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Privacy Policy

I. Name and Address of the Controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states, as well as other data protection regulations, is:

welearn GmbH

Grosser Burstah 36

20354 Hamburg

Germany

Phone: +49 2922 8863014

Email: team@wehorse.com

Website: www.wehorse.com

II. General Information on Data Processing

1. Scope of Processing of Personal Data

We process personal data of our users only to the extent necessary to provide a functional website and our content and services. Processing of personal data of our users takes place regularly only with the user's consent. An exception applies in cases where obtaining prior consent is not possible for factual reasons and the processing of data is permitted by law.

2. Legal Basis for the Processing of Personal Data

We process personal data exclusively on the basis of the applicable legal basis under the GDPR – in particular on the basis of your consent (Art. 6(1)(a) GDPR), for the performance of a contract or to take pre-contractual steps (Art. 6(1)(b) GDPR), for compliance with a legal obligation (Art. 6(1)(c) GDPR), or for the purposes of our legitimate interests (Art. 6(1)(f) GDPR).

The specific legal basis for individual processing operations is stated in the respective sections of this Privacy Policy.

3. Data Deletion and Storage Duration

The personal data of the data subject will be deleted or restricted as soon as the purpose of storage no longer applies. Storage may also take place if provided for by European or national legislation in EU regulations, laws, or other provisions to which the controller is subject. Data will also be blocked or deleted when a storage period prescribed by the aforementioned standards expires, unless there is a necessity for further storage of the data for the conclusion or performance of a contract.

Notwithstanding the above principle, we retain certain personal data – in particular user account and logbook data (e.g. horse data, training and health logs) – beyond the termination of the subscription. The legal basis for this is Art. 6(1)(f) GDPR (legitimate interests). Our legitimate interest lies in enabling users who return to wehorse after cancellation and take out a new subscription to seamlessly restore their previously recorded data. Following a balancing of interests, we have determined that this interest does not override the legitimate interests of the data subjects, provided the data is stored exclusively and not actively used for other purposes. This practice is governed by our General Terms and Conditions (GTC).

Data subjects have the right to object to the storage of their data after the end of the contract at any time and to request complete deletion. A corresponding request can be submitted informally by email to team@wehorse.com. The data will then be deleted without delay, unless statutory retention obligations prevent deletion.

III. Provision of the Website and App and Creation of Log Files

1. Description and Scope of Data Processing

1.1 Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

1.2 The following data is collected:

  1. Information about the browser type and version used
  2. Device type
  3. The user's operating system
  4. Date and time of access
  5. Websites from which the user's system reached our website
  6. Websites accessed by the user's system via our website

This data is also stored in the log files of our system. This data is not stored together with other personal data of the user. We do not carry out automatic browser or device fingerprinting – i.e. the creation of an individual user profile based on device characteristics without the use of cookies.

2. Legal Basis for Data Processing

The legal basis for the temporary storage of data and log files is Art. 6(1)(f) GDPR.

3. Purpose of Data Processing

3.1 The storage in log files is carried out to ensure the functionality of the website. The data also serves us to optimise the website and to ensure the security of our information technology systems. No evaluation of the data for marketing purposes takes place in this context.

3.3 These purposes also constitute our legitimate interest in the processing of data pursuant to Art. 6(1)(f) GDPR.

4. Duration of Storage

4.1 Data is deleted as soon as it is no longer required for the purpose for which it was collected or at the end of the statutory retention period. In the case of data collected for the provision of the website, this is the case when the respective session has ended.

4.2 In the case of storage of data in log files, this is the case after no more than seven days. Storage beyond this is possible.

5. Right to Object and Erasure

The collection of data for the provision of the website and the storage of data in log files is strictly necessary for the operation of the website. Consequently, there is no possibility for the user to object.

IV. Use of Cookies

1. Description and Scope of Data Processing

1.1 Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is accessed again.

1.2 We use cookies to make our website more user-friendly. Some elements of our website require that the accessing browser can be identified even after a page change.

