Legal

Privacy Notice

Last updated: October 2026

This privacy notice (notice) explains how we, Marengo Auctions B.V., a company incorporated in the Netherlands with Chamber of Commerce number 42056183 and registered office at Geerenweg 4, 3755 NM Eemnes, the Netherlands (we, us, our) process your personal data if you use our website, horse trading platform ("Platform"), online content, or otherwise engage with us online or offline.

If you have any question about your data protection rights or if you do not understand anything explained in this notice, please contact us by privacy@marengo.horse for data protection requests, legal@marengo.horse for formal notices and complaints, support@marengo.horse for everything else.

1. Who does this privacy notice apply to?

This notice applies to:

This notice applies to you if you act in your personal capacity, for example, as a private Member of our Platform, and if you act in your professional capacity, for example, as an employee or agent of a business Member of our Platform or supplier.

2. What types of personal data do we process?

“Personal data” means any information that identifies you or relates to you.

This may include your contact details, information about your engagement with us, online behavioural data, and other information as set out in the "categories of personal data" section below.

However, the exact meaning of personal data and the scope of your data rights will be determined by the laws of your country.

3. Data accuracy

We will trust that your personal data is accurate, complete and up to date. We ask that you keep us informed of any changes.

4. How is your personal data collected?

We may collect your personal data as follows:

If you provide information about others, please ensure you have their consent to do so (where required by law) or let us know if you do not.

Our Platform and services are not intended for children, and you must be at least 16 years old to create an account. You must be at least 18 years old to bid, buy or sell on the Platform. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child, we will take appropriate steps to delete it, unless we are required by law to retain it.

5. Signing in with Google or another provider

You can create your Marengo account and sign in with your Google account or with an account you hold with another supported sign-in provider. When you choose one of these options, you sign in with that provider, and the provider asks for your agreement before it shares information with us. We never receive the password for your account with Google or any other provider.

What we receive. Google shares your name, your email address and, if your account has one, your profile picture. Other providers share your name and email address and, if the provider offers it, your profile picture. Some providers let you share a private relay address instead of your own email address. If a provider does not share an email address, you add and verify an email address before you continue.

How we use it. We use the information we receive from Google or another provider only to create your account and to keep it secure: to sign you in, to recognise you when you return, and to prevent duplicate or unauthorised accounts. Your name and email address are filled in on your profile, where you can check and change your name. We do this to perform our contract with you and in our legitimate interest in keeping accounts on our Platform secure.

How we store it. We store this information with your account for as long as your account exists, protected by the measures described in “How do we secure your personal data?” below. When you delete your account, we delete it as described in “Deleting your account and your data” below.

How we share it. We do not sell this information. When you buy or sell a horse, the other party receives your name and contact details so that you can complete the transaction, as described in “Who is your personal data disclosed to?” below. Apart from that, we share this information only with the service providers that host our Platform and run sign-in for us. They process it on our behalf and only on our instructions.

6. Why do we process your personal data?

On some occasions, we process your data with your consent (e.g., when you agree that we may place cookies, or if you ask us to send you information about our services).

On other occasions, we process your data when we need to do this to fulfil a contract with you (e.g., to facilitate your sale or purchase via our Platform) or where we are required to do this by law (e.g., where we have to fulfil anti-money laundering requirements). If it is mandatory for you to provide data for these purposes and you do not provide the data then we may not be able to provide the relevant service to you or facilitate the relevant transaction via our Platform (e.g., that we will not be able to facilitate your sale or purchase).

We also process your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in ensuring the security and integrity of transactions conducted via our Platform, in learning about the interests and preferences of current and prospective customers, in developing new business opportunities, in maintaining accurate business and provenance records, and in ensuring that our website operates effectively. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use the various categories of your personal data. We have also identified what our legitimate interests are where appropriate.

The "lawful basis" column explains how we comply with a technical legal justification for data processing under some data protection laws (e.g. the UK GDPR in the UK and the EU GDPR).

Purpose Personal data Lawful basis of processing (EU / UK only)
To assist with your enquiry.
  • general information
  • contact information
  • user information
 Necessary for our legitimate interest in responding to enquiries and complying with best practice or, as the case may be, necessary for taking steps prior to entering into a contract or the performance of our contract with you.

To register you as a user of our Platform and to publish listing information of our sellers.

