POLARITY PRIVACY POLICY

Updated as of May 9, 2018

Polarity Technologies Ltd (“Polarity” “we” or “us”) has established this Privacy Policy to explain how we may collect, retain, process, share and transfer your personal data when you use our websites to allow you to make an informed decision about how you will use our Services.

This Privacy Policy addresses only our practices with respect to information we collect in the course of using our Services and does not apply to information about you that might be collected by a third-party website or an offering linked to or otherwise accessible from our Services. Any information collected, obtained and/or used by any such third parties is subject to the privacy policies of those third parties. We encourage you to review the policies of such third parties.

I. What Information Do We Collect?

Polarity may collect information about you when you visit our Sites or use our Services, including the following:

  • Information you provide us. We collect the content, communications and other information you provide when you contact us, including your email address.
  • Information we get from your use of our services. We collect information about the Services that you use and how you use them. This information includes:
    • Device Information:
      We collect device-specific information (such as your hardware model and operating system version).
    • Log Information:
      When you use our Services or view content provided by Polarity, we automatically collect and store certain information in server logs. This includes:
      • Internet protocol address (“IP Address”)
      • The type of browser you are using when using our Services, including your browser's "user agent" (e.g., Internet Explorer, Safari, and other browsers)
      • Device event information such as crashes, system activity, hardware settings, browser language, and the date and time of your request and referral URL
      • Your geographic location
      • The domain name of your Internet service provider
      • The source of traffic acquisition
      • The date of traffic acquisition

II. How Do We Use This Information?

We are able to deliver, personalize, and improve our Services by combining and using the information that we have about you to understand how you use and interact with our Services. We also may use the information that we have about you for the following purposes:

  • Provide, maintain, improve, and develop relevant features, content, and Services.
  • To communicate with you by responding to your requests, comments, and questions.
  • Help advertisers and publishers connect to offer relevant advertising in their apps and websites.
  • Create analytics and reports for internal purposes. These analytics and reports may include aggregate or anonymous information.
  • Detect and defend against fraudulent, abusive, or unlawful activity.

III. How Do We Share This Information?

We will not share the personal information we collect about you with any third party for their own marketing purposes without your consent. We do not sell, license or share information that individually identifies our users with companies, organizations or individuals outside of Polarity. We will share your information in the following ways:

  • Our vendors, subcontractors and business partners (“service providers”): We may share your data with our services providers who process your personal data to provide services to us or on our behalf. We have contracts with our service providers that prohibit them from sharing the information about you that they collect or that we provide to them with anyone else or using it for other purposes.
  • Companies within Polarity’s group of companies: We may share your information with our parent company and our affiliates, which are entities under common ownership or control of our ultimate parent company.
  • Fraud prevention: We may disclose the personal information we collect about our users when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
  • Law enforcement purposes and public safety: If requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose information collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
  • Sale