and act strictly according to our instructions and take appropriate measures to ensure that Personal Data remains protected.
  7. International data transfers — Your Personal Data is not transferred outside the European Economic Area (EEA), where the Application is hosted.
  8. Data retention — We retain the Personal Data we collect from you when we have a legitimate business need (e.g., to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). We delete user accounts after two years of inactivity.

When we no longer have a legitimate business need to process your Personal Data, we delete or anonymize it, or if this is not possible (e.g., your Personal Data has been stored in backup archives), we securely store and isolate it from any further processing until deletion is possible.

Automated Decision Making

We do not make automated decisions (including profiling) that produce legal effects concerning you or significantly affect you in a similar manner.

Minors

The services we provide on the Application are not intended for individuals under the age of 18. If you are under 18, please do not download this Application.

Your Data Protection Rights

  1. You have the following data protection rights, which you can exercise by contacting us at data@eqwin.app:

    1. You can access, correct, update, or request deletion of your Personal Data at any time.
    2. Additionally, under certain circumstances, you can object to the processing of your Personal Data, ask us to restrict the processing of your Personal Data, or request the portability of your Personal Data.
    3. If we have collected and processed your Personal Data with your consent, you can withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect the processing of your Personal Data based on legal grounds other than consent.
    4. You have the right to opt-out of marketing communications that we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.
    5. During your lifetime, you may choose to designate someone to carry out specific or general instructions on how to retain, delete, or disclose your data after your death. If the instructions only concern data that PMI Group holds about you, you may choose to inform us directly.
    6. If you have a complaint or concern about how we process your Personal Data, we will strive to address those concerns. If you feel that we have not adequately addressed your complaint or concern, you have the right to lodge a complaint with a data protection authority regarding the collection and use of your Personal Data. For more information, please contact your local data protection authority. The contact details for data protection authorities in the European Economic Area are available at the following link. In particular, the CNIL in France is located at 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 and can be contacted as explained here.
  2. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updating this Statement

We may update this Statement from time to time in response to evolving legal, technical, or business developments. When we update our Statement, we will take appropriate steps to inform you, considering the significance of the changes we make. We will obtain your consent to any significant changes to this Statement if required by applicable data protection laws.

You can view the date of the last update to this Statement by referring to the "last updated" date displayed at the top of this Statement.