[Draft for solicitor review before publication]
Last updated: [DATE]
This notice explains how [COMPANY NAME] uses personal data when you use caninebreeder.co.uk (the “Site”). It applies to visitors, account holders, advertisers and anyone who sends an enquiry to a breeder through the Site. We process personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Who is the controller
[COMPANY NAME] is the controller for the personal data described here. Company number: [COMPANY NUMBER]. Registered office: [ADDRESS]. Email: [EMAIL]. ICO registration number: [ICO REGISTRATION NUMBER]. We are not required to appoint a statutory data protection officer; our data protection lead can be reached at [EMAIL].
A breeder who receives your enquiry is a separate controller for what they do with your details afterwards.
What we collect
Visitors: IP address, device and browser information, pages visited, referring site and the cookie identifiers described in our Cookie policy.
Account holders and advertisers: name, email address, phone number, postcode and address, password (stored as a hash), seller type, licence number and issuing authority, uploaded documents (for example licence, health test results, registration certificates and docking certificates), photos and listing text, payment confirmation from our payment processor (we never see full card numbers), messages sent and received, verification history, strikes and moderation notes.
Enquirers: name, email address, phone number (optional), your message, the listing you enquired about and technical data such as IP address.
Everyone: reports you make about content, complaints, appeals and correspondence with us.
We do not ask for special category data. Please do not include health or other sensitive information about yourself in messages.
Why we use it and our lawful bases
| Purpose | Lawful basis |
|---|---|
| Creating and running your account, publishing paid listings and taking payment | Contract |
| Passing your enquiry to the breeder and showing them your contact details | Contract (performing the service you asked for) |
| Verifying documents, licences and identity | Legitimate interests: keeping the directory honest and protecting buyers |
| Moderation, fraud prevention, security and enforcing our rules | Legitimate interests, and legal obligation under the Online Safety Act 2023 |
| Keeping records of reports, complaints and takedowns | Legal obligation and legitimate interests |
| Accounting and tax records | Legal obligation |
| Sending service emails (receipts, listing expiry, security alerts) | Contract |
| Sending marketing emails | Consent, which you can withdraw at any time |
| Statistics cookies | Legitimate interests, with a simple opt-out (see Cookie policy) |
| Advertising cookies | Consent |
Where we rely on legitimate interests we have balanced them against your rights and freedoms. You can ask for a summary of that assessment.
Who we share it with
- The breeder you contact (your enquiry and contact details).
- Service providers acting on our instructions: hosting, email delivery, payment processing, analytics, customer support and document storage.
- Public bodies where the law requires or permits it: the police, local authority licensing teams, Trading Standards, Ofcom, the Information Commissioner and the courts.
- A buyer of our business if we sell or restructure it, under confidentiality terms.
We do not sell personal data.
Public information
Breeder profiles and listings are public. Your name or kennel name, general location, licence number and issuing authority, and the details you choose to show are visible to anyone and may be indexed by search engines. Enquirers’ details are never published.
International transfers
We store data in the UK or the European Economic Area. Some providers may process data elsewhere, including the United States. When they do, we rely on UK adequacy regulations or the ICO’s International Data Transfer Agreement or Addendum, and we can provide details on request.
How long we keep it
| Data | Retention |
|---|---|
| Account and profile data | Life of the account, then 12 months |
| Listings and photos | Life of the listing, then archived for [X] years for disputes and record-keeping |
| Verification documents | Life of the badge plus 2 years, then deleted |
| Enquiry messages | 24 months from the message date |
| Reports, complaints, appeals and takedown records | 6 years |
| Payment and tax records | 6 years after the end of the financial year |
| Marketing consents | Until withdrawn, then a suppression record only |
| Server and security logs | 90 days |
We may keep data for longer if a legal claim, regulatory request or investigation requires it.
Your rights
You have the right to access your data; to have it corrected; to have it erased in certain cases; to restrict processing; to data portability; and to object to processing based on legitimate interests, and to direct marketing, at any time. Where we rely on consent you can withdraw it at any time without affecting earlier processing.
To exercise any right, email [EMAIL]. We respond within one month, which we may extend by two months for complex requests, and we may ask you to prove your identity.
Automated decisions
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. Automated filters flag listings and messages for a human to review; a person makes the decision.
Children
The Site is for adults. We do not knowingly collect data from anyone under 18. If you believe a child has given us data, email [EMAIL] and we will delete it.
Cookies
See our Cookie policy for the cookies we use, which ones need consent and how to opt out of statistics cookies.
Complaints
If you are unhappy with how we handle your data, please complain to us first using our Data protection complaints procedure. We acknowledge complaints within 30 days as required by the Data (Use and Access) Act 2025. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint or on 0303 123 1113.
Changes
We will update this notice when our processing changes and show the new date at the top.