Last updated: 22 June 2023
This notice is layered, so you can easily find the information that is applicable to you. Please click the headings or subheadings to read the full text.
There is a Glossary of terms at the end of this document.
Please read this Privacy Notice and any other privacy notice or fair processing notice we may provide on specific occasions carefully, as it is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export and delete your information.
This Privacy Notice supplements the other notices and is not intended to override them.
We do not and will not sell your data to third parties.
We are Polaris UK Ltd. (“Polaris”), a company incorporated and registered in England and Wales with company number: 02911441, whose registered address at New London House, 6 London Street, London EC3R 7LP.
Polaris is the controller of the personal data that we process, or that may be processed on our behalf, in connection with this website.
We have appointed Inse-Com Limited (“Inse-Com”) to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email our representative at [email protected] or write to them at 3rd Floor Kilmore House, Park Lane, Spencer Dock, Dublin 1.
We may collect, use, store and transfer different kinds of information about you, depending on our relationship with you, including:
Includes first name, last name, title and gender.
Includes your work address, work email address and work telephone number(s).
We may collect your location data from your IP address, address and telephone codes.
Includes details about payments to and from you and other details of services you have purchased from us. Details of surveys or research you have participated in.
Includes IP address, your login data, browser type and version, time zone setting and location, browser plugin types and versions, operating system and platform, and other technology on the devices you use to access our website.
Includes your email and password, the services you have used on our Website, feedback, survey responses and such information as you provide to us.
Includes information about how you use our Website and the services you use.
Includes information you have provided to us in your curriculum vitae, covering letter and/or application form, including name, title, address, telephone number(s), personal email address, date of birth, gender, employment history, qualifications.
This also includes any information you provide to us during an interview.
Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Category Personal Data is personal data that needs more protection because it is sensitive, and we may collect this type of personal data from you in the course of providing you with our services or during our interactions with you.
We use different methods to collect data from and about you, including:
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us.
The table below explains what we use your personal data for and why.
LAWFUL BASIS
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PURPOSE EXAMPLES
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Contractual
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Onboarding
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Legitimate interestWhen we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. |
Managing our businessWe hold Personal Data for our own legitimate business interest. This relates to us managing our business to enable us to give you the best service/products and most secure experience, including when we respond to your queries and complaints, where you are not a client or supplier, or a potential client or supplier. We may use the following personal data:
Provide and maintain our WebsitesTo provide and maintain our Website, including to monitor the usage of these, troubleshooting, data analysis, network security and system testing necessary for our legitimate interests in maintaining the useability, security and integrity of our website. We may use the following personal data:
Recommendations and marketingTo make recommendations to you about services that may interest you. We may use the following personal data:
To measure and analyse the effectiveness of the advertising we serve you. We may use the following personal data:
Ensuring that our marketing is tailored to your interests and to keep our records up to date and to provide you with marketing as allowed by law. We may use the following personal data:
To make suggestions and recommendations to you about goods or services that may be of interest to you and necessary for our legitimate interests (to develop our products/services and grow our business). We may use the following personal data:
Recruitment of candidates (contractors, employees and providers)We will use the personal information we collect about you to assess your skills, qualifications and suitability for the work. We may use the following personal data:
It is in our legitimate interests to decide whether to appoint you to work since it would be beneficial to our business to appoint someone to that work. ReviewsWhen we capture your service reviews, for example when you buy goods and services from us, we may follow it up with an enquiry about your experience of the service to help us gauge customer satisfaction. We may use the following personal data:
Data analyticsWe use data analytics to improve our Website, products/services, marketing, customer relationships and experiences. We may use the following personal data:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). We may use the following personal data:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). We may use the following personal data:
Rights and claimsTo enforce or apply our Website terms of use, our policy terms and conditions, or other contracts. To exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with. We may use the following personal data: We may use the following personal data:
Data subject rights
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Legal obligationsWe may use your Personal Data to comply with laws (for example, if we are required to co-operate with a police investigation after a court order orders us to). |
Legal requirementThe processing is necessary for compliance with legal obligations, such as but not limited to healthcare requirements, security requirements and accounting requirements. To comply with applicable law, for example in response to a request from a court or regulatory body, where such request is made in accordance with the law. Criminal activityTo detect fraudulent or criminal activity, we may share information with forces such as the police. |
ConsentWe may have to get your consent to use your Personal Data, such as when we collect and use Special Category Personal Data about you or when we want to send you marketing. We will get your consent before sending third-party direct marketing communications to you via email or text message or before processing any Personal Data relating to your health. Wherever consent is the only reason for using your Personal Data, you have the right to change your mind and/or withdraw your consent at any time by clicking the Unsubscribe button at the bottom of an applicable email or by withdrawing your consent here. |
MarketingTo measure and analyse the effectiveness of the advertising we serve you. We may collect IP addresses and store Cookies on visitors’ devices. Sending third-party direct marketing communications to you via email, letters or phone calls. To participate in Focus groups (in person or online), one to one interview (in person or online), online communities, customer observation / diaries (online platform), online surveys, face to face surveys, telephone surveys. We may use the following personal data, depending on what you consent to:
Special Category Personal DataWe will get your express consent for collecting and processing Special Category Personal Data. |
We will not usually collect Special category Personal data, however if we do we must, in addition to the Lawful Basis in the Lawful Basis table, process your Special Category Personal Data because of an additional condition, including You have given us your explicit consent to process that data or you have made the data manifestly public.
