Privacy Policy
Explains how we collect, use, and protect your personal data in accordance with UK GDPR and the Data Protection Act 2018.
- Version:
- 1.3
- Effective date:
- 20 May 2026
- Last updated:
- 20 August 2026
- Company number:
- 17225382
- Registered address:
- 62 Kings Road, Newbury, RG14 5RG
1.Introduction
This Privacy Policy explains how TROTTR Ltd ("TROTTR", "we", "us") collects, uses, and protects personal data in accordance with UK GDPR and the Data Protection Act 2018. TROTTR operates a digital marketplace connecting riders with riding schools.
2.Data Controller
TROTTR Ltd is the data controller responsible for personal data.
Contact: hello@trottr.co.uk
Jurisdiction: England & Wales.
3.Categories of Data Collected
3.1Rider Data
Name, email address, booking preferences, usage data, and communications.
3.2Riding School Data
Publicly available business data including name, address, contact details.
3.3Platform Data
Usage analytics, device data, approximate location derived from an IP address, and demand signal interactions.
3.4School Staff Capture Data
Where a member of school staff records a safety check, an incident, a near miss or a per-session PPE confirmation, we record who captured it, the role they held at the time, our own server timestamp, their device clock, and — where their browser supplies one and they have allowed it — a single position reading with its accuracy. Clause 15 describes this in full.
4.Lawful Basis for Processing (UK GDPR Article 6)
We process personal data under:
- Consent (Art. 6(1)(a))
- Contractual necessity (Art. 6(1)(b))
- Legitimate interests (Art. 6(1)(f)), including platform operation and improvement
5.Unclaimed Listings
TROTTR may list riding schools using publicly available data. Listings do not imply partnership or endorsement. Schools may request modification or removal at any time.
Where riders have expressed interest in an unclaimed listing, we may contact the school using its publicly available business contact details to invite it to claim its Trottr profile. This is processed under legitimate interest (UK GDPR Article 6(1)(f)). Every such email includes a one-click unsubscribe link; schools can opt out at any time via that link, by replying "remove", or by emailing hello@trottr.co.uk, and we maintain a suppression list so opted-out addresses are not contacted again.
6.Demand Signal Functionality
When users express interest in a riding school, their name and email may be shared with that school to facilitate booking opportunities. This is processed under legitimate interest.
7.Data Sharing and Processors
We may share data with service providers including payment processors (e.g., Stripe), hosting providers, and analytics platforms. All processors comply with GDPR obligations.
8.Data Retention
We keep personal data only for as long as we need it. The periods below are the ones we actually apply; they are enforced by automated jobs, not by hand.
- “Your account”
- For as long as it is active. If you delete it, we keep it for 30 days so it can be recovered, then hard-delete or anonymise it.
- “Bookings”
- Six years from the booking date. Once your account is deleted the booking is anonymised — the personal details are stripped and only the commercial record remains, which we must keep for HMRC and company-law purposes.
- “Your health declaration”
- For the life of your rider profile, then hard-deleted 365 days after that profile is deleted or becomes inactive. If you erase your account we delete it immediately. Health data is never held on the six-year booking clock — it has no tax or accounting basis, so it goes sooner.
- “The record of who saw your health data”
- For as long as the school has access, then 90 days after that access is revoked, then deleted. It exists so you can find out which school saw your data and when.
- “The record that you signed a waiver or agreement”
- This holds the document version, a cryptographic fingerprint of the exact text you signed, the name you signed with, and the date. It contains no health information. We keep it for as long as a claim relating to your participation could be brought — and where you signed as a child, the law does not start that clock until you turn 18, so the record outlives your account. If you erase your account we unlink the record from you; the name you signed with stays on it, because a signature no one can attribute proves nothing.
- “Sign-in and security logs”
- Twelve months from the event. Kept to investigate suspicious access and abuse.
- “Error reports”
- Ninety days, which is our error-monitoring provider's standard retention. We have not extended it.
- “Payment records”
- Held by Stripe under UK tax law for six years. We store only the payment reference, not your card details.
- “Marketing preferences”
- Until you unsubscribe, plus 30 days on a suppression list so that we do not accidentally add you back.
One exception applies across all of the above. If a legal claim has been made, or we reasonably expect one, we suspend deletion of the records relevant to that claim until it is resolved. We do not rely on this to keep data for any other reason.
9.Data Subject Rights
Users have the right to:
- Access their personal data
- Rectify inaccurate data
- Erase data ("right to be forgotten")
- Restrict processing
- Object to processing
- Data portability
Requests should be directed to hello@trottr.co.uk.
