Privacy Policy
Last updated: 27 May 2026
Sillion B.V. (“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 B.V.
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 |
| Follow-up material | Photographs, video, observation records, and notes of changes you submit after the initial report | Comparison with the initial material and written reanalysis within your contracted tier |
| 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 | Payment and order data (bank transfer); we do not store card numbers | Order billing and manual payment confirmation |
3. Legal Basis for Processing
- Contract performance (Art. 6(1)(b)): Delivery of advisory and consulting services, 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 observation note generation, passport data extraction. Horse name, date of birth, breed, coat colour, and optional profile data are sent to Anthropic for processing. Session data may be retained in Anthropic Managed Agent memory for up to 365 days to maintain reading coherence. Anthropic does not use customer data for model training. | 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).
- AI session memory (Anthropic): Retained for up to 365 days to maintain reading coherence across the 7-day cycle. You may request deletion at any time via support@equinenotion.com.
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 B.V. as part of its official terms governing the Equine Notion service. For specific legal questions, please consult a qualified attorney in your jurisdiction.