Further detail on the information shared between transaction counterparties is set out in section 7 below, “Who is your personal data disclosed to?”
  • general information
  • contact information
  • user information
 Performance of a contract with you, if you are a personal customer or seller, or necessary for our legitimate interests in fulfilling our contractual obligations to our business customers and sellers
To publish and moderate listing questions on our Platform
  • general information
  • contact information
  • user information
 Performance of a contract with you, if you are a personal customer or seller, or necessary for our legitimate interests in fulfilling our contractual obligations to our business customers and sellers
To publish veterinary evidence submitted by sellers with a listing, including radiographs and reports prepared by Veterinarians
  • general information
  • contact information
  • user information
  • veterinary information
 Necessary for our legitimate interests in fulfilling our contractual obligations to our customers and sellers
To facilitate bidding and payment integrity, including card registration and 3-D Secure verification before bidding, an authorisation to collect funds later, and a hold on funds at the moment of purchase, all through our payment processor
  • identity information
  • general information
  • user information
  • financial information
  • transaction information
 Performance of a contract with you, if you are a personal customer or seller, or necessary for our legitimate interests in fulfilling our contractual obligations to our business customers and sellers
To facilitate sales and purchases on our Platform and to provide our services to you including managing payments, fees and charges, preparing invoices in the name and for the account of our sellers, preparing payout statements and facilitating the settlement of the Marengo Guarantee in Marengo Credit, and collecting and recovering money owed to us.
  • identity information
  • general information
  • user information
  • financial information
  • transaction information
 Performance of a contract with you, if you are a personal customer or seller, or necessary for our legitimate interests in fulfilling our contractual obligations to our business customers and sellers, and for recovering debts due to us.
To provide our online services including our Platform, website, content and features to you and the general public which may remember your preferences or include personalised content and services.
  • technical information
  • usage information
  • profile information

Necessary for our legitimate interest in providing our Platform to our users and our website to the public and complying with best practice, the performance of our contract with you as our client and compliance with our legal obligations.

Where required by law, we rely on your consent to deploy cookies or similar technologies on your device or to read information on your device except where necessary for essential services.
To personalise Member accounts and provide saved preferences and listing data
  • technical information
  • usage information
  • profile information
  • user information
 Performance of a contract with you, if you are a personal customer or seller, or necessary for our legitimate interests in fulfilling our contractual obligations to our business customers and sellers
To manage our relationship with you, including sending you service communications about matters relevant to your use of our services and your engagement with us, and other feedback requests and contacting you by phone, email and other means.
  • general information
  • contact information
 Necessary for the performance of our contract with you and our legitimate interest in keeping our records updated, managing our relationship with you or your employer, and understanding how our services are used, views about our services and keeping our users informed.
To conduct onboarding checks, including identity and eligibility verification and VAT number validation through VIES
  • identity information
  • contact information
  • user information
  • financial information
 Necessary for compliance with our legal obligations. Where processing is not strictly required by law, necessary for our legitimate interests in complying with know-your-client best practice, maintaining accurate transaction records and responding to tax authority or regulatory requests.
To comply with tax reporting obligations, including where applicable under DAC7, the UK platform reporting regime rules, including collecting, verifying, retaining and reporting seller information to tax authorities or other regulators
  • identity information
  • contact information
  • user information
  • financial information
  • transaction information
 Necessary for compliance with our legal obligations. Where processing is not strictly required by law, necessary for our legitimate interests in complying with tax reporting best practice, maintaining accurate transaction records and responding to tax authority or regulatory requests.
To send you relevant marketing communications including our email newsletter, and email and social media marketing campaigns as further described in the "direct marketing" section below
  • contact information
  • general information
  • user information
  • profile information
  • technical information
 Consent or, as the case may be, necessary for our legitimate interest (including the soft opt-in, where available) in promoting our organisation.

To assess your job application and for business administration purposes.

For example, if you apply for a job, we will review your CV, publicly available information about you, information from your previous employers and professional references.
  • general information
  • contact information
  • profile information
  • public information
  • special categories of personal data
  • your background information
 Necessary for our legitimate interest in considering applications, responding to queries and, as the case may be, necessary for taking steps prior to entering into a contract. Special categories data may be processed as is necessary in the context of employment and social security laws.
To develop and improve our information, Platform, services, content and features and organisation including measurement of engagement and activity, data analytics, development of our tools, services and algorithms and development of our internal processes. aggregated and anonymised, or pseudonymised usage, profile and technical information

Necessary for our legitimate interest in service and process development and keeping our offering relevant.

Where required by law, we rely on your consent to deploy cookies or similar technologies on your device or to read information on your device except where necessary for essential services.

