Legal

Privacy Policy

Last updated: 27 May 2026

Sillion BV (“we,” “us,” “Equine Notion”) is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1. Data Controller

Sillion BV
Voordesdijk 12, 7475 NW Markelo, The Netherlands
KVK: 90687469
VAT: NL865409808B01
Email: support@equinenotion.com

2. Data We Collect

Category	Data	Purpose
Account	Name, email address, password (hashed)	Authentication and service delivery
Horse data	Horse name, date of birth	Five-system pattern analysis, Field Reading
Passport images	Horse passport photograph	Name and date extraction via AI; deleted within 24 hours
Observations	Karte entries (owner observations)	Ongoing pattern tracking and AI analysis
Technical	IP address, browser type, device info	Security, fraud prevention, consent records
Payment	Processed by payment provider; we do not store card numbers	Subscription billing

3. Legal Basis for Processing

Contract performance (Art. 6(1)(b)): Delivery of Field Readings, membership services, Karte system.
Explicit consent (Art. 6(1)(a)): Email sequences, AI-generated analysis, passport image processing.
Legitimate interest (Art. 6(1)(f)): Security, fraud prevention, service improvement.
Legal obligation (Art. 6(1)(c)): Tax records, EU CRD consent documentation.

4. Third-Party Processors

Provider	Purpose	Location	Safeguard
Google (Firebase)	Authentication, database, storage	EU (europe-west1)	EU data residency
Twilio (SendGrid)	Email delivery	USA	Standard Contractual Clauses
Anthropic (Claude)	AI analysis, passport extraction	USA	Standard Contractual Clauses
Vercel	Website hosting	USA/EU	Standard Contractual Clauses

5. International Data Transfers

Where data is transferred outside the EEA (to Anthropic, SendGrid, Vercel), we rely on Standard Contractual Clauses (SCCs) adopted by the European Commission, in accordance with GDPR Art. 46(2)(c).

6. Data Retention

Passport images: Deleted within 24 hours of processing.
Account data: Retained while account is active; deleted within 30 days of account deletion request.
Karte entries: Retained while account is active.
Consent records: Retained for 5 years (legal obligation).
Financial records: Retained for 7 years (Dutch tax law).

7. Your Rights

Under GDPR, you have the right to:

Access your personal data (Art. 15)
Rectify inaccurate data (Art. 16)
Erase your data (“right to be forgotten”) (Art. 17)
Restrict processing (Art. 18)
Data portability (Art. 20)
Object to processing (Art. 21)
Withdraw consent at any time (Art. 7(3))

To exercise these rights, email: support@equinenotion.com. We will respond within 30 days.

8. Supervisory Authority

You have the right to lodge a complaint with the Dutch Data Protection Authority:
Autoriteit Persoonsgegevens (AP)
https://autoriteitpersoonsgegevens.nl

9. Children

Our services are not directed at individuals under 16 years of age. We do not knowingly collect data from children.

10. Changes to This Policy

We may update this policy periodically. Changes will be posted on this page with an updated date. Continued use of the service constitutes acceptance of the revised policy.

This document is provided by Sillion BV as part of its official terms governing the Equine Notion service. For specific legal questions, please consult a qualified attorney in your jurisdiction.