OUR COMMITMENT TO PROTECTING YOUR PRIVACY
February 14, 2022
1. WHAT INFORMATION DO WE COLLECT?
Information Provided By You
We collect information you provide when you utilize our Services, go through our identity or account verification process, authenticate into your account, communicate with us for support, or otherwise use or interact with our Services.
When you are using or interacting with our Services, the information we collect can include:
- Identification Information. Your name; email address; mailing address; phone number; birthdate; passport, driver’s license, Social Security, Taxpayer Identification, or other government-issued identification when you apply or sign up for an account or other Services, signature, and authentication credentials (for example, information you use to login to your account), including IP address.
- Other Information You Provide. Information that you voluntarily provide to us, which can include survey responses; participation in contests, promotions, or other prospective seller marketing forms or devices; suggestions for improvements; referrals; or any other actions performed on the Services.
Information We Automatically Collect About You From Your Use of Our Services
We also automatically collect information about you from your use of our Services. The information that we can collect includes:
- Use Information. Information about how you use our Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, Internet Protocol (“IP”) address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your visit to or use of the Services, your search terms, the website you visited before you visited or used the Services, data about how you interact with Services, and other clickstream data.
2. HOW WILL WE USE YOUR INFORMATION?
The following sections describe different ways we may use your information. We may use information about you for a number of purposes, including:
- Providing, Improving, and Developing our Services
- Processing or recording payment transactions;
- Providing, maintaining and improving our Services;
- Delivering the information and support you request or that you may require, including technical notices, security alerts, and support and administrative messages, which may be used to resolve disputes, collect fees, or provide assistance for problems with our Services or your account;
- Personalizing and facilitating your use of our Services;
- Measuring, tracking, and analyzing trends and usage in connection with your use or the performance of our Services.
- Communicating with You About our Services
- Sending you information that we think you may find useful or that you have requested from us about our Services;
- Conducting surveys and collecting feedback about our Services.
- Protecting our Services and Maintaining a Trusted Environment
- Investigating, detecting, preventing, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities, or to otherwise help protect your account, account, including to dispute chargebacks on your behalf;
- Protecting our visitors, our customers’, or your customers’ rights or property, or the security or integrity of our our Services;
- Enforcing our Terms of Service or other applicable agreements or policies;
- Verifying your identity or determining your creditworthiness;
- Complying with any applicable laws or regulations, or in response to lawful requests for information from from the government or through legal process;
- Fulfilling any other purpose disclosed to you in connection with our Services;
- Contacting you to resolve disputes, collect fees, and provide assistance with our Services.
Advertising and Marketing
- Marketing of our Service;
- Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners.
3. HOW DO WE SHARE YOUR INFORMATION?
We may share information about you as follows:
With Other Users of our Services with Whom You Interact
- With other users of our Services with whom you interact through your own use of our Services when such sharing is expressly indicated in product documentation as an element of the Services;
Among our Affiliates
- Information supplied to any one affiliate of Polaris may be shared with and used by any other affiliate of Polaris for any purpose permitted by this Policy, unless otherwise expressly and in writing agreed in a particular instance.
With Third Parties
- With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus, partners providing services on our behalf, and other entities in connection with the Services;
- With third parties that run advertising campaigns, contests, special offers, or other events or activities on our behalf or in connection with our Services.
- Polaris shares Personal Information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering Services to you, managing and enhancing customer data, providing customer service, assessing your interest in our Services, and conducting customer research or satisfaction surveys.
Business Transfers and Corporate Changes
- To a subsequent owner, co-owner, or operator of one or more of the Services; or
- In connection with (including, without limitation, during the negotiation or due diligence process of) a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock or assets; financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.
Safety and Compliance with Law
- If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process, or governmental request; (ii) to enforce or comply with our Terms of Service or other applicable agreements or policies; (iii) to protect our or our customers’ rights or property, or the security or integrity of our Services; or (iv) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.
With Your Consent
- With your consent. For example:
- At your direction or as described at the time you agree to share;
- When you authorize a third party application or website to access your information.
Aggregated and De-Identified Information
- We also may share (within our group of companies or with third parties) aggregated and de-identified information that does not specifically identify you or any individual person.
4. HOW WILL WE STORE YOUR INFORMATION?
Polaris securely stores your Personal Information as follows:
When your personal data is stored by Polaris, we use computer systems with limited access housed in facilities using physical security measures.
However, when you use some Polaris Services, or post on a Polaris forum, the Personal Information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.
Despite our efforts, no website, mobile application, database or system is completely secure or “hacker proof.” You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.
5. HOW LONG DO WE RETAIN YOUR INFORMATION?
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law or relevant industry standards.
However, even after you deactivate your account (as applicable), we retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is (a) authorized under the agreements we have made with you or under applicable law, (b) reasonably necessary for us to comply with applicable law, regulation, legal process, or governmental request, or (c) reasonably necessary for us to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Service or other applicable agreements or policies, or to take any other actions permitted under applicable law.
In addition, for EU citizens or residents, Personal Information processed by Polaris as a data processor will be removed in accordance with the instructions of the applicable data controller, not to exceed two years except where required to be retained for longer than that by applicable law, and except in the context of a legal dispute in which the particular data is relevant.
