This Website collects some Personal Data from its Users.
Legal Information
This privacy policy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation – more commonly know as GDPR).
This privacy policy relates solely to this Website, if not stated otherwise within this document.
Owner And Data Controller
POLARIS Agency
20 St Andrew St,
Holborn Circus,
London
EC4A 3AG
Owner contact email: info@polarisagency.co.uk
Types Of Data Collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Cookies and Usage Data are collected at an anonymous level.
First name, last name, phone number, company name, email address and business names are collected when physically included in forms.
Below we have provided complete details on each type of Personal Data collected. This are outlined in dedicated section of this privacy or by specific explanation displayed in advance of any data being collected.
Personal data may be freely provided by the User, or in the case of Anonymous Usage Data, collected automatically when using this website.
Unless otherwise specified, all Data outlined in the requests by this Website is mandatory. Failure to provide this Data may make it impossible for this Website to provide its services, and meet the needs of Users on this Website.
In cases where this Website specifically states Data is not mandatory (such as on form fills), Users are not to communicate this Data without any consequence to the services of this Website or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner on info@polarisagency.co.uk of call 0203 004 9647 for further clarification on data collection and the Users protection upon this data collection.
Any use of Cookies and tracking tools by this Website, or by the owners of third party services used by this Website serves a purpose in providing the Service required by the User. This is further to any other purposes described in any third party tracking and Cookie Policies where present.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode And Place Of Processing The Data
Methods Of Processing
The Owner of the Website takes all needed and appropriate security measures to prevent unauthorised access to the Website, including the disclosure, modification or unauthorised use/destruction of the Data held therein.
The Data Processing for this Website is completed using computers and/or IT enabled tools. The use of any tools is strictly related to the purpose outline herein the Privacy Policy of this Website. In addition to the Owner of this Website, the data collected may be accessible to certain types of persons in charge, involved within the operation of this Website, and the Service it provides.
This includes: Administration, Marketing, Legal, Sales and IT Management. Further, this includes any third party technical service providers, mail carriers, hosting providers and communications agencies used by the Owner of this Website.
If necessary, any future Data Processors appointed by the owner following 08/05/2018 will also have access to this information.
The updated list of these parties may be requested from the Owner at any time.
Legal Basis Of Processing Place
The Data is processed at the Owner’s operating offices based in London and the Owners management offices, based in Surrey and in any other places where the parties involved in the processing are located.
Office locations are outlined below:
POLARIS Agency
20 St Andrew St,
Holborn Circus,
London
EC4A 3AG
Owner contact email: info@polarisagency.co.uk
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are entitled to learn about the legal basis of Data transfers to any country, including those outside of the European Union, or to any international organisation governed by public international law, oe set up by two of more countries – this includes the UN – and about the security measures take by the Owner to safeguard data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention Time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected in relation to the performance of any contract between the Owner and the User shall be retained until such contract is complete and closed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period when the User has given consent to such processing, as long as such consent is not withdrawn. Once consent has been withdrawn the data will be removed.
Further, the Owner of this Website may be obliged by law to retain Personal Data for a longer period. This includes upon the order of an authority and where applicable for financial reporting.
Upon the expiration of any retention period, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Purposes Of Processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes:
Analytics
Contacting the User
Content commenting
Content performance
Features testing (A/B testing)
Displaying content from external platforms
Heat mapping and session recording
Interaction with live chat platforms
Managing contacts and sending messages
Managing landing and invitation pages
Remarketing and behavioural targeting
User database management.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed Information On The Processing Of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable the Owner to monitor and carry out analysis of web traffic and can be used to keep track of User behaviour.
Display Advertising extension for Google Analytics (Google Inc.)
The installed Google Analytics code on this Website will at times use Google’s Interest-based advertising, 3rd-part audience data and information from the DoubleClick Cookie to extend the use of Analytics based on Ad Interaction and Interest data.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads Conversion tracking is an analytics service provided by Facebook, Inc. This tracking connects data from Facebook advertising clicks to actions performed on this website.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps tracking is an analytics service provided by Facebook, Inc. This tracking connects data from Facebook Apps clicks to actions performed on this website.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Google AdWords conversion tracking (Google Inc.)
Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Website. Including the completion of actions. These actions are not identifiable by personal data.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Google Tag Manager (Google Inc.)
Google Tag Manager is an analytics service provided by Google Inc. and allows the Owner of this Website to setup event tracking and other usage data.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
Contacting the User
Contact form (this Website)
Mailing list or newsletter (this Website)
Phone/email contact (this Website)
Users that provided their phone number and email address might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests. This includes any requests for information of services. Further follow-up requests may also be made based on the nature of the request of services that were not purchased at a later date.
Personal Data collected: phone number.
Displaying Content From External Platforms
This type of service allows the User to view content hosted on external platforms directly from the pages of this Website and interact with them in a way that allows the service to be complete.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Inc.)
Google Fonts is a typeface service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages. This includes the provision of text in different formats to all Users.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Heat Mapping And Session Recording
Heat Mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User’s data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data collected: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Managing Contacts And Sending Messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Managing Landing And Invitation Pages
This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Remarketing And Behavioral Targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioural targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioural targeting service provided by Google Inc. that connects the activity of this Website with the Adwords advertising network, related adverts and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioural targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network in order to privde related adverts to users.
Personal Data collected: Cookies and email address.
Place of processing: US – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioural targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network to privde related adverts to a user.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Remarketing through Google Analytics for Display Advertising (Google Inc.)
Google Analytics for Display Advertising is a remarketing and behavioural targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
User Database Management
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner – including the destroying and access of data.
In particular, Users have the right to do the following:
Withdraw their consent at any time.Users always maintain the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data.Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. This includes any relation to personal data provided by a user.
Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected should it be necessary.
Restrict the processing of their Data.Users have the right, under certain circumstances, to restrict the processing of their Personal Data. In this case, data will be stored only.
Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the removal of their Data from the Owner.
Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy
Additional Information About Data Collection And Processing
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Owner remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies
Small piece of data stored in the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Website, if not stated otherwise within this document.
