Privacy policy
We respect your privacy and are committed to protecting it through our compliance with
this privacy policy (“Policy”). This Policy describes the types of information we may collect
from you or that you may provide (“Personal Information”) on the pollerco.com website
(“Website” or “Service”) and any of its related products and services (collectively,
“Services”), and our practices for collecting, using, maintaining, protecting, and disclosing
that Personal Information. It also describes the choices available to you regarding our use of
your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and
POLLERCO (“POLLERCO”, “we”, “us” or “our”). If you are entering into this agreement on
behalf of a business or other legal entity, you represent that you have the authority to bind
such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to
such entity. If you do not have such authority, or if you do not agree with the terms of this
agreement, you must not accept this agreement and may not access and use the Website
and Services. By accessing and using the Website and Services, you acknowledge that you
have read, understood, and agree to be bound by the terms of this Policy. This Policy does
not apply to the practices of companies that we do not own or control, or to individuals that
we do not employ or manage.
Collection of personal information
You can access and use the Website and Services without telling us who you are or revealing
any information by which someone could identify you as a specific, identifiable individual. If,
however, you wish to use some of the features offered on the Website, you may be asked to
provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an
account, publish content, make a purchase, or fill any forms on the Website. When
required, this information may include the following:
– Account details (such as user name, unique user ID, password, etc)
– Contact information (such as email address, phone number, etc)
– Basic personal information (such as name, country of residence, etc)
– Payment information (such as credit card details, bank details, etc)
– Geolocation data of your device (such as latitude and longitude)
Some of the information we collect is directly from you via the Website and Services.
However, we may also collect Personal Information about you from other sources such as
social media platforms, public databases, third-party data providers, and our joint partners.
Personal Information we collect from other sources may include demographic information,
such as age and gender, device information, such as IP addresses, location, such as city and
state, and online behavioral data, such as information about your use of social media
websites, page view information and search results and links.
You can choose not to provide us with your Personal Information, but then you may not be
able to take advantage of some of the features on the Website. Users who are uncertain
about what information is mandatory are welcome to contact us.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 13. If
you are under the age of 13, please do not submit any Personal Information through the
Website and Services. If you have reason to believe that a child under the age of 13 has
provided Personal Information to us through the Website and Services, please contact us to
request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to
help enforce this Policy by instructing their children never to provide Personal Information
through the Website and Services without their permission. We also ask that all parents and
legal guardians overseeing the care of children take the necessary precautions to ensure
that their children are instructed to never give out Personal Information when online
without their permission.
Use and processing of collected information
We act as a data controller and a data processor in terms of the GDPR when handling
Personal Information, unless we have entered into a data processing agreement with you in
which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information.
We act in the capacity of a data controller when we ask you to submit your Personal
Information that is necessary to ensure your access and use of the Website and Services. In
such instances, we are a data controller because we determine the purposes and means of
the processing of Personal Information and we comply with data controllers’ obligations set
forth in the GDPR.
We act in the capacity of a data processor in situations when you submit Personal
Information through the Website and Services. We do not own, control, or make decisions
about the submitted Personal Information, and such Personal Information is processed only
in accordance with your instructions. In such instances, the User providing Personal
Information acts as a data controller in terms of the GDPR.
In order to make the Website and Services available to you, or to meet a legal obligation, we
may need to collect and use certain Personal Information. If you do not provide the
information that we request, we may not be able to provide you with the requested
products or services. Any of the information we collect from you may be used for the
following purposes:
– Create and manage user accounts
– Fulfill and manage orders
– Deliver products or services
– Improve products and services
– Send administrative information
– Send marketing and promotional communications
– Send product and service updates
– Respond to inquiries and offer support
– Request user feedback
– Improve user experience
– Deliver targeted advertising
– Administer prize draws and competitions
– Run and operate the Website and Services
Processing your Personal Information depends on how you interact with the Website and
Services, where you are located in the world and if one of the following applies: (i) you have
given your consent for one or more specific purposes; this, however, does not apply,
whenever the processing of Personal Information is subject to California Consumer Privacy
Act or European data protection law; (ii) provision of information is necessary for the
performance of an agreement with you and/or for any pre-contractual obligations thereof;
(iii) processing is necessary for compliance with a legal obligation to which you are subject;
(iv) processing is related to a task that is carried out in the public interest or in the exercise
of official authority vested in us; (v) processing is necessary for the purposes of the
legitimate interests pursued by us or by a third party.
