Politik om beskyttelse af persondata
Table of Contents
A. COLLECTION OF INFORMATION.
· Information That You Provide to Us
· Information That We Collect Automatically
· Information That We Receive From Third Parties
B. USE OF PERSONAL DATA.
C. DISCLOSURE OF PERSONAL DATA.
D. RETENTION
E. RIGHTS REGARDING PERSONAL DATA.
F. COOKIES.
G. MINORS.
H. SECURITY MEASURES
I. CHANGES TO THIS PRIVACY POLICY
J. VISITORS FROM THE EUROPEAN UNION
· Legal Basis for Data Processing.
· International Transfers of personal information.
· Your Rights.
K. Language
L. HOW TO CONTACT US.
We at Polara.dk (“we”, or “us”) recognize the importance of privacy and confidentiality of personal
information.
Polara.dk (“Polara” or, the “Platform”) is a business to consumer (or “B2C”) platform which connects
and facilitates sales and purchases between business sellers (or “Sellers”) and consumer buyers (or
“Buyers”).
This Privacy Policy sets out the ways in which we collect, use, and disclose information in connection
with the operation of the Platform, including personal information about you, Platform users, visitors, and representatives. This Privacy Policy also applies to the use of the Platform via your mobile device.
- COLLECTION OF INFORMATION
The personal information that we collect broadly falls into the following categories:
Information That You Provide To Us:
If you are a Buyer, we will ask you to provide:
· contact information including name; address; phone number; email address;
· purchase and/or payment information including credit card or similar payment information
that you intend to purchase with; billing and delivery address;
· information about your purchases including the goods purchased and how many;
· information about and/or to support complaints made in connection with the Platform or
goods and/or services purchased via the Platform;
If you are a Seller (i.e. an employee or representative of a Seller or a sole trader Seller
(we’ll refer to you as a Seller)), we will ask you to provide:
· information about the Seller’s business (if applicable) including corporate registration,
business licenses (if applicable), tax or similar information;
· details about the goods and products that the Seller intends to sell via the Platform;
· purchase and/or payment information including bank account or other payment
information that the Seller intends to be paid by.
If you are a certified blogger/influencer for Polara.dk, we may also ask you to provide us with
your contact information and social media accounts/blog information.
If you choose to provide us with any additional information, such as in response to
questionnaires for market research/analytics. This may include marital status, nationality, gender,
date and/or year of birth, annual income, monthly spending, and user preferences. If you prefer not
to provide such information, the use of our services and products will not be affected.
Information That We Collect Automatically:
If you are a Buyer or Seller or prospective Buyer or Seller we will automatically collect:
· A copy of any correspondence with us, including any verification information we ask
for if you contact us for any reason (such as our customer service department chat service,
telephone, or email).
· Details of transactions and communications over the Platform, including the types
and specifications of the goods sold and purchased, pricing and delivery information, any dispute
records, communications between Buyers and Sellers over the Platform, and any information
disclosed in any discussion forum.
· Details of Platform buying and browsing activities, for these purposes we will automatically
collect information from your device. In some jurisdictions, including countries in the European
Economic Area and the UK, this information may be considered as personal information under
applicable data protection laws. Specifically, this collected information may include IP addresses,
device type, unique device identification numbers, browser type, broad geographic location (e.g.
country or city-level location), browsing patterns and details of how you have interacted with our
Platform and the goods and services available on it. In addition, we gather information about the
Platform and visitors to the Platform, including browser software, operating system, software and
hardware attributes, pages viewed, number of sessions, and unique visitors. Some of this information
may be collected using cookies and similar tracking technology, as explained further under section F “COOKIES” below. Where we are required by applicable law, we will seek your prior
consent to the collection of information using cookies and similar tracking technologies. We also may
derive or collect inferences about you based on your buying and browsing activity information and
other information we have collected about you.
If you are successfully certified by Polara.dk as a blogger or an influencer, we may also collect your
social media account handles and posts/comments made in relation to the Platform.
Information That We Receive From Third Parties:
If you are a Buyer or Seller we may receive personal information about you from:
· Social media platforms if you choose to register for a Platform account via a social media
account. Exactly what information we receive will depend on your privacy settings with
the applicable platform, but would typically include basic public profile information such as:
· Your social media user name, nickname or username
· Your social media profile picture
· Country
· Company name (if applicable).
