Part 1 — Terms and Conditions
1. Who we are
EQuelora Companion is a service provided by Johan Pieter van den Herik, trading as EQuelora, registered with the Dutch Chamber of Commerce under number 98674188, with its place of business at Bredaseweg 98, 4902 NS Oosterhout, the Netherlands ("EQuelora", "we", "us"). You can reach us at info@equelora.com, by telephone or WhatsApp on +31 85 200 90 70, or through equelora.com.
In plain language
Who you are dealing with. EQuelora is not a company with staff but one person, Johan Pieter van den Herik, registered with the Dutch Chamber of Commerce. The address and phone number are there because they have to be — you need to know who to turn to if something goes wrong.
This explanation helps you read the article; the article text itself is what counts.2. The service
EQuelora Companion is a personal assistant for horse and rider. The service is made up of modules, such as asking the assistant questions, the record, Growth, Academy and Community; which modules there are may change over time. The Video Analysis module is included in every subscription: you choose a section of 10 to 30 seconds from your own video and may add a question, and the service interprets what happens in that section between you and your horse, in two ways — an open view, and a grounded analysis that refers to moments in your video. For this, the chosen section, with horse and rider in shot, is reduced in size and stripped of sound and shared temporarily with our technical partner (see Article 3 and Part 2, Article 6); nothing is measured on horse or rider. A video in which no horse can be seen is also analysed and costs Credits. There are three subscriptions, WALK, TROT and CANTER:
WALK — free of charge, with a monthly allowance in Credits; see Article 5.
TROT — paid subscription. See Article 5 for the monthly allowance in Credits and the option to buy additional Credits.
CANTER — paid subscription, with a higher monthly allowance than TROT. Which modules belong to which subscription can be found in the app. See Article 5.
Onward Pro is a module through which you find an independent professional, for example a veterinarian, physiotherapist, behavioural specialist, saddle fitter, farrier or trainer. EQuelora does not select or vet these professionals. For a professional with an extended listing, you can send a contact request through the app; you then make arrangements directly with the professional, and EQuelora is not a party to them. This is free of charge for you as a rider; the professional pays separately, under their own terms (see equelora.com/professionals).
You can hold an account in your own name from the age of 16. If the rider is younger, their parent or guardian holds the account and also gives consent for the analysis of video in which the rider can be seen. See Article 4 and Part 2, Article 10.
EQuelora bears the cost of processing and storing your data within the service. The internet connection you need in order to upload video and use the service — including the associated data usage within your own fixed or mobile data plan — is your own responsibility and at your own expense.
To prevent misuse and overload, there are limits on the number of questions and look-ups per day. You will not notice this in normal use; if you do reach a limit, the app will say so and tell you when you can continue.
The service does not provide a diagnosis and does not replace the judgement of a veterinarian, behavioural specialist or instructor. Results are presented with a degree of certainty that matches the degree of actual observation — an interpretation is never presented as established fact. Quantitative or biomechanical measurements are shown only where they have actually been measured through image analysis.
At your request, the service can assess which of your horses appears in a photograph. To do so, that photograph and the profile photographs of your horses are shared at that moment with the same technical partner that carries out the interpretation; nothing is retained in the process. The other photographs in your gallery do not leave your device.
Getting to know the app without an account. You can use the app for a week to look around, without an account and without accepting these terms. During that week you can see what the service looks like; you cannot ask the assistant questions, have video analysed, or enter any data about yourself or your horse. After that week, an account is required in order to continue. The Privacy Statement can also be read in the app without an account. As soon as you create an account, these terms apply — including to the free WALK subscription.
In plain language
What the app does and does not do. The app is made up of modules — asking questions, your record, Growth, Academy, Community — and Video Analysis is part of every subscription. You choose a section of 10 to 30 seconds from your own video and may add a question. That section — with your horse and you in it — goes, reduced in size and without sound, briefly to a technical partner, which describes what happens in two ways: an open view and a grounded analysis. **Nothing is measured on horse or rider: it is an interpretation of the images.** A video without a horse is also analysed, and it costs Credits as usual. There are three subscriptions; CANTER has a higher monthly allowance than TROT. **What exactly belongs to which subscription is shown in the app** — that is where you look to see what you get. There is also Onward Pro: not a subscription but a module that refers you to a real professional, such as a veterinarian, farrier or saddle fitter. Under 16 you do not have your own account; a parent arranges it, including consent for the analysis. And the app makes no diagnosis. What you see is an interpretation, with the level of certainty that goes with it. In Onward Pro we do not select or vet the professionals; for an extended listing you send a contact request through the app, and you then make arrangements with the professional yourself. It is free for you.
This explanation helps you read the article; the article text itself is what counts.3. AI system and transparency
EQuelora Companion uses artificial intelligence to classify behaviour and movement and to present the results to you in understandable language. In accordance with the transparency obligations under the European AI Act (Regulation (EU) 2024/1689) we expressly inform you: where you receive text, an interpretation or a spoken explanation within the service that has been generated by the system, this is always the result of automated processing and not of a human assessor, unless expressly stated otherwise (for example in the case of a referral through Onward Pro to a professional).
As with any AI system, the text, interpretation or spoken explanation generated by the system may contain errors or give an incomplete picture. We advise you to keep looking at generated output critically and, where the result differs from your own observation of the horse or cannot be reconciled with it, not to treat it as established without question. This is separate from the degree of certainty with which a result is presented (see above): even an observation shown with a high degree of certainty may be the result of an error in the underlying AI processing.
Insofar as the analysis of your own posture, tension or movement as a rider also gives an interpretation of your physical or emotional state, we inform you of this separately and expressly: this part of the service may qualify as an emotion recognition system within the meaning of the AI Act, and you are informed of this before you come into contact with it.
