Active Capital Ltd. (Polyn) is committed to being a responsible custodian of the information you provide to us and the information we collect in the course of operating our business.
· The types of information, including personal information, we may collect;
· How we may use and share or otherwise process the information we collect;
· The measures we have in place to protect and safely store the information we collect;
· Legal grounds for using the personal information we collect;
· Your choices and rights in respect of the information we hold;
· Retention of the information we collect;
· How to contact us;
· Complaints; and
The types of information, including personal information, we may collect
To activate the Polyn service you need to submit limited personal information when you register on the website. To use the service thereafter, you do not need to submit further personal information. "Personal information" is any information that can be used to identify you or that we can link to you as an individual. We may automatically collect certain information when you use, access, or interact with our Online Services which may include, but is not limited to your:
· Full name, age, date of birth, gender and nationality;
· Telephone number;
· Email address;
· Postal address; and
· IP address and/or MAC address.
We may also collect photos, videos or other images of you when you attend Polyn events.
We may also collect information from other sources, such as social media platforms that may share your device information/content and/or how you interact with our social media content.
Information you provide to us voluntarily
We also collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you marketing materials; when you sign up for an event; and when you respond to our communications or requests for information. The information you provide may include your name, contact information, title, and information about the organisation with which you are affiliated. Our Online Services require that you enter a password or other information in order to access certain features, and we collect such credentials when you enter them.
Information we may collect automatically through cookies and similar technologies
Information we may collect from third party sources
We may receive information about you from other sources, including third parties that help us: update, expand, and analyze our records; identify new customers; or prevent or detect fraud. We may also receive information about you from social media platforms, including but not limited to, when you interact with us on those platforms or access our social media content. Please note that the information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.
Precise location information
When you access the Online Services via a mobile device, we may collect precise location information if you permit the Online Services to access such information. We use this information to provide you with content based on your location.
How we use the information we collect
We may use the information we collect:
· To provide you with the Polyn loyalty program and to automatically enter you into free promotional offers and events;
· To respond to your enquiries;
· To operate and improve our Online Services;
· With your consent, to send you marketing communications, and other information or materials that may be of interest to you or which you have expressed an interest in receiving;
· With your consent, to post images and videos of you to social media platforms that promote our services or use those images within our own marketing materials;
· To maintain our list of contacts;
· To understand how people use our Online Services, including by generating and analysing statistics;
· For other business purposes, including data analysis; submitting invoices; detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
· To assess the effectiveness of our events, promotional campaigns and publications;
· As we believe reasonably necessary or appropriate to comply with our legal obligations;
· To respond to legal process or requests for information issued by government authorities or other third parties; and
· To protect your, our, or others’ rights.
How we may share the information we collect
We may share the information we collect with other businesses that accept Polyn for business purposes such as internal administration, billing or providing you or your organisation with the services you have requested. For a full list of the businesses that accept Polyn please click here.
We do not share the information we collect with other businesses that accept Polyn for their marketing purposes without obtaining your prior consent.
We may also disclose information we collect:
· To third-party service providers that perform services on our behalf, such as web-hosting companies, mailing vendors, analytics providers, event hosting services, and information technology providers;
· Employees, agents or contracted parties of Polyn and Active Capital Ltd. may be given access to any information which we collect via our Online Services, but their use shall be limited to the performance of their duties and in line with the reason for processing. Our employees are required to keep that information confidential and are not permitted to use it for any purposes other than to enable you to use the Online Services or to deal with requests which you submit to us;
· To law enforcement, other government authorities, or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided for under contract; or as we deem reasonably necessary to provide our services. In these circumstances, we take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organisation, unless prior notice is prohibited by applicable law, or is not possible or reasonable in the circumstances; and
· To service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
· Performance of a contract – We may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us. For example, when you use our Online Services we will use your personal information to respond to your requests and provide you with the business services you have requested;
Third-party services and content
We engage third parties that support the operation of our Online Services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see our Cookies Policy for more information.
Protection and storage of the information we collect
The Online Services are controlled and operated by us. We may store the information we collect in the Cayman Islands or in other countries where we or our service providers have facilities. We may process the information we collect in jurisdictions where we or our service providers have facilities.
In addition we deploy administrative, technical, and physical safeguards designed to comply with applicable legal requirements and safeguard the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by us.
However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.
Your choices and rights
If you no longer wish to receive marketing communications from us, you can let us know by sending us an email via our Contact Us page. Where required by applicable laws we will rely on your consent for direct marketing and to collect information from you device or computer. Any electronic marketing communications we send you also contain opt-out mechanisms that allow you to opt-out from receiving those communications at any time. We will honour your choice and refrain from sending you such announcements. You may also opt back in to receive those communications at any time.
Subject to local law, you may have certain rights regarding information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or out of date. You can also ask us to see what personal information we hold about you, to erase your personal information and you may tell us if you object to our use of your personal information. In some jurisdictions, you may have a right to complain to your local data protection authority. If you would like to discuss or exercise the rights you may have, send us an email at [email protected].
Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request, for example because we have legitimate grounds for not doing so or where the right doesn’t apply to the particular information we hold on you.
We welcome your enquiries and comments. If you would like to contact us with questions about our privacy or data protection practices, please email: [email protected].
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to complain to the data protection authority/regulator, as applicable, in your jurisdiction.
Cookies and Tracking Technologies
Web Browser Cookies
A web browser cookie is a small text file that is sent by a website to your computer or mobile device where it is stored by your web browser. Web browser cookies may store information such as your IP address or other identifier, your browser type, and information about the content you view and interact with on the Online Services. By storing such information, web browser cookies can remember your preferences and settings for online services and analyse how you use online services.
Tracking Technologies: Web Beacons/Gifs, Pixels, Page Tags, Script
Emails and mobile applications may contain a small transparent image files or lines of code to record how you interact with them. This information is used to help website and application publishers better analyse and improve their services.
Your choices: managing cookies and opting out
You can choose how web browser cookies are handled by your device via your browser settings, including refusing or deleting all cookies. Some devices allow you to control this via your device settings. If you choose not to receive cookies at any time, the website may not function properly and certain services will not be provided. Each browser and device is different, so check the settings menu of the browser or device you are using to learn how to change your advertising settings and cookie preferences.