This Privacy Policy is designed to help you understand how POLKA LAB (“POLKA LAB,” “we,” “us,” or “our”) collects, uses, processes and shares information related to your use of our products, services, and the website. This Policy complies with the requirements of the European General Data Protection Regulation (“GDPR”) and seeks to establish the transparent, lawful, fair and secure handling of personal data of our customers and users.
We recommend you read this Policy in full to be aware and informed of the processes your data is involved into and your rights. For any questions regarding this Privacy Policy, collection and use of your data, disclosure and sharing of your data, and other concerns or requests related to your personal data, please contact us at: info@polkalab.xyz.
Privacy Policy Scope
This Privacy Notice applies to personal information processed by us on our website (“Site”).
Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Site after the new Privacy Notice takes effect.
Personal information we collect
The categories of personal information we collect depend on how you interact with us, our Site, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Site, and information from other sources such as third-party services and organizations, as described below.
Personal information you provide to us directly
We may collect personal information that you provide to us.
Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Site, register for our newsletter, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Services provision. When you make an inquiry to enter into service agreement with us, we may ask for your contact information, including your full name, personal address, e-mail address and phone number. In addition, in order to further verify your identity for the purposes of compliance measures imposed by us under the relevant legislative acts, such as AML/FT, we may collect the following personal information from you:
Formal identification information: such as identity documents issued by the competent governmant authorities in the country of your domicile and/or birth, e.g. passport, national ID card, residence permit, driver’s license, birth certificate, visa information, and other relevant identification documents necessary to determine your identity.
Financial information: such as bank account details, tax information, and other relevant information.
Information about your business: such as formal certificate of incorporation issued by the competent authorities of t: country of incorporation of your business, extracts from the commercial registries, tax and/or VAT number and information, Articles and/ or Memorandum of Association, personal identification information about all ultimate beneficial owners (hereinafter: the “UBOs”), shareholders and management board members, information about the origina dn source of funds, etc.
Employment information: such as the job title, location of the employer’s officer and/or job description.
Personal Information Collected Automatically
We may collect personal information automatically when you use our Site.
Automatic Collection of Personal Information. We may collect certain information automatically when you use our Site, such as your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Site, such as pages that you visit before, during and after using our Site, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Site.
Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Site, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Site.
Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Site that collects information about engagement on our Site. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you access to our Site, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
Performance-Related. We may use Technologies to assess the performance of our Site, including as part of our analytic practices to help us understand how individuals use our Site (see Analytics below);
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site. This may include identifying you when you sign into our Site or keeping track of your specified preferences or interests;
Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Site or on third-party digital properties.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
Analytics. We may use Technologies and other third-party tools to process analytics information on our Site. These Technologies allow us to better understand how our digital Site are used and to continually improve and personalize our Site.
Personal Information Collected from Other Sources
Third-Party Services and Sources.
We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Site through a third-party application, such a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
How we use your Personal Information
We use your personal information for a variety of business purposes, including to provide our Site, for administrative purposes, and to market our products and Site, as described below.
Provide Our Site
We use your information to fulfill our contract with you and provide you with our Site, such as:
Providing access to certain areas, functionalities, and features of our Site;
Answering requests for Site support;
Processing meeting requests if you set up one on our Site;
Communicating with you about your activities on our Site, and policy changes.
Administrative Purposes
We use your information for various administrative purposes, such as:
Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Site;
Short-term, transient use, such as contextual customization of ads;
Improving, upgrading, or enhancing our Site;
Developing new products and services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
Debugging to identify and repair errors with our Site;
Auditing relating to interactions, transactions, and other compliance activities;
Sharing personal information with third parties as needed to provide the Site;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations, and ensuring compliance with relevant regulations to prevent anti-money laundering, terrorism financing, fraud and other financial crimes;
Marketing and Advertising our Products and Site
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns and custom audiences advertising.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
Other Purposes
We also use your personal information for other purposes as requested by you or as permitted by applicable law.
With Your Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as information about the device from which you access our Site, or other analyses we create.
Anonymized Data
As defined by the GDPR, anonymization is a technique that alters personal information to the point when it may no longer be directly linked to a particular individual and such an individual may not be identified, directly or indirectly, from such data.
We may employ amonymized data for the purposes of conducting research about quality of our Services, understanding customer needs and demands, conduct marketing, detect and prevent security vulnerabilities and braches, and other relevant business purposes.