· Third parties that are engaged by us to provide verification services, such as conducting
suitable money laundering, fraud, and “Know Your Customer” checks on Buyers and Sellers. This may
include your name, email address, company details, and contact information. - USE OF PERSONAL DATA
We may collect and use your personal information for the following purposes:
· verifying Platform account registrations, including conducting fraud, security, “Know Your
Customer” and anti-money laundering checks in order to approve your Seller account;
· verifying your eligibility as a Platform blogger or influencer;
· setting up / administering Buyer and Seller accounts, including providing log-in IDs and setting
up payment / transaction accounts;
· providing customer service support, such as responding to your queries, feedback and
managing claims and/or disputes;
· providing/supporting general Platform services, facilitating communication between Buyers
and Sellers, processing transactions and payments, assessing advance withdrawal requests from
Sellers and providing logistics and delivery services;
· providing relevant membership benefits, including birthday rewards, membership offers and
coupons, anniversary awards, exclusive member prices;
· verifying your identity and purchases in connection with product warranty or other aftersales
claims;
· sending and serving tailored marketing and advertising that we believe will be of interest
to you based on the ways in which you use the Platform, your browsing records, and order history;
· conducting research and analytics to ensure the security of our Platform, to improve the
content and layout of the Platform, and to improve our product offerings and services;
· Cookies or other similar technologies may be used to provide you with advertising based upon your
browsing activities and interests (see section F. COOKIES below for more information).
We may also use your personal information for other purposes that are not incompatible with the
purposes we have disclosed to you if and where this is permitted by applicable data protection laws.
C.DISCLOSURE OR SHARING OF PERSONAL DATA
We disclose/share personal information with the following categories of recipients:
· Other Platform Buyers and/or Sellers where necessary to support purchases and
communications made between you. If you are a Buyer, Sellers that you purchase from will also
control personal information about you relevant to or connected with your Platform purchases and
communications with them. Please refer to Seller Privacy Policies for information about how they will
process your information.
· Third party partners and service providers and/or affiliates engaged by or working with us to
assist us in providing services to you or who otherwise process personal information for purposes
described in this Privacy Policy or notified to you when we collect your personal information.
Categories of these partners and service providers include:
· Polara.dk group entities and affiliated companies and/or their designated service providers that
work with us to provide processing services such as software, tools, systems and messaging services
for purposes described in this Privacy Policy;
· our business partners (for example, in order for them to provide you with discounts or offers that
may interest Buyers or prospective Buyers) where you have consented to receiving such information
from them if required by applicable data protection laws;
· marketing and advertising partners, such as Google, Twitter, Facebook, Instagram, and
VKontakte, and providers of analytics services relating to users’ behaviour, so that they may tailor
the content you see when visiting our Platform for analytics and/or advertising purposes. These
partners may combine information they collect on our Platform with data on their platforms and
data they collect from other websites or through other sources in order to conduct targeted
advertising. The processing activities of these third party marketing platforms are governed by their
own privacy policies, not this Privacy Policy (please refer to section F “COOKIES” below);
· payment service providers that provide payment processing services. The activities of payment
service providers may be governed by their own privacy policies, not this Privacy Policy;
· logistics partners for providing delivery services for Buyers and Sellers, including return and
exchange of products, and warehousing services for Sellers;
· customs agents for customs clearances purposes, where applicable to support Buyers and Sellers
with international sales/purchases;
· cloud computing or other hosting service providers to provide cloud storage services;
· warranty service providers to provide product warranty services where requested by a Buyer or
Seller;
· customer service support providers to provide after-sale services or other customer service
support;
· risk control service providers to assess the security of Buyer and Seller accounts and transaction
risks; and
· third party rating / reviewing service providers to carry out reviews of our services with
customers if you choose to participate in reviewing or rating Platform products and/or services;
· To our professional advisers, law enforcement agencies, insurers, government and
regulatory and other organisations where we believe it is necessary to comply with applicable
laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any
other person; or as otherwise required or permitted by applicable laws.
· To an actual or potential buyer (and its agents and advisers) in connection with any actual or
proposed purchase, merger or acquisition of any part of our business, provided that we inform the
buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
· To any other person with your consent to the disclosure.