The AI assistant is called Lora. Whatever that name suggests, it remains a technical tool: the assistant is not a friend, not a therapist, and has no feelings of its own. The assistant remembers earlier conversations in order to help you better, not in order to build a personal relationship. This explanation is shown to you when you first use the service.
Analysis results are never used to take a decision with legal consequences for you without human involvement. You remain free at all times to set an analysis result aside.
What happens to your video? For the analysis we share the section you choose — with horse and rider in shot, reduced in size and without sound — temporarily with a specialised technical partner (see Part 2, Article 6), which describes what it sees. The video analysis is processed within the EU. This partner does not use your video to train its own AI models, and we never sell your data to third parties. We do not keep video ourselves: your video remains yours, on your own device. The precise terms concerning non-retention by the partner (zero data retention) are laid down in our data processing agreement; for as long as that has not been confirmed, we give no stronger guarantee on this point than described here and in Part 2, Article 8 — as soon as those terms are settled, we will amend this text.
Preliminary assessment of our own — not a legal opinion, prepared in view of professional review
Risk category: on the basis of the current description of the service, EQuelora Companion presumably does not fall under a prohibited practice (Article 5) and not under a high-risk category of Annex III (no recruitment, education, credit provision, law enforcement, migration, critical infrastructure or comparable context). The service therefore appears to fall within the "limited risk" category, to which the transparency obligations of Article 50 apply.
Two separate Article 50 obligations appear to be relevant, not one: (1) the general obligation that users know they are dealing with AI-generated output (Article 50(1)) — addressed in the first paragraph above; and (2) possibly a specific obligation concerning emotion recognition (Article 50(3)) — if the rider-focused analysis (posture, muscle tension) is construed as inferring the emotional state of a natural person, and not only that of the horse.
This distinction was not found in the comparison with competitors’ terms (Annex A). There are providers that measure the rider’s movement or heart rate, but none that infers the rider’s emotional state or addresses this in its terms; no external precedent was therefore found for that question.
This assessment has been drawn up using the same classification criteria (Article 5 prohibited practices, Annex III high-risk categories, Article 50 transparency) as those applied by free self-service scanning tools such as EuroComply and Legibright — see Annex B for the full explanation. This is not a legally binding opinion.
In plain language
Everything the app says to you in words comes from a computer, not from a person. European AI law requires us to say so, and it is simply true. A computer can be wrong: if an outcome does not match what you see in your horse yourself, do not take it at face value. **An outcome that sounds certain can be wrong too** — that is a different kind of error from uncertainty, which is why it is stated separately. Lora is a tool with a name, not a friend and not a therapist. And no decision is ever made about you without a person involved.
This explanation helps you read the article; the article text itself is what counts.4. Your account
To use the service, you create an account. You are responsible for the accuracy of the details you provide.
Access to your account. We work without passwords: you provide your email address and receive a six-digit code at that address, valid for one hour. For as long as that code is valid, it gives access to your account — so do not share it with anyone. You are also responsible for ensuring that only you have access to the email address you provide; anyone who can read that mailbox can gain access to your account. If you change that address, we send a confirmation link to the new address; it becomes your login address only after you have clicked that link. Until that moment, the old address continues to work. Your old address receives notice of the change, with the option to undo it.
If you can no longer log in, you restore access through the purchase of your subscription in the App Store or Google Play, on a device where you are signed in with the same store account. Outside that route we cannot establish with sufficient certainty who is entitled to an account; we would run the risk of disclosing your data to someone else. This does not take away your right to demonstrate by other means that you are the person entitled to the account.
If you do not have a paid subscription, there is no recovery route: your email address is then the only way your account can be reached. That is another reason we recommend making a backup of your own from time to time.
Your data is on your device. The app keeps your horse and rider data, your notes and your analyses on your own device, not with us. If you lose your device or delete the app, we cannot retrieve that data for you; your account and your Credits do remain. You can restore it with a backup you made yourself — in the app under Data and privacy; you decide yourself where that file is saved, and the app reminds you when something has changed since your last backup. On an Android device, the device’s own backup can also restore the data, if you have switched it on; photos are not included. On an iPhone, your own backup is the only way back.
This recommendation is advice, not a condition for using the service, and it does not limit our own obligations. What we keep ourselves, and for how long, is set out in the Privacy Statement (Part 2, Articles 2 and 8).
Age. You can hold an account in your own name from the age of 16. If the rider is younger, their parent or guardian holds the account and decides about the child’s data. When the rider profile is created we ask for the date of birth; we use it to know whether the parent or guardian gives consent. See the Privacy Statement (Part 2, Article 10).
The rider’s date of birth is not mandatory. If the rider is under 16, the parent or guardian who holds the account gives the consent under Part 2, Article 4 — including for the analysis of video in which that rider can be seen.
Payment. You take out a paid subscription through the App Store or Google Play. There, the holder of that store account makes the purchase; if that holder is under 18, the rules of the store concerned for purchases by minors apply, including approval by a parent.
In plain language
How you get in, and what happens when you cannot. There is no password: you get a six-digit code by email, valid for an hour. **Whoever can read your email can reach your account** — that is what it comes down to. If you can no longer reach your email, there is still a way back through the store purchase with a paid subscription, without one there is not. **And your horses, notes and analyses are on your phone, not with us: if you lose your phone or delete the app, your account and your Credits remain, but your record only comes back with a backup you made yourself.** On Android your phone's own backup can also restore it (without photos); on an iPhone your own backup is the only way. The app reminds you when something has changed since your last backup. From 16 you hold your own account; if the rider is younger, a parent holds it. You do not have to fill in your date of birth; if the rider is under 16, the parent who holds the account gives consent.