Commonly we will process that data on your express consent.
For more information about us using your Special Category Personal Data, please see the Special Category Personal Data table below or contact us. The ICO has some useful information here.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the Lawful Basis that allows us to do so.
We may use your information to provide you with details about services.
Where we are legally required to obtain your consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.
You can opt out of us using your personal information for marketing purposes by following the unsubscribe link included in each marketing email or by contacting us via email
We may share your personal information with the following organisations that help us manage our business and deliver our products, applications, or services, or where we are legally obliged to share information, including with:
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.
We will keep your Personal Data in line with our data retention policy for no longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties that have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
You should be aware that information about your use of this website (including your IP address) may be retained by your ISP (Internet Service Provider), the hosting provider and any third party that has access to your Internet traffic.
Our Website may contain links to third-party websites and plugins. If you choose to use these websites, plugins, or services, you may disclose your information to those third parties.
We are not responsible for the content or practices of those websites, plugins, or services. The collection use and disclosure of your Personal Data will be subject to the privacy notices of these third parties and not this Privacy Notice. We urge you to read the privacy and cookie notices of the relevant third parties.
We use Cookies and similar technologies like pixels, tags, and other identifiers to remember your preferences, to understand how our website is used, and to customise our marketing offerings.
Further details can be found in our Cookie Notice.
For more information on how we use cookies, please read our cookie policy.
Please note that we may send personal information outside of the EEA and/or UK generally for, but not limited to, reasons relating to processing and storage by our service providers. For example, we may have Cloud storage providers with data storage facilities in the US, Canada or other countries.
When we do this, we will ensure it has an appropriate level of protection and the transfer is made in line with Data Protection Law. Often, this protection is set out under a contract with the organisation that receives that information. You can find more details of the protection given to your information when it is transferred overseas by contacting us.
You have several rights under Data Protection Law. The rights available to you depend on our reason for processing your information and are set out in the table below. Information on your rights under Data Protection Law can also be found at https://ico.org.uk/for-the-public/.
YOUR RIGHTS |
DETAILS |
Right to be informed |
We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific information, you can contact us to exercise this right. |
Right of access |
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information. When you request this data, this is known as making a data subject access request (DSAR). In most cases, this will be free of charge; however, in some limited circumstances, for example repeated requests for further copies, we may apply an administration fee. |
Right to rectification |
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. |
Right to erasure |
You have the right to ask us to erase your personal information in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the Personal Data for one of the following reasons:
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Right to restriction of processing |
You may ask us to stop processing your Personal Data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
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Right to object to processing |
You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or your legitimate interests (or those of a third party). |
Right to data portability |
This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated. |
In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you.
If you are accessing our website from the UK and wish to exercise your rights or get more information about exercising them, please contact us, giving us enough information to identify you.
If you are accessing our website from within the EU, please contact Inse-Com at [email protected] to exercise your rights.
We hope that we can resolve any query or concern you raise about our use of your information. Please contact us first and title your email “Complaint“. All complaints will be treated in a confidential manner, and we will try our best to deal with your concerns.