1.3 The following data is stored and transmitted in the cookies:

  1. Language settings
  2. Log-in information
  3. Videos viewed
  4. Saved videos

2. Legal Basis for Data Processing

The legal basis for the processing of personal data using cookies is Art. 6(1)(f) GDPR.

3. Purpose of Data Processing

3.1 The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

3.2 We require cookies for the following applications:

  • Login process
  • Transfer of language settings
  • Access management
  • User management
  • Saving search terms
  • Registration
  • Shopping cart
  • Checkout/payment

3.3 The user data collected by technically necessary cookies is not used to create user profiles. These purposes also constitute our legitimate interest in the processing of personal data pursuant to Art. 6(1)(f) GDPR.

4. Duration of Storage, Right to Object and Erasure

Cookies are stored on the user's computer and transmitted to our site by the user. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it may no longer be possible to use all functions of the website to their full extent.

V. Newsletter

1. Description and Scope of Data Processing

1.1 Our website offers the possibility to subscribe to a free newsletter. The data entered in the input form is transmitted to us when registering for the newsletter:

  • Email address
  • Optional: first and last name

1.2 In addition, the following data is collected at the time of registration:

  • Date and time of registration

1.3 Your consent to the processing of data is obtained during the registration process and reference is made to this Privacy Policy. If you purchase goods or services on our website and provide your email address, it may subsequently be used by us to send a newsletter. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter.

1.4 No data is passed on to third parties in connection with data processing for the sending of newsletters. The data is used exclusively for sending the newsletter.

2. Legal Basis for Data Processing

The legal basis for the processing of data after the user has subscribed to the newsletter, where the user's consent exists, is Art. 6(1)(a) GDPR. The legal basis for sending the newsletter following the sale of goods or services is Section 7(3) UWG.

3. Purpose of Data Processing

The collection of the user's email address serves to deliver the newsletter. The collection of other personal data during the registration process serves to prevent misuse of the services or the email address used.

4. Duration of Storage

Data is deleted as soon as it is no longer required for the purpose for which it was collected. The user's email address is therefore stored for as long as the newsletter subscription is active. The other personal data collected during the registration process is generally deleted after a period of seven days.

5. Right to Object and Erasure

The newsletter subscription can be cancelled by the affected user at any time. A corresponding link is provided in every newsletter. This also enables the revocation of consent to the storage of personal data collected during the registration process.

6. Use of Newsletter and Marketing Service Providers

We use external service providers for sending our newsletters and for providing further marketing functions (e.g. email automation, social media integration). These providers process the data you have submitted (in particular email address, name) exclusively on our behalf and according to our instructions. We have concluded data processing agreements in accordance with Art. 28 GDPR with all service providers used. Where data is processed outside the EU, this is done on the basis of appropriate safeguards pursuant to Art. 46 GDPR (in particular EU standard contractual clauses).

VI. Registration

1. Description and Scope of Data Processing

1.1 On our website, we offer users the possibility to register by providing personal data. The data is entered into an input form and transmitted to us and stored. No data is passed on to third parties. The following data is collected during the registration process:

  • First name
  • Last name
  • Email address
  • Password
  • Country
  • Payment method (SEPA direct debit, credit card or PayPal)

1.2 At the time of registration, the following data is also stored:

  • Date and time of registration
  • Selected payment method and associated payment data

1.3 The user's consent to the processing of this data is obtained during the registration process.

2. Legal Basis for Data Processing

The legal basis for the processing of data, where the user's consent exists, is Art. 6(1)(b) GDPR.

3. Purpose of Data Processing

Registration of the user is necessary for the performance of a contract with the user or for taking pre-contractual steps. This is required to issue a proper invoice and to process payments.

4. Duration of Storage

Data is deleted as soon as it is no longer required for the purpose for which it was collected. This is the case for data collected during the registration process for the performance of a contract or for taking pre-contractual steps when the data is no longer required for the performance of the contract. Even after conclusion of a contract, there may be a need to store personal data of the contracting party in order to comply with contractual or legal obligations.

