1. The importance of your privacy to us
- The Pollpass website (pollpass.com) and Pollpass mobile app, together with any other Pollpass branded services provided or made available (collectively the “Pollpass Platform”) is brought to you by GlobalWebIndex Labs Limited (doing business as ‘Pollpass’), a company incorporated and registered in England and Wales with company number 10891092. (“Pollpass”, “us”, “our” or “we”).
- We take the privacy of the Pollpass Platform users very seriously. We ask that you read this privacy statement (“Privacy Statement”) carefully as it contains important information about:
- what personal data we may collect from you;
- how we will use, store and protect your personal data; and
- with whom we may share personal data.
- For the purposes of data protection legislation (including, but not limited to the Data Protection Act 1998 (for collection of data prior to 25 May 2018 and the General Data Protection Regulation for collection of data from 25 May 2018 onwards) Pollpass is the ‘data controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data).
- If you need to contact us please e-mail us at: firstname.lastname@example.org.
2. Legal grounds for collecting your information
- Where relying upon your consent to collect and process your personal data, we shall seek such consent before we collect and process your personal data. You have the right to withdraw your consent to this at any time by disabling certain services, opting out through the settings on your mobile or internet connected device or directly contacting us to indicate your request.
3. What information may we collect from you?
- We may collect and process the following data about you:
- Registration information: We may collect various personal data which you choose to provide when you register with us (including your name, mobile phone number, email address and date of birth). Such registration may be through other applications and may require collecting user information about such other applications to enable registration.
- Response Information: We shall collect information from you through your interaction on the Pollpass Platform, such information relates to your habits and preferences and shall be collated based on your Reponses.
- Device information: We may collect information about the mobile telephone, tablet or other device you may use to download the Pollpass App or access the Pollpass Platform, including, where available, the mobile device’s identifiers, operating system, browser type and network information. From time to time we may associate mobile device information with registration information and will treat the combined information as personal data in accordance with this Privacy Statement for as long as it is combined.
- Location information: The Pollpass Platform may collect your location data, for example postcode, zip code or other location information and IP address, and potentially geolocation and location presence awareness technology and functionality when you are using the Pollpass Platform if you have consented to us collecting such geolocation data.
- Log information: When you use the Pollpass Platform or view content on sites or app operated by third parties, we may automatically collect and store certain information in server logs, including but not limited to pages or products you viewed or searched for, internet protocol (IP) addresses, internet service provider (ISP), clickstream data, browser type and language, viewed and exit pages and date or time stamps. We may also create a unique device ID and unique user ID as part of the authentication process for your use of the Pollpass Platform.
- Analytic information: When you use the Pollpass Platform we may collect information of your use of the Pollpass Platform to understand whether there are any products or services which may be of interest to you. Such information may be collated to help build a picture of your interests and use of the Pollpass Platform which may be used for marketing. Such information shall only be used to the extent as notified to you. Pollpass or its chosen third parties shall not market to you based on such information where you have expressly requested that such marketing is ceased.
- The following additional information may also be collected:
- if you contact us or other companies within our corporate group, for example if you report a problem with the Pollpass Platform, we may keep a record of that correspondence. In such circumstances, we may monitor and record such communications with you; and
- information you voluntarily provide to us in response to any surveys, competitions or promotions or to enable the delivery or supply of a Reward to you.
This helps us count how many people visit Pollpass by tracking if you’ve visited before
|This cookie is set by Mixpanel for analyzing traffic, and in particular how users reached the plataform|
this lets us know if you’ve visited before, so we can count how many of our visitors are new to Pollpass or to a certain page
|This cookie is used for online ad effectiveness, tracking website visits, developing online look-a-like cohorts and audience insights|
- Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
5. What do we do with information collected from you?
We may use your personal data for the following purposes:
Profile management and behaviour analysis
- to build an understanding and obtain insights into internet user behaviour and to add such information to our database of information which we maintain about users of the Pollpass Platform (the “Pollpass Database”). We can then use the Pollpass Database to collectively ascertain preferences and behaviours about our users, for example in relation to the preferences or behaviours of individuals within a particular age-range or demographic;
- to facilitate ‘ID syncing’ techniques, such as device fingerprinting. This is carried out by matching your unique Pollpass ID with an online identifier, such as a cookie placed by us or our clients on your device. Your Pollpass ID will be anonymised before it is shared with our clients. The purpose of ID syncing is for our clients to build a picture of your online behaviour on an anonymous basis;”
- to inform our clients and business partners of preferences and behaviours about our users in order to help shape their marketing and product development;
- to enrich third party databases by sharing preferences and behaviours of our users – typically this is on a collective and, where possible, and anonymised basis. However, we can never fully know what other information a third party holds about you already, and it may be that third parties are able to link such information we provide to other information that you have previously shared directly with them. For example, third parties such as our clients (and our clients’ own clients) are likely to have databases of their own, and it may be that you have consented to them holding information about you that could allow them to match their records with the data we supply. Similarly, if we share data with social networks, it may be that they can match our data with the other information that you have permitted them to hold about you. Please note that third parties should only lawfully be able to undertake this “matching” if you have given them specific permission to hold and use your data in such a way;
- we may also receive personal data about you from third parties, where such third parties are permitted to collect, process and share with us such personal data. Typically such personal data shall be collected subject to your consent. Such personal data shall be combined with the Pollpass Database;
Managing and tailoring your Pollpass Platform user experience
- for our business purposes, such as data analysis, audits, developing new products, operating and improving the Pollpass Platform, identifying usage trends and determining the effectiveness of our communications;
- to personalise your experience on the Pollpass Platform and by presenting information tailored to you and to your geographic location. This is intended to make the Pollpass Platform more useful to you, for example by allowing notifying you of information or offers that may be of interest;
- to provide customer service, including to respond to your enquiries and fulfil any of your requests for information;
- where applicable, to facilitate the provision of Rewards to you;
- to send you important information regarding the Pollpass Platform and/or other technical notices, updates, security alerts, and support and administrative messages;
- to send you marketing or promotional information about services or products that may be of interest to you, including where we e-mail you such information on behalf of third parties or details of Rewards that may be provided by third parties;
- as we believe to be necessary or appropriate:
- under applicable law, including laws outside your country of residence;
- to comply with legal process;
- to verify your identity, in particular that you are at least 16 years old or to identify multiple accounts;
- to respond to requests from law enforcement and other government authorities including public and government authorities outside your country of residence;
- to protect our rights, privacy, property or safety, and/or that of our affiliates, you or others; and
- to allow us to pursue available remedies or limit the damages that we may sustain; and
- in any other way that is envisioned by this Privacy Statement or may be required in order to improve our service.
