Polo HQ Privacy Policy

Effective date: 31 July 2026
Last updated: 8 September 2026

This Privacy Policy explains how POLO HQ LTD collects, uses, shares, stores and protects personal information in connection with the Polo HQ website, web application, mobile applications and related services (the Service).

POLO HQ LTD is incorporated in England and Wales under company number 17059471. Its registered office is 43 Diamond Ridge, Camberley, England, GU15 4LB.

Privacy enquiries and rights requests may be sent to info@polohq.com.

1. Scope

This policy applies when you:

• visit a Polo HQ website;

• start, activate or use a trial;

• create, manage or use an Account;

• receive an invitation from a Polo HQ customer;

• select a free or paid Plan;

• purchase or manage a subscription;

• contact support;

• receive Account, trial, billing or security communications; or

• appear in information uploaded by a Polo HQ customer.

It should be read with the Terms of Service, Cookie Policy, Data Retention and Account Deletion Policy, and, for organisational customer data, the Data Processing Addendum.

2. Who is the controller and who is the processor

Polo HQ acts as a controller where it decides why and how personal information is used for its own purposes, including:

• trial signup and Account activation;

• authentication and direct Account administration;

• subscription and billing administration;

• security, fraud prevention and platform integrity;

• legal acceptance records;

• support and direct communications;

• product administration and service improvement; and

• compliance with legal obligations.

An Organisation using Polo HQ ordinarily acts as the controller for personal information it chooses to upload, organise or use within its operational workspace. Polo HQ ordinarily acts as that Organisation's processor for that Customer Data and processes it under the Data Processing Addendum.

The correct legal role depends on the particular processing activity. A service provider, including Stripe, may also act as a processor or an independent controller for different activities.

3. Personal information we collect

3.1 Signup, checkout and Account information

We may collect:

• Account or Organisation name;

• first name and last name;

• email address;

• User role and permissions;

• Account, Organisation and User identifiers;

• login, activation and invitation status;

• password-related authentication information handled by our authentication provider;

• language and interface preferences;

• Account type, selected Plan, billing interval and selected extras at signup;

• date and time of signup, checkout, activation and last access; and

• records of acceptance of legal terms and policies.

We do not intend to store plaintext passwords.

3.2 Trial, Plan and entitlement information

We generate or store:

• Checkout Trial and Full-Access Trial start, end and status timestamps;

• whether a payment method was successfully set up with Stripe for a Checkout Trial;

• Account Type, core Plan, billing interval, Add-ons, Bundles and Capacity Pack quantities selected or requested in onboarding and billing;

• the itemised amount due today, amount and date due after a Checkout Trial, and renewal frequency shown to the Customer;

• cancellation request, effective date, immediate or period-end treatment and Account-lock status;

• current entitlements, requested modules and requested or recorded counts of horses, players or members, Users, practices, lessons, maintenance tasks, breeding records and other capacity-relevant records where needed to validate or recommend a package;

• candidate and Recommended Configurations generated for a Full-Access Trial, including suggested extras, quantities and all-in recurring totals;

• product catalogue rules, Account-Type eligibility, parent-entitlement dependencies, pack limits, price identifiers, candidate packages, validation results and any corrected package presented to the Customer;

• Plan-change, deactivation and reactivation timestamps;

• status of User seats and operational records; and

• whether an expired Full-Access Trial has selected a Plan.

3.3 Billing and subscription information

Where a paid product is purchased, we may process:

• billing contact name and email;

• Organisation name;

• selected products, prices and billing frequency;

• Stripe customer, checkout, subscription, price and subscription-item identifiers;

• invoice and payment status;

• billing period dates;

• upgrade, downgrade, cancellation and renewal status;

• failed-payment and recovery events; and

• limited payment-method display information made available by Stripe, where applicable.

Payment card details are entered on Stripe-hosted pages. Polo HQ does not receive or store full card numbers or card security codes.

3.4 Customer-controlled operational data

Customers may upload or create information about:

• players, members, staff, grooms, coaches, managers, contractors, suppliers and horse owners;

• names, contact details, roles, dates of birth, availability and participation;

• account access, tasks, notes, schedules, practices, lessons and events;

• contracts, identification, passports, visas and other documents;

• invoices, expenses, payments, fees and other operational financial information;

• performance, attendance, workload and activity information;

• communications and internal notes; and

• other information selected by the Customer.

Horse data, such as a horse's health, pedigree or training record, is not personal information by itself. It may become personal information where it identifies or is linked to a person, such as an owner, rider, groom or veterinary professional.

