Privacy notice
Draft for review, not yet legal advice.
Who is responsible for your data
The controller of your personal data is [To be completed: legal entity name, company or registration number, and registered address]. Contact us at hello@kelpais.co.uk. [To be completed: ICO data protection fee registration number, or the reason none is needed] [To be completed: say whether a data protection officer is appointed (usually not required)]
This notice covers the kelpais website (kelpais.co.uk) and the kelpais app (app.kelpais.co.uk).
The short version
- We hold what we need to run your account, your settings and your subscription, and nothing for advertising. We do not sell your data.
- We do not take bets, so we hold no betting history, no bankroll and no bookmaker account details. The bookmaker you pick in Settings is only a preference for which price to show.
- We never see your card number. Stripe takes payments and holds card details.
- The marketing website collects nothing about you. There are no accounts, forms, analytics or tracking there.
What we hold, why, and our legal basis
| Data | Why we use it | Legal basis |
|---|---|---|
| Your email address, your name if you gave one, a hashed password, and whether your email is verified | To create your account, sign you in, verify your email, reset your password and tell you things about your account. | Contract (providing the service you signed up for). |
| Sign-in sessions: a session token, the IP address and the browser or device details (user agent) the session was started from, and when it started and expires | To keep you signed in until 30 days after you last used the app, show and end your sessions, and spot misuse of an account. | Contract, and legitimate interests (keeping accounts secure). |
| Sign-in and sign-up attempt counters, kept against your IP address | To slow down password guessing and mass sign-ups. | Legitimate interests (security and protecting our email reputation). |
| Your settings: your default stake (a display amount), your bookmaker choice, which price to show, your favourite courses, and which picks you follow | To show you prices and returns the way you asked, and to predict your favourite courses. | Contract. |
| Your notifications and alerts, and the time you last pressed a race's re-check button | To deliver the notices you asked for and to stop the re-check button being pressed over and over. | Contract, and legitimate interests (preventing abuse). |
| Push notification subscriptions: your browser's push address and keys, and its user agent, and when you turned them on | To send race notifications to your device, and to show you which devices are on. | Consent. You turn push on in your browser and in Settings, and can turn it off in either at any time. |
| Billing records: your Stripe customer reference, your subscription's status, trial and period dates, whether it will cancel at the end of the period, whether a card is on file, and flags for disputes, refunds or fraud warnings | To start and end your free trial, give you access while you are subscribed, email you about your trial and payments, and deal with disputes and fraud. | Contract, legal obligation (tax and accounting records) and legitimate interests (preventing fraud). |
| A log of the notifications Stripe sends us: event and object references and what we did with them, without card details | To keep your subscription correct and to make sure each notice is handled once. | Contract and legitimate interests. |
| Account emails we send you: verification, password reset, trial ending, payment failed and receipt | To run your account and your subscription. | Contract. |
| The optional morning sheet, a daily email of the day's racing, if you turn it on | To send you the sheet you asked for. | Consent. You switch it on in Settings and can switch it off at any time. |
| Messages you send to hello@kelpais.co.uk, and our replies | To answer you and keep a record of what was agreed. | Legitimate interests (running the service and handling your request), and contract. |
| Technical logs and error reports. Our servers log requests, which can include your IP address. Error reports to our error monitoring tool are stripped of emails, passwords, request bodies, cookies and headers, and keep only an opaque user ID | To keep the service running, find and fix faults, and investigate misuse. | Legitimate interests. |
We do not make decisions about you by automated means that have a legal or similarly significant effect. The predictions on kelpais are about horses and races, not about you.
We do not knowingly collect special category data, and we do not ask for anything about your gambling habits. We do not hold bets you place elsewhere.
If you do not give us your email address and password we cannot make you an account. Everything else in the table is needed to give you the service you asked for, except push notifications and the morning sheet, which are optional.
Who handles your data for us
We use a small number of companies to run kelpais. Each acts as a processor, handling data on our instructions under a data processing agreement, except where we say otherwise.