We have established relationships with other parties and websites to offer you the benefit of
products and services which we do not offer. We offer you access to these other parties and their
websites either through the use of hyperlinks to these sites from our Platform or through offering
“co-branded” sites in which both we and other parties share the same uniform resource locator
(URL), domain name or pages within a domain name on the Internet. In some cases you may be
required to submit personal information to register or apply for products or services provided by
such third parties or co-branded partners. This Privacy Policy does not apply to these third party sites
or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no
control over the information that you submit to those third parties. You should read the relevant
privacy policy for those third party sites and co-branded sites before responding to any offers,
products or services advertised by those parties.
- RETENTION
We will retain your personal information for as long as we have an ongoing legitimate business need
to do so, to provide services or products to you, as required or permitted by applicable laws. When
we have no ongoing legitimate business need to process your personal information, we will either
delete or anonymize it, or if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal information and isolate
it from any further processing until deletion is possible. How long your data is kept will also
depend on how you use our website (for example if you are logged in as a member or you are visiting
our website as a guest) and what the information you provide to us is used for. For example, if you
are a registered member, certain data will be retained for a length of time following termination or
deletion of your account, in order to comply with applicable laws or in case of disputes. In other
instances, the period of retention may be determined according to your activity on the Platform or to
comply with a specific arbitration period/resolve a dispute. - RIGHTS REGARDING PERSONAL DATA
Under applicable laws, you may have rights of access to personal information held by us and other
rights. If you are a Visitor from the European Union, please refer to section J. VISITORS FROM THE
EUROPEAN UNION below for more information. - COOKIES
This section explains how we use cookies and similar technologies (we refer to them collectively as
“cookies”) to recognize you when you visit our Platform. It explains what these technologies are and
why we use them, as well as your rights to control them.
What are cookies?
A cookie is a string of information that is sent to your browser and stored on your computer’s or
mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same
browser or device to access the Platform, our web servers will be notified of your visit to the
Platform and, in turn, we may have knowledge of your visit and the pattern of your usage.
Cookies set by the site or app owner (in this case, AliExpress) are called “first party cookies”.
Cookies set by third parties other than the website owner are called “third party cookies”. Third
party cookies enable third party features or functionality to be provided on or through the website
(e.g. like advertising, interactive content, and analytics). The parties that set these third party cookies
can recognize your device both when it visits the website in question and also when it visits certain
other websites.
Cookies are also categorized as “session cookies” (which are erased once you close the browser or
shut down the device) and “persistent cookies” (which remain even after closing the browser or
shutting down the device/application and which are activated each time you visit the Platform).
Session cookies use encrypted data to authenticate you. Persistent cookies do not store account
numbers or passwords. We use both session cookies and persistent cookies.
Why we use cookies?
We use first and third-party cookies for several reasons.
Some cookies are required for technical and/or security reasons in order for our Platform to operate,
and we refer to these as “essential” or “strictly necessary” cookies. First-party cookies are mainly
served to enable basic functionality on our Platform; including web analytics cookies that help us
understand how users use our web pages and how we can improve their use. For example, we use
essential or strictly necessary cookies to enable us to remember goods added to your shopping
basket and to recognize you when you sign in to your account.
We also use social media cookies. You may register for Platform membership and “share” Platform
content through social media such as Facebook and Twitter. Sometimes we embed videos from
websites like YouTube. These websites have their own privacy policies that govern their use of
information, which you can find on the respective websites.
We also use cookies to enable us to track and target the interests of Platform visitors to enhance the
experience on our Platform by researching visiting patterns and conducting interest-based
advertising; assisting our partners in tracking user visits to the Platforms, and to track progress and
participation in promotions and the success of our email marketing campaigns. We use first and third
party cookies for these purposes.
Essential Cookies These cookies are strictly necessary for enabling access and use of our Platform.
They provide the necessary functionality to ensure the proper performance, security, and functionality of
our Platform. These cookies cannot be disabled. Essential cookies cannot be disabled
Analytics Cookies: These cookies collect information in aggregate form to help us determine and
understand how users interact with and use our Platform. We use this information to help us to
improve and optimize our Platform and its security. To refuse these cookies, please follow the
instructions below under the heading "How can I control cookies?"
