This privacy notice sets out how Polaris UK Ltd (“Polaris”) (company number: 02911441), with a registered address at New London House, 6 London Street, London EC3R 7LP, uses the information we collect from you or that you provide in connection with our website at www.polarisukltd.org, how we safeguard your privacy, and explains your rights in relation to the use of your personal data. Please read this privacy notice carefully to understand how we may process your personal data.

Polaris is the controller of the personal data that we process, or that may be processed on our behalf, in connection with this website.

The information that we collect from you

We may collect the following information about you:
  • the name of the organisation you work for
  • your name and job title
  • contact details (such as your office address, telephone number and email address)
  • your IP address
  • the products and/or service(s) you wish to access; and
  • any other personal information you provide to us.

What we do with the information we gather or which you provide

We require this information in order to:
  • respond to any questions you have raised with us
  • notify you of any updates to website areas in which you have indicated an interest
  • enter into and maintain a contract for provision of our products and services
  • keep internal records and process invoices and payment
  • monitor website usage to help us further develop the website and enhance your user experience;and
  • let you know about new products/services or enhancements to existing products/services.
This personal data may be processed by Polaris or on its behalf in circumstances where it can rely on one or more of the following legal bases:
  • the processing is necessary for the purposes of entering into or performing a contract with you or in order to take steps at your request prior to entering into a contract with you;
  • the processing is based on your consent, which can be withdrawn at any time;
  • the processing is necessary where we, or a third party, has a legitimate interest in processing your personal data such as conducting our business in a commercially prudent manner, managing and improving the performance of the website, improving our products and services or to protect against and prevent fraud; and
  • the processing is necessary for compliance with a legal obligation or other regulatory obligation to which Polaris are subject.
Personal data that we require you to provide
You are not obliged to provide us with any personal data. However, if you want to register with our website in order to avail of certain services such as to access our resources, you will need to provide us with the information that we specify on our website as being required. If you do not provide us with this information, we will not be in a position to process your registration and provide you with the services you are requesting (e.g. accessing our resources). Similarly, you may be required to provide certain information if you contact us with a query or complaint. We will inform you where such information is required.

How we may share your personal data
Your information may be shared with service providers who are acting on our behalf including, in maintaining both the Polaris and imarket websites (the latter being used to provide security passwords for the imarket site), or delivering Polaris products and services, and/or service providers providing administrative support to Polaris.
Details you provide to us when registering for access to the website may also be shared with others within your organisation, but only to validate the request and ensure you are acting on behalf of your organisation.
Your information may be shared with third parties as required or permitted by applicable law including law enforcement authorities.
We will not share your personal data with any other third parties, or use your information for any purpose not stated above.

How long will we retain your personal data?

We do not hold your personal data for longer than is necessary for the purposes for which we obtained it.
Where you enter into a contract with us, we will retain your data for that period or for the period of your engagement with us (whichever is longer) and for a period thereafter (up to 7 years) in case of account/audit queries, or to comply with legal requirements. However, if this is the case we will only retain the data that is necessary to deal with such issues.
If you do not enter into a contract with us, we will retain your personal data for the period necessary to fulfil the purposes outlined in this notice or such longer period as is necessary to comply with our legal requirements or as relevant to deal with any complaint or dispute that might arise in connection with your interactions with us.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, technical and managerial procedures to safeguard and secure the information we collect online.

Links to other websites

Our website contains links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over these other websites. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites, and such sites are not governed by this privacy notice. You should exercise caution and look at the privacy notice applicable to the website in question.

Use of cookies

A cookie is a simple text file that is stored on a computer or mobile device by a website's server, and only that server is able to retrieve or read its contents. It allows a website to remember things like preferences or the contents of a shopping basket. We use "session" cookies on the website. These retain information about your current visit to assist your navigation around the website, so you are not required to enter the same information multiple times during the same visit to the site. Session cookies are deleted from your computer when you close your browser. To the extent that such cookies involve the processing of personal data, that personal data will be treated in accordance with this notice.
For more information on how we use cookies, please read our cookie policy.

Data transfers

If you are accessing this website from within the EU, Polaris may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the EU. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework.

Your rights in relation to your personal data

You have the following rights, in certain circumstances, in relation to your personal data:

  • Right of access - You may request details of personal information that we hold about you and for a copy of the information held.
  • Right of data portability - If you wish us to supply details of data that you have provided to us in a structured, commonly used and machine-readable format to another controller, you can ask us to do so.
  • Right of rectification - If you believe that any information we are holding about you is incorrect or incomplete, you can ask us to promptly correct any information found to be incorrect.
  • Right of erasure - If you wish us to cease processing your personal data, we will remove any data we hold about you unless it is needed to comply with legal or statutory requirements, or we have a legitimate interest in retaining the data (for example because we have no other contact within your organisation). In this case we will only retain any data needed for such purposes.
  • Right to restrict the use of your personal data – If you would like us to restrict the use of your personal data, you can ask us to do so.
  • Right to object - If you wish to object to the processing of your personal data, including requesting that we cease sending emails to you, or to remove your details from our records, please contact us or use the unsubscribe link in the latest email sent to you (as appropriate).
  • Right not to be subject to a decision based solely on automated decision making – You have the right not to be subject to a decision based solely on automated decision making, including profiling, which produces legal effects.
Please contact us to exercise any of the above rights. We will respond to your request within the statutory deadline.
You have a right to complain to the UK’s data protection supervisory body (the Information Commissioner’s Office) if you believe us to be in breach of data protection regulations..

Privacy Notice v1: Published Date 04/05/2020