| Company | What it does | Your data it handles | Where |
|---|---|---|---|
| Railway | Hosts the app, the API, the engine, this website and the database. | Everything in the table above except card details and email delivery. | Our services run in the EU West region (Amsterdam, Netherlands). [To be completed: confirm Railway's data processing agreement is signed, and what its US-based parent can access] |
| Stripe | Takes payments, runs the free trial and subscription, hosts the checkout and customer portal, sends receipts. | Your email, payment card details, billing details and payment history. Stripe is a processor for this, and also a controller for its own fraud prevention and legal duties. | Stripe may process data in the UK, the EU and the US. [To be completed: confirm which Stripe entity contracts with UK customers and its transfer safeguard (Stripe's terms rely on the UK Addendum and the Data Privacy Framework)] |
| Resend | Sends our emails (verification, password reset, trial and payment notices, the morning sheet). | Your email address, the content of each email and delivery details such as bounces. | Resend sends from Ireland (eu-west-1), but says it stores account data and email logs in the United States. Its terms include the UK Addendum to the EU standard contractual clauses and the Data Privacy Framework. [To be completed: confirm the current Resend data processing agreement] |
| Cloudflare | Runs our domain name records and forwards mail sent to hello@kelpais.co.uk to our inbox. | The addresses and contents of the messages you send to us. It does not sit between you and the app. | Cloudflare is a global company. Its terms include the UK Addendum and the Data Privacy Framework. [To be completed: confirm] |
| Our mailbox provider | Holds the inbox where hello@kelpais.co.uk is delivered. | Messages you send us. | [To be completed: name the mailbox provider and where it stores data] |
| Sentry | Collects error reports from our API so we can fix faults. | A stripped-down error report with an opaque user ID. No email, no cookies, no request contents. | [To be completed: confirm Sentry is on in production, its data region, and its data processing agreement] |
| Your browser's push service (for example Google, Apple or Mozilla) | Delivers push notifications to your device if you turn them on. | Your push address and the notification text, which names a race and sometimes a pick. It is not personal to you. | Run by your browser or device maker, under its own terms. |
We also use a licensed racing data supplier (The Racing API), other public racing and weather data sources, and AI services to help write the plain-English explanations of picks. These handle racing data only: horse names, prices, course facts and weather. We do not send them any information about you or any other subscriber.
We may share data if the law or a court requires it, to protect our rights, or if the business is sold (the buyer would be bound by this notice). We do not sell your data and we do not share it with advertisers.
Sending data outside the UK
Our main servers are in the Netherlands, which the UK treats as adequate for personal data. Some of the companies above can also process data in the United States. When they do, the transfer relies on one of: the UK Addendum to the EU standard contractual clauses, the UK-US data bridge, which is the UK Extension to the Data Privacy Framework (where the company is certified), or another safeguard the law accepts. You can ask us for a copy of the safeguard that applies, at hello@kelpais.co.uk.
[To be completed: lawyer to confirm each transfer mechanism against the current agreements]
How long we keep it
- Your account, settings, favourites, followed picks and notifications: while your account is open, and deleted or made anonymous within [To be completed: days, for example 30] after you ask us to close it.
- A sign-in session ends 30 days after you last used the app: using the app renews it (at most once a day), so a session you keep using does not run out. Email verification and password reset links last one hour.
- Billing and tax records (payments, invoices, subscription history): [To be completed: period, usually 6 years for tax and accounting records], even after your account is closed.
- Sign-in attempt counters, request logs and error reports: [To be completed: retention periods; confirm what Railway and Sentry actually keep]
- Emails sent through Resend: Resend keeps delivery logs for [To be completed: retention on our Resend plan; the free plan keeps 30 days].
- Messages to hello@kelpais.co.uk: [To be completed: period, for example 2 years after the matter is closed]
[To be completed: there is no self-service account deletion in the app yet, so the notice tells people to email; confirm that is the process at launch]
Your rights
Under UK data protection law you can ask us to:
- give you a copy of the personal data we hold about you, and tell you how we use it;
- correct data that is wrong or incomplete;
- delete your data, where we no longer need it or do not have a good reason to keep it;
- restrict how we use your data while a problem is sorted out;
- give you your data in a form you can move to another service (for data you gave us and that we use under contract or consent);
- stop using your data where we rely on legitimate interests, unless we have a compelling reason; and
- stop using data that we use on the basis of your consent, by withdrawing it. That does not affect what we did before.
Email hello@kelpais.co.uk. We may need to check it is you. We will reply within one month, and it is free unless a request is clearly unfounded or excessive. You can sign out of every device, change your password and turn off push notifications yourself in Settings, and change your email by writing to us.
If you are unhappy with how we have handled your data, please tell us first so we can put it right. You can also complain to the Information Commissioner's Office (ICO), the UK data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113.
Keeping it safe
Passwords are stored hashed, never as plain text. The app and website use HTTPS. Each person's account data is protected in the database so that one account cannot read another's, and only the people who run kelpais can reach our systems. No system is perfectly safe. If a breach puts your rights at risk we will tell you and the ICO as the law requires.
Children
kelpais is for people aged 18 and over. We do not knowingly hold data about anyone under 18, and we delete it if we find we do.
Cookies
The website sets no cookies. The app sets one sign-in cookie that it needs to work. See our cookie notice.
Changes to this notice
We will update this page if what we do with your data changes, and email you about a change that matters to you. [To be completed: date of the last update, once it is final]