This policy replaces the Race Advisor privacy policy dated 30 September 2019.
1. Who we are
Race Advisor is operated by Anonymous Ginger Ltd, a company registered in England and Wales under company number 08236514, whose registered office is at International House, 109-111 Fulham Palace Road, London, W6 8JA. Our VAT number is GB143522830.
We trade as Race Advisor. In this policy, “we”, “us” and “our” mean Anonymous Ginger Ltd. “You” and “your” mean the person whose information we hold.
For the purposes of UK data protection law, Anonymous Ginger Ltd is the controller of the information described here. We are registered with the Information Commissioner’s Office under registration number ZA084458.
To reach us about your information: [email protected], or write to us at the address above.
2. What this policy covers
This policy explains what we collect when you use Race Advisor, why, who we share it with, how long we keep it, and what rights you have.
It covers the website, the racing data and tools, our AI tools, our emails and our support.
Our Terms of Service set out the contract between us, and our Cookie Policy lists the technologies in use on the site.
Race Advisor links to other sites, including bookmakers and exchanges. Once you follow a link away from us, that site’s own privacy policy applies rather than this one.
3. What we collect
You give us: your name, email address and password. Your billing name and address, and the last four digits and expiry of your card, though we never see or hold your full card number because Stripe handles that. Which products you hold and when. Anything you send to support. What you put into our AI tools and the strategies you build. Anything else you choose to tell us, such as survey responses or preferences.
We collect automatically: your IP address, browser, operating system and device type. Which pages and tools you use, and when. Whether you opened an email from us and what you clicked. Cookies and similar technologies, covered in section 8.
We use your IP address to control access to paid products and to spot account sharing and fraudulent sign-ups.
We receive from others: payment and fraud signals from Stripe, and delivery and engagement signals from our email provider.
4. Why we use it, and our lawful basis
We must have a lawful basis for everything we do with your information, and tell you what it is.
| What we do | Lawful basis |
|---|---|
| Run your account, give you access to the tools, take payment | Contract |
| Run the AI Assistant and Strategy Builder, and keep a record of what you put in so they give you better answers | Contract |
| Keep the strategies you build | Contract |
| Send you emails about products you hold | Contract |
| Keep tax and accounting records | Legal obligation |
| Send you marketing emails | Consent, or the soft opt-in for existing customers |
| Look at overall patterns across all users, in a form that does not identify anyone, to decide what to build | Legitimate interests |
| Detect fraud, account sharing and abuse | Legitimate interests |
| Measure how the site is used and improve it | Legitimate interests |
| Keep records to defend chargebacks and disputes | Legitimate interests |
Where we rely on legitimate interests, we have weighed our interest against your rights and concluded it does not override them. You can object at any time. See section 11.
5. Our AI tools
Race Advisor includes AI tools. At the time of writing these are the AI Assistant and the Strategy Builder. This section covers all of them, including any we add later.
What you put in goes to a third party. What you type, together with the racing data needed to answer, is sent to our AI model provider, who processes it on our behalf and returns a result. We currently use Anthropic. We may change provider, and we will update this policy if we do. The provider acts as our processor and is contractually restricted to processing your input for the purpose of returning a result to us.
We do not use what you put in to train AI models.
What we store. We keep a record of what you put in and of the strategies you build, so the tools give you better answers over time. That record personalises your own use of them. We do not use it to personalise anyone else’s.
Separately, we look at overall patterns across all users, in a form that does not identify anyone, to decide which features to build and to develop our racing analysis. We do not single out, copy or resell what any individual has built. You can object to this at any time and we will exclude you.
What the AI says back to you. We also keep a copy of the answer our AI tools give you, for 90 days, after which it is deleted automatically. We keep it for one reason: if you tell us an answer was wrong or unhelpful, we can look at exactly what you were shown and put it right. We do not keep the racing data the answer
was built from. We keep the question you asked only where the assistant could not fully answer it, so we can see what we need to improve. Answers are stored against your account so we can find them if you contact us, and only Race Advisor staff dealing with your query can see them.
To have what we hold from your use of our AI tools deleted, email [email protected].
Please do not put sensitive personal information, financial details, card numbers, passwords or anything confidential into our AI tools. They are for working with racing data.
We do not make automated decisions about you that produce legal or similarly significant effects. Decisions about your account are made by a person.
If you are outside the UK. Race Advisor is aimed at users in the United Kingdom. Some of our customers are in the European Union, where EU law also applies. Rather than run two versions, we apply one standard to everyone and follow whichever gives you more protection. We tell you every purpose up front rather than collecting information for one reason and finding another use for it later.
6. Marketing emails
If you subscribe to our emails, or buy from us, we may send you emails about our racing content and products.
Every marketing email carries an unsubscribe link. Use it at any time and we will stop. Unsubscribing does not stop emails about a product you hold, such as billing notices or your daily selections.