10.Cookies and Tracking
We use a small number of cookies and analytics tools, listed in full below. We do not use advertising cookies, marketing trackers, or third-party fingerprinting. The lawful basis for the analytics and error-monitoring tools is our legitimate interest (UK GDPR Article 6(1)(f)) in operating and securing the Platform — data is anonymous or pseudonymous, and personal data is scrubbed before transmission.
10.1Essential cookies
- “trottr_session”
- Sign-in session identifier. Lasts up to 30 days. Required to keep you logged in. Cannot be disabled without breaking sign-in.
- “trottr_cookie_notice”
- Records that you have seen the cookie notice. Lasts 1 year. Lets us avoid showing the notice on every page load.
10.2Analytics and error monitoring
- “Vercel Analytics”
- Anonymous page-view counts. No cross-site tracking, no IP storage, no profile building. Used to understand which pages visitors use. Provider: Vercel Inc. (USA, data transferred under standard contractual clauses).
- “Vercel Speed Insights”
- Anonymous performance metrics (page load timings). Helps us keep the site fast. Provider: Vercel Inc. (USA, SCCs).
- “Sentry”
- Application error reports. Personal data is scrubbed before transmission; URL query strings and request cookies are stripped by default. Used to find and fix bugs. Provider: Functional Software Inc. d/b/a Sentry (EU region hosting).
10.3How to opt out
You can block analytics and error-monitoring at any time by enabling your browser’s "Do Not Track" / "Block third-party cookies" setting, by using a privacy extension (uBlock Origin, Privacy Badger), or by clearing cookies for this domain. Blocking these cookies does not affect your ability to use the Platform.
11.Security Measures
We implement technical and organisational safeguards to protect data, including:
- Encryption
- Secure access controls
- Continuous monitoring
12.International Transfers
Where data is transferred outside the UK, appropriate safeguards such as standard contractual clauses are applied.
13.Future Data Use
Aggregated and anonymised data may be used for:
- Analytics
- Platform optimisation
- Potential insurance partnerships
14.Complaints
Users may lodge complaints with the Information Commissioner's Office (ICO) if they believe their data rights have been violated.
15.Location on Safety Records (School Staff)
This clause is addressed to the person doing the capturing — an instructor, a yard manager, a school owner — rather than to the school as an organisation. If a safety record you create carries a position, this is what is recorded and why.
15.1What is recorded
- A single position reading, with the accuracy your device reports, taken at the moment you save a record.
- Your identity as the person who captured it, and the role you held on that day.
- Our server’s own timestamp, and your device clock, stored separately so that any disagreement between them is visible.
- A short list of confidence flags derived from the above — for example that no position was supplied, or that the reading was imprecise.
15.2What is not recorded
- Nothing runs in the background. We do not track your location between captures, and no trail of movement is kept or can be reconstructed.
- We do not ask your browser for a position at all unless you have already allowed it. Where you have not, nothing is requested and nothing is collected.
- Position is never used for attendance, timekeeping, productivity or staff management, and we do not provide any figure that would support it. The verified-capture share shown to a school is for the school as a whole and is never broken down by person.
15.3Why
A safety record is worth more if it can be shown to have been created at the time and place it describes, rather than reconstructed afterwards. That matters to the school if a claim is ever made, and to the riders whose safety the checks exist to protect.
A position is recorded as attested, never as proof. A device can be made to report any location, so a single reading establishes nothing on its own. Its value is in the pattern, and it is mostly negative: a check logged from thirty miles away is worth a second look.
15.4Lawful basis, and your right to object
We rely on our legitimate interests and those of the school under Article 6(1)(f) UK GDPR, assessed in a written legitimate interests assessment available on request. We deliberately do not rely on your consent: in a working relationship consent is rarely freely given, and we would rather be straightforward about the basis than ask for a permission we would treat as a formality.
You may object at any time under Article 21, and you can act on it yourself: switching the location permission off in your browser stops the collection immediately. You do not need to ask anyone, and no record is ever refused, delayed or held back because a position is missing. A record saved without one is complete and valid; it simply carries no position, and reads as unverified in the school’s evidence.
15.5Who can see it, and for how long
The school whose records you are capturing can see that a record carried a position and roughly how precise it was. It is not shown a coordinate. The Evidence Pack a school may produce for its insurer or broker contains no position data and does not identify staff at all.
Position is stored on the safety record it belongs to. Safety records are append-only and are retained for as long as the school’s compliance history is retained, which is currently indefinite — a record that could be deleted would be worth little as evidence. We are reviewing whether position specifically should be removed from older records while keeping the fact that one was attested; clause 8 covers retention generally.
16.Contact
For all privacy-related enquiries, contact hello@trottr.co.uk.