This explanation helps you read the article; the article text itself is what counts.5. Subscriptions and payment
Your subscription gives you a monthly allowance in Credits. You use that allowance to pay for the parts of the service you use: having images analysed and asking the assistant questions. Each part has a fixed price in Credits, which is the same for all subscriptions; the subscriptions differ in the size of the allowance and in which parts are available. An allowance therefore gives you a quantity, not additional capabilities.
Your subscription takes effect immediately: the monthly allowance is available as soon as the purchase is complete.
The monthly allowance belongs to the month you pay for and lapses at the end of it; at the start of each new month it is made available again. Credits you buy separately do not lapse: they remain available for as long as you have an account, including after a change of subscription. When you use the service, your monthly allowance is used first and your separately purchased Credits only after that.
If we terminate the service, we refund what you have paid for separately purchased Credits that you have not yet used. If you have paid for the current month and we terminate the service during that month, we also refund the proportionate part of that month. If you delete your account yourself, your allowance lapses — both the monthly allowance and the separately purchased Credits — once the 30-day recovery period set out in Part 2, Article 8 has expired. If we terminate your account because you have used the service contrary to Article 7, we refund unused purchased Credits, unless that use was made with those very Credits.
If a fault on our side means you cannot use the service for more than 24 consecutive hours, a proportionate part of your monthly allowance carries over to the following month: one thirtieth of that allowance for each full day the fault lasted.
The service has three subscriptions: WALK, which is free of charge, and the paid subscriptions TROT and CANTER, both on a monthly basis only. We do not offer annual subscriptions. The monthly allowance per subscription, the price per part in Credits and the option to buy additional Credits can be found in the app. These details form part of this agreement.
Upgrading from WALK to TROT, or from TROT to CANTER, takes effect immediately. Any allowance still available from your old subscription remains available after the upgrade; from the next billing month onwards, the monthly allowance of your new subscription applies.
You can cancel at any time, with no notice period. Your subscription then continues until the end of the month you have already paid for and is not renewed after that. If you do not cancel, the subscription is renewed each time for a further month.
If you took out your subscription through the App Store or Google Play, you also cancel it there, in the subscription settings on your device. A message to us does not stop the renewal, because the store manages the payment and the renewal; we cannot stop it for you.
We terminate the service only if we discontinue it, or if continuing it can no longer reasonably be required of us for technical or business reasons. If we terminate the service, we inform you at least 30 days in advance and remind you that you can make a backup of your data before the service goes offline.
In the event of an acquisition, merger or sale of EQuelora Companion, this agreement transfers in its entirety to the acquiring party — your account, your subscription and your allowance in Credits. Your record is on your own device and does not transfer. We inform you of this in advance and you can, at that moment as at any other, cancel your subscription free of charge. Your data is not transferred without prior notice.
If we change the price, the monthly allowance or the price of a part in Credits, we announce this at least 30 days in advance. If you do not agree, you can cancel your subscription free of charge before the change takes effect. An allowance you already hold remains available after a change on the terms under which you obtained it.
Payment is made through the purchase function of the App Store (Apple) or Google Play. Apple and Google respectively are the selling party and process your payment details; from them we receive only the status of your subscription. We do not see your payment details and do not store them.
In plain language
How paying works. You do not buy analyses but Credits, and every part of the service costs a fixed number. **The subscriptions differ in how much allowance you get each month and in which parts are included; the app shows what that is per subscription.** The allowance itself only gives you a quantity — more Credits do not unlock a feature. Your monthly allowance expires at the end of the month; Credits you buy separately do not. You can stop at any time with no notice period, but you cancel where you bought — in the App Store or Google Play, not with us, because they manage the renewal. If *we* stop, you get back the separately bought Credits you have not used, plus the part of the month you had already paid for, and we tell you in time that you can still make a backup. If EQuelora is taken over, your account, subscription and Credits go along — your record does not, it is on your phone. If the app is down for more than a day through our fault, part of your allowance carries over to the next month.
This explanation helps you read the article; the article text itself is what counts.6. Right of withdrawal
Right of withdrawal. As a consumer within the EU you have the right to withdraw from a paid subscription within 14 days of taking it out, without giving a reason.
How you do so depends on where you bought it. If you take out the subscription through the App Store or Google Play, Apple and Google respectively are the selling party and you exercise your right of withdrawal with them, under their terms and through their own procedure. With Google Play you agree on purchase that the service is available immediately and thereby waive your statutory right of withdrawal; with Apple a 14-day cooling-off period of its own applies, which lapses as soon as you request immediate delivery. We cannot ourselves reverse a purchase made through a store, nor refund the amount ourselves.
If you buy directly from us, you exercise the right of withdrawal with us, at info@equelora.com or using the model form in Annex D or at equelora.com/herroeping. If you have expressly asked us to begin before the cooling-off period has expired, you receive the amount paid back less a proportionate part for the period during which you used the service. If you have not made that request, you receive the full amount back.
Apart from the right of withdrawal, you can cancel your subscription at any time — see Article 5.
In plain language
Your fourteen-day cooling-off period, and who you claim it from. That last part is the point: **if you buy through the App Store or Google Play, Apple or Google is the seller, not us.** We cannot reverse such a purchase or refund the money, however much we might want to — you have to go to them, and each has its own rules. With Google you agree at purchase to start immediately and thereby waive your cooling-off period; with Apple you have fourteen days that lapse as soon as you ask for immediate delivery. If you ever buy directly from us, the ordinary arrangement applies and you withdraw with us.
This explanation helps you read the article; the article text itself is what counts.7. Permitted use
You may not use the service to upload material to which you have no rights, for unlawful purposes, or in order to attempt to copy or reverse-engineer EQuelora’s underlying classification method. You are responsible for what you have analysed, including where other people, or animals belonging to others, are in shot; where appropriate, ask them beforehand whether they object.