5. Right to Object and Erasure

As a user, you have the option at any time to cancel the registration. You can have the data stored about you changed at any time. For deletion, please contact us by email at team@wehorse.com. If the data is required for the performance of a contract or for taking pre-contractual steps, early deletion of the data is only possible insofar as contractual or legal obligations do not prevent deletion.

VII. Contact Form and Email Contact

1. Description and Scope of Data Processing

1.1 A contact form is available on our website which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input form is transmitted to us and stored. This data is: Name, email address, subject, message

1.2 Your consent to the processing of data is obtained during the submission process and reference is made to this Privacy Policy.

1.3 Alternatively, contact can be made via the email address provided. In this case, the user's personal data transmitted with the email will be stored. No data is passed on to third parties in this context. The data is used exclusively for processing the conversation.

2. Legal Basis for Data Processing

The legal basis for the processing of data, where the user's consent exists, is Art. 6(1)(a) GDPR. The legal basis for the processing of data transmitted in the course of sending an email is Art. 6(1)(f) GDPR. If the email contact is aimed at the conclusion of a contract, the additional legal basis for processing is Art. 6(1)(b) GDPR.

3. Purpose of Data Processing

The processing of personal data from the input form serves us solely to handle the contact request. In the case of contact by email, this also constitutes the necessary legitimate interest in the processing of data. The other personal data processed during the submission process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of Storage

Data is deleted as soon as it is no longer required for the purpose for which it was collected. For the personal data from the input form of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified. The additional personal data collected during the submission process is deleted no later than after a period of seven days.

5. Right to Object and Erasure

5.1 The user has the option at any time to revoke their consent to the processing of personal data. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued. The revocation can be submitted by email to team@wehorse.com.

5.2 All personal data stored in the course of the contact will be deleted in this case.

VIII. Web Analytics via Google Analytics

1. Scope of Processing of Personal Data

1.1 We use the Google Analytics tool on our website to analyse the browsing behaviour of our users. The software places a cookie on the user's computer (see above regarding cookies). When individual pages of our website are accessed, the following data is stored:

  • The web page accessed
  • The website from which the user reached the accessed web page (referrer)
  • The sub-pages accessed from the accessed web page
  • The time spent on the web page
  • The frequency with which the web page is accessed

1.2 Personal data of users is stored only in Google Analytics. No data is passed on to third parties.

2. Legal Basis for the Processing of Personal Data

The legal basis for the processing of personal data of users is Art. 6(1)(f) GDPR.

3. Purpose of Data Processing

The processing of personal data of users enables us to analyse the browsing behaviour of our users. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continually improve our website and its user-friendliness. These purposes also constitute our legitimate interest in the processing of data pursuant to Art. 6(1)(f) GDPR.

4. Duration of Storage

Data is deleted as soon as it is no longer needed for our recording purposes. In our case, this is after 50 months.

5. Right to Object and Erasure

5.1 Cookies are stored on the user's computer and transmitted to our site by the user. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it may no longer be possible to use all functions of the website to their full extent.

5.2 By clicking the button at the bottom of the page, you can enable or disable tracking via Google Analytics.

IX. Meta (Facebook) Pixel / Conversion Tracking

  1. We use services of Meta Platforms Ireland Limited (formerly Facebook Ireland Limited), 4 Grand Canal Square, Dublin 2, Ireland ("Meta") on our website, in particular the Meta Pixel and/or comparable conversion tracking technologies.
  2. The integration is carried out via the Google Tag Manager. As a result, when our website is accessed and during certain actions (e.g. page views, registration or purchase completion), information may be transmitted to Meta in order to measure the effectiveness of our advertising measures, attribute conversions, and create target audiences (e.g. website visitors).
  3. In particular, the following data may be processed: IP address, device/browser information, referrer URL, pages visited and event data (e.g. "PageView", "Lead", "Purchase"), possibly together with cookie IDs or comparable online identifiers.
  4. Where consent is required, processing takes place only with your consent via our cookie or consent banner. You can adjust or revoke your selection at any time via the cookie settings.
  5. For more information on data processing by Meta, please refer to Meta's data policy: https://www.facebook.com/privacy/policy/.

