1
Polygona Ltd
Company Number 12493019
215 Charlton Crescent, Barking, IG11 0NH, United Kingdom
23 December 2022
Website Privacy Policy
1 INTRODUCTION
1.1 Important information and who we are
Welcome to Polygona Ltd’s Privacy and Data Protection Policy (“ ”).Privacy Policy
At Polygona Ltd (“ ”, “ ”, or “ ”) we are committed to protecting and respecting your we us our
privacy and Personal Data in compliance with the United Kingdom General Data Protection
Regulation (“ ”), the Data Protection Act 2018 and all other mandatory laws and GDPR
regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy
Policy will tell you about your privacy rights, how the law protects you, and inform our
employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
Customers
Suppliers
Business contacts
Employees/Staff Members
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data
processed at any time by us.
2
1.2 Who is Your Data Controller
Polygona Ltd is your Data Controller and responsible for your Personal Data. We are not
obliged by the GDPR to appoint a data protection officer and have not voluntarily
appointed one at this time. Therefore, any inquiries about your data should either be sent
to us on email at support@polygona.io or sent in a letter to 215 Charlton Crescent,
Barking, IG11 0NH, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s
Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We
would, however, appreciate the chance to deal with your concerns before you approach
the ICO so please contact us in the first instance.
1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal
with your data on our behalf (known as “ ”). Therefore, the responsibilities Processors
described below may be assigned to an individual, or may be taken to apply to the
organisation as a whole. The Data Controller and our Processors have the following
responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases
laid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed
themselves to confidentiality or are under an appropriate statutory obligation of
confidentiality;
Implement appropriate technical and organisational measures to ensure a level of
security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging
another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to
requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate
compliance with the obligations laid down in the GDPR and allow for and contribute
to audits, including inspections, conducted by the Controller or another auditor
mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a
Controller;
Cooperate, on request, with the supervisory authority in the performance of its
tasks;
Ensure that any person acting under the authority of the Processor who has access
to Personal Data does not process Personal Data except on instructions from the
Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data
Breach;
2 LEGAL BASIS FOR DATA COLLECTION
2.1 Types of Data / Privacy Policy Scope
3
“ ” means any information about an individual from which that person can Personal Data
be identified. It does not include data where the identity has been removed (anonymous
data).
We may collect, use, store and transfer different kinds of Personal Data about you which
we have grouped together below. Not all of the following types of data will necessarily be
collected from you but this is the full scope of data that we collect and when we collect it
from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date
of birth.
Contact Data: This is data relating to your phone number, addresses, email
addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receiving
marketing information and other information from us.
Billing Data: This is information relating to your debit and credit card information
such as the name attached to your payment details and your billing address.
Transactional Data: This is information of details and records of all payments you
have made for our services or products.
We also collect, use and share Aggregated Data such as We also collect use and share
Aggregated Data such as how often products are visited, downloaded or purchased..
Aggregated Data could be derived from your Personal Data but is not considered Personal
Data in law as this data will not directly or indirectly reveal your identity. However, if we
combine or connect Aggregated Data with your Personal Data so that it can directly or
indirectly identify you, we treat the combined data as Personal Data which will be used in
accordance with this Privacy Policy.
We may also aggregate data to enable research or analysis so that we can better
understand and serve you and others. For example, we may conduct research on your
demographics and usage. Although this aggregated data may be based in part on Personal
Data, it does not identify you personally. We may share this type of anonymous data with
others, including service providers, our affiliates, agents and current and prospective
business partners.
We do not collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health, and genetic
and biometric data). Nor do we collect any information about criminal convictions and
offences.
2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and
processing of Personal Data. The main avenues we rely on are:
“ ”: Certain situations allow us to collect your Personal Data, such as when Consent
you tick a box that confirms you are happy to receive email newsletters from us, or
‘opt in’ to a service.
“ ”: We may require certain information from you in order Contractual Obligations
to fulfil our contractual obligations and provide you with the promised service.
“ ”: We’re required by law to collect and process certain types of Legal Compliance
data, such as fraudulent activity or other illegal actions.
4
“ ”: We might need to collect certain information from you to be Legitimate Interest
able to meet our legitimate interests - this covers aspects that can be reasonably
expected as part of running our business, that will not have a material impact on
your rights, freedom or interests. Examples could be your address, so that we know
where to deliver something to, or your name, so that we have a record of who to
contact moving forwards.
3 HOW WE USE YOUR PERSONAL DATA
3.1 Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table
containing the different types of Personal Data we collect and the lawful basis for
processing that data. Please refer to section 2.2 for more information on the lawful basis
listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which
we use your data may be broader than described but we will never process your data
without a legal basis for doing so and it is for a related purpose. For further inquiries
please contact us.
Activity Type of data Legal
Justification
Lawful basis for
processing data
when a customer
signs up
Profile/Identity
Data
Legitimate
Interest
We need to process this
data so that we know who
to charge for the products
you have purchased from
us.
when a customer
signs up
Contact Data Legitimate
Interest
We need to process this
data so that we know who
to contact in case of
technical issues.
when a customer
uses our platform
Usage Data Legitimate
Interest
Necessity
We need to process this
data so that we know how
to improve the services
offered.
when a customer
opts-in to
marketing
communications
Marketing and
Communications
Data
Explicit
Consent
We need to process this
data so we know to whom
to send marketing
communications about new
products and offers.
when a customer
purchases a
product
Billing Data Legitimate
Interest
We need to process this
data so that we know who
and where to charge for the
products you have
purchased from us.
