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Last updated on 24th May, 2018

Privacy Policy

Introduction

Your privacy is important to us.

This privacy policy has been created to explain how and why we collect and use information about our users, and how we manage your privacy protection. We recommend that you read this statement in full, so that you understand how we will use your personal data. You can also read about specific issues by clicking on one of the topics below.

 

Table of Contents

  1. What personal data do we collect?
  2. Legal basis for processing.
  3. How do we use your personal data?
  4. How do we share your information?
  5. Your rights and choices.
  6. Other important information.

 

What personal data do we collect?

Polonez collects personal data to operate our business and to provide you with the product and services that we offer. You provide some of this data to us directly, for example when you open an account with us, contact an advertiser on the site, or send a query to our support team. Other data is collected when you interact with our products, by using cookies and other technologies.

When using our site, you have choices about what data we collect, and when you are asked to provide personal data you may decline. If you decline to provide data that is necessary to provide you with a particular product or feature, you may not be able to use this product or feature.

We collect personal data in the following ways:
 

  • Through information you provide to us
     

When you register with us as a user, you provide us with some personal data such as your name and email address, which we will store in order to create your account. We will also store information relating to any further use of our service, when you contact another user of the site through our platform, the contents of the emails you send to them and any other information that you may upload to the Sites. Finally, we may also collect information from any correspondence that you have with us.
 

  • Through your use of our services
     

When you use our services, we collect information about what types of services you use and how you use them. For example, which parts of our websites you visit, and what advertisements you view. The information that we collect while you use our services can be grouped into the following categories.
 

  • Information about your device and internet connection
     

Using technical logs and other tools, we register information about the device you use, such as the device manufacturer, operating systems and browser version. We also collect information about the connection to our services, such as IP address, network ID, cookies and unique ID files. This information can help us to adapt the way content is displayed to you, based on your device and user profile.
 

  • Information about how our services are used
     

We also register information about how you use our services. For example, which pages of the site you visit, the searches that you have performed, the times and dates that you visited our site, how long a page is displayed on your screen, how you navigate around the page, which websites you have visited before visiting our site, what functions you have carried out on a page, and if you have completed a transaction.
 

  • Cookies and other locally stored content
     

When you use our services, cookies and other data are stored locally on your device. These cookies provide us with information that we can then read. You can find more information about cookies, how and why we use them, and how to manage them in our cookie policy.
 

  • Information about user location
     

We register your geographical location based on your IP address and mobile network code.
 

  • Through other sources.
     

We receive information from third parties where you use their services to log into our site, for example, if you log in using Facebook or Twitter.

 

Legal Basis for Processing

We process your Personal Data in order to ensure the necessary performance of your contract with us. In certain circumstances, we may also process your Personal Data for the purposes of our legitimate interests, such as to inform you of changes to our services, to provide you with information about other services we offer, or in order to comply with any legal obligations to which we are subject.


We may also rely upon your consent as a relevant legal basis for processing your Personal Data (for example, to the use of cookies on the Site). In the event you wish to withdraw your consent to the collection and processing of your Personal Data in this manner, please follow the links below:
 

  1. Cookie Preference Manager
  2. Dashboard

 

How We Use Your Personal Data

We use the data that we collect to provide you with the products and services that we offer. This allows us to improve the products that we offer you and to personalise your experience on our site. We may also use the data to communicate with you, to inform you about your account and to provide you with security updates. Where you have consented for us to do so, we may also use your data to contact you in relation to updates about our own products, products provided by third parties, and to help to show you more relevant adverts on the site.

Your data will be used by us to authenticate your account and to enable you to interact with other users of our site.
 

  • Communications
     

We will contact you via email and messages posted on our website or apps. These messages will communicate about service related issues and security updates. Where you have consented for us to do you, we will also contact you with promotional marketing materials from us and from our partners. You can update your marketing preferences at any time within your account. Please note that it will not be possible to opt out of receiving service messages from us. This includes messages relating to security and legal notices.
 

  • Advertising
     

Banner advertising on our site is targeted to visitors of the site through a variety of ad networks and exchanges. We also use this data to measure the performance of these adverts. We use the data that you provide to us, through your cookie preferences, either separately or combined to achieve this.
 

  • Research and Developing Our Services
     

We use data that we collect through your use of our site and through public feedback, to conduct research and develop our services based on our findings. This allows us to provide you with a better experience when using our site.
 

  • Customer Support
     

We use the data that you provide to us, including your communications, to investigate and respond to service issues and complaints.
 

  • Insights
     

We use your data to generate statistics about our site that do not identify you. These statistics provide us information about how our site is used, the number of ad impressions served or clicked on, and the demographic distribution of visitors to our site.
 

  • Security Monitoring and Investigations
     

We will use your data when necessary to investigate and identify possible fraudulent behaviour on the site and possible attempts to harm other members or visitors to the site. We will also use your data to investigate violations of our Terms of Use or Privacy Policy.