Customers control the types of operational data they enter. They must not upload personal information unless they have a lawful basis and authority to do so.

3.5 Documents and potentially sensitive information

Customer-uploaded documents may contain sensitive information, including identification records, immigration information, financial information or, if a Customer chooses to enter it, health or other special category information about a person.

Polo HQ does not require Customers to upload unnecessary special category data. Customers should minimise sensitive data and must establish an appropriate lawful basis and any additional legal condition required before uploading it.

3.6 Technical, device and usage information

We may collect:

• IP address;

• browser, operating system and device information;

• application version;

• session and authentication events;

• timestamps and request logs;

• error, diagnostic and performance information;

• security alerts and suspicious-activity indicators;

• pages and features used;

• authorised integration events; and

• cookie or similar technology information described in the Cookie Policy.

3.7 Communications and support

We may process:

• support messages and attachments;

• email delivery and event logs;

• feedback, requests and survey responses;

• complaints and dispute records; and

• records of service, security, trial and billing communications.

4. Where personal information comes from

We obtain personal information:

• directly from the person signing up, activating or using an Account;

• from an Account Manager or Organisation that invites or adds a User or record;

• from Stripe and other service providers;

• automatically from devices, browsers and the Service;

• from integrations authorised by a Customer; and

• from public or professional sources where reasonably necessary for support, security, fraud prevention or legal claims.

5. Why we use personal information and our lawful bases

5.1 To create and administer Accounts

We use names, email addresses, Organisation details, roles and activation information to create Accounts, verify email addresses, manage access and provide support.

Lawful basis: performance of a contract, steps taken at the person's request before a contract, and legitimate interests in secure account administration.

5.2 To operate Checkout Trials and Full-Access Trials

For a standard Checkout Trial, we use signup details, selected products, Stripe status, Trial dates and cancellation status to provision the confirmed Subscription Configuration, send reminders, start paid billing after day 14 unless cancelled, cancel immediately when requested during Trial, and lock or restore the Account as required.

For a legacy or manually granted Full-Access Trial, we use signup details, Trial dates, usage counts and module activity to provide evaluation access, issue reminders, restrict normal access at expiry and show Plan options.

Lawful basis: performance of a contract, steps taken at the person's request before a contract, and legitimate interests in administering transparent and secure Trials.

5.3 To validate, optimise and recommend eligible subscription packages

During initial onboarding, basket review, checkout validation, Plan recommendations and changes in the billing area, we may use the selected Account Type, requested modules, requested capacity, current entitlements, relevant usage counts, product eligibility, parent-module dependencies, pack limits, Bundle contents, prices and billing interval.

These rules are used to:

• reject products unavailable to the selected Account Type;

• prevent Player Free from being combined with paid extras;

• prevent a Capacity Pack being purchased without its required entitlement;

• enforce plan-specific pack limits;

• remove duplicated standalone Add-ons covered by a Bundle or core Plan;

• identify a Valid Package; and

• identify a lower-priced package that provides the same or greater requested entitlement.

Where a correction is needed, the Service presents the corrected items, reason and recurring total for Customer review. The Customer must confirm the corrected package before a subscription is created or amended.

Lawful basis: steps taken at the person's request before entering a contract, performance of a contract, and legitimate interests in transparent pricing, preventing billing errors, protecting the integrity of the product catalogue and avoiding commercially invalid or unnecessarily expensive subscriptions.

The process does not use advertising profiles, external behavioural data, protected characteristics or credit scoring. It does not compare different Account Types as interchangeable products. It is not intended to produce a legal or similarly significant effect on an individual without Customer confirmation.

5.4 To apply product eligibility and capacities

We use Plan information, Account Type, entitlements and relevant record counts to apply the modules and limits attached to the confirmed Subscription Configuration and to prevent incompatible or excess requests.

Lawful basis: performance of a contract and legitimate interests in applying the selected product consistently and protecting Service and billing integrity.

5.5 To process subscriptions and billing

We use billing contacts, selected products, Stripe identifiers, status and payment events to create and manage recurring subscriptions, apply entitlements, issue invoices and receipts, handle confirmed upgrades or downgrades, recover failed payments and restore access.

Lawful basis: performance of a contract, legal obligations relating to financial records, and legitimate interests in accurate billing, fraud prevention and revenue recovery.