How we disclose your Personal Information
We disclose your personal information to third parties for a variety of business purposes, including to provide our Site, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
Disclosures to Provide our Site
The categories of third parties with whom we may share your personal information are described below.
Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Site. This includes service providers and vendors that provide us with IT support, hosting, and related services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Site to collect information regarding your activities and your device (for example, your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “targeted advertising,” “personalized advertising, or cross-context behavioral advertising.”
Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
How we secure this information
We understand the importance of keeping your personal information in a secure and integral manner, as any breach of personal data may lead to detrimental consequences to you. Therefore, we employ various physical, technical and administrative safeguards to ensure intergrity, security and confidentiality of your personal data.
In addition, your personal information is stored by us in an encrypted manner. Such encrypted data is stored and maintainted with the use of our relevant service providers that help us maintaint physical, technical, electronic and administrative safeguards.
At the same time, even with all the security and safety measures imposed by us at all times, we cannot guarantee that your data may not be breached, accessed without authorization or otherwise tainted and leaked. We ask you to kindly acknowledge that a great part in data security lies with you, and it is important to treat your personal data with diligence, attentiveness, and care. It is strongly recommended to check for the safety of your connection (which can be accessed by clicking a lock sign next to the URL field of your browser) to make sure you do not submit your personal information to fraudulent and compromised versions of our website, developed and maintained by unauthorized persons with malicious intent.
Should you become aware of any attempt to misuse your personal information by the above-mentioned or any other malicious means, or should you believe your personal information is not stored, handled and maintained securely by us, please notify us immediately at info@polkalab.xyz.
Your Privacy Choices and Rights
Your Privacy Choices.
The privacy choices you may have about your personal information are determined by applicable law and are described below.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or the Site as you have requested. We may also send you certain non-promotional communications regarding us and our Site, and you will not be able to opt out of those communications (for example, communications regarding our Site or updates to our Terms or this Privacy Notice).
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Site may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights
In accordance with applicable law, you may have the right to:
Confirm Whether We Are Processing Your Personal Information (the right to know);
Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
Request Correction of your personal information where it is inaccurate or incomplete;
Request Deletion of your personal information;
Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
Request Restriction of or Object to our processing of your personal information;
Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; and
Appeal our Decision to decline to process your request.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
International Data Transfers
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
We opt for the most secure and diligent data processors to secure the personal information you are entrusting us with. Some of such processors are located outside of the EU/EEA area in countries that have different regulations on personal information. However, our partners follow the requirements and safeguards of the GDPR when receiving and handling your personal information that we share with them.
For transfers of information to and from processors located in the UK, the European Commission adequacy decision has been adopted, meaning that data may flow freely from the EU/EEA to the UK and back since the EU considers the data protection regime in the UK essentially equivalent to the regime of the GDPR.
For transfers of information into the EU from other countries covered by the European Commission adequacy decisions, such as Andorra, Argentina, Canada, Faroe Islands, Guernsey, Isle of Man, Israel, Japan, Jersey, New Zealand, Switzerland and Uruguay, we are required to comply with the local legal requirements and regulations on transfers of personal data, therefore we make sure the specific arrangements are being followed when receiving data from any of the aforementioned countries.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws (i.e. for transfers of information to processors located in the US), one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses for data protection.
Retention of Personal Information
We store the personal information we collect as described in this Privacy Notice for as long as you use our Site, or as necessary to fulfill the purpose(s) for which it was collected, provide our Site, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
Children's Information
The Site is not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.
Other Provisions, including EU/UK Citizens
Third-Party Websites/Applications/Services.
The Site may contain links to other websites/applications and other websites/applications may reference or link to our Site or the Site may allow you to interact with Third-Party Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the third party’s actions or omissions, including but not limited to their privacy practices, content of such other websites or applications, and errors or bugs in their software. Providing personal information to third-party websites or applications is at your own risk.
Our Lawful Basis for Processing Personal Information.
If your personal information is subject to the EU General Data Protection Regulation or other related legislation, our processing of your personal information is supported by the following lawful bases:
Supervisory Authority.
If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.
EEA Data Protection Authorities (DPAs)
Swiss Federal Data Protection and Information Commissioner (FDPIC)
UK Information Commissioner’s Office (ICO).
Contact Us
POLKA LAB is the controller of the personal information we process under this Privacy Notice.
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: info@polkalab.xyz.