We record whether you opened a message and what you clicked, and use that to judge what to send you and how often.
7. Who we share it with
We do not sell your personal information.
Suppliers who handle it on our behalf. These companies act on our instructions and cannot use your information for their own purposes.
| Supplier | What they do |
|---|---|
| Stripe | Payments and subscription billing |
| Anthropic | Processing what you put into our AI tools |
| Email Octopus | Sending our marketing and product emails |
| Mailgun | Delivering transactional emails |
| DigitalOcean | Hosting the platform |
| Cloudflare | Content delivery, security, and managing the third party tools on our site |
| Zendesk | Handling your support requests |
| Google Analytics | Measuring how the site is used |
Companies that receive it in their own right. Meta receives information about your visit for measuring and targeting our advertising on Facebook and Instagram, and uses it for its own purposes as well as ours. Its own privacy policy governs what it does with it. Nothing in this group is set before you agree, and you can change your mind at any time by using the ‘Cookie preferences’ link in the footer.
We will also disclose information where the law requires it, or to establish or defend legal claims, including chargeback disputes.
8. Cookies
We use cookies and similar technologies to keep you logged in, remember your preferences, and measure how the site is used.
Some do not need your consent, either because they are strictly necessary to provide the service you asked for, or because they are used solely to collect statistics to improve our own site. We still tell you about them and you can object.
For everything else we ask first, and nothing non-essential is set until you agree. You can change your choices at any time by using the ‘Cookie preferences’ link in the footer.
Our Cookie Policy lists every technology in use, what it does and how long it lasts.
9. Sending information outside the UK and the EU
Most of your information stays within the UK or the European Economic Area. Our servers are in the UK, our email lists are held in Ireland, and our transactional email runs on European servers.
Some of the companies in section 7 are based in the United States and your information reaches them there. They are Stripe, Anthropic, Cloudflare, Zendesk and Google. Meta also receives advertising information there, if you have agreed to advertising technologies.
For those transfers we rely on the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, and on the European Commission’s Standard Contractual Clauses. These are standard clauses approved by the UK and EU regulators, and they form part of our contract with each of those companies. You can ask us for a copy by emailing [email protected].
10. How long we keep it
We do not keep your information longer than we need it.
| What | How long |
|---|---|
| Account details | While your account is open. When you close it we delete what we no longer need, keeping only what we must for tax or to deal with a dispute |
| Subscription and payment records | Six years from the end of the relevant financial year, because tax law requires it |
| What you put into our AI tools, and your strategies | While your account is open, or until you ask us to delete them |
| What our AI tools said back to you | 90 days |
| Support correspondence | While it may still be relevant to your account or a dispute |
| Marketing list membership | Until you unsubscribe. We then keep a record that you unsubscribed, solely so we do not email you again |
| Email engagement data | While it is useful for deciding what to send you, and no longer than your account is open |
| Site usage and analytics data | Our analytics provider deletes this automatically after 14 months |
| Fraud and chargeback evidence | While a payment can still be disputed, and afterwards where we may need it to defend a claim |
11. Your rights
You have the right to ask what we hold and get a copy, have it corrected, have it deleted where we have no good reason to keep it, restrict what we do with it while a dispute is resolved, object to our use of it for legitimate interests, object to direct marketing at any time, receive it in a portable form, and withdraw consent where we relied on it.
These rights are free. We will respond within one month, and will tell you if we need to extend that because your request is complex.
If we need more information to identify you or understand what you are asking for, we will ask, and the time limit pauses until you reply. We carry out a reasonable and proportionate search, so we may not be able to return everything from every system.
To exercise any of these, email [email protected]. We will need to verify your identity first.
12. Complaints
If you are unhappy with how we have handled your information, tell us first at [email protected]. You can also raise it through any other route you use to contact us and we will treat it as a complaint.
We will acknowledge it within 30 days, look into it without undue delay, and tell you the outcome.
If you are not satisfied with our response, you can complain to the Information Commissioner’s Office at ico.org.uk. You may go to the ICO at any time, though they will normally expect you to have raised it with us first.
13. Keeping your information safe
We hold your information on servers protected by our hosting providers’ security arrangements and restrict access to it. Payments are handled by Stripe and we never see or store your full card number.
No system is completely secure. If a breach happens that is likely to risk your rights and freedoms, we will tell the ICO within 72 hours, and where the risk is high we will tell you.
14. Age
Race Advisor is for adults. You must be 18 or over to hold an account. We do not knowingly collect information about anyone under 18. If you believe a child has given us information, email [email protected] and we will delete it.
15. Changes to this policy
We will update this policy when what we do changes, and the date at the top always shows the current version. Where a change materially affects your rights, we will tell you by email before it takes effect.