As a collective team, we stand committed to preserving your privacy. With stringent protocols in place, we guarantee the utmost security of your personal data. Upholding strict compliance with legal standards, we safeguard your rights and treat your information with the highest levels of integrity, transparency, and accountability. Rest assured, your privacy is our paramount concern, and we spare no effort in ensuring its protection.

Eng. Hans Wagner

Who is responsible for your personal data?

POLASEN takes responsibility for the personal data that we hold about you. We are a global organisation with a presence in many countries.

Share information about your brand with your customers. Describe a product, make announcements, or welcome customers to your store.

How to contact us

Informaion on which POLASEN Group company or companies are primarly responslble for any personal data colected about you and how to getin fouch, is avaiable in your local cantact
page.

If you would like to receive this, oir any oher noticein anoher ommat or hawe any quesions,commensor concems about how we use the peronal data we hold about yoy, pleose coniacour Global Privacy Team by email at info@polasen.com

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Personal Data

It is not necessary for us to collect every personal detail about you. Our main reason for collecting your personal data is to provide and improve the service, products and experiences that you and our customers expect from us.

Personal data is defined slightly differently across the world. To guarantee your privacy and the protection of your information, we define it as any information that could be used to identify you or another individual.

We collect personal data about you in a number of different ways including:

  1. Through the information you provide when creating an account on our platform.

  2. When you make a purchase or request a service from us, we collect data related to the transaction.

  3. If you participate in surveys, contests, or promotions, we may collect information you provide.

  4. When you interact with our website or mobile app, we automatically collect usage data through cookies and similar technologies.

  5. If you contact our customer support team, we may collect information about your inquiries and communications.

  6. We may receive personal data from third-party service providers, such as payment processors or delivery services, in connection with your transactions.
  7. Through social media platforms if you engage with our content or share it on your profiles.

  8. When you sign up for our newsletter or marketing communications, we collect your contact information.

  9. If you use location-based services, we may collect data about your device's location.

  10. Finally, we may collect information from publicly available sources or from other users who provide information about you.

The personal data that we process about you will mainly fall into one of the following categories:

  1. Contact Information: This includes your name, email address, phone number, and postal address.

  2. Account Details: Information related to your account with us, such as username, password, and account preferences.

  3. Transaction Data: Details about the products or services you have purchased from us, including transaction amount, payment method, and billing details.

  4. Usage Information: Data about how you use our website or mobile app, including browsing history, clickstream data, and interactions with our platform.

  5. Device Information: Information about the device or browser you use to access our services, such as IP address, device type, and operating system.

  6. Location Data: If you enable location-based services, we may collect data about your device's precise or approximate location.

  7. Communication Data: This includes any communications you have with us, such as emails, messages, or calls to our customer support.

  8. Marketing and Preferences: Information about your preferences for receiving marketing communications and your communication preferences.

These categories aim to provide better services and personalized experiences.

Considerations for other identities

If you share the details of other people with us (for example, if you have bought a POLASEN product for another person or if you register another person for a POLASEN app), then you will need to check with that person that they are happy for you to share their personal data with us, and for us to use it in accordance with this privacy notice.

Finally, POLASEN's websites, apps and products are not directed at children. Where we knowingly collect and process children’s data, appropriate information about that processing will be provided at the point of collection. Parental, and or legal guardian, consent for this data will be collected at the time of data collection, as and when required.

How and why we use your personal data

It is not necessary for us to collect every personal detail about you. Our main reason for collecting your personal data is to provide and improve the service, products and experiences that you and our customers expect from us.

Personal data is defined slightly differently across the world. To guarantee your privacy and the protection of your information, we define it as any information that could be used to identify you or another individual.

To provide products and services

This processing includes:

  • managing and coordinating the purchase, delivery and after sales care of your products (as required);
  • responding to your queries and requests (through various channels such as online, in person, over the phone, post, live chat and SMS);
  • documenting, monitoring and recording the lifecycle of our products, including stock management; and
  • contacting you when products or models are next in stock.

To provide support

From time to time, we use your personal data to help you with the POLASEN products you own. If you have a connected product, please visit the Connected Products page for information specific to your product.

We do this by monitoring your product’s performance and sending you relevant product support communications. You can opt out of these activities at any time; see the section below titled “Your controls and choices”.

If you have the MyPOLASEN App , we monitor your product’s performance and stability, which allows us to:

  • Optimise its performance and your experience of the product; in particular, we want to be able to identify when there may be an issue with your product so that we can let you know about it as soon as possible (sometimes we are able to do this before the issue becomes apparent); and
  • Provide updates and services to our connected products (which includes updates and upgrades to the software in the product and the app that connects to it).

Sending you product support communications enables us to:

  • provide helpful information about your POLASEN product or the POLASEN service you use, for example
  • essential product service updates;
  • reminders about how to carry out maintenance for optimal performance;
  • alerts for recommended app or software updates or upgrades that we think will improve the performance of your product;
  • information about how and where to get help from POLASEN experts should you need support;
  • information about your POLASEN warranty; and
  • alerts regarding any important product safety or recall announcements; and
  • provide improved owner experiences via new technologies such as our mobile applications.