Personalization / Advertising Cookies: These cookies are used to make advertising messages
more relevant to you. They also perform functions like preventing the same ad from continuously
reappearing ensuring that ads are properly displayed for advertisers, and in some cases selecting
advertisements that are based on your interests. To refuse these cookies, please follow the
instructions below under the heading "How can I control cookies?"
Marketing Cookies. Marketing cookies help us to ensure that provide you with more targeted and
relevant marketing. We will also use marketing cookies to evaluate the effectiveness of our
marketing communications by monitoring open rate and conversions. To refuse these cookies, please
follow the instructions below under the heading "How can I control cookies?"
Social Networking Cookies: These cookies are used to enable you to share pages and content that
you find interesting on our Platform through third-party social networking and other websites.These
cookies may also be used for advertising purposes too. To refuse these cookies, please follow the
instructions below under the heading "How can I control cookies?"
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to our Platform. We may use other, similar
technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”).
These are tiny graphics files that contain a unique identifier that enable us to recognize when
someone has visited our Platform or opened an e-mail that we have sent them. This allows us, for
example, to monitor the traffic patterns of users from one page within our Platform to another, to
deliver or communicate with cookies, to understand whether you have come to our Platform from an
online advertisement displayed on a third-party website, to improve site performance, and to
measure the success of e-mail marketing campaigns. In many instances, these technologies are
reliant on cookies to function properly, and so declining cookies will impair their functioning.
How can I control cookies?
You can determine if and how a cookie will be accepted by configuring the privacy setting of the
browser you are using to access the Platform or the “privacy setting” of your device. As the means by
which you can refuse cookies through your web browser controls vary from browser-to-browser, you
should visit your browser’s help menu for more information. If you adjust the privacy setting in the
browser, your mobile device will continue collecting data unless you adjust the privacy setting of the
device and vice versa.
You have the right to decide whether to accept or reject cookies. If you choose to set your web
browser controls to reject cookies, you may still use our website though your access to some
functionality and areas of our website may be restricted.
In addition, most advertising networks offer you a way to opt-out of targeted advertising. If you
would like to find out more information, please
visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
Certain features of the Platform depend on cookies. Please be aware that if you choose to block
cookies, you may not be able to sign in or use those features, and preferences that are dependent on
cookies may be lost.
Google Analytics (More information) Our Platform uses Google Analytics, an internet analytics
service provided by Google, Inc. (“Google”). Google’s cookies allow us to analyze the use of the Platform by
telling us which pages our users are viewing, which ones are most popular, what time of day our
Platform are visited, if users have previously visited our Platform, from which website users are
redirected to our Platform were and the like. The data generated by the cookie about your use of the
Platform will be transmitted to Google and stored by Google on servers in the United States.
The Platform uses an anonymization tool of IP addresses so that the IP addresses are truncated
within the territory of the Member States of the European Union and the other members of the
agreement on the European Economic Area. In some cases, a non-truncated IP address may be
transmitted to Google’s servers in the US and then truncated there.
Google uses the data on behalf of AliExpress to evaluate your use of the Platform, to compile reports
on website activity for the website operators, and for other website activity and internet usage
services. Google may disclose this information to third parties under the terms of the law or for
further processing by third parties on behalf of Google. For more information about Google Analytics
cookies, visit the Google Help pages and Privacy Policy: Google Privacy
Policy: https://policies.google.com/privacy; and the Google Analytics Help
Centre: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookieusage.
Through your browser settings, you can block cookies; however, this can lead to problems with the
use of some functionalities of the website. Through the add-on “Google Analytics Opt-out” you can
through your current web browser opt-out to the use of Google Analytics from then
on: http://tools.google.com/dlpage/gaoptout?hl=en.
More information can be found here: https://support.google.com/analytics/answer/6004245. - MINORS
The Platform is intended for adults and users must be over 18 to use our Platform. We do not intend
to sell any of our products or services to minors, as defined by applicable law. If a minor has provided
us with personal information without parental or guardian consent, the parent or guardian should
contact Info@polara.dk to remove the information. - SECURITY MEASURES
We implement appropriate technical and organizational measures to prevent unauthorized access to
the Site, to maintain data accuracy, and to ensure the correct use of the information we hold. Upon
becoming aware of a data breach, we will notify you and the regulatory authorities in accordance
with the timescales and scope required by applicable data protection law.