XI. Rights of the Data Subject

If personal data about you is processed, you are a data subject within the meaning of the GDPR and you have the following rights with respect to the controller:

1. Right of Access

1.1 You may request confirmation from the controller as to whether personal data concerning you is being processed by us.

1.2 If such processing exists, you may request information from the controller about the following:

  1. The purposes for which the personal data is being processed;
  2. The categories of personal data being processed;
  3. The recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
  4. The planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage duration;
  5. The existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
  6. The existence of a right to lodge a complaint with a supervisory authority;
  7. Any available information about the origin of the data, if the personal data is not collected from the data subject;
  8. The existence of automated decision-making, including profiling, pursuant to Art. 22(1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved and the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

2. Right to Rectification

You have a right to rectification and/or completion with respect to the controller if the processed personal data concerning you is inaccurate or incomplete. The controller must carry out the rectification without delay.

3. Right to Restriction of Processing

3.1 You may request the restriction of the processing of personal data concerning you under the following conditions:

  1. If you contest the accuracy of the personal data concerning you for a period that enables the controller to verify the accuracy of the personal data;
  2. The processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
  3. The controller no longer needs the personal data for the purposes of processing, but you need it for the establishment, exercise or defence of legal claims; or
  4. If you have objected to processing pursuant to Art. 21(1) GDPR and it is not yet certain whether the legitimate grounds of the controller override your grounds.

3.2 Where the processing of personal data concerning you has been restricted, such data may, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3.3 If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right to Erasure

4.1 Obligation to Erase

4.1.1 You may request the controller to delete the personal data concerning you without undue delay, and the controller is obligated to delete this data without undue delay if one of the following reasons applies:

  1. The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
  2. You revoke your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
  3. You object to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) GDPR.
  4. The personal data concerning you was processed unlawfully.
  5. The erasure of the personal data concerning you is necessary to comply with a legal obligation under Union or Member State law to which the controller is subject.
  6. The personal data concerning you was collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

4.2 Information to Third Parties

Where the controller has made the personal data concerning you public and is obliged pursuant to Art. 17(1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure of all links to, or copies or replications of, such personal data.

4.3 Exceptions

4.3.1 The right to erasure does not exist to the extent that processing is necessary:

  1. For exercising the right of freedom of expression and information;
  2. For compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. For reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
  4. For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89(1) GDPR, insofar as the right referred to in section (a) is likely to render impossible or seriously impair the achievement of the objectives of such processing; or
  5. For the establishment, exercise or defence of legal claims.

5. Right to Notification

5.1 If you have exercised the right to rectification, erasure or restriction of processing against the controller, the controller is obligated to communicate such rectification or erasure of data or restriction of processing to all recipients to whom the personal data concerning you has been disclosed, unless this proves impossible or involves a disproportionate effort.

5.2 You have the right to be informed about those recipients by the controller.

6. Right to Data Portability

6.1 You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided, where:

  1. The processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR; and
  2. The processing is carried out by automated means.

6.2 In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another controller, where technically feasible. The freedoms and rights of other persons must not be adversely affected. The right to data portability does not apply to processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to Object

7.1 You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions.

7.2 The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

7.3 Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

7.4 If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.

7.5 You have the option, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.

8. Right to Withdraw a Declaration of Consent under Data Protection Law

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal.

