Privacy Policy
PolarDC Privacy Policy
1. Who we are
We are PolarDC Group LTD, a company with registered office at 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN. We operate this website - www.polardc.com – and the services made available through it (our "Website").
This Privacy Policy applies to PolarDC Group LTD and our group companies, including PolarDC Services LTD and local operating entities where we host our data centers, referred to collectively as "PolarDC", "we", "our" and "us".
PolarDC Services LTD is our group services company and is the relevant data controller. PolarDC Services LTD has a registered office at 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN.
You can find out more about PolarDC here.
2. Our values and what this Privacy Policy is for
We respect your privacy and want you to be familiar with how we collect, use and disclose information directly or indirectly relating to you as an individual ("Personal Data"), and the rights that you have in this regard.
This privacy policy (the "Privacy Policy") describes how we, as a data controller, process your Personal Data when you use our Website, and when you interact with us in relation to our business and services. We use "you" to mean users of our Website and the individuals with whom we interact.
If you have any queries or feedback on this Privacy Policy, you can contact us by using the contact information in Section 16 of this Privacy Policy.
3. Your key rights
You have various rights in respect of our use of your Personal Data as set out in more detail in Section 7. Two of the fundamental rights to be aware of are that:
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You may ask us to stop using your Personal Data for direct-marketing purposes. If you exercise this right, we will stop using your Personal Data for this purpose.
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You may ask us to consider any valid objections which you have to our use of your Personal Data where we process your Personal Data on the basis of our, or another person's, legitimate interest.
4. Your confirmation to us
Please read this Privacy Policy carefully to understand how we handle your Personal Data. By engaging with us in the ways set out in this Privacy Policy, you confirm that you have read and understood it, as it applies to you.
5. What Personal Data do we process about you?
a. How we collect your Personal Data
We collect your Personal Data in the following ways:
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When you submit Personal Data to us. We collect Personal Data about you when you actively provide it to us, for example when you send us an email, contact us through our Website, call us or provide us with any Personal Data in any other manner.
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When you use our website or services. We may collect some Personal Data about you when you use our Website or services.
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From your employer. We may receive some Personal Data from your employer or your employer's company website.
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From third parties. We may collect some Personal Data from selected third parties who have the right to share the information with us, such as other companies in the PolarDC group, third party service providers and selected industry partners.
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When we procure services. When we procure services from third parties, we collect certain Personal Data to manage this relationship (or prospective relationship), such as contact details made available to us and information about how you use our products and services.
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When you visit us. We may collect some Personal Data from you when you visit one of our offices, such as contract information and from CCTV recordings in our buildings.
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Other publicly available sources. We may collect your Personal Data from publicly available sources such as (but not limited to) LinkedIn and your employer's website.
b. What Personal Data we process
We process the following Personal Data about you:
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"Contact Information" means Personal Data such as your first and last name, job title, phone number, email address, and postal address. We may also record your preferences, such as for marketing communications.
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"Technical Information" means information about how you use our Website and data that we may collect or track using technology such as pixels, web beacons and HTML snippets, for example to monitor if our marketing emails have been opened or content interacted with. Please see our Cookies Policy for more information.
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"Relationship Information" means information about our professional relationship with you and your employees, such as a customer-supplier information (pitch documents, information from third parties such as LinkedIn, ID details and other data related you the provision of products and services).
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"Information from other sources" we may also periodically obtain information about you from other sources. The collection of such information will be in accordance with applicable privacy laws.
6. Why we process your Personal Data
The purposes for which we process your Personal Data and the relevant legal bases for that processing are set out in the list below.
Information on our services
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Purpose for Processing: To provide you with information regarding our services.
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Legal Basis for Processing: This processing is necessary for our legitimate interests, which are to provide you with information about us and our services.
Providing, managing and improving our services
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Purpose for Processing: To provide you with and manage our services and to ensure we can improve our services and deal with any enquiries you may have.
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Legal Basis for Processing: Our processing of your Personal Data for this purpose is necessary either for:
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us to fulfil a contract with you; or
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pursuing our legitimate interests which are to provide you with the services or with information on our services we would reasonably expect you to have an interest in.
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Marketing
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Purpose for Processing: To send you direct marketing communications about services, events or any other activities which may be of interest to you, and (in some instances) to track your receipt and interaction with the communication in order to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials.
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Legal Basis for Processing: This processing will be based on:
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our legitimate interests to do so for marketing and business development purposes; or
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where required by law, your consent.