6. How we store information we collect from you
- The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) including the US where the laws on processing personal data may be less stringent than in your country. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of providing the services through the Pollpass Platform.
- Presently personal data collected from you is stored in data centres as well as Cloud networks which are located or hosted in the European Economic Area.
- When your personal data is transferred to parties located outside of the European Economic Area which are not on the European Council’s ‘whitelist’ or are Privacy Shield certified we shall either enter into the Standard Contractual Clauses for the transfer of personal data (as approved by the European Council) or undertake an assessment to ensure such third party will provide adequate security of such personal data and respect your rights to privacy.
- We take all steps reasonably necessary to ensure that your personal data is treated securely. In particular, all information you provide to us is stored on secure servers. You should be aware, however, that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data during its transmission; any transmission is at your own risk.
- The Pollpass Database is an ongoing resource which is regularly supplemented by further information provided by users of the Pollpass Platform. Where information has been aggregated into the Pollpass Database (including any personal data supplied by you), it will be retained for as long the Pollpass Database is in operation and we shall delete or anonymise the personal data when the purpose or legal grounds for which we have collected the personal data ends.
7. Disclosure of your information
- In order to fulfil the purposes set out above, we may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006, as well as any of our strategic business partners or third party agents, contractors or service providers under contract who provide business operations support.
- We may, following a request from you, disclose your personal data to any third party whose website, app, products or services are referred to within the Pollpass Platform. For example, if the Pollpass Platform enables you to obtain a Reward from a third party, your information will be shared with that third party to enable the fulfilment of the Reward.
- We may supply aggregated data from the Pollpass Database to third party customers of Pollpass. This information may contain your IP Address, and ‘hashed’ versions of your email address (which effectively translates your e-mail address into a unique code of letters and numbers which is unrecognisable from the original e-mail address), cookie information and user preference and behaviours we understand about you. Where possible such information shall be anonymised, however, even in such instances it may be possible for such third parties to use the personal data to identify you as we can never folly know what other information a third party holds about you already. It may be that third parties are able to link such information we provide to other information that you have previously shared directly with them.
- Finally, we may disclose your personal data to the following third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Pollpass or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
- we believe in good faith that the disclosure of the information (including personal data) is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to enforce, act in compliance of, or investigate violations of, this Privacy Statement; or
- if you have otherwise provided your consent to such disclosure.
- Please note that we do not disclose your personal data to any third parties except as set out in this Privacy Statement.
8. Information about other individuals
- If you give us information (including personal data) on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can (in accordance with this Privacy Statement):
- give consent on the individual’s behalf to the processing of their personal data;
- receive on the individual’s behalf any data protection notices; and
- give consent to the transfer of the individual’s personal data abroad.
9. Your rights
- You have the right, which may be subject to the payment of a small fee, to request access to personal data that we may process about you. If you wish to exercise this right, you should:
- put your request in writing;
- include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill);
- provide payment, if so requested, to GlobalWebIndex Labs Limited; and
- specify the personal data you want access to, including any account or reference numbers where applicable.
- You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should either amend your profile directly via the Pollpass Platform or:
- put your request in writing to email@example.com;
- provide us with enough information to identify you (e.g. account number, user name, registration details); and
- specify the information that is incorrect and what it should be replaced with.
- Where you have consented to us collecting and processing your personal data, you also have the right to: (i) ask us to stop processing your personal data; (ii) ask for an electronic copy of the personal data we have about you; and/or (iii) delete your account and the personal data we hold in relation to you. If you wish to exercise any of these rights, you should either amend your profile directly via the Pollpass Platform or:
- put your request in writing to firstname.lastname@example.org;
- provide us with enough information to identify you (e.g. account number, user name, registration details); and
- if your objection is not to receive direct marketing in general, but to receive direct marketing by a particular channel (e.g. email or telephone), please specify the channel you are objecting to.
- Where you exercise your rights we shall endeavour to process such actions as soon as practically possible. Please note that such processes may take a short time to process and update, however, please let us know if you have any concerns that such requests have not been folly processed and provide us with details.
- Should you have any complaints, please contact us at email@example.com. Should we be unable to resolve your complain and you wish to take your complaint further you may do so with the Information Commissioner’s Office.
10. Links to other sites
The Pollpass Platform may, from time to time, contain links to and from the apps and websites of other networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these apps and websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these apps, websites or services. Please check these policies before you submit any personal data to these websites or use such services.
11. Amendments to this Privacy Statement
No changes to this Privacy Statement are valid or have any effect unless agreed by us in writing. We reserve the right to vary this Privacy Statement from time to time. Our updated terms will be displayed on the Pollpass Platform. It is your responsibility to check this Privacy Statement from time to time to verify such variations.
Questions, comments and requests regarding this Privacy Statement are welcomed and should be addressed to firstname.lastname@example.org.