Analysis results are indicative and intended for personal use. Do not use them as a substitute for professional veterinary, behavioural or training advice. If in doubt, or where a result stands out, always consult a veterinarian or behavioural specialist. Any advice from the service to consult a professional may be given emphatically, but always concerns recommending that step itself; the service never makes any statement about the likely outcome of such an assessment.
EQuelora Companion is a coaching and analysis tool, not a substitute for human contact or professional help. If you notice that a conversation with the assistant is about your own wellbeing rather than about your horse, and you feel that things are not going well for you, please contact someone you trust or, in an emergency, 113 Suicide Prevention — 113.nl, available day and night on 0800-0113. If you are under 18, you can also contact De Kindertelefoon: free and anonymous, every day from 11:00 to 21:00 on 0800-0432 or through the chat at kindertelefoon.nl. The assistant is not equipped to handle signals of this kind and will always refer you on rather than trying to help you itself. The services named here are Dutch; if you use the app from another country, the assistant refers you to the helpline that applies there.
If you use the service contrary to this article, we first warn you and give you the opportunity to stop that use. If it is repeated, or if it is so serious that a warning is not appropriate, we may suspend your access and, if it continues, terminate your account. In all cases we tell you what we are doing and why, and you can respond to that. If we terminate your account on the basis of this article, we refund unused, separately purchased Credits, unless the use contrary to this article was made with those very Credits.
In plain language
What you may not do with the app, and where the app stops. Do not upload footage you have no right to, nothing illegal, and do not try to reconstruct how the app works. **If you film other people, or animals that are not yours, that is your responsibility** — just ask them. More important day to day: **an outcome is a pointer, not a vet's verdict.** If you have doubts, or something strikes you, call a vet or a behaviour specialist — the app can urge you to do so, but never says what will come of it. If a conversation with Lora is about *you* rather than your horse and you are not doing well, she refers you on; she is not built for that. If you breach this article you get a warning first, then a suspension, and only on repetition or something serious does your account go.
This explanation helps you read the article; the article text itself is what counts.8. Intellectual property
All rights in the EQuelora Companion software, the underlying classification method and the imagery of the service itself belong to EQuelora. Analysis results (your personal record) remain your property.
If you sell your horse or hand over its care, you can pass on that horse’s profile to the new owner as a file. You decide yourself whether to do so and what that file contains; it holds the data about the horse, including health data, and not your own rider or combination data. Your own record continues to exist unchanged. We are not a party to that transfer: the file goes directly from you to the recipient, no link is created between the accounts, and from the moment of transfer the recipient is responsible for what they do with that data.
In plain language
Who owns what. The app, the way it analyses and the app's own imagery belong to EQuelora. **What you build up is yours:** your record, the outcomes, your data. If you sell your horse you can hand that horse's profile to the new owner as a file — you decide whether to and what goes in it, and it covers the horse, not you. That file goes straight from you to the other person; we are not in between and no link is created between the two accounts.
This explanation helps you read the article; the article text itself is what counts.9. Liability
We make every effort to provide the service as reliably as possible, but do not guarantee uninterrupted availability or error-free operation.
Irrespective of what follows below, you are legally entitled as a consumer to have the service do what we have said about it. If the service does not conform to the agreement, you can require it to be brought into conformity, ask for a price reduction, or terminate the agreement. You have that right by operation of law; you do not have to pay anything for it and we cannot limit it.
Decisions about your horse and about yourself remain your own decisions. We are not liable for loss arising from decisions you take on the basis of analysis results. That applies both to loss said to have arisen because you did not act on advice to consult a professional, and to loss which you consider to have arisen because such advice subsequently proved unnecessary.
These limitations do not apply in the event of death or personal injury, nor in the event of intent or conscious recklessness on our part. Nor do they apply to your statutory rights where the service does not conform to the agreement.
Nothing in these terms limits rights that you have as a consumer under mandatory Dutch or European law, including protection against unreasonably onerous contract terms (Articles 6:236 and 6:237 of the Dutch Civil Code).
In plain language
What we are and are not answerable for. We do not promise an app that always works and never errs — no such app exists. **Your legal rights stand:** if the service does not do what we say it does, you can demand repair, a price reduction or cancellation, and we cannot write that away. Decisions about your horse remain yours, and we are not liable for their consequences — whether you set aside advice to call a vet, or afterwards feel it was not needed. **Where this expressly does not apply: injury or death, and intent or conscious recklessness on our part.** There we cannot and will not escape.
This explanation helps you read the article; the article text itself is what counts.10. Changes to these terms
We may change these terms. We announce material changes at least 30 days in advance, by email to the address you log in with and also in the app. If you do not agree, you can cancel your subscription free of charge before the change takes effect; if you do not, the amended terms apply from the announced date.
The same applies where we materially limit or discontinue a part of the service without terminating the service as a whole.
In plain language
What happens if we change this text. For a material change you get thirty days' notice, by email at the address you log in with and in the app as well. **If you disagree, you can cancel free of charge before the change takes effect.** If you do not cancel, the new text applies from that date. The same goes if we substantially limit or drop part of the app without shutting it down — you have the same choice.
This explanation helps you read the article; the article text itself is what counts.11. Governing law and disputes
These terms are governed by Dutch law. Disputes are submitted to the competent court in the Netherlands. If you live in another EU Member State, you may also bring proceedings against us before the court of your own place of residence; we may bring proceedings against you only there. If you are a consumer resident in another EU Member State, you continue to enjoy the protection of the mandatory provisions of the law of your own country of residence; this choice of law does not affect that.
Before submitting a dispute to a court, you can lodge a complaint at info@equelora.com; we respond to your complaint within 14 days and then tell you what we will do about it. If we cannot reach agreement together, you can turn to a recognised body for out-of-court dispute resolution. If you are a consumer in another EU Member State, the European Consumer Centre in your country can help you further free of charge.