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Managing website content
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Purpose for Processing: To ensure that the content on our Website is presented in the most effective manner for you and your device.
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Legal Basis for Processing:
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as is necessary for the purposes of legitimate interests pursued by us, which are to ensure the proper and compliant operation of our Website and services and communications; or
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where required by law, your consent.
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Procuring and using services
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Purpose for Processing: To procure and use services.
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Legal Basis for Processing: Our processing of your Personal Data for this purpose is necessary for pursuing our legitimate interests to run and operate our business.
Legal obligation
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Purpose for Processing: To comply with our legal obligations (including KYC requirements and to manage fraud), court orders or government authority requests, when we reasonably believe that we are legally required to disclose your Personal Data.
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Legal Basis for Processing: Our processing of your Personal Data for this purpose is for compliance with a legal obligation to which we are subject, or for pursuing our legitimate interests which are to protect our organisation.
Safety and security
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Purpose for Processing: To ensure the safety and security of people and property.
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Legal Basis for Processing: Our processing of your Personal Data for this purpose is necessary for pursuing our legitimate interests which are to ensure the safety and security of people and property or compliance with a legal obligation to which we are subject.
Pursuing legal rights
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Purpose for Processing: To lawfully enforce our legal rights and perform our obligations and allow us to pursue any available legal remedies or limit the damages we may sustain.
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Legal Basis for Processing: Our processing of your Personal Data for this purpose is for compliance with a legal obligation to which we are subject.
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Processing Operations: For this purpose, we will collect, record, store, organise, retrieve, disseminate, restrict and use your Personal Data.
Reorganisation or business sale
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Purpose for Processing: To run and operate our business, and to sell and re-organize it (including with third parties).
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Legal Basis for Processing: Our processing of your Personal Data for this purpose is necessary for pursuing our legitimate interests to run and operate our business, and to sell and re-organise it (including with third parties).
The Personal Data we don't collect
We will not intentionally process the following sensitive Personal Data, referred to as "Special Category" data: racial or ethnic origin; political opinions; religion or philosophical beliefs; health or medical condition; criminal background; trade union membership; genetic or biometric data; or sexual life or orientation.
Please do not send, nor disclose, any Special Category data to us.
7. Your UK and EU rights in relation to your Personal Data
You have the following specific rights in respect of your Personal Data that we hold:
a. The right to be informed about how your Personal Data is being used.
b. The right to access the Personal Data we hold about you.
c. The right to request that we correct inaccurate Personal Data or request that we delete your Personal Data, if you consider that it is incorrect or we do not have the right to hold it.
d. A right to object to or restrict certain processing activities.
e. The right to withdraw consent to any consent-based processing at any time. You can do this by contacting us using the details in Section 16 below. Where you do withdraw your consent, we will stop processing your Personal Data for that purpose immediately, except where we are required by law to continue the processing. We cannot reverse any processing that we may have carried out before you withdrew your consent.
f. To ask us to stop or start sending you direct marketing messages at any time.
g. The right to data portability (moving some of your Personal Data elsewhere) in certain circumstances.
h. The right not to be subject to a decision based on automated processing and to ask us to explain any computer-system decision about you.
i. The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office, contact details for which can be found under Contacting Us in Section 16.
If you have questions, you wish to contact us to exercise your rights, or you wish to make a complaint, you can contact us using the contact information listed in Section 16 of this Privacy Policy.
We will consider all such requests and provide our response within a reasonable period (and in any event within such period required under applicable law).
8. Who do we share your Personal Data with and why?
We may share any categories of your Personal Data set out in Section 5 to the following categories of recipients as an essential part of being able to provide our services to you.
Other members of the PolarDC group or our affiliated companies
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Who: We may also share information with third parties in which we have an ownership interest or commercial relationship.
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Why: To support the provision of our services, to manage our Website to ensure everything is working as it should be and to manage our communications to you.
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Where: UK and EU.
Third party service providers
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Who: Third party service providers appointed by us including (but not limited to): (a) companies who help operate our Website; (b) marketing and promotional partners; (c) IT service providers; (d) third party payment providers; (e) software solutions providers; and (e) companies who provide communication, auditing, archiving, data analysis and administration services including banks, accountants and legal services.
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Why:
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to support the provision of our services;
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to develop and improve our Website;
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to provide technical support for our systems and digital platforms when things go wrong;
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to send email communications to you (which could include direct marketing) and to conduct analysis of any relevant email campaigns;
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to host our systems and Website;
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to provide reporting solutions and data analytics; and
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to provide necessary support to our business in relation to communications, auditing and consulting.