To ensure the proper administration of our organisation, including to:

  • keep appropriate records;
  • resolve complaints;
  • enforce our terms;
  • debt collection; and
  • similar purposes.
 the relevant categories of personal data described above, limited to what is necessary and proportionate Necessary for compliance with our legal obligations, to establish, exercise or defend legal claims and necessary for our legitimate interest in the proper administration of our organisations and services and protecting our reputation.
To ensure information security of our information systems, Platform, premises, meetings and communications, including rate limiting of registration and profile access, and logging of suspicious or rejected traffic without profile details
  • general information
  • user information
  • security information
  • your background information
 Necessary for our legitimate interest in ensuring the security of people, our organisations and assets and compliance with our contractual obligations, and as necessary for compliance with our legal obligations.
To ensure your health and safety at our premises or to make reasonable adjustments on account of your disability.
  • general information
  • special categories of personal data
 Necessary for our legitimate interest in ensuring health and safety and good accessibility at our premises in the substantial public interest and complying with our legal obligations.
To engage our third-party service providers and advisors who may process your personal data on our behalf or otherwise to facilitate the provision of our services and the fulfilment of essential service functions including cloud storage, telecommunications, information security, professional advice and other services. the relevant categories of personal data described above, limited to what is necessary and proportionate Necessary for our legitimate interest in providing our services and running our organisations.
To monitor interactions and operations for the prevention and detection of crime including fraud and share information with law enforcement authorities and other stakeholders. the relevant categories of personal data described above, limited to what is necessary and proportionate Necessary for our legitimate interest in protecting people, our organisations and assets and detecting and preventing crime, and compliance with our legal obligations.
To share data with another organisation in accordance with the law for the purposes of a joint venture, collaboration, merger or acquisition. the relevant categories of personal data described above, limited to what is necessary and proportionate Necessary for our legitimate interest in undertaking and managing strategic business opportunities and complying with our legal obligations.
Processing and sharing your personal data in connection with legal claims, law enforcement or regulatory requests. the relevant categories of personal data described above, limited to what is necessary and proportionate Necessary for compliance with our legal obligations, to establish, exercise or defend legal claims or for our legitimate interest in complying with best practice.

We may process your personal data for other purposes which are compatible with the existing ones. However, we will obtain your prior consent for any new purpose where required by law.

Direct marketing

You will receive marketing communications including our newsletter and email and social media marketing campaigns from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing. We also conduct advertising campaigns.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view regarding which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you, or by changing your preferences in your Platform account.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to bids, purchases, sales and auctions, appointment reminders, updates to our Terms and Conditions, and checking that your contact details are correct.

7. Who is your personal data disclosed to?

We may share your personal data with the following third parties:

Where these organisations process your personal data on behalf of Marengo, it will be on the basis that these organisations are required to keep the information confidential and secure, and that they will only use the information to carry out the instructed services. Some of these organisations may be located outside the UK or the EEA or the list of countries deemed by the UK or EU authorities to provide adequate level of protection. Any transfer of your personal data to those organisations will be subject to appropriate safeguards such as the standard data protection clauses approved by the UK ICO which are available from the ICO website www.ico.org.uk.

8. How do we secure your personal data?

We have put in place appropriate organisational and technical measures designed to safeguard your personal data that we keep on premise and on our systems. Access to your personal data is restricted on a "need to know" basis.

We seek to ensure our third-party service providers do the same. We appoint service providers only under an appropriate contract who provide sufficient guarantees about data security in accordance with applicable law.

As effective as modern security practices are, we cannot guarantee the complete security of personal data held in our systems, nor that information you supply through the internet or any network is entirely safe from unauthorised intrusion, access or manipulation during transmission. Any transmission is at your own risk. We will deal with any personal data breach in accordance with our incident response procedure and will notify you and the regulator where we are legally required to do so.

9. How long is your data kept?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of maintaining business records and satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

After the retention period, your personal data will either be securely deleted or anonymised, and it may be used for analytical purposes.

10. Deleting your account and your data

You can delete your account and your personal data at any time. Delete your account under Account settings on the Platform, or send your request to privacy@marengo.horse.

Deletion takes effect immediately, and you receive a confirmation. If you send your request by email, we may first ask you to confirm that the request comes from you.

We delete all your personal data, except the transaction records and invoices that we keep for tax purposes for the statutory retention period. At the end of that period, we delete or anonymise them.

The same steps are set out on our data deletion page.

11. Where we store your personal data

Generally, your personal data will be held in the Netherlands, the EEA and by our third party processors in the United States of America.

Where our processors hold your personal data in the United States of America, or where we use tools which require the transfer of your personal data outside the UK, the EEA or any country deemed by the UK or EU authorities to provide an adequate level of protection, we will only make the transfer where we are satisfied that your data protection rights are adequately protected. We will put in place appropriate technical, organisational and contractual safeguards in accordance with applicable data protection laws before any such transfer. These safeguards may include the standard contractual clauses approved by the UK or EU authorities, as applicable.