We rely on user’s consent and personal information is already publicly available as legal
bases as defined in the GDPR upon which we collect and process your Personal Information.
Note that under some legislations we may be allowed to process information until you
object to such processing by opting out, without having to rely on consent or any other of
the legal bases above. In any case, we will be happy to clarify the specific legal basis that
applies to the processing, and in particular whether the provision of Personal Information is
a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Payment processing
In case of Services requiring payment, you may need to provide your credit card details or
other payment account information, which will be used solely for processing payments. We
use third-party payment processors (“Payment Processors”) to assist us in processing your
payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security
Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express
and Discover. Sensitive and private data exchange happens over a SSL secured
communication channel and is encrypted and protected with digital signatures, and the
Website and Services are also in compliance with strict vulnerability standards in order to
create as secure of an environment as possible for Users. We will share payment data with
the Payment Processors only to the extent necessary for the purposes of processing your
payments, refunding such payments, and dealing with complaints and queries related to
such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you,
which allows them to process your payments (e.g., your email address, address, credit card
details, and bank account number) and handle all the steps in the payment process through
their systems, including data collection and data processing. The Payment Processors’ use of
your Personal Information is governed by their respective privacy policies which may or may
not contain privacy protections as protective as this Policy. We suggest that you review their
respective privacy policies.
We may also ask you to permit us to collect data about you from third-party providers to
verify your identity, do a credit check and prevent fraud or assess risk. This helps us ensure
that you are using our Services legally, that you are eligible for the Services you want to use,
and to protect your data and our Services from fraudsters who may put you and your money
at risk.
Managing information
You are able to delete certain Personal Information we have about you. The Personal
Information you can delete may change as the Website and Services change. When you
delete Personal Information, however, we may maintain a copy of the unrevised Personal
Information in our records for the duration necessary to comply with our obligations to our
affiliates and partners, and for the purposes described below. If you would like to delete
your Personal Information or permanently delete your account, you can do so by contacting
us.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or
provide any Service you have requested, we may share your information with our affiliates,
contracted companies, and service providers (collectively, “Service Providers”) we rely upon
to assist in the operation of the Website and Services available to you and whose privacy
policies are consistent with ours or who agree to abide by our policies with respect to
Personal Information. We will not share any personally identifiable information with third
parties and will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary
to perform services on our behalf or comply with legal requirements. Service Providers are
given the information they need only in order to perform their designated functions, and we
do not authorize them to use or disclose any of the provided information for their own
marketing or other purposes.
We may also disclose any Personal Information we collect, use or receive if required or
permitted by law, such as to comply with a subpoena or similar legal process, and when we
believe in good faith that disclosure is necessary to protect our rights, protect your safety or
the safety of others, investigate fraud, or respond to a government request.
Retention of information
We will retain and use your Personal Information for the period necessary as long as your
user account remains active, until the purchase order or Services are fulfilled, until our and
our affiliates and partners obligations are fulfilled, to enforce our agreements, resolve
disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information
after you update or delete it, but not in a manner that would identify you personally. Once
the retention period expires, Personal Information shall be deleted. Therefore, the right to
access, the right to erasure, the right to rectification, and the right to data portability cannot
be enforced after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your
information in a country other than your own. The transfer of your Personal Information to
countries outside the European Union will be made only if you have explicitly consented to
it or in the cases provided for by the GDPR and will be processed in your interest.
You are entitled to learn about the legal basis of information transfers to a country outside
the European Union or to any international organization governed by public international
law or set up by two or more countries, such as the UN, and about the security measures
taken by us to safeguard your information. If any such transfer takes place, you can find out
more by checking the relevant sections of this Policy or inquire with us using the
information provided in the contact section.
Data protection rights under the GDPR
If you are a resident of the European Economic Area (“EEA”), you have certain data
protection rights and we aim to take reasonable steps to allow you to correct, amend,
delete, or limit the use of your Personal Information. If you wish to be informed what
Personal Information we hold about you and if you want it to be removed from our systems,
please contact us. In certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to
the processing of your Personal Information. To the extent that the legal basis for our
processing of your Personal Information is consent, you have the right to withdraw that
consent at any time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.
(ii) You have the right to learn if your Personal Information is being processed by us, obtain
disclosure regarding certain aspects of the processing, and obtain a copy of your Personal
Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated
or corrected. You also have the right to request us to complete the Personal Information
you believe is incomplete.