You have the right to lodge a complaint with a supervisory authority in the EEA member state where you work or normally live, or where any alleged infringement of Data Protection Law occurred.
The supervisory authority in the UK is the ICO, which may be contacted at https://ico.org.uk/concerns or by telephone on + 44 (0) 303 123 1113.
The supervisory authority for the Republic of Ireland is the Data Protection Commission, which may be contacted by telephone on +353 (0) 1 7650100 / 1800437 737.
Please see this list for all other supervisory authority in the other EEA member states.
Consent |
The UK GDPR and EU GDPR set a high standard for consent, consent should be given by a clear affirmative act establishing a freely given, specific, informed, and unambiguous indication of the data subject’s agreement to the processing of personal data relating to him or her, such as by a written statement, including by electronic means, or an oral statement. |
Controller |
means the natural or legal person, public authority, agency or any other entity or person who alone or jointly with others determines the purposes and means of the processing of personal data. Our entry as a Controller on the ICO‘s Data protection register can be found here. |
Cookies |
means a small file of letters and numbers that is stored on a browser or the hard drive of a computer. Cookies contain information that is transferred to a computer’s hard drive. Controllers must have users’ informed consent before storing cookies on a user’ device and/or tracking them. For more information, please read our cookie notice. The ICO provides information about cookies here. |
DPA 2018
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UK Data Protection Act 2018 |
Data Protection Law |
means all applicable data protection and privacy legislation in force from time to time including the UK GDPR and the EU GDPR, the Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003 No. 2426) as amended, and any other legislation relating to personal data and all other legislation and regulatory requirements in force from time to time that apply to the use of personal data. |
EU Representative
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the GDPR requires organisations not established in the EU to appoint a representative in an EU member state (or the EEA), if (i) it is apparent that the organisation intends to offer goods or services to individuals in the EU or (ii) it monitors the behaviour of individuals in the EU (or the EEA). |
EU GDPR |
means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing the Directive. |
ICO |
means the Information Commissioner’s Office, the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. |
Information Security Risks |
comprises the impacts on individuals or organisations that could occur due to the threats and vulnerabilities associated with the operation and use of information systems and the environments in which those systems operate. |
Lawful Basis |
under the EU GDPR and the UK GDPR, you must have a valid lawful basis to process personal data. Lawful Basis of processing personal dataThere are six lawful bases for processing personal data available:
For more information
Lawful basis for processing | ICO Special category data Special category data is personal data that needs more protection because it is sensitive. |
Legitimate Interests Assessment (LIA) |
is a form of risk assessment and should be conducted by an organisation when your personal data processing is based on legitimate interest. The LIA is split into three steps:
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Personal Data |
this is also referred to as “personal information” and it means any information relating to an identified or identifiable natural person (‘data subject‘); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. |
Personal Data Breach |
means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed |
Privacy Notice |
(also sometimes called a privacy policy or fair processing notice) is a public document from an organisation that explains how that organisation processes personal data and how it applies data protection principles under Articles 12, 13 and 14 of the EU GDPR and the UK GDPR. |
Special Category Personal Data |
some of the personal data that organisations process is more sensitive and needs higher protection. Under the GDPR, this is known as ‘special categories of personal data‘, and includes information about a person’s:
In order to lawfully process special category personal data, we must identify both a lawful basis under Article 6 of the UK GDPR and the EU GDPR and a separate condition for processing under Article 9. These do not have to be linked. There are ten conditions for processing special category data in Article 9 of the UK GDPR. Five of these require us to meet additional conditions and safeguards set out in UK law, in Schedule 1 of the DPA 2018. |
Special Category Personal Data Conditions for Processing |
the conditions for processing special category data:
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Supervisory Authorities |
means the data protection authority tasked with supervising GDPR compliance in each member state of the European Union. What are Data Protection Authorities (DPAs)? | European Commission (europa.eu) |
UK GDPR |
means the GDPR as transposed into United Kingdom national law by operation of section 3 of the European Union (Withdrawal) Act 2018, together with the DPA 2018, the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019, and other data protection or privacy legislation in force from time to time in the United Kingdom. |
Website |
Polaris UK Ltd and including all subdomains thereof, present and future. |