You may request further information on the measures used for the international transfers or access to your personal data.

12. Third party websites

Our website may contain links to other websites not operated by us. The information you provide to us will not be transmitted to other websites, but these other websites may collect personal information about you in accordance with their own privacy notice and cookies policy. We cannot accept any responsibility for the privacy practices or content of those websites.

13. Your rights

Depending on the data rights granted to you by the laws of your country, you may have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information then please write to us at our registered address (provided above) or email at the below email address (see section 16).

Subject to certain exemptions and conditions, you may also have the following rights in relation to your personal data:

If you wish to exercise any of the rights set out above, please contact us as set out below.

All requests will be processed without undue delay and no later than within one month. We will first require appropriate proof of your identity. Your data rights are not absolute and they are subject to exemptions and limitations under your country's laws. If we cannot process your request within this period, we shall explain why and process it as soon as possible thereafter.

Please note that we will not discriminate against you for exercising any of your rights, for example, by denying you our services, providing lower quality services, or amending our pricing.

14. Third parties may process your personal data

Our website, Platform, content and features may involve the use of third-party services, social media platforms such as X and Instagram, or other third-party services.

We may also share your personal data with third parties, such as event organisers, payment services providers, public authorities and others who process your personal data for their own purposes.

You should check the privacy statements of these third parties, and we are not responsible for how they may process your personal data. Please note some of them may use your personal data for business administration or product development purposes.

15. Automated decision making

We use automated tools to support the operation, security and personalisation of the Platform, including in connection with onboarding checks, VAT validation, payment verification, fraud prevention, traffic monitoring, recommendations and veterinary review. These tools may verify information, flag activity for review, request further authentication or assist with internal decision-making.

We do not use automated processing to make significant decisions about you without meaningful human involvement, except where permitted by applicable data protection law and subject to appropriate safeguards. Decisions to refuse, suspend or unwind transactions are made by our Support team and recorded in an audit log. We do not use automated decision-making in recruitment.

16. Our contact details

If you have any queries or complaints in relation to our processing your personal data please contact us at privacy@marengo.horse.

17. Categories of personal data

We process the following categories of personal data about you:

Contact information including your home or business address, telephone, email and similar information.
Financial information including seller bank accounts for payout, customer payment card details verified through 3-D Secure before bidding, together with an authorisation to collect funds later and a hold of funds at the moment of purchase, and tax information.
General information including your name, job function, education status, gender, date of birth, age bracket, details of your enquiry or communication and similar information.
User information including your buying / selling levels, horse listing details (where you are a seller), veterinary information, inspection arrangements, pricing, bids, guarantees, ownership and provenance information, verified competition results, listing media including the Marengo Reel, photographs and 360-degree video, the questions and replies on a listing, and Marengo Credit and Seller's Side settlement records, preferences, price range, stable address (if different from private address), insurance, transport or delivery arrangements, and other information within your user profile.
Profile information including your demographic information from our analytics and advertising partners, your preferences and interests known, observed or inferred by using analytics, advertising or other tools and sources including notes of your past interactions with us.
Public information from public registers, databases, social media, the Internet and similar sources.
Security information including logs, network monitoring and logging data, antivirus scan and similar information.
Special categories of personal data including your race, ethnic origin, religious or philosophical beliefs, sexual orientation, political or trade union affiliation and information about your health.
Technical information including online identifiers, device ID, internet protocol (IP) address, details of operating system and platform, browser and plug-in type and version, language, time zone setting, location, date and time of access, local storage data and similar information obtained from your device, browser, an API or similar source.
Transaction information including details about payments to and from you and other details of purchases made via our website.
Usage information about how you navigate and engage with our online services, newsletters and marketing communications, features including online activity data such as downloads, clickstream data with URLs visited previously, page interaction, such as scrolling, clicks, and mouse-overs, methods used to browse away from our websites, information in security logs and similar information, funnel milestones and aggregated usage statistics are used for product development, and internal registration alerts report totals rather than individuals
Veterinary information Name and practice details of examining veterinarian who have produced veterinary documents which sellers upload to the Platform.
Your background information including your personal, professional and financial information obtained from you, public sources and third parties such as former employers, colleagues and similar information.

18. Updates to this notice

If we make any changes to our notice, you will be able to see them on this page, as indicated by the “Last updated” date at the top. We encourage you to visit this page periodically to learn of any updates.

If any such changes materially affect you, we will ask for your prior consent where we are required to do so by law.