(iv) You have the right to object to the processing of your information if the processing is
carried out on a legal basis other than consent. Where Personal Information is processed for
the public interest, in the exercise of an official authority vested in us, or for the purposes of
the legitimate interests pursued by us, you may object to such processing by providing a
ground related to your particular situation to justify the objection.
(v) You have the right, under certain circumstances, to restrict the processing of your
Personal Information. These circumstances include: the accuracy of your Personal
Information is contested by you and we must verify its accuracy; the processing is unlawful,
but you oppose the erasure of your Personal Information and request the restriction of its
use instead; we no longer need your Personal Information for the purposes of processing,
but you require it to establish, exercise or defend your legal claims; you have objected to
processing pending the verification of whether our legitimate grounds override your
legitimate grounds. Where processing has been restricted, such Personal Information will be
marked accordingly and, with the exception of storage, will be processed only with your
consent or for the establishment, to exercise or defense of legal claims, for the protection of
the rights of another natural, or legal person or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal
Information from us. These circumstances include: the Personal Information is no longer
necessary in relation to the purposes for which it was collected or otherwise processed; you
withdraw consent to consent-based processing; you object to the processing under certain
rules of applicable data protection law; the processing is for direct marketing purposes; and
the personal data have been unlawfully processed. However, there are exclusions of the
right to erasure such as where processing is necessary: for exercising the right of freedom of
expression and information; for compliance with a legal obligation; or for the establishment,
to exercise or defense of legal claims.
(vii) You have the right to receive your Personal Information that you have provided to us in
a structured, commonly used, and machine-readable format and, if technically feasible, to
have it transmitted to another controller without any hindrance from us, provided that such
transmission does not adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority about our collection and
use of your Personal Information. If you are not satisfied with the outcome of your
complaint directly with us, you have the right to lodge a complaint with your local data
protection authority. For more information, please contact your local data protection
authority in the EEA. This provision is applicable provided that your Personal Information is
processed by automated means and that the processing is based on your consent, on a
contract which you are part of, or on pre-contractual obligations thereof.
California privacy rights
Consumers residing in California are afforded certain additional rights with respect to their
Personal Information under the California Consumer Privacy Act (“CCPA”). If you are a
California resident, this section applies to you.
In addition to the rights as explained in this Policy, California residents who provide Personal
Information as defined in the statute to obtain Services for personal, family, or household
use are entitled to request and obtain from us, once a calendar year, information about the
categories and specific pieces of Personal Information we have collected and disclosed.
Furthermore, California residents have the right to request deletion of their Personal
Information or opt-out of the sale of their Personal Information which may include selling,
disclosing, or transferring Personal Information to another business or a third party for
monetary or other valuable consideration. To do so, simply contact us. We will not
discriminate against you if you exercise your rights under the CCPA.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details
provided in this document. Please note that we may ask you to verify your identity before
responding to such requests. Your request must provide sufficient information that allows
us to verify that you are the person you are claiming to be or that you are the authorized
representative of such person. If we receive your request from an authorized
representative, we may request evidence that you have provided such an authorized
representative with power of attorney or that the authorized representative otherwise has
valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and
respond to it. We cannot respond to your request or provide you with Personal Information
unless we first verify your identity or authority to make such a request and confirm that the
Personal Information relates to you.
Cookies
Our Website and Services use “cookies” to help personalize your online experience. A
cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be
used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to
you, and can only be read by a web server in the domain that issued the cookie to you.
We may use cookies to collect, store, and track information for security and personalization,
and for statistical purposes. Please note that you have the ability to accept or decline
cookies. Most web browsers automatically accept cookies by default, but you can modify
your browser settings to decline cookies if you prefer.