These terms have been drawn up in Dutch. If you use the app in another language, we provide you with the text in that language so that you can read it; such a translation is given for information only. Where the Dutch text and a translation differ, the Dutch text prevails. This does not affect your rights as a consumer: if you live in another EU Member State, the mandatory protection of the law of your own country of residence continues to apply, whichever language you read these terms in.
In plain language
Which law applies and where you can go. Dutch law, and in principle the Dutch court. **If you live in another EU country you can also take us to court in your own country, and we can only sue you there** — that is a right you have regardless and we cannot remove it. The mandatory consumer rules of your own country also continue to apply to you. But start with an email: we respond within fourteen days and tell you what we are doing with it.
This explanation helps you read the article; the article text itself is what counts.12. Relationship to the test phase
If you take part in a test phase of EQuelora Companion (beta), the additional terms of the separate consent and test document you received and signed at the start of the test apply to that participation. In the event of any conflict between that document and these Terms and Conditions, the test document prevails for test participants for the duration of the test phase.
In plain language
If you take part in the test, another document applies as well. You received and signed it at the start, and it describes the things that are different during a test. **If the two contradict each other, the test document wins** — but only for test participants and only while the test runs.
This explanation helps you read the article; the article text itself is what counts.13. Contact
EQuelora — info@equelora.com — +31 85 200 90 70 — equelora.com — Dutch Chamber of Commerce 98674188 — VAT NL002032075B69
In plain language
Where to reach us. One email address, one website, one registration number. Do write; there is no customer service department in between.
This explanation helps you read the article; the article text itself is what counts.Part 2 — Privacy Statement
1. Who is responsible
EQuelora (Johan Pieter van den Herik, Dutch Chamber of Commerce 98674188, Oosterhout) is the controller within the meaning of the GDPR for the personal data processed within EQuelora Companion.
In plain language
Who is legally answerable for what happens to your data. That is one person with a Chamber of Commerce registration, not a department. For a question or a complaint, that is the address.
This explanation helps you read the article; the article text itself is what counts.2. What data we process
Where your data is. Most of what you enter in the app is kept only on your own device: your rider profile, your horses and what you enter about them, your notes and analyses, your notification settings, your photos and your conversations with the assistant. We receive only what is needed at the moment you ask the assistant something or have an analysis made (see below and Article 6), and we do not keep it. We keep only what we need to provide the service and stay in touch with you.
Account data, kept by us: email address, optionally a telephone number, the purchase ID of your subscription in the App Store or Google Play, your acceptance of these terms (which version and when) and your allowance in Credits. There is no password: the service works without one (see Part 1, Article 4). We keep the purchase ID because it is the only way your access can be restored if you can no longer reach your email address.
Horse and rider data, on your device: what you enter — including name, age or date of birth, discipline and descriptions, and for the rider, if you enter them, previous injuries or medical notes. When you ask the assistant a question, the fields you filled in for your horses go along for that one question (see Article 6); we do not keep them.
Video and analysis (WALK, TROT and CANTER): the section of video you choose, with horse and rider in shot, is reduced in size and stripped of sound, shared temporarily with our technical partner and not kept afterwards; nothing is measured on horse or rider. What is kept, on your device, is the analysis: the text of the readings, the question you added, your answer to whether you recognise it, the start and length of the chosen section, and two numbers by which the app recognises the same video later (the file size and the length) — no images. On your device the app also remembers which section of a video you chose. We only record that an analysis took place, how many seconds of video and whether it succeeded (see Technical and usage data).
Photographs used for horse recognition: if you ask which horse appears in a photograph, that photograph and the profile photographs of your horses are shared at that moment with our technical partner for image analysis. These images are not retained.
Contact requests in Onward Pro: your name, your contact details and the description you write, sent only to the professional you choose, at the moment you send the request. We ourselves keep only the fact that you sent a request to that professional at that moment — not what you wrote — for settling accounts with the professional, any dispute, and the maximum number of requests per day. The overview of your requests and your prepared message are stored only on your own device.
Payment details: processed by Apple and Google respectively as the selling party; from them we receive only the status of your subscription and we do not see your payment details.
Technical and usage data: device type, app version, error reports, usage patterns, and the provenance of each analysis (which AI model produced it, in which version, at which tier, how much video was analysed and when). We use this data to improve the service and also to be able to account for where an earlier result came from. In addition, for each analysis we count, without any data about you, how many seconds of video were analysed, how much computing it took and whether it succeeded. For each account we also record when you last used the app, which app version you have and which country is set in your phone's region settings, so that we know which versions are in use and where the service is used. For each account and each day we count how many questions you asked the assistant, and whether the answer came from our own knowledge base, from an online search or only from the assistant’s own knowledge — without the questions themselves. This lets us monitor usage and see where the knowledge base falls short.
Reports you send us: what you write when you report or ask something through the app, together with the moment you sent it and the technical details of that moment (the screen you were on and the app version). We use these to handle your report, to recognise recurring problems and to improve the service. A report about a professional in Onward Pro is not passed on to that professional, and neither is your name.
In plain language
The full list, and it is worth reading once. **First, where everything is: almost everything you enter — your profile, your horses, your notes and your analyses — is kept only on your own phone.** We keep your email address, your phone number if you gave it, your purchase ID, your Credits and your reports. Beyond that, the key point: **the section of video you choose goes briefly to a technical partner and is not kept afterwards; what stays is the analysis, on your phone** — the text, your question and whether you recognised it. Beyond that: your account details (no password — there isn't one here), what you enter yourself about horse and rider, photos only at the moment of a recognition question, and technical data about how the app runs. For every analysis we record which AI model made it — so it can later be traced where an outcome came from — and we count, without anything about you, how many seconds of video were analysed. **If you send a professional a contact request, your name, contact details and description go only to that professional; we only record that you sent a request, not what you wrote.** Your list of requests and your prepared message are stored only on your phone. We also record when you last used the app, which version you have and which country your phone has set as its region, and per day how many questions you asked and where the answer came from — not what you asked.