5
Activity Type of data Legal
Justification
Lawful basis for
processing data
when a customer
sells a product
Financial Data Legitimate
Interest
We need to process this
data so that we know who
and where to pay for the
products sold through our
platform.
3.2 Marketing and Content Updates
You will receive marketing and new content communications from us if you have created
an account and chosen to opt into receiving those communications. From time to time we
may make suggestions and recommendations to you about goods or services that may be
of interest to you.
3.3 Change of Purpose
We will only use your Personal Data 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 you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we
will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent,
in compliance with the above rules, where this is required or permitted by law.
4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 What Control Do I Have Over Polygona Ltd’s Use Of My Personal Data?
You may delete your account at any time – this will remove your account page from our
systems and our related software.
We guarantee this will delete all stored data.
You can access information associated with your account by logging into your account you
created with us.
Your account information will be protected by a password for your privacy and security.
You need to prevent unauthorized access to your account and personal information by
selecting and protecting your password appropriately and limiting access to your
computer or device and by signing off after you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California
residents are entitled to ask us for a notice identifying the categories of personal customer
information which we share with our affiliates and/or third parties for marketing purposes,
and providing contact information for such affiliates and/or third parties. If you are a
California resident and would like a copy of this notice, please submit a written request to
support@polygona.io.
4.2 How Does Polygona Ltd Protect Customers' Personal Data?
6
We are concerned with keeping your data secure and protecting it from inappropriate
disclosure. Any Personal Data collected by us is only accessible by a limited number of
employees who have special access rights to such systems and are bound by obligations
of confidentiality. If and when we use subcontractors to store your data, we will not
relinquish control of your Personal Data or expose it to security risks that would not have
arisen had the data remained in our possession. However, unfortunately no transmission
of data over the internet is guaranteed to be completely secure. It may be possible for
third parties not under the control of Polygona Ltd to intercept or access transmissions or
private communications unlawfully. While we strive to protect your Personal Data, we
cannot ensure or warrant the security of any Personal Data you transmit to us. Any such
transmission is done at your own risk. If you believe that your interaction with us is no
longer secure, please contact us.
4.3 Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by You can ask us to
stop sending you marketing messages at any time by disabling marketing notifications
from your account settings..
Where you opt out of receiving these marketing messages, we will continue to retain other
Personal Data provided to us as a result of interactions with us not related to your
marketing preferences.
4.4 How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other
rights). However, if your request is clearly unfounded, we could refuse to comply with your
request.
We may need to request specific information from you to help us confirm your identity
and ensure you have the right to access your Personal Data (or to exercise any of your
other rights). This is a security measure to ensure that Personal Data is not disclosed to
any person who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
5 YOUR DATA AND THIRD PARTIES
5.1 Will We Share Your Data With Third Parties?
We may also share Personal Data with interested parties in the event that Polygona Ltd
anticipates a change in control or the acquisition of all or part of our business or assets or
with interested parties in connection with the licensing of our technology.
If Polygona Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer,
sell or assign your Personal Data to a third party as part of or in connection with that
transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the
further use of your Personal Data. In all other situations your data will still remain
protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to
enforce our terms or this Privacy Policy.
5.2 Third-Party Links
SeedLegals - Website Privacy Policy - PYCP-1-2020-02-19
d_70CavjE3Mz
7
This Site may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave our Site, we encourage you to read the privacy policy
of every website you visit.
6 HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes
we collected it for. We may retain your Personal Data for a longer period than usual in the event
of a complaint or if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.
7 INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictions
outside the US where Polygona Ltd has facilities. We are currently storing data in the EU and so,
by using Polygona Ltd, you are permitting and consenting to the transfer of information,
including Personal Data, outside of the US.
8 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. This
version is dated 23 December 2022. By using Polygona Ltd, you consent to the collection and use
of data by us as set out in this Privacy Policy. Continued access or use of Polygona Ltd will
constitute your express acceptance of any modifications to this Privacy Policy.
9 INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated
examples are not intended to in any way limit the term which they serve to illustrate. Any email
addresses set out in this policy may be used solely for the purpose for which they are stated to
be provided, and any unrelated correspondence will be ignored. Unless otherwise required by
law, we reserve the right to not respond to emails, even if they relate to a legitimate subject
matter for which we have provided an email address. As a matter of common sense, you are
more likely to get a reply if your request or question is polite, reasonable and there is no
relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other
areas of our website etc.).
Our staff are not authorised to contract on behalf of Polygona Ltd, waive rights or make
representations (whether contractual or otherwise). If anything contained in an email from a
Polygona Ltd address contradicts anything in this policy, our terms or any official public
announcement on our website, or is inconsistent with or amounts to a waiver of any Polygona
Ltd rights, the email content will be read down to grant precedence to the latter. The only
exception to this is genuine correspondence expressed to be from the Polygona Ltd legal
department.
10 TERMS OF USE
Please also see our Terms of Use (https://polygona.io/terms-of-use) which set out the terms,
disclaimers, and limitations of liability governing your use of Polygona Ltd.