Data analytics
Our Website and Services may use third-party analytics tools that use cookies, web beacons,
or other similar information-gathering technologies to collect standard internet activity and
usage information. The information gathered is used to compile statistical reports on User
activity such as how often Users visit our Website and Services, what pages they visit and for
how long, etc. We use the information obtained from these analytics tools to monitor the
performance and improve our Website and Services. We do not use third-party analytics
tools to track or to collect any personally identifiable information of our Users and we will
not associate any information gathered from the statistical reports with any individual User.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that
you do not want to have your online activity tracked. Tracking is not the same as using or
collecting information in connection with a website. For these purposes, tracking refers to
collecting personally identifiable information from consumers who use or visit a website or
online service as they move across different websites over time. The Website and Services
do not track its visitors over time and across third-party websites. However, some third-
party websites may keep track of your browsing activities when they serve you content,
which enables them to tailor what they present to you. For a description of Do Not Track
protocols for browsers and mobile devices or to learn more about the choices available to
you, visit internetcookies.com
Social media features
Our Website and Services may include social media features, such as the Facebook and
Twitter buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social
Media Features may collect your IP address, what page you are visiting on our Website and
Services, and may set a cookie to enable Social Media Features to function properly. Social
Media Features are hosted either by their respective providers or directly on our Website
and Services. Your interactions with these Social Media Features are governed by the
privacy policy of their respective providers.
Email marketing
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are
committed to keeping your e-mail address confidential and will not disclose your email
address to any third parties except as allowed in the information use and processing section
or for the purposes of utilizing a third-party provider to send such emails. We will maintain
the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-
mail is from and provide clear information on how to contact the sender. You may choose to
stop receiving our newsletter or marketing emails by following the unsubscribe instructions
included in these emails or by contacting us. However, you will continue to receive essential
transactional emails.
Push notifications
We offer push notifications to which you may also voluntarily subscribe at any time. To
make sure push notifications reach the correct devices, we use a third-party push
notifications provider who relies on a device token unique to your device which is issued by
the operating system of your device. While it is possible to access a list of device tokens,
they will not reveal your identity, your unique device ID, or your contact information to us
or our third-party push notifications provider. We will maintain the information sent via e-
mail in accordance with applicable laws and regulations. If, at any time, you wish to stop
receiving push notifications, simply adjust your device settings accordingly.
Affiliate links
We may engage in affiliate marketing and have affiliate links present on the Website and
Services for the purpose of being able to offer you related or additional products and
services. If you click on an affiliate link, a cookie will be placed on your browser to track any
sales for purposes of commissions.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled
by us. Please be aware that we are not responsible for the privacy practices of such other
resources or third parties. We encourage you to be aware when you leave the Website and
Services and to read the privacy statements of each and every resource that may collect
Personal Information.
Information security
We secure information you provide on computer servers in a controlled, secure
environment, protected from unauthorized access, use, or disclosure. We maintain
reasonable administrative, technical, and physical safeguards in an effort to protect against
unauthorized access, use, modification, and disclosure of Personal Information in our
control and custody. However, no data transmission over the Internet or wireless network
can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i)
there are security and privacy limitations of the Internet which are beyond our control; (ii)
the security, integrity, and privacy of any and all information and data exchanged between
you and the Website and Services cannot be guaranteed; and (iii) any such information and
data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you
use to communicate with us and the security you use to protect your credentials, please
take appropriate measures to protect this information.
Data breach
In the event we become aware that the security of the Website and Services has been
compromised or Users’ Personal Information has been disclosed to unrelated third parties
as a result of external activity, including, but not limited to, security attacks or fraud, we
reserve the right to take reasonably appropriate measures, including, but not limited to,
investigation and reporting, as well as notification to and cooperation with law enforcement
authorities. In the event of a data breach, we will make reasonable efforts to notify affected
individuals if we believe that there is a reasonable risk of harm to the User as a result of the
breach or if notice is otherwise required by law. When we do, we will post a notice on the
Website, send you an email, mail you a letter.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at
any time at our discretion. When we do, we will revise the updated date at the bottom of
this page. We may also provide notice to you in other ways at our discretion, such as
through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the
revised Policy unless otherwise specified. Your continued use of the Website and Services
after the effective date of the revised Policy (or such other act specified at that time) will
constitute your consent to those changes. However, we will not, without your consent, use
your Personal Information in a manner materially different than what was stated at the time
your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By
accessing and using the Website and Services and submitting your information you agree to
be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not
authorized to access or use the Website and Services.
Contacting us
If you have any questions regarding the information we may hold about you or if you wish
to exercise your rights, you may use the following data subject request form to submit your
request:
Submit a data access request
If you have any other questions, concerns, or complaints regarding this Policy, we encourage
you to contact us using the details below:
https://www.pollerco.com/contact/
info@pollerco.com
We will attempt to resolve complaints and disputes and make every reasonable effort to
honor your wish to exercise your rights as quickly as possible and in any event, within the
timescales provided by applicable data protection laws.