XII. Data Protection Provisions on the Use of DATEV

For our accounting we use the software of DATEV eG, Paumgartnerstraße 6–14, 90429 Nuremberg. DATEV processes incoming and outgoing invoices and, if applicable, the bank transactions of our company in order to prepare financial accounting. For more information about DATEV eG, the processing of data and data protection provisions, please visit https://www.datev.de/web/de/datev-eg/unternehmen/datenschutz/.

XIII. Data Protection Provisions on the Use of Chargebee

For the management of our user and contract data we use the service of the cloud-based billing & subscription management software Chargebee INC., 44 Montgomery Street, San Francisco, CA 94104, USA. Chargebee processes the registration data of our users and, if applicable, the bank transactions of our company in order to manage subscriptions and carry out automated invoice management.

When a contract is concluded, your user, contract and payment data is forwarded to Chargebee via an encrypted interface. The data you have entered is stored on Chargebee's servers. The data you have provided is stored by us until the termination of your contract and deleted from Chargebee upon the effective date of termination. Data stored by us for other purposes is not affected by this. For more information about Chargebee INC., the automated processing of data and data protection provisions, please visit https://www.chargebee.com/.

XIV. Special Notes on the wehorse App

Data Collection During Use

We process the data of users of our application to the extent necessary to provide users with the application and its functionalities, to monitor its security, and to further develop it. We may also contact users in accordance with legal requirements if communication is necessary for the purposes of administration or use of the application. Otherwise, with regard to the processing of user data, we refer to the data protection notices in this Privacy Policy.

Legal bases: The processing of data required for the provision of the functionalities of the application serves the performance of contractual obligations. This also applies if the provision of functions requires authorisation from users (e.g. authorisation of device functions). Where the processing of data is not required for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or for security purposes), it is carried out on the basis of our legitimate interests. Where users are expressly asked for their consent to the processing of their data, processing of the data covered by the consent is carried out on the basis of that consent.

Commercial use: We process the data of users of our application, registered and any trial users (hereinafter collectively referred to as "users"), in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to further develop it. The required information is identified as such in the context of the usage, order or comparable contract conclusion and may include the information required for the provision of services and any invoicing, as well as contact information to enable any follow-up enquiries.

Storage of a universally unique identifier (UUID): For the purpose of analysing the use and functionality of the application and storing user settings, the application stores a so-called universally unique identifier (UUID). This identifier is generated when this application is installed (but is not linked to the device, so it is not a device identifier in this sense), remains stored between the launch of the application and its updates, and is deleted when users remove the application from their device.

Storage of a pseudonymous identifier: In order to provide the application and ensure its functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no plain data such as names is used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated when this application is installed, remains stored between the launch of the application and its updates, and is deleted when users remove the application from the device.

Device permissions for access to functions and data: The use of our application or its functionalities may require users to grant access permissions to certain functions of the device used or to the data stored on the device or accessible by means of the device. By default, these permissions must be granted by users and can be revoked at any time in the settings of the respective device. The exact procedure for controlling app permissions may depend on the device and software of the user. If further explanation is needed, users can contact us. We point out that the refusal or revocation of the respective permissions may affect the functionality of our application.

Processing of location data: In the context of using our application, location data collected by the device used or otherwise entered by users is processed. The use of location data requires authorisation from users, which can be revoked at any time. The use of location data serves only to provide the respective functionality of our application, in accordance with its description to users or its typical and expected mode of operation.

Location history and movement profiles: Based on the location data collected during use of our application, a location history is created showing the geographical movements of the devices used over a period of time (which may allow inferences to be drawn about the movement profile of users). The location history serves only to provide the respective functionality of our application, in accordance with its description to users or its typical and expected mode of operation.

  • Types of data processed: Master data (e.g. names, addresses), meta/communications data (e.g. device information), location data (information about the geographical position of a device or person), location history and movement profiles (collection of location data and positional changes over a certain period of time).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal bases: Consent (Art. 6(1)(a) GDPR), contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Voice Function (Recording Training) / Speech Recognition

If you use the voice function to record training content, we process audio data (voice recording) for the purpose of speech recognition and transcription. This creates a text transcript that we store in your Logbook for documenting your training.

For speech recognition, we use speech recognition services from Apple and Google. For this purpose, it may be necessary to transmit the voice recording to the respective provider for processing (depending on the end device, operating system and the settings you have made).

We do not use the voice recording to improve our product.

The legal basis for the processing is Art. 6(1)(b) GDPR (contract performance), insofar as the processing is necessary for the provision of the voice function and for the creation of the training documentation.

We store the transcript as part of your logbook entry. The voice recording is not stored by us permanently, but is only processed to the extent necessary for creating the transcript.

You can stop using the voice function at any time by revoking the microphone permission in the settings of your end device; in this case, the voice function cannot be used.

Obtaining the App via App Stores

Our application is available via special online platforms operated by other service providers (so-called "app stores"). In this context, in addition to our data protection notices, the data protection notices of the respective app stores apply. This applies in particular with regard to the procedures used on the platforms for reach measurement and interest-based marketing, as well as any costs.

  • Types of data processed: Master data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communications data (e.g. device information).
  • Data subjects: Customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal bases: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers used:

  • Apple App Store: App and software sales platform; service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; website: https://www.apple.com/de/ios/app-store/; privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Google Play: App and software sales platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://play.google.com/store/apps?hl=de; privacy policy: https://policies.google.com/privacy.

XV. Logbook Feature and AI-Supported Evaluations

1. Scope of Data Processing

As part of the Logbook feature, we process horse-related data that you actively enter (e.g. health, training, feeding and keeping data), as well as location data where the corresponding device permission has been granted. A complete list of the categories of data processed can be found in Section 11.1 of our GTC.

If you upload photos or videos within your entries (e.g. for the identification of your horse or for documenting your training), we also process these image or video files including any metadata transmitted along with them (e.g. date of recording). The photos and videos are not used for AI evaluations, but are stored exclusively within the Logbook functionality and displayed to you.

2. Purpose and Legal Basis of Data Processing

2.1 The data entered is processed in order to (a) provide you with the Logbook functionality and to store and display your entries, (b) generate automated evaluations and personalised recommendations for your horse and its training, and (c) contribute to the improvement of our platform in anonymised and aggregated form. The contractual framework for these purposes is governed by Section 11.2 of our GTC.

AI Report: After a certain number of Logbook activities (currently five), we can provide you with a so-called AI Report. For this purpose, we evaluate your most recent Logbook entries in order to provide you with (i) a summary, (ii) an evaluation and (iii) questions/impulse questions about your training. In addition, we can (iv) recommend suitable content from our offering (e.g. videos or training sessions) based on this evaluation. This processing serves the provision and personalisation of our contractual services.

2.2 The legal basis for processing under (a) and (b) is Art. 6(1)(b) GDPR (contract performance). For the anonymised platform improvement under (c) and for the retention of your data after the end of the contract, we rely on Art. 6(1)(f) GDPR (legitimate interest). Details can be found in Section 11.3 of our GTC and in Section II.3 of this Privacy Policy.

3. Use of AI Services

To create personalised evaluations and recommendations, we use external AI service providers. The transmitted data is anonymised or pseudonymised where technically possible. Where data is transferred to third countries, this is done on the basis of appropriate safeguards pursuant to Art. 46 GDPR.

4. Duration of Storage and Right to Object

The storage duration and the procedure for active deletion of data are governed in detail in Section 11.5 of our GTC and in Section II.3 of this Privacy Policy. Deletion requests should be sent informally to team@wehorse.com.

You have the right to object at any time to the storage of your data after the end of the contract (Art. 21 GDPR). Your further data protection rights with regard to Logbook data (access, rectification, erasure, data portability) are governed by Section 11.6 of our GTC and in Section XI of this Privacy Policy. Technical and organisational protective measures for the stored data are described in Section 11.7 of our GTC.

Last updated: 04.06.2026

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