This explanation helps you read the article; the article text itself is what counts.3. Why and on what legal basis
Performance of the agreement: account management, carrying out the analysis, answering your questions to the assistant — including looking up current information and comparing a photograph with your horse profiles when you ask for this — and invoicing. Sending a contact request to the professional you choose, when you ask for this, also falls under this heading.
Legitimate interest: improvement of the service, security, fraud prevention, and being able to account for how an analysis came about. For the data of professionals in Onward Pro: helping riders find a professional (see Article 11).
Consent: processing of movement and body data that may be traceable to health-related information about you as a rider (for example posture or muscle tension), and marketing communication.
Profiling and automated decisions. In order to provide the service we automatically assess images of you and your horse and derive an interpretation from them — that is profiling within the meaning of the GDPR. We never use it to take a decision with legal consequences for you without human involvement; nothing is decided about you. What the system sees, and with what degree of certainty, is shown to you with every result, and you are free to set it aside.
In plain language
Why we are allowed to process anything. The law sets out fixed grounds, and three apply here: **because it is needed to deliver the service**, **because we have a legitimate interest** (improving, securing, being able to account for outcomes), and **because you consent** — the last only for the sensitive parts, such as what the analysis may say about your own body. The difference matters: consent you can withdraw, the other two you cannot. It also states that the app profiles — it infers something from images of you — but that no decision is ever made about you.
This explanation helps you read the article; the article text itself is what counts.4. Movement and body data — separate consent
Because video analysis of you as a rider may yield data traceable to your body, posture or health, we ask for separate, express consent for this, apart from the consent for general use of the account. You can withdraw this consent at any time through the settings in the app or at info@equelora.com. Withdrawal does not affect the lawfulness of earlier processing and does not affect your access to WALK.
In plain language
For the analysis of video in which you can be seen we ask separate consent, apart from creating an account. The reason: posture and muscle tension can say something about your health, and stricter rules apply to that. **You can withdraw that consent at any time, and it does not cost you your free access.** What was processed before you withdrew remains lawfully processed — withdrawal works forwards, not backwards.
This explanation helps you read the article; the article text itself is what counts.5. Data protection impact assessment (DPIA)
Given the nature of the processing — systematic analysis of movement and behaviour data through video, possibly traceable to health-related information — we assess whether a data protection impact assessment (DPIA) is required before this processing is carried out at scale. Where a DPIA proves to be required, we carry it out before the processing concerned begins.
In plain language
A DPIA is a mandatory risk assessment beforehand, for processing that is far-reaching enough. This article says we assess whether one is required here and then carry it out before processing at scale begins. **It deliberately does not say it has already been done** — there is a draft, and the real assessment belongs with a specialist.
This explanation helps you read the article; the article text itself is what counts.6. Who we share data with
Our hosting partner for the database and the user accounts: your account data, your Credits, your reports to us and the usage data from Article 2 are kept here — not your horse and rider data or your record, which are on your device. Processing takes place within the EU.
Technical processors for cloud analysis: Google (Gemini) for the video analysis, processed within the EU, and Google (Gemini) and/or Anthropic (Claude) for the assistant — the service may use both or either, depending on technical and regional routing. These parties process your data solely on our instructions, on the basis of a data processing agreement (DPA). For the assistant, each question carries: the conversation so far, the fields you filled in for your horses and which horse you have open in the app. This data is used only for the answer and is not kept by us.
Our supplier for push notifications, solely in order to send notifications to your device; no horse or rider data is included.
Our partner for the website and email, which also sends the login code to your email address: for that purpose it processes your email address, and whatever you send us by email. Processing takes place in the Netherlands. We also use this partner to send the contact requests you send to a professional.
Our supplier for app updates: when your device fetches a new version of the app, this supplier sees your IP address at that moment. No account, horse or rider data is included. This supplier is established in the United States.
The speech recognition of your device: if you speak something in, your device turns the spoken words into text using the speech service set up on it — on most phones Google's, on a Samsung sometimes Bixby's. If your device has the offline language pack for your language, the audio stays on your device; if not, it goes to that speech service, under its own terms. We receive only the text, and you can always type instead.
Your device’s backup: if you have switched on backup on an Android device, your device includes the app’s data in your own backup with Google, under your own account and Google’s terms; photos and your sign-in key are not included. We have no access to it. A backup you make yourself goes to the place you choose.
Our partner for looking up current or location-related information: if you ask a question for which current information is needed, your question — or a search query derived from it — is passed on for that one question to this partner and the search engine it engages for that purpose. Your name, your account and your horse data are not included, nor is your location. This processing takes place outside the EU, on the basis of the standard contractual clauses in the agreement with this partner. When a question needed an online search, we keep a general topic line with a short summary and the sources found — without your question, your name or account, or any details about your horse. We use it to extend our own knowledge base, so that such a question can later be answered without searching online.
Apple and Google, as the selling party for your subscription, solely in order to handle the purchase and its status.
YouTube (Google), when you play a video in Academy or Community. The app shows those videos with YouTube's embedded player. When a video plays, YouTube receives what it collects itself, such as your IP address, information about your device and which video you watch; YouTube is itself responsible for that, under Google's privacy policy. We give YouTube no account, horse or record data. The player loads only after you have given your consent to this once (see Article 12); without that consent you can always watch a video on YouTube itself.
WhatsApp (Meta), if you contact us through WhatsApp: that conversation runs through WhatsApp, which is itself responsible for it under its own terms. We use what you send us that way solely to answer you.
In the context of Onward Pro: the professional you choose, when you send them a contact request. The screen shows beforehand what will be shared; sending it is your choice. From that moment, that professional is themselves responsible for the processing of your data. What you later share with a professional through Follow-up information, you send yourself from your own device; it does not go through us.