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Where: The location of our third party service providers is global although the majority are based in the UK and EEA.
Authorities
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Who: Authorities, public agencies, regulators and law enforcement.
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Why: We may share your Personal Data as we believe to be necessary or appropriate with relevant authorities, affiliates and third parties:
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to comply with our legal obligations;
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to respond to requests from public and government authorities (including courts and law enforcement) which may include public and government authorities outside your country of residence;
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to enforce our legal rights;
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to protect our operations or those of any of our affiliates;
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to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
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to allow us to pursue available remedies or limit the damages that we may sustain.
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Where: The location of the competent authorities shall depend on the particular purpose, but they are most likely in the UK and EEA.
Third parties in the event of any sale, merger etc.
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Who: Third parties in the event of any sale, merger, reorganisation, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
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Why: We may share your Personal Data with a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
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Where: The location of the third party shall depend on the specific details of the reorganisation, merger, sale, joint venture, assignment, transfer or other disposition.
We may also disclose and use anonymised, aggregated reporting and statistics about users of our Website or our products and services for the purpose of internal reporting or reporting to our group companies or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable individuals to be personally identified.
If you would like to know more about the third parties we may share your Personal Data with, or how to find out more about how they will use your Personal Data, please contact us using the contact details listed in Section 16 below.
9. Children
Our Website and services are not directed at children and we do not knowingly collect any Personal Data from children.
10. Marketing
As set out in Sections 5 and 6 above, we may collect and use your Personal Data for undertaking marketing by email, telephone and post.
We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes. However, we will always obtain your consent where we are required to do so by law.
As is common practice, some of our marketing communications may collect and process Technical Information, as defined in in Section 5 above, in order to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials.
If you wish to stop receiving marketing communications, you can contact us by email at contact@polardc.com.
11. What overseas transfers of Personal Data do we carry out?
To achieve the purposes described in this Privacy Policy, we may transfer your Personal Data to countries which do not offer the same level of protection for your Personal Data as the UK or the European Economic Area.
Where such locations do not offer an adequate level of protection for your Personal Data, we will ensure that your Personal Data will continue to be protected by implementing appropriate safeguards when it is transferred to one of these countries.
Section 8 above provides details of the countries to which we transfer Personal Data, but if you want any information about any transfers of your Personal Data to third countries (including the relevant transfer mechanisms or safeguards), please contact us using the contact details listed Section 16 below.
12. How long do we keep your Personal Data?
It is important to us that we keep your Personal Data accurate and up-to-date. We will delete the Personal Data that we hold about you when we no longer need it for the purposes for which it was obtained (as described in this Privacy Policy) or as required to comply with any legal obligations to which we are subject.
13. Risks to your information
The main risk of our processing of your Personal Data is if it is lost, stolen or misused. This could lead to your Personal Data being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
In the course of your Personal Data being provided to us, your Personal Data may be transferred over the internet. Although we make every effort to protect the Personal Data which you provide to us, the transmission of information over the internet is not completely secure not within our control. As such, you acknowledge and accept that we cannot guarantee the security of your Personal Data transmitted over the internet and that any such transmission is at your own risk.
14. How we protect your information
We are committed to protecting your Personal Data from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your Personal Data, including through use of appropriate organisational and technical measures.
However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%.
15. Links to other websites
Our Website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any Personal Data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.
16. Contacting us
If you have any questions or wish to raise a concern or exercise any of your rights about our processing of your Personal Data, you can contact us using one of the options below.
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You can contact us by using the Contact Us page on our Website.
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You can send us an email to the following address: contact@polardc.com
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You can write to the following postal address: 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN
You also have a right to lodge a complaint with the relevant supervisory authority, if you are of the opinion that any of your Personal Data is processed in a manner constituting an infringement of applicable data protection law. In the UK this is the Information Commissioner's Office, which can be contacted on 0303 123 1113 or www.ico.org.uk/make-a-complaint.
17. Updates to this Privacy Policy
You can find out when this Privacy Policy was last amended by checking "LAST REVISED" date at the bottom of this page.
All changes to this Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes to this Privacy Policy.
If you object to any changes, you may cease using our Website. By continuing to use our Website, products or services after we publish changes to this Privacy Policy, you are confirming that you have read and understood the changes.
LAST REVISED: October 2024