5.6 To send service communications

We use names, email addresses, Account status and billing status to send activation links, Checkout Trial reminders, cancellation confirmations, first-charge and renewal information, Plan confirmations, failed-payment and recovery messages, security alerts and, for Full-Access Trials, Trial-ended notices and deletion warnings.

Lawful basis: performance of a contract, legal obligations and legitimate interests in reliable service administration.

These communications are service messages, not optional marketing.

5.7 To secure and protect the Service

We use authentication events, IP addresses, device information, logs, webhook records and security indicators to prevent unauthorised access, investigate misuse, verify payments, detect attempts to bypass product eligibility or commercial controls, and maintain tenant isolation.

Lawful basis: legitimate interests in cybersecurity, fraud prevention, protection of Customers and enforcement of our rights, and legal obligations where applicable.

5.8 To meet legal and regulatory obligations

We may process information for tax, accounting, corporate, consumer-protection, data-protection, law-enforcement and court requirements.

Lawful basis: compliance with legal obligations and legitimate interests in establishing, exercising or defending legal claims.

5.9 To improve and support the Service

We may use support information, error logs, usage patterns and feedback to troubleshoot, maintain and improve the Service.

Lawful basis: legitimate interests in operating and improving Polo HQ.

Where reasonably possible, improvement analysis uses aggregated or de-identified information.

5.10 Marketing

If we send optional direct marketing, we will use consent or legitimate interests as permitted by applicable law and provide an unsubscribe route.

Service communications cannot be opted out of while they remain necessary to administer an active Account or legal obligation.

5.11 Cookies and similar technologies

Strictly necessary technologies are used to provide authentication, security and requested functionality. Non-essential technologies will be used only with the consent required by law.

See the Cookie Policy.

6. Automated processes

Polo HQ uses automated rules for operational and commercial administration, including:

• validating Account-Type and product eligibility;

• preventing Player Free from being combined with paid extras;

• enforcing parent-entitlement dependencies and Capacity Pack limits;

• removing duplicated entitlements covered by a Bundle or core Plan;

• comparing Valid Packages within the selected Account Type and identifying a lower-priced package that provides the same or greater requested entitlement;

• creating the confirmed Subscription Configuration after Stripe confirms Checkout Trial setup;

• calculating Checkout Trial dates and triggering the first charge after the Trial unless cancelled;

• cancelling a Checkout Trial immediately when an authorised manager confirms cancellation;

• locking every User when a Checkout Trial is cancelled, when paid cancellation becomes effective, or when billing is unresolved;

• restoring access after a successful new subscription or recovered payment;

• applying Plan and module entitlements;

• restricting normal access after a Full-Access Trial ends;

• triggering lifecycle, cancellation and billing emails; and

• permanently deleting an abandoned Full-Access Trial 90 days after expiry if no Plan has been chosen.

Package validation may prevent an invalid basket from proceeding. Where the system proposes a Corrected Package, it does not create or amend a paid subscription until the Account Manager is shown the corrected items and recurring total and deliberately confirms them.

The package rules operate within the Account Type selected by the Customer and do not use protected characteristics, credit scoring or external behavioural profiles. They are commercial eligibility and pricing rules and are not intended to make a solely automated decision producing a legal or similarly significant effect on an individual.

A person who believes an automated rule has been applied incorrectly may contact info@polohq.com for human review before deletion or as soon as possible after another action.

7. Abandoned-Trial deletion and surviving audit record

The automatic 90-day deletion process applies only to a legacy or manually granted Full-Access Trial that has ended and has never selected any Plan, including Player Free.

It does not apply merely because a standard Checkout Trial is cancelled. A cancelled Checkout Trial is locked and its Customer Data is retained under the ordinary Account retention rules unless the Account is separately closed or a valid deletion request is completed.

For an abandoned Full-Access Trial, the Account and Customer Data are retained for 90 days after expiry and then permanently deleted. Warning emails are normally sent 60 and 80 days after expiry. Choosing any Plan before deletion stops the process.

After deletion, we retain a limited audit record containing:

• Account or Organisation name;

• signup email address;

• Full-Access Trial start and expiry dates;

• deletion date; and

• counts of deleted records by data category.

We retain this audit record normally for six years from the deletion date for operational accountability, duplicate-Trial and abuse prevention, dispute handling and establishment or defence of legal claims. At the end of that period it is deleted or irreversibly anonymised, unless a legal hold requires longer retention.

8. Service providers and other recipients

We may share personal information with service providers that help operate Polo HQ.

8.1 Supabase

Supabase provides database, authentication and related application infrastructure.

8.2 Vercel

Vercel provides website and application hosting, delivery, server-side execution and webhook infrastructure.

8.3 Resend

Resend provides transactional email delivery and related delivery-event information.

8.4 Stripe

Stripe provides checkout, payment processing, subscription billing, payment-method storage, invoices and customer billing tools.

Stripe may act as a processor for some activities and as an independent controller where it determines processing needed to provide its regulated payment services, prevent fraud or meet legal obligations.

8.5 Other recipients

We may disclose information to:

• professional advisers, auditors and insurers;

• regulators, law enforcement, courts or public authorities where lawful;

• a purchaser, investor or successor in a corporate transaction, subject to appropriate safeguards; and

• another provider or integration at the Customer's direction.

We do not disclose Customer Data to unrelated parties merely so they can copy or commercially exploit the Service.

9. Subprocessors for Customer Data

Where Polo HQ acts as processor for an Organisation's Customer Data, subprocessors are governed by the Data Processing Addendum.

The current core list includes Supabase, Vercel and Resend. Stripe processes billing-related data and may have a different legal role depending on the activity.

10. International transfers

Some providers or their subprocessors may process personal information outside the United Kingdom, including in the United States or other countries where they operate.

Where a disclosure is a restricted international transfer under UK data-protection law, we use an available lawful mechanism, such as:

• UK adequacy regulations;

• the UK International Data Transfer Agreement;

• the UK Addendum to approved standard contractual clauses;

• binding corporate rules; or

• another lawful safeguard or exception.

Where required, we or the relevant exporting party assess whether the transfer provides appropriate protection and apply supplementary measures.

You may contact info@polohq.com for further information about relevant safeguards.

11. Retention

We keep personal information only for as long as reasonably necessary for the stated purposes, legal obligations and legitimate claims.

11.1 Active Checkout Trial

Account and Customer Data are retained while the Checkout Trial is active. Stripe and billing records are retained as described below.

11.2 Cancelled Checkout Trial or cancelled paid Account

Cancelling a Checkout Trial locks the Account immediately but does not automatically delete Customer Data. Cancelling after paid billing starts locks the Account when the paid period ends. Account and Customer Data are retained for re-subscription, support, dispute handling and lawful operational purposes until the Account is separately closed or another retention rule applies.

11.3 Full-Access Trial

Full-Access Trial data is retained during the Trial. If the Trial ends without any Plan being chosen, the Account is retained for 90 days and then permanently deleted under section 7. If any Plan is chosen, the Account is removed from that deletion process.

11.4 Free or paid active Account

Customer Data and Account information are retained while the Account remains active, including on Player Free. Inactive Records are retained while the Account remains open so they can be reviewed or reactivated within available capacity.

11.5 Account deletion and closure

A person can delete their account from Settings, under Account & Security, in the app or on the web, or request deletion without signing in at app.polohq.com/delete-account. Deletion is scheduled after a 30-day recovery period during which the account is disabled and can be restored only through the cancellation link emailed to the account address.

When deletion becomes permanent, we delete the sign-in identity, profile details (name, email address, phone number, photo), preferences, registered devices and push tokens, personal tasks and files, notifications, memberships and consent records. Messages the person sent are replaced with a deleted-message placeholder in shared conversations.

Records belonging to a club, team or Organisation, such as horses, practices, lessons, roster entries, finances, stable and maintenance logs and activity timelines, remain with that Organisation, which is the controller of that data; the person's name is removed from them.

Veterinary clinical records submitted by a veterinary account are immutable and must identify the treating practitioner; for such accounts the identity attached to retained clinical records is anonymised and the sign-in identity permanently disabled rather than removed. Financial accounting records remain with the relevant Organisation.

We keep a pseudonymous record of deletion and export events, limited to account identifiers, timestamps and record counts, for security and compliance; it contains no names or email addresses.

Closure and deletion requests handled through support are verified first; operational Customer Data is then ordinarily scheduled for deletion within 90 days, subject to the Data Processing Addendum, legal holds, fraud prevention, dispute handling and protected backups. The Data Retention and Account Deletion Policy describes the full process.

11.6 Billing, tax and accounting records

Invoices, payment and accounting records are normally retained for six years from the end of the relevant company financial year, or longer where required by law or an active investigation.

11.7 Legal acceptance and contract records

Records showing acceptance of Terms, Plan selection and material billing actions are normally retained for six years after the Account relationship ends.

11.8 Security and technical logs

Security, authentication and diagnostic logs are kept for a period proportionate to security and troubleshooting needs. They are normally retained for up to 24 months, unless a longer period is required for an incident, investigation or legal claim.

11.9 Support and complaints

Support and complaint records are retained for as long as needed to resolve the matter and normally for up to three years afterwards, unless linked to a contract, security incident or legal claim requiring longer retention.

11.10 Backups

Residual copies may remain in encrypted or access-restricted backups until overwritten under provider backup cycles. Backup data is not used for ordinary business purposes and will not be restored solely to recover a deleted Account unless legally required or needed for disaster recovery.

12. Security

We use technical and organisational measures designed to protect personal information, including, as appropriate:

• role-based access and authentication controls;

• tenant and database access restrictions;

• row-level security;

• server-side service credentials;

• encrypted network transmission;

• single-use, expiring activation and browser-handoff links;

• Stripe webhook signature verification;

• idempotent event processing;

• audit and security logging;

• restricted administrative access;

• vulnerability, patch and incident-management processes; and

• service-provider due diligence and contractual safeguards.

No system is completely secure. Users must protect credentials, devices and access permissions and report suspected compromise promptly.

13. Children and junior players

Polo HQ is an operational platform for players and Organisations. It is not designed for children to purchase or independently administer an Account.

An Account Manager and paid purchaser must be at least 18.

Users aged 13 to 17 may use the Service only where appropriately authorised by the Organisation and, where required, a parent or guardian. Children under 13 must not create or independently operate a User account.

Organisations may record legitimate information about junior players or members. The Organisation is responsible for safeguarding, lawful basis, transparency and appropriate permissions for that information.

Because an online service may be likely to be accessed by people under 18, Polo HQ assesses children's privacy risk and seeks to apply proportionate, privacy-protective defaults. Concerns about a junior User's information should be sent to the relevant Organisation and may also be sent to info@polohq.com.

14. Your data-protection rights

Depending on the circumstances, you may have the right to:

• access personal information;

• correct inaccurate or incomplete information;

• request erasure;

• restrict processing;

• object to processing based on legitimate interests;

• receive certain information in a portable format;

• withdraw consent where processing is based on consent; and

• complain to a supervisory authority.

These rights are not absolute. An exemption or another person's rights may apply.

Two of these rights have self-service tools in the Service. You can download a copy of your data as a CSV-and-media archive from Settings, under Account & Security, using Download My Data; the download link expires 7 days after the export is generated. The export covers the data you own: an Account Manager also receives the records of the clubs they manage, while every other User receives their own account data only, because operational records belong to the Organisation that controls them. You can delete your account from the same screen, or without signing in at app.polohq.com/delete-account, with the 30-day recovery period described in section 11.5.

Where the request concerns operational data controlled by a Polo HQ Customer, you should normally contact that Customer. Polo HQ will assist the Customer as required by the Data Processing Addendum.

To exercise a right relating to Polo HQ's own controller activities, email info@polohq.com. We may verify identity and authority before acting.

15. Objection to direct marketing

You may object to direct marketing at any time by using the unsubscribe link or contacting info@polohq.com.

This does not stop necessary Account, trial, billing, security or legal communications.

16. Complaints

Please contact info@polohq.com first so we can investigate.

You also have the right to complain to the Information Commissioner's Office, the UK data-protection regulator. Information is available at ico.org.uk.

17. Customer responsibility for third-party data

Customers must:

• have a lawful basis for personal information they upload;

• provide privacy information to affected people where required;

• limit access to authorised Users;

• avoid collecting unnecessary information;

• respect individual rights; and

• comply with safeguarding and special-category-data requirements.

Polo HQ may restrict Customer Data where necessary to protect rights, comply with law or enforce the Terms.

18. Cookies

The Service uses essential cookies or similar technologies for authentication, session management, security and requested functions.

At the date of this policy, Polo HQ does not intentionally use advertising cookies or behavioural profiling cookies. Any non-essential analytics or tracking technology will require an appropriate consent mechanism before use where required by law.

See the Cookie Policy for more detail.

19. Changes to this policy

We may update this Privacy Policy to reflect legal, technical or operational changes.

We will publish the updated version and change the effective date. Material changes may also be notified through the Service or by email.

20. Contact details

POLO HQ LTD
Company number: 17059471
Registered office: 43 Diamond Ridge, Camberley, England, GU15 4LB
Email: info@polohq.com