We never sell your data to third parties, and your video or behaviour data is not used to train third parties’ underlying AI models (such as Gemini).
In plain language
Everyone who gets to see any of your data, and what for. In short: the party running the database (in the EU; it holds your account and your Credits, not your horses or your record), the technical partners that interpret the images (the video analysis within the EU), the push-notification supplier (which gets nothing about you or your horse), the party that emails your login code, the app-update supplier (which only sees your IP address), your phone's speech recognition when you speak something in, YouTube when you play a video, WhatsApp when you message us there, the party that looks something up when you ask a current-affairs question (without your name, account or location), Apple and Google for payment, and — only if you ask — a professional. When you ask the assistant a question, what you filled in for your horses goes along for that one question; we do not keep it. And if you have your phone's backup switched on on Android, the app's data goes into your own backup with Google — we cannot access it. **Two things are stated firmly: we never sell your data, and your video is not used to train anyone else's AI models.** In Onward Pro, your request goes by email to the professional you choose — through the same party that emails your login code. What you later share yourself through Follow-up information, you send from your own phone; it does not go through us. If your question needed an online search, afterwards we keep only a general topic line with a short summary and the sources found — not your question, not who you are, nothing about your horse — so that next time we can answer that question from our own knowledge base.
This explanation helps you read the article; the article text itself is what counts.7. Transfers outside the EU/EEA
Some of our technical partners, including Google (Gemini) and/or Anthropic (Claude), are established outside the EU/EEA or process data (partly) on servers outside the EU/EEA. Where possible we opt for regional processing — an EU user through the partner’s EU region, a user elsewhere through the nearest region — but we cannot guarantee that processing never takes place outside the EU/EEA. The video analysis is processed within the EU. In those cases we provide appropriate safeguards, such as the European Commission’s Standard Contractual Clauses. Further information on this can be requested at info@equelora.com.
In plain language
Some technical partners are outside Europe, or process partly on servers outside Europe. **It says honestly that we cannot guarantee this never happens** — we choose a European region where we can, but a guarantee would promise more than we can deliver. **The video analysis does take place within the EU.** Where it does go outside Europe, it happens under the European Commission's standard contractual clauses, the standard legal safety net for that.
This explanation helps you read the article; the article text itself is what counts.8. Retention periods
Video: the section you choose for an analysis is not kept after the analysis — not by us and, except for the misuse check below, not by our technical partner. The analysis itself (the text, your question and your recognition) is on your device, for as long as you leave it there.
Analysis results (the record) and horse and rider data: these are on your device and stay there for as long as you leave them; you can delete them yourself in the app. If you ask for your account to be deleted, a recovery period of 30 days applies (in case you change your mind). After that, the next time you open the app on that device, it deletes what it kept itself for this account on that device: your horse and rider data, your record and the photos you added in the app. Only the app’s own data is deleted. Everything else on your device stays — the photos and videos in your gallery, your other apps and their data, and any backup you made yourself. Such a backup, and your device’s backup, are yours to manage; we cannot delete them.
Account data: deleted after the same recovery period of 30 days, with the exception of data we are legally required to keep for longer. The only exception is invoicing data (a statutory tax retention period of 7 years) — this is kept separately from your personal record in our accounts, and is relevant only for paid subscriptions (TROT and CANTER).
Backups of our systems: we make a backup daily and keep it for a maximum of 7 days. If you delete your account, your data disappears from our active systems once the 30-day recovery period has expired; it may then still be present in a backup for a maximum of 7 days, until that copy is automatically overwritten. Backups are shielded and are used solely to recover after a fault or incident — never to bring deleted data back into use.
Our own copy of the database: in addition to the backups at our hosting partner, we sometimes make a copy of the database ourselves, in case something goes wrong at that partner. We keep that copy shielded, outside our hosting partner's systems, and solely in order to be able to recover. We also keep this copy for a maximum of 7 days; after that it is deleted.
Misuse checks at our technical partners: only where an automated check by the partner flags a request as possible misuse may that partner retain the content of that request — possibly including the video — for up to 90 days in order to investigate it. This takes place at the partner and not with us, within the EU, solely in order to counter misuse and never to train AI.
Reports: retained for as long as they are open and for ninety days thereafter. After that we delete what you wrote and what we replied, and only a count remains: what kind of report it was, on which screen and in which app version. If you delete your account, your reports go with it.
Contact requests: we keep only the fact that there was a request, to which listing and when, for as long as this is needed for settling accounts with the professional and any dispute, and thereafter for as long as the statutory tax retention obligation requires. If you delete your account, only the fact that there was a request remains, not who sent it.
Technical and usage data (see Article 2) may be retained after account deletion in anonymised or aggregated form for the purpose of improving the service — in that form it is no longer personal data, and it falls outside this deletion period.
In plain language
How long what is kept. **We do not keep video**, not even if you would like us to; the analysis itself is on your phone. Only if our partner's check flags a request as possible misuse may that partner keep it for up to 90 days — within the EU, never to train AI. Your record and your horses are on your phone for as long as you leave them there. **Ask for your account to be deleted and there are thirty days to change your mind. After that your account is gone from our side, and the next time you open the app it deletes what it kept itself on your phone — only that: your gallery, your other apps and any backup you made stay** — and all we still keep is invoicing, which the tax authority requires us to keep for seven years, and which is held separately from your record. Backups are kept for seven days, so something can linger there briefly after it has gone from the app, and those copies are only used to recover after a failure. Our own copy of the database is also kept for no more than seven days. Of a contact request we keep only the fact that there was one, to whom and when — for settling accounts with the professional. If you delete your account, only the fact that there was a request remains, not who sent it.