For registered users of the Site, some of your information can be viewed and edited through your
account, which is protected by a password. We recommend that you do not divulge your password
to anyone. We have instructed our personnel to never ask you for your password in an unsolicited
phone call or in an unsolicited email. If you share a computer with others, you should not choose to
save your log-in information (e.g., user ID and password) on that shared computer. Remember to
sign out of your account and close your browser window when you have finished your session.
No data transmission over the internet or any wireless network can be guaranteed to be perfectly
secure. As a result, while we use appropriate technical and organizational measures to protect the
information we hold for you, we cannot guarantee the security of any information you transmit over
the internet. -
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in response to changing legal, technical or
business developments.
When we update our Privacy Policy, we will take appropriate measures to inform you, consistent
with the significance of the changes we make and as required by applicable law, such as by posting
an amended Privacy Policy on the Platform. -
VISITORS FROM THE EUROPEAN UNION
This section applies if you are based in the European Economic Area (which for the purposes of this
Privacy Policy shall include the UK in the event of the UK’s departure from the European Union)
(“EEA”). The data controller of your personal information is Polara.DK incorporated in Rotterdam
under the Dutch law and registered at Chamber of Commerce under 73462195 Your personal data
will be stored in The Netherlands. For contact details, please see section L. HOW TO CONTACT US
below. Please also note, if you are a Buyer, Sellers will also act as a data controller of personal
information about and your Platform purchases and communications with them. Please refer to the
Privacy Policies of those Sellers for more information about the ways in which they will process such
information.
Legal Basis for Data Processing
We process personal information for the purposes set out in this Privacy Policy. Our legal basis to
process for processing your personal information will depend on the personal information concerned
and the specific context in which we collect it but will include where it is:
· necessary for the performance of contract between you and Polara.dk (for example, to
provide you with the services you request and to identify and authenticate you so you may
use the Platform);
· necessary to comply with legal requirements (for example, to comply with applicable
accounting rules and to make mandatory disclosures to law enforcement);
· necessary for our legitimate interests and not overridden by your rights; and/or where it is
based on your consent.
If we collect and use your personal information in reliance on our legitimate interests (or those of
any third party), this interest will normally be to operate our Platform and services, manage our
relationship with you and communicate with you as necessary to provide our services to you and for
our legitimate commercial interest, for instance, when responding to your queries, improving our
Platform and our services, undertaking marketing, or for the purposes of ensuring the security of our
Platform and services and detecting or preventing illegal activities such as fraud. We may have other
legitimate interests and if appropriate we will make clear to you at the relevant time what those
legitimate interests are.
If we ask you to provide personal information to comply with a legal requirement or to enter into a
contract with you, we will make this clear at the relevant time and advise you whether the provision
of your personal information is mandatory or not (as well as of the possible consequences if you do
not provide your personal information). In some instances, you may be required to provide us with
personal information for processing as described above, in order for us to be able to provide you all
of our services, and for you to use all the features of our Platform.
If you have questions about or need further information concerning the legal basis on which we
collect and use your personal information, please contact us using the contact details provided under
section L. HOW TO CONTACT US below.
International Transfers of personal information
In connection with providing the services through our Platform, we may transfer your personal
information to countries outside of the EEA in order to provide services.
Your Rights
If you are a resident of the EEA, you have the following data protection rights, which you can exercise
at any time by contacting us using the contact details provided under section M. HOW TO CONTACT
US below:
· The right to access, correct, update or request deletion of your personal information.
· The right to object to the processing of your personal information when it is based on our legitimate
interests.
· The right to ask us, in some situations, to restrict processing of your personal information or
request portability of your personal information.
· The right to opt-out of marketing communications we send you at any time. You can exercise
this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To
opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact
us using the contact details provided under section L. HOW TO CONTACT US below.
· If we have collected and processed your personal information with your consent, then you have the
right to withdraw your consent at any time. Withdrawing your consent will not affect the
lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of
your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection
rights in accordance with applicable data protection laws.
If you are aware of changes or inaccuracies in your information, you should inform us of such
changes so that our records may be updated or corrected. -
Language
If there is any conflict between the English version and another language version of this Privacy
Policy, the English version shall prevail. -
HOW TO CONTACT US
Info@polara.dk