 

How we Share Your Information

We retain access to all personal information that we have collected from you. If you have consented on signup or on the appropriate email form, we may provide any of the information we collect to carefully screened third parties to contact you regarding products or services that we think may be of interest to you. If Polonez enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.
 

  • Our Services
     

Our service allows you to engage with other members of our site. If you send a message to another member of our site, your message will be shared with that site member. If you comment on an advert, or leave feedback on the account of another person, these will be publicly visible on our site.
 

  • Service Providers
     

We engage other service providers to help us to provide our service to you. For example, to process payments, site maintenance and fraud detection. These service providers will have access to your information as much as is reasonably necessary for them to perform these tasks on our behalf. They are obligated not to disclose or use your data for any other purpose.
 

  • Legal Disclosures
     

When required to by law, we may disclose information about you. This may be as the result of a subpoena or other legal process. Your personal information will also be shared if we believe that the disclosure is necessary to
 

  1. Be used by government enforcement agencies to investigate, prevent or take action against any suspected or actual illegal activities.
  2. To enforce the agreements that we have with you.
  3. To investigate and defend Polonez against any allegations made by third parties.
  4. To protect the integrity and security of our services.
  5. To exercise the rights and safety of Polonez, our employees and other users of our service.
     
  • Change of Ownership
     

If Polonez enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners in preparation for, or as a result of, any of these events. Any other entity which buys Adverts or any part of our business, will have the right to continue to use your data in the way described by this privacy policy, unless you consent otherwise.
 

  • Your Rights and Choices
     

The General Data Protection Regulations offer you a number of rights in relation to your data. This includes the right to access a copy of your data, a right to receive a copy of your data that can be transferred to another organisation, a right to data deletion, a right to withdraw your consent to data processing, a right to restrict the processing of your data, and information on any automated decision making processes.
 

  • Data Retention
     

The amount of time that we retain data for, depends on the type of data being retained, and how that is used. In some cases, there will be a legal requirement for us to hold data for a specified amount of time. In other cases, we will not retain the data for any longer than necessary for the purpose that it was collected and processed.

When you register an account with us, we will retain the information that you provide to us for as long as you hold this account. Once an account has been closed, we will continue to retain this data for a period of seven years. This timeframe is in line with the Irish statutory limitation periods. If you don’t actively close your account with us, it automatically become inactive after 3 months of you not accessing it. After this, the data you have provided us will be retained for seven years.

If you have provided data to us without registering an account, this data will be retained for 7 years after your last date of activity with us.
 

  • Right to Access Your Personal Data
     

Non- registered and registered users of the Sites can request we provide them with a copy of the personally identifiable information we hold by using our data request feature.

Right to Control Your Personal Data
Registered users of our site can update their information by using our data request feature or contacting our Customer Support Team directly. You can also edit and make changes to the personal information by logging into your account and editing it directly from there. You can change your marketing and contact preferences at any time in your account dashboard by opting out receiving of these communications. You may ask us to make any necessary changes to ensure that such information is accurate and kept up-to-date.

 

  • Right to Data Deletion
     

Non- registered and registered users of our sites can request we delete any personally identifiable information we hold by using our data request feature. In some instances we may be unable to delete your data if we are required to retain it to comply with our legal obligations (including requests from law enforcement agencies).
 

  • Right to Data Portability
     

Registered users of our site have the right to data portability. This means that you can request that a copy of your data is made available in a structured, commonly used and machine readable form that can be transferred to you or to another organisation. You may request a portable copy of your data by using our data request feature.

 

Other Important Information
 

  • Special Category Personal Data
     

Adverts does not collect any special categories of personal data. However, if you enter this information into any free text section of our site, such as the ad description, or on our forums, this information will be held and processed in the same manner as all other data that you have provided to us.
 

  • Security
     

The security of your data is important to us. We perform regular monitoring of our systems to identify possible vulnerabilities and attacks. However, we cannot guarantee the security of any information that you send to us. No guarantee is given that the data will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
 

  • Direct marketing
     

We will only send you marketing information where you have opted in to receive these communications. You can change your marketing preferences at any time, by logging into your account and changing this on your account dashboard. You can also opt out of receiving marketing at any time using the unsubscribe link that can be found at the end of each email that we send.
 

  • Changes to this Statement
     

This statement will be updated when necessary to reflect changes that we make to our products. When this statement is updated, the “last updated” dated at the top of this statement will be changed. We will notify you of any changes to our privacy statement either by directly sending you a notification, or by posting a notification of the change on our site. We encourage you to review our Privacy Policy regularly so that you can stay informed about our use of your data.


Contact information
If you have any questions in relation to this Policy, please contact our Data Privacy Officer at info@polonez.ie. You can also contact us by writing to

Data Privacy Officer

POLONEZ

TEMPSIDE LTD
Unit 1A Cloverhill Industrial Estate
Clondalkin, Dublin 22
IRELAND

Tel: +353 1 4576888
Email: info@polonez.ie

 

If contacting us does not resolve your complaint, you have the right to contact your local Data Protection Commissioner. In Ireland, they can be contacted via their website here.

 

 

Polonez Ireland