Haltered handles personal information so the marketplace can work — verifying credentials, processing payments, and routing communication between trainers. We try to keep that footprint small, transparent, and under your control.
01 Scope & Operator
This Privacy Policy applies to information we collect when you use haltered.com and related services (the "Service") operated by The Horsedad LLC dba Haltered, an Arizona limited liability company.
It does not apply to third-party services that may be linked from the Service (for example, Stripe's hosted payment pages, USEF's website, or hauling-partner sites). Each third party has its own privacy policy.
02 What We Collect
We collect personal information directly from you, automatically as you use the Service, and from third parties (such as USEF for credential verification and Stripe for payment processing).
03 How We Use It
We use personal information for the following purposes:
- Operate the marketplace. Create and authenticate accounts, display profiles and listings, route messages between trainers, and run the offer, trial, and contract flows.
- Verify identity and credentials. Confirm USEF membership status for trainers and barns; confirm horse identifiers; protect the marketplace from impersonation and false listings.
- Process payments. Move funds through Stripe Connect; settle to seller and barn payout accounts; calculate and apply commission splits; collect and remit ACH and card processing fees.
- Tax reporting. Calculate annual payments to each trainer and barn; issue Form 1099-NEC at the $600 threshold; report to the IRS and state tax authorities as required.
- Communicate with you. Transactional emails (offer received, contract ready to sign, trial confirmed); customer-support replies; service announcements. Marketing emails only with consent and with an opt-out in every message.
- Trust and safety. Detect fraud and circumvention; review messages flagged by automated filters; investigate disputes; enforce these Terms.
- Improve the Service. Aggregate analytics to understand which features are useful; product-quality bug investigations; A/B test new features.
- Comply with law. Respond to lawful subpoenas, court orders, or other legal process; comply with anti-money-laundering and tax reporting obligations.
04 Legal Basis for Processing
To the extent any privacy law requires us to identify a legal basis, our bases are:
- Contract performance. Most processing — operating your account, processing payments, routing messages — is necessary to provide the Service you requested.
- Legal obligation. Tax reporting, anti-money-laundering, and response to legal process.
- Legitimate interests. Trust and safety, fraud prevention, product analytics, and security monitoring, balanced against your privacy interests.
- Consent. Marketing communications, optional analytics cookies, and any specific features that prompt you for opt-in consent.
06 Stripe & Payment Data
When you connect a payout account or pay for a transaction, you interact with Stripe directly. Stripe's privacy policy governs that interaction. By using payment features on the Service, you agree to Stripe's Connected Account Agreement and Privacy Policy, in addition to this Policy.
07 USEF Verification Data
For trainers and barns, we look up your USEF membership status and your horses' USEF identifiers to verify credentials and to surface verified show records. We share with USEF only the identifiers needed to look up the relevant records (such as USEF member numbers and horse identifiers). We store the look-up results to display "USEF-verified" indicators on profiles and listings.
USEF's processing of your information is governed by USEF's own privacy policy, which is independent of ours.
08 Tax Data (1099-NEC)
Trainers and barns who earn $600 or more in a calendar year through the Service are required to provide a Form W-9, including SSN or EIN. We collect this information for the sole purpose of issuing Form 1099-NEC and reporting to the IRS and applicable state tax authorities.
Tax data is stored separately from general account data, with restricted access limited to the personnel responsible for tax operations. We retain tax records for the period required by law (generally seven years).
10 Security
We protect personal information using a combination of technical, administrative, and physical safeguards:
- Encryption in transit for all communications with the Service (TLS 1.2 or higher).
- Encryption at rest for our databases and file storage.
- Access controls on personnel access to production systems, on a need-to-know basis, with audit logging.
- Stripe handles card and bank-account data on PCI-DSS-compliant infrastructure.
- Security monitoring for unusual access patterns and abuse.
- Chargeback risk is borne by Haltered, not by sellers — see the Terms of Service for the financial allocation.
No system is perfectly secure. If we discover a security incident affecting your personal information, we will notify you and the appropriate authorities as required by law.
11 Data Retention
We retain personal information only as long as we need it for the purposes described in this Policy, then delete or de-identify it. Specifically:
- Account information — for as long as your account is active, plus a limited period after closure to handle disputes and legal obligations.
- Transaction records, contracts, and tax records — at least seven years from the transaction date, to comply with tax and recordkeeping obligations.
- Messaging content — for the life of the relevant transaction plus a reasonable period thereafter for dispute resolution and trust-and-safety review.
- Analytics and security logs — as long as necessary to operate, secure, and improve the Service, typically not more than two years.
- Backups — residual copies may persist in routine backups for a limited period after deletion from active systems.
12 Your Rights & Choices
You have the following rights with respect to your personal information, subject to applicable law and reasonable verification of your identity:
To exercise any of these rights, email [privacy@haltered.com — confirm]. We will respond within the time required by applicable law, generally within thirty days. We may need to verify your identity before fulfilling certain requests.
13 Children's Privacy
The Service is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected information from a child under 13, please contact us and we will delete it.
For minors aged 13 to 17 — riders are common in this age range — personal information is collected only when their parent or guardian creates a Family Account and adds the rider as a child profile. The parent or guardian is responsible for the rider's information and for compliance with COPPA and similar laws.
Barns may not create rider profiles for minors under any circumstances. The financial party of record for any transaction involving a minor is always the minor's parent or guardian.
14 California Residents (CCPA)
If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information we have collected about you, the right to delete that information, the right to correct inaccurate information, and the right to limit the use of sensitive personal information.
To exercise your California rights, follow the process in Section 12. We will not discriminate against you for exercising any of your rights.
[Confirm full CCPA disclosure language and "Do Not Sell or Share My Personal Information" link with counsel before launch, even though we don't sell or share — California requires the link be present.]
15 International Users
The Service is operated from the United States and is intended for users located in the United States. If you access the Service from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data-protection laws may differ from those in your country.
[If Haltered later operates in jurisdictions with GDPR or similar regimes, this section will need expansion — Standard Contractual Clauses, data protection officer designation, etc.]
16 Changes to This Policy
We may update this Privacy Policy from time to time. We will post the updated version with a new effective date. Material changes will be communicated by email or in-app notice when feasible. Your continued use of the Service after the updated effective date constitutes your acceptance of the updated Policy.
17 Contact
For privacy questions, requests, or complaints:
Haltered
[Mailing address — confirm with counsel]
Email: [privacy@haltered.com — confirm]
Web: haltered.com
If you are not satisfied with our response, you may contact a relevant data-protection authority, including the Arizona Attorney General's Office.
This is a working draft prepared for attorney review and is not in effect. Effective date will be posted upon launch.