This explanation helps you read the article; the article text itself is what counts.9. Your rights
You have the right of access to, rectification of, erasure of and restriction of the processing of your personal data, the right to data portability, and the right to object to processing based on our legitimate interest. Insofar as processing is based on your consent, you can withdraw it at any time. To exercise these rights, please contact us at info@equelora.com; we respond in principle within one month.
In plain language
What you can ask of us, and it is more than most people think. Access to what we hold, correction of what is wrong, deletion, restriction of use, a copy of your data in a file, and objection to processing that rests on our own interest. **If you gave consent, you can always withdraw it.** One email is enough; we respond within a month as a rule.
This explanation helps you read the article; the article text itself is what counts.10. Minors
If the rider is under 16, their parent or guardian holds the account. That person decides about the child’s data, gives the consent under Article 4 — including for the analysis of video in which the child can be seen — and exercises the rights under Article 9 on the child’s behalf. We ask for the date of birth in the rider profile in order to be able to apply this.
In plain language
Under 16 the account is held by a parent or guardian, who decides about the child's data. **That parent also gives consent for the analysis of video in which the child can be seen.** That is why we ask for the date of birth in the rider profile.
This explanation helps you read the article; the article text itself is what counts.11. Data about people other than yourself
If a child under 16 rides on your account, the data about that child is also that child’s personal data. We ask you to explain to the child what the app does with their data; the app also does this itself, in language suited to that. The child has the same rights as you, and you exercise them on the child’s behalf.
If someone else happens to appear in shot during a recording at the stable or in the arena, their data too may be processed briefly during the analysis. We cannot reach that person to tell them; that is why it is stated here. Those images are not retained and are not used to recognise anyone. We ask you to take account of people who do not want to be filmed. If you deliberately film other people, or animals that are not yours, you are responsible for that (see Part 1, Article 7); ask them beforehand whether they object.
Professionals in Onward Pro: for a professional listed in Onward Pro, we process what they themselves make public in order to be found — the name of the practice, the profession, province and country, the website, and a registration that can be checked publicly — or what they give us themselves through the application form. We do so on the basis of our legitimate interest: helping riders find a professional. We let the professional know before a listing becomes visible; if they object, the listing is not published or is removed. More information is in the terms for professionals at equelora.com/professionals.
In plain language
Cases where it is not about you but about someone else. **A child riding on your account** has rights of their own, and you exercise them on their behalf. **Someone who happens to walk into shot** at the stable — we cannot reach them ourselves, so it is stated here; that footage is not kept and not used to recognise anyone. **If you deliberately film other people, or other people's animals, that is your responsibility.** **Professionals in Onward Pro** are also people whose data we process: what they make public themselves in order to be found, or what they give us through the application form. They are told before they become visible, and anyone who objects is not listed or is removed.
This explanation helps you read the article; the article text itself is what counts.12. Cookies
At present equelora.com uses only technically necessary cookies, no tracking or advertising cookies.
In the app we use no tracking or advertising cookies. If you play a video in Academy or Community, YouTube's embedded player loads, and YouTube may store or read information on your device when it does. That is why we ask for your consent once, before the player loads for the first time. You can withdraw that consent in the app's settings; videos can then still be watched on YouTube itself.
In plain language
On the website only what is technically necessary. No tracking, no advertising cookies. The app itself sets none — but the YouTube player in Academy and Community can, so we ask you once whether that is all right. Say no, and you simply watch the video on YouTube itself.
This explanation helps you read the article; the article text itself is what counts.13. Security
We take appropriate technical and organisational measures to protect your data against loss or unlawful processing.
Your horse and rider data and your record are on your device, in the app’s protected storage, which other apps cannot access. How well that data is protected therefore also depends on your device: use a screen lock and keep it up to date. Because this data is not with us, it cannot leak in an incident in our systems.
Those measures include making regular backups of our systems, so that we can restore the availability of and access to your data in a timely manner after a physical or technical incident (Article 32 GDPR). How long we keep those copies, and what that means for deleted data, is set out in Article 8.
In the event of a security incident involving personal data, we report this to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) within 72 hours where this is legally required. If the incident entails a high risk to your rights and freedoms, we also inform you directly, without undue delay.
Whether or not a report to the Dutch Data Protection Authority is legally required, we keep an internal register of every security incident involving personal data (the nature of the incident, its consequences, the measures taken) — in accordance with the statutory documentation obligation, including for incidents that do not have to be reported.
In plain language
What we do to prevent leaks and loss, and what happens when something goes wrong anyway. Daily backups, so there is something to restore after a failure. **Your horses and your record are on your phone, in the app's protected storage; use a screen lock.** What is not with us cannot leak from us. **And in an incident involving personal data: a report to the regulator within 72 hours where required, and direct notice to you if the risk to you is high.** Every incident goes into an internal register, including those that need not be reported.
This explanation helps you read the article; the article text itself is what counts.14. Complaints
Do you have a complaint about how we handle your data? Please contact us first at info@equelora.com. You also have the right to lodge a complaint with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).
In plain language
With us first, and if you get nowhere with us, with the Dutch Data Protection Authority. **That second right is always yours** — you do not need our permission first and you do not have to tell us.
This explanation helps you read the article; the article text itself is what counts.15. Changes
We may change this privacy statement. We announce material changes at least 30 days in advance.
This privacy statement has been drawn up in Dutch. Translations into other languages are provided for information only; where there is any difference, the Dutch text prevails.
In plain language
If something material changes in this statement, you hear about it at least thirty days in advance. That is the same period as for the Terms, with the same purpose: time to see whether you still agree.
This explanation helps you read the article; the article text itself is what counts.16. Contact
EQuelora — info@equelora.com — +31 85 200 90 70 — equelora.com — Dutch Chamber of Commerce 98674188 — VAT NL002032075B69
In plain language
The same address as for the Terms. One email address for everything.
This explanation helps you read the article; the article text itself is what counts.