6. WHAT ARE YOUR DATA PROTECTION RIGHTS (EU CITIZENS AND RESIDENTS)?
As an EU citizen or resident, you are entitled to the following:
The right to access—You have the right to request copies of your Personal Information.
The right to rectification—You have the right to request that any Personal Information you believe is inaccurate be corrected, and request that any incomplete Personal Information be completed.
The right to erasure—You have the right to request that your Personal Information be erased under certain conditions.
The right to restrict processing—You have the right to request that the processing of your Personal Information be restricted under certain conditions.
The right to object to processing—You have the right object to the processing of your Personal Information be restricted under certain conditions.
The right to data portability—You have the right to request that your Personal Information be transferred to another organization, or directly to you, under certain conditions.
Contact information for our Data Protection Officer and our Article 27 Representative may be obtained by sending an email request for such information to [email protected]
Transfers of Personal Information from the EU to the U.S.
Polaris is responsible for the processing of Personal Information it receives from the European Union, including any subsequent transfers to a third party acting as an agent on its behalf.
7. WHAT ARE YOUR PRIVACY RIGHTS (CALIFORNIA RESIDENTS)?
All terms used in this section pertaining to the privacy rights of California residents have the definitions given to them in the California Consumer Privacy Act of 2018 (“CCPA”), unless otherwise clearly indicated.
Polaris confirms that when it receives Personal Information from its customers and users or authorized distributors, Polaris processes that information only for authorized business purposes in accordance with the contracts it has with those businesses, and Polaris does not sell or otherwise use the Personal Information so received for any purpose other than providing the services to its customers or distributors pursuant to the contracts it has with those businesses. Polaris will take such and provide information as its customers and distributors may reasonably request to assist those businesses in complying with their relevant obligations under the statute.
To the extent that Polaris otherwise receives Personal Information directly from a consumer, Polaris states that:
- Polaris has and will maintain reasonable administrative, technical, and physical safeguards to ensure the data’s confidentiality, integrity, and availability, that are designed in accordance with applicable industry standards to prevent unauthorized or inappropriate access or use by, or disclosure to, third parties;
- Polaris has and will maintain security measures appropriate to (i) protect data against accidental or unlawful destruction or loss, unauthorized alteration, unauthorized disclosure or access, in particular where the handling of or access to data involves the transmission of data over a network, and against all other unlawful forms of processing, and (ii) ensure a level of security appropriate to the risks presented by the services and the nature of the data to be protected having regard to the state of the art and the cost of implementation;
- Polaris has processes to receive and timely response to consumer requests to access, correct, modify, delete, or opt out of the sale of their Personal Information, and will comply with its statutory obligations with respect thereto; and
- Polaris will not sell or otherwise disclose or use Personal Information received from a consumer other than as necessary to fulfill the specific purposes for which it was supplied to Polaris.
To request access, correction, modification, deletion, or opt-out, you can use the phone, email, or physical address indicated below in this policy for Privacy Questions. Per the statute, Polaris may deny a request (but comply to the greatest extent that it can) if the consumer is unable or unwilling to verify his/her identity in conjunction with making such a request.
Polaris does not authorize the collection of personally identifiable information from our users for third party use through advertising technologies.
8. HOW TO ENSURE INTEGRITY AND ACCESS TO YOUR INFORMATION?
You can help ensure that your contact information and preferences are accurate, complete, and up to date by contacting us at [email protected] For other Personal Information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Polaris is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by applicable law.
You may also contact us [email protected] if you would like Polaris to delete the information that we have retained. However, in some circumstances, we may not be able to continue to provide you with some Services if some kinds of information are deleted. Also, if we send you emails, each email will contain instructions permitting you to opt out of receiving future marketing or other communications.
9. WHAT ARE COOKIES, AND HOW DO WE USE THEM?
Ads that are delivered by Polaris advertising platform may appear on Polaris’s website and the websites of our Affiliates. You may see ads in third-party environments based on context like your search query or the channel you are reading. In third-party apps, you may see ads based on other information. This reflects that cookies and similar data from web usage are used to generate and select advertising visible to the user.
If you want to disable cookies, seek out the policies and terms of your internet web browser to manage your browsing privacy preferences. Please note that certain features of the Polaris website will not be available once cookies are disabled.
As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Polaris may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the Polaris website. When you click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format that customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
10. CHILDREN’S PRIVACY
11. THIRD-PARTY SITES AND SERVICES
Polaris websites, products, applications, and services may contain links to third-party websites, products, and services. We may also use or offer products or services from third parties.
Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
If you purchase a subscription in a third party app, we create an identifier that is unique to you and the developer or publisher that we use to provide reports to the developer or publisher that include information about the subscription you purchased, and other pertinent information. This information is provided to developers so that they can understand the performance of their subscriptions.
12. COMMITMENT TO YOUR PRIVACY
Subject to applicable legal requirements, we will notify you in the manner and in accordance with timeframes specified in the law if we discover that there has been an unauthorized use or unauthorized disclosure of your information. If that were to occur, and in addition to other applicable rights and remedies, we will undertake appropriate steps to remediate the breach and to reduce the risk of future reoccurrences.
13. PRIMARY COMPANY LOCATIONS
The Polaris Program
2202 North Irving Street
Allentown, PA 18109
14. PRIVACY QUESTIONS
When a privacy question or access request is received we will seek to address the specific concern or query that you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues that may be applicable to your circumstances.