As part of these activities, we combine different categories of personal data that we collect about you. For example, we combine personal data from your online interactions, information you share with us, or information from POLASEN products, for the profiling and statistical analysis of product popularity, of your behaviour when you use our website or apps or of how our products are used.

How long do we keep your data?

We only keep your personal data for as long as we need to, to be able to use it for the reasons given in this privacy notice, and for as long as we are required to keep it by law.

The actual period for which we store your personal data will vary depending on the type of personal data and how it is used. For example, when you buy a product from us, we will store information about you and your purchase for at least the term of your warranty or guarantee.

To keep you updated

We love to keep you posted, whether it’s on our latest product announcements, owner offers, opportunities to test new POLASEN products, or upcoming events. From time to time, we may also provide you with information about the Hans Wagner Foundation and the Hans Wagner Award.

Ultimately, we want to make sure you’re happy with the communications you receive from us. We do this by either offering you the opportunity to opt out (e.g., service emails) or requiring you to opt in (e.g., consent to marketing emails). See the section titled “Your controls and choices” for further information.

We will contact you in various ways, including e-mail, post, SMS, in-app and push notifications, via social media platforms and by phone. We use profiling and statistical analysis to identify which communications from POLASEN are relevant and interesting to you.
We do this through:

  • analysing and enhancing the information that we collect;
  • producing user profiles, reports and targeted advertising;
  • only including you in selected marketing campaign and event invitation lists;
  • measuring the effectiveness of our promotional campaigns and advertising; and
  • customising and improving the way that you shop and engage with us in the future (e.g., matching what you see on our website based on what you have previously been interested in).

To promote POLASEN, our products and services

To promote our products we often hold POLASEN events in a variety of venues, such as POLASEN stores or other retailer properties. By attending these events your personal data may be captured:

  • as part of photographs or filming for social media, promotional media or archiving purposes;
  • by our experts and stylists for sharing on social media or in promotional materials; and
  • to book an appointment with one of our experts.

To protect POLASEN and our customers

POLASEN may also process some of the personal data that you provide to:

  • detect and prevent criminal activity, including fraud;
  • keep our websites, apps, products and IT systems secure;
  • assist in any disputes, claims or investigations relating to your POLASEN product or warranty matters;
  • comply with our legal obligations; and
  • provide updates to you about significant changes to POLASEN’s policies, terms and conditions and any other matters which we may need to inform you about.

Our justification for handling your personal data

Data protection and privacy laws in some countries require us to have what's called a "legal basis" or "lawful ground" for handling personal data. Broadly, that means that we have to have a legal justification for handling your personal data.

To process your data we will mainly use the following legal bases:

  1. Contract – e.g. we have to process your delivery and payment details to provide you with the product that you have purchased
  2. Consent – e.g. we will send you marketing communications where you have provided consent
  3. Legitimate interests – e.g. we will process order information to detect fraudulent activities and protect POLASEN and our customers

In some circumstances, we will need to handle your personal data in a certain way to be able to comply with our legal obligations; for example, if we receive a request for your personal data from a regulatory body or law enforcement authority.

Ultimately, the reason we handle your personal data in the way that we do is so that we can directly or indirectly, improve our products, services and your overall experience of POLASEN as a business. Whatever our justification for handling your personal data, we make sure that we take steps to honour our commitment to protect your privacy.

Sharing and transferring your personal data

Most importantly, we never sell your personal data to anyone and only share it as outlined in this privacy notice or when you ask us to.

Sharing within the POLASEN Group

  • Most of POLASEN's processes, procedures and systems are shared across the POLASEN Group, which means that we need to share your personal data between us. We make sure that access to your personal data is limited to those of our staff who need it, and that all staff understand how and why we protect your personal data. Transfers of personal data between POLASEN entities (including those outside of the EEA) are governed by POLASEN’s Intercompany Agreement.

Sharing with third parties

We share your personal data with certain third party service providers. They only have access to the personal data they need to perform those services. For example, your order and delivery details will be shared with our couriers. They are required to keep your personal data confidential, must not use it other than instructed by us and must always act in accordance with this privacy notice.

The third parties providing services fall into the following categories:

  • Distributors, who help us to sell our products in certain countries;
  • Those helping us to deliver products to you;
  • Those helping us to provide you with relevant and interesting communications (e.g., social media platforms, analytics companies, marketing and advertising agencies);
  • Third parties that help us with mailing services, product services and repairs, processing product purchases, financial services, audit services, administrative services, IT technologies (e.g., data storage), security services and insurance claims; and
  • Third parties that help us to provide services and responses to you.

