Privacy Policy

1. Introduction

Circle by Shergard (“Circle”, “we”, “our”, “us”) is a private professional network designed for participants in the horse racing and breeding industry.

We are committed to protecting your personal data and handling it transparently, securely, and in accordance with:

• The General Data Protection Regulation (EU) 2016/679 (“GDPR”)
• The Irish Data Protection Acts
• UK GDPR (where applicable)

This Privacy Policy explains how we collect, use, store, and protect your information.

2. Data We Collect

A. Account Information

When you apply for or create an account, we may collect:

• Full name
• Business or professional affiliation
• Email address
• Phone number
• Country of residence
• Profile information
• Membership status

B. Platform Usage Data

• Login activity
• IP address
• Device and browser type
• Interaction with content
• Messaging activity within Circle

C. Content You Provide

• Posts
• Comments
• Messages
• Uploaded documents
• Marketplace or syndicate listings

D. Payment Information (If Applicable)

If Circle operates on a subscription model, payments are processed by secure third-party providers. We do not store full payment card details.

3. Legal Basis for Processing

We process personal data under the following lawful bases:

• Contractual necessity – to provide Circle membership
• Legitimate interest – to manage and improve the platform
• Legal obligation – tax and compliance requirements
• Consent – marketing communications (where applicable)

4. How We Use Your Data

We use your information to:

• Provide access to Circle
• Verify professional eligibility
• Facilitate member interactions
• Manage memberships and billing
• Improve platform functionality
• Ensure community integrity and security
• Comply with legal obligations

We do not sell personal data.

5. Data Sharing

We may share data with:

• Cloud hosting providers
• Payment processors
• IT and security providers
• Legal or regulatory authorities where required

All third-party service providers are contractually required to protect your data.

We do not share private messages with third parties unless legally required.

6. International Transfers

If your data is transferred outside the EEA or UK, we ensure appropriate safeguards are in place, such as:

• EU Standard Contractual Clauses
• Adequacy decisions
• Approved secure cloud providers

7. Data Retention

We retain personal data:

• While your membership is active
• For up to 1 year following termination where legally required
• As necessary to resolve disputes or enforce agreements

If you request deletion, we will remove your data unless we are legally required to retain it.

8. Your Rights Under GDPR

You have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request erasure (“right to be forgotten”)
• Restrict processing
• Object to processing
• Request data portability
• Withdraw consent (where processing is based on consent)

You may also lodge a complaint with the Irish Data Protection Commission.

Requests can be made to: info@shergard.net

9. Security Measures

We implement appropriate technical and organisational measures, including:

• SSL encryption
• Secure cloud infrastructure
• Role-based access controls
• Access monitoring
• Regular system updates

While we strive to protect your data, no system is entirely immune to risk.

10. Confidentiality Within Circle

Circle is designed as a professional environment.

Content shared within private groups or direct messages is visible only to intended members. However, we cannot control actions of other members outside the platform.

Members are responsible for respecting confidentiality obligations.

11. Cookies

Circle uses cookies for:

• Authentication
• Session management
• Analytics
• Performance optimisation

You may control cookies via your browser settings.

12. Changes to This Policy

We may update this Privacy Policy periodically. The latest version will always be published on circle.shergard.net.

13. Contact

For any privacy-related queries or data requests: