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Privacy Policy

Equestic | EQ Coach-Copilot | EQ Saddle-Clip

Last updated: 15-08-2026

1. Who We Are and What This Policy Covers

This Privacy Policy describes how Smart Horse Technologies B.V., a company registered in the Netherlands under Chamber of Commerce number 74806068, with its registered address at Rondveld 21, 5845 EP Sint Anthonis, the Netherlands (the “Provider”, “We”, “Us” or “Our”), collects, uses, shares and protects personal data.

We are the data controller responsible for the processing of personal data described in this Privacy Policy.

This Privacy Policy applies to personal data processed in connection with: (i) Our websites, including the web shop and the Online Portal; (ii) the Products We sell, such as sensors and related equipment; (iii) the Applications We provide under the Equestic, EQ Saddle-Clip and EQ Coach-Copilot brands; and (iv) the Services made available through any of the above. Capitalised terms used but not defined in this Privacy Policy have the meanings given to them in Our General Terms and Conditions, available at https://www.equestic.com/terms_and_conditions.

Contact details for privacy matters: privacy@equestic.com; Rondveld 21, 5845 EP Sint Anthonis, the Netherlands; +31 6 22 88 63 00, https://equestic.com.

2. Personal Data We Collect

The personal data We process depends on how You interact with Us: whether You purchase a Product, use an Application or the Online Portal, subscribe to a Plan, or simply visit Our website.

2.1 Data You provide to Us

  • Account data:          
  • Profile data: information You choose to add to Your profile, such as Your riding discipline or experience, and details of the horses You register (for example, the horse’s name, age, breed or discipline). Information about a horse is not in itself personal data, but it becomes personal data where it is linked to You or to another identifiable person.
  • Purchase and delivery data: name, delivery address, contact details, order details and related correspondence, where You purchase a Product or a Plan from Us.
  • Communications: the content of Your support requests, feedback, and any corrections or annotations You make within the Application or the Online Portal.

2.2 Data generated by Your use of the Products, Applications and Services

  • Sensor data: movement metrics, training indicators and related session data captured by the Product during training sessions You record. The Product functions as a data collection device and records data only in connection with sessions initiated by You.
  • Audio recordings and transcriptions: where You actively start an audio recording of a training session, a reflection session or another activity relating to Your horse, We record the audio and generate a transcription of it from which a summary is created for You. Where sensor data is recorded at the same time, the audio and sensor data are integrated. A recording may also capture the voice of another person whom You choose to record, such as a professional advising You on Your horse. No audio is recorded in the background or without Your action. See Section 5 for details.
  • AI Outputs: analyses, segmentations, classifications, comparisons, reports, summaries and recommendations generated from Your data, as described in Section 4.
  • Usage data: Your interactions with the Application and the Online Portal, such as the features You use, the settings You select, and events marking Your progress in the Application (for example, account created, coach rights approved, lesson registered, subscription purchased or cancelled).
  • Technical data: device type and model, operating system, Application version, device and network identifiers (including IP address and advertising identifiers of Your device), connection data (including data required to pair the Product with Your device via Bluetooth), log files and crash reports.
  • Advertising and attribution data: marketing and advertising identifiers and records of Your key in-app actions (such as registration, subscription or recording a session), which may be used to measure the effectiveness of Our advertising and, where We use such functionality on the basis of Your consent, shared with advertising platforms as described in Sections 3 and 7.
  • Location data: the Product does not record geolocation. Your device’s operating system may require location permission to enable Bluetooth connectivity with the Product; where this is the case, the permission is used for connectivity purposes and We do not build location histories of You.

2.3 Data We receive from third parties

We may receive limited data from third parties involved in serving You, such as confirmation of payment status from payment service providers or app stores, and delivery status information from logistics partners.

3. Purposes and Legal Bases of Processing

We process personal data for the purposes, and on the legal bases, set out below. Where We rely on legitimate interests, We have assessed that Our interests are not overridden by Your interests, rights and freedoms; You may object to such processing as described in Section 11.

We do not intend to collect special categories of personal data (such as data concerning health) and ask You not to include such information in Your profile, annotations or recordings.

4. AI Processing and Automated Decision-Making

The Applications, the Online Portal and the Services include AI-powered functionality. In practice, this works as follows.

Speech recognition. Where You record audio of a training session or activity, the audio is converted into text by a specialised third-party speech recognition service acting as Our processor, on Our instructions and under a data processing agreement. These services are used solely to generate the transcription for You and are not permitted to use Your audio or transcriptions for their own purposes, including the training or improvement of their own models.

Analysis by Our own AI models. All further analysis — including segmentation and classification of training sessions and activities, interpretation of transcriptions, correlation of multi-source data, comparison of current and historical performance, and the generation of reports, summaries, recommendations and alerts — is performed by AI models developed and operated by Us, on infrastructure under Our control.

Model improvement. We do not use Your identifiable personal data to train Our AI models. We may use aggregated and anonymised data derived from the use of Our Products, Applications and Services for research, statistical analysis, service improvement and the improvement of Our AI models. Such data can no longer be linked to You.

Insights concerning Your horse. AI Outputs may include observations concerning the condition, gait or performance of a horse — for example, an indication of an irregularity and a suggestion to interrupt training and consult a veterinarian. Such information relates to the horse, not to You, and is not personal data. It is provided for informational purposes only and does not constitute veterinary or other professional advice, as further described in Our General Terms.

No automated decision-making within the meaning of Art. 22 GDPR. AI Outputs are informational in nature: they support Your own judgment and the judgment of the professionals You choose to involve. We do not make decisions based solely on automated processing that produce legal effects concerning You or similarly significantly affect You.

5. Audio and Video Recordings

Audio is recorded only when You actively start a recording of a training, a reflection session or another activity relating to Your horse in the Application. While a recording is in progress, audio and, where applicable, sensor data are captured. Nothing is recorded in the background, and no recording starts without Your action.

You control Your recordings: You can review Your recordings and the related transcriptions, and You can have them deleted at any time by contacting Our support team at service@equestic.com, as described in Section 11.

Other people’s voices. A recording may capture the voices of other people present, either incidentally — such as a coach or other riders present — or because You choose to record them, such as a professional advising You. Where You start a recording, You are responsible for informing the people around You and, where required by applicable law, obtaining their permission. We process such recordings solely to provide the Services to You.

We do not use voice recordings to identify individuals, and We do not process them as biometric data.

Future recording features. Certain recording features, such as video recording, may be introduced in the future. Any such feature will be activated only by Your explicit action, and We will update this Privacy Policy and provide further information before or at the time such a feature is made available.

6. Sharing Your Data with Other Users

By default, Your training data, recordings, transcriptions and AI Outputs are visible only to You. They are shared with other users — for example, with a coach or other team members — only where You have explicitly authorised this within the Application or the Online Portal. You can review and revoke such authorisations at any time.

Features enabling new forms of sharing or interaction between users may be introduced gradually. Any such feature will be initiated and controlled by the users concerned, and further details will be provided within the Application and, where appropriate, in an updated version of this Privacy Policy at the time the feature is made available.

Where a Professional User (a user acting for professional or commercial purposes, such as a coach or trainer other specialist advising You on Your horse) accesses data You have shared, that Professional User is independently responsible for their own use of the data and for the advice and services they provide on the basis of it.

7. Disclosure to Third Parties

We do not sell personal data. We disclose personal data to third parties only where this is necessary to provide the Products, Applications and Services, to perform Our contract with You, to comply with a legal obligation, or as otherwise described in this Privacy Policy. The categories of recipients are:

  • Hosting and infrastructure providers, which host Our systems and data on servers located in the European Union.
  • Speech recognition and other technology providers, which process data on Our instructions to deliver specific functionality, as described in Section 4.
  • Logistics partners, to which We pass Your delivery details for the purpose of shipping Products.
  • Payment service providers and app stores, which process Your payments under their own terms and privacy policies.
  • Communication and analytics service providers, including providers of e-mail delivery, SMS and messaging platforms used to deliver service and support messages (such as WhatsApp, which is operated by Meta), customer support and app analytics tools, which process data on Our instructions. Where We send messages to You via WhatsApp, Your telephone number is processed through Meta’s WhatsApp infrastructure for that purpose.
  • Advertising, measurement and attribution providers, including mobile measurement and attribution providers (acting as Our processor) and advertising platforms (such as Google, Meta and app-store advertising services). Where We share app events or contact details with advertising platforms for advertising and audience-building purposes, We do so on the basis of Your consent, and those platforms may act as independent or joint controllers in respect of the data they receive, under their own privacy policies.
  • Marketing agencies, which We may engage to run campaigns and events and which act on Our instructions as Our processors under data processing agreements.
  • Professional advisers and authorities, where disclosure is required to comply with a legal obligation, to respond to a lawful request, or to establish, exercise or defend legal claims.

Service providers that process personal data on Our behalf do so as processors, under data processing agreements consistent with Art. 28 GDPR. The specific providers We use may change from time to time; this Privacy Policy describes them by category, and We will keep this description up to date.

Klarna. In order to offer You Klarna’s payment options, We will pass to Klarna Bank AB (publ) (https://www.klarna.com) certain of Your personal data, such as contact and order details, only after You have chosen to use a Klarna payment option, so that Klarna can assess whether You qualify for its payment options and tailor those options for You. Your personal data is handled by Klarna in accordance with applicable data protection law and Klarna’s own privacy statement (https://cdn.klarna.com/1.0/shared/content/legal/terms/0/en_nl/privacy).

8. International Transfers

Our core systems, and the infrastructure on which Our own AI models operate, are hosted on servers located in the European Union. Because Our users are located around the world, Your data is delivered to You, and to the users You authorise, wherever You or they access the Applications, the Online Portal or the Services.

Some of Our recipients — in particular advertising and communication providers such as Google and Meta — may process personal data outside the European Economic Area, including in the United States. Where personal data is transferred outside the EEA, We ensure that the transfer is covered by an adequacy decision of the European Commission or by appropriate safeguards within the meaning of Art. 46 GDPR, in particular the European Commission’s Standard Contractual Clauses or, where the recipient is certified, the EU-US Data Privacy Framework. You may contact Us for further information on the safeguards applied.

9. How Long We Keep Personal Data

We keep personal data no longer than is necessary for the purposes for which it was collected, and in any event in accordance with the following retention principles:

Category of data Retention period
Account and profile data For as long as Your account is active; deleted or anonymised within twelve (12) months after the account is closed
Sensor data, session data and AI Outputs For as long as Your account is active, or until You delete the relevant sessions; deleted or anonymised together with the account
Transcriptions and summaries generated from Your recordings Until deleted by You, or until Your account is closed, whichever occurs first
Audio recordings Two (2) weeks after the recording has been processed, so that We can assist You if You ask Us to check or correct the generated text, and deleted thereafter
Purchase, invoicing and payment records Seven (7) years, in accordance with Dutch fiscal retention obligations
Support correspondence Two (2) years after the matter is resolved
Marketing preferences and consents Until consent is withdrawn; a minimal suppression record is kept thereafter to honour Your opt-out
Technical logs and crash reports Up to twelve (12) months
Records of consent (e.g. cookie and marketing consents) For registered users, for as long as the account is active plus 12 months after closure; for non-registered website visitors, for the lifetime of the cookie consent set in the banner (3 months), after which consent is requested again
Advertising, attribution and event data shared with or generated through advertising tools Retained for as long as needed for the related campaign measurement, and in line with the retention applied by the advertising tools concerned

Data may be retained for longer where this is required by law or necessary for the establishment, exercise or defence of legal claims. Aggregated and anonymised data, which can no longer be linked to You, may be retained without limitation.

10. How We Protect Personal Data

We take the protection of Your data seriously and implement appropriate technical and organisational measures to prevent misuse, loss, unauthorised access, unintended disclosure and unauthorised alteration, taking into account the nature of the data and the risks of the processing. If You believe that Your data is not secure, or You see indications of misuse, please contact Us at privacy@equestic.com.

11. Your Rights

Subject to the conditions and limitations of applicable law, You have the right to:

  • access the personal data We hold about You and receive a copy of it;
  • have inaccurate personal data rectified and incomplete personal data completed;
  • have Your personal data erased;
  • restrict the processing of Your personal data, in particular where You contest its accuracy, where the processing is unlawful but You oppose erasure, where We no longer need the data but You require it for legal claims, or where You have objected to processing;
  • receive the personal data You have provided to Us in a structured, commonly used and machine-readable format, and have it transmitted to another controller (data portability);
  • object to processing based on Our legitimate interests, on grounds relating to Your particular situation, and to object at any time to processing for direct marketing purposes; and
  • withdraw any consent You have given, at any time, without affecting the lawfulness of processing carried out before the withdrawal.

How to exercise Your rights. Much of this You can do directly: You can review and update Your profile within the Application. To delete Your recordings, sessions or Your account, please contact Our support team at service@equestic.com and We will action Your request. For all other data protection requests, contact Us at privacy@equestic.com.

You can change or withdraw Your cookie and advertising choices on Our website at any time via the “Cookie Preferences” panel in the footer, and, where consent-based advertising features are offered in the Application, You will be able to manage those choices in the Application settings. For all other requests, contact Us at privacy@equestic.com. To protect Your data, We will verify Your identity in a proportionate manner, normally by corresponding with the e-mail address linked to Your account; We will not ask You for a copy of Your identity document unless no less intrusive means of verification is available. We will respond to Your request without undue delay and in any event within one month, which may be extended by two further months for complex or numerous requests, in which case We will inform You.

Complaints. You have the right to lodge a complaint with a supervisory authority, in particular the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, https://www.autoriteitpersoonsgegevens.nl) via link https://autoriteitpersoonsgegevens.nl/een-tip-of-klacht-indienen-bij-de-ap or the supervisory authority of the EU member state where You habitually reside or work. We would, however, appreciate the opportunity to address Your concerns first.

12. Marketing Communications, Promotions and Events

We distinguish between service communications, which are necessary to operate Your account, orders and subscriptions (and which We may send by e-mail, in-app message, WhatsApp or SMS), and marketing communications. We send marketing communications, including any promotional messages sent by e-mail, WhatsApp or SMS, only with Your consent, and every marketing message contains a simple means of opting out. Withdrawing Your consent does not affect service communications. Marketing agencies and communication platforms We engage for this purpose act on Our instructions as Our processors.

Promotions, giveaways and events. Where You take part in a promotion, giveaway or event organised by Us, We process Your data as described in this Privacy Policy and in the specific terms or consent document of that promotion or event, which will describe any additional data collected, any additional recipients involved (such as an event venue or an agency engaged for the event), and the retention applicable to it.

Advertising and audience targeting. Where We advertise Our Products and Services on third-party platforms (such as Google and Meta) and in app stores, We and those platforms may use cookies, device and advertising identifiers, app events and, where We use such features, contact details (such as e-mail addresses) to measure, optimise and target that advertising, including building audiences of similar users. On Our website, advertising of this kind is activated only with Your consent given via the cookie banner; in the Application, where such advertising features are introduced, they will operate on the basis of Your consent. Information about how Google uses data from sites and apps that use its services is available at https://policies.google.com/technologies/partner-sites.

13. Children

The Products, Applications and Services are not directed at children under the age of sixteen (16), and We do not knowingly collect personal data from them. Where local law requires parental or guardian consent for users below a certain age, the Application may be used only with such consent. If You believe that We have collected personal data of a child without the required consent, please contact Us at privacy@equestic.com and We will delete it.

14. Cookies and Similar Technologies

A cookie is a small text file that is stored on Your computer, tablet or smartphone when You visit Our website. We use the following categories of cookies:

  • Technical and functional cookies, which are necessary for the technical operation of the website and for Your convenience: they ensure that the website works properly and remember Your settings. These cookies are placed without consent.
  • Analytical cookies, which help Us understand how the website is used and optimise it. These are placed only with Your consent.
  • Marketing cookies, which are used for marketing purposes. These are placed only with Your consent.

When You first visit Our website, the cookie banner identifies the cookies used and allows You to give or refuse consent for analytical and marketing cookies. You can change Your choices at any time via the banner. You can also delete previously stored cookies and prevent the storage of new ones through the settings of Your internet browser.

15. Users in the United Kingdom and California

If You are in the United Kingdom, references in this Privacy Policy to the GDPR include the UK GDPR, and You may lodge a complaint with the Information Commissioner’s Office (ICO).

If You are a California resident, then if and to the extent that California privacy law (CCPA/CPRA) applies to Our processing, You may have rights under that law, including the rights to know, access, correct and delete personal information and the right not to be discriminated against for exercising those rights. We do not sell personal information and do not share it for cross-context behavioural advertising. You may exercise these rights through the channels described in Section 11.

16. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time, for example to reflect new features or changes in law. The current version is always available on Our website, with the date of the last update indicated at the top. Where a change materially affects You, We will inform You through the Application or by e-mail before the change takes effect.

17. Language

This Privacy Policy is drawn up in English. If translations are made available, the English version shall prevail in the event of discrepancies.

18. Contact

Smart Horse Technologies B.V., Rondveld 21, 5845 EP Sint Anthonis, the Netherlands; privacy@equestic.com; +31 6 22 88 63 00.