We share certain personal data with third parties who help us to detect and prevent criminal activity (such as fraudulent transactions). The information we share with those third parties includes some of the information that you share with us (such as your contact details and information about the transaction), and some of the information from your online interactions (such as the IP address of your device). That information is used to determine whether a transaction could be fraudulent. One of the third parties we use to help us detect and prevent fraudulent transactions is a company called Riskified; they are responsible for their use of your personal data and will use it for the purposes set out in their privacy notice.

We will also share your personal data if we are required to do so by law, including in response to a legal process, such as a court order or subpoena, or to comply with other national, state, provincial or local laws.

Finally, in the process of purchasing a POLASEN product you may interact with a third party who will be independently responsible for the personal data that you provide. For example, if you purchase a POLASEN product under finance, your finance agreement will be directly with that third party and you should read their privacy notice(s) separately.

Transfer, storage and the global handling of your personal data

The relevant POLASEN group company or companies will collect personal data from you in the country in which you live. We, and those third parties that we share your personal data with, then host, store and otherwise handle that information in the UK, in the countries within the European Economic Area (EEA) or in any country outside of the EEA, including those listed in the Contacts page.

We will make sure that any transfers of your personal data from one country to another comply with those data protection and privacy laws which apply to us.

European data protection laws, in particular, include specific rules on transferring personal data outside the EEA. Transfers of personal data between POLASEN entities (including those outside of the EEA) are governed by POLASEN’s Intercompany Agreement.

When transferring personal data outside the EEA, we will:

  • include standard data protection contractual clauses approved by the European Commission for transferring personal data outside the EEA into our contracts with those third parties; and

ensure that the country in which your personal data will be handled has been deemed "adequate" by the European Commission.

  • Ensure a data transfer risk assessment has been conducted

In any case, our transfer, storage and handling of your personal data will continue to be governed by this privacy notice.

Interaction between our connected products and third party products

We have added functionality to some of our connected products which allows your POLASEN product to interact with certain third party products that you have in your home (such as Amazon Echo, otherwise known as Alexa). This functionality allows you to take full advantage of a “smart home” environment. However, the products will only interact if you want them to, by enabling the relevant functionality.

If you choose to allow your POLASEN connected product to interact with a third party product, certain information (including potentially personal data) will need to be shared with the third party product and the relevant third party provider. Generally, we will need to share a unique reference number to connect the two products, and information about your product and how you use it. We only share the minimum amount of personal data that we need, to enable the two products to interact. Details of how the third party uses your personal data (as well as any personal data which it collects through its own product) are set out in the third party's privacy notice. You should carefully review third parties' privacy notice(s) before using their products, and before connecting them with your POLASEN connected product. You can stop your POLASEN connected product from sharing information with the third party product at any time by disabling the connection between the two.

See POLASEN smart machines for further information specific to your product.

Links to third party websites

We provide links to other websites which are not operated and controlled by POLASEN. We have no control over and are not responsible for the content of those sites or how the third parties responsible for them collect and use your personal data. We do not endorse or make any representations about third party websites.

Third party websites usually have their own privacy notices explaining how they use and share your personal data. You should carefully review those privacy notices before you use these websites to make sure that you are happy with how your personal data is being collected and shared.

Your controls and choices

Where possible, we give you control over the personal data we collect about you, to ensure it is accurate and reflects your preferences. You have the right to access, update and amend personal data that we hold about you; you can do that in relation to some of your personal data through your account with POLASEN.

We will only send you marketing communications when you have told us that you are happy for us to do so. If you have previously said that you would like us to contact you ("opted in") but would like to change or update the way that we do so, you can update your preferences by:

    ◦ Contacting POLASEN customer service and stating that you would like to change or update the way that we contact you;

       or

    ◦ Logging onto your account on our website and changing your preferences and information.

In certain circumstances, you also have the right to ask us to:

    ◦ Stop using your personal data for certain purposes;

    ◦ Limit or restrict our use of your personal data;

    ◦ Remove or delete personal data about you; or

    ◦ Provide your personal data to a third party provider of services.

Protecting your data

We are committed to protecting your personal data. We use appropriate technical and organisational measures, including encryption, to protect your personal data and privacy, and review those regularly. We protect your personal data using a combination of physical and IT security controls, including access controls that restrict and manage the way in which your personal data and data is processed, managed and handled. We also ensure that our staff are adequately trained in protecting your personal data. Our procedures mean that we may occasionally request proof of identity before we share your personal data with you.

Where we have given you (or where you have chosen) a password which enables you to access any portal or account, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.

In the unlikely event that we do suffer a security breach which compromises our protection of your personal data and we need to let you know about it, we will do so.

Changes to this privacy notice

We wilrequlary review and update this privacynoice. This privacy noice was lastreviewed and updated in sepember 2022.lf we change our pivacy notice in a way that significanlychanges how we proces the perondldata hatwe hold aboutyoy,we wil also askyou to conim that you are happy wihthose changesthrough the most appropriate method le.g. in emaor a notification on our website).

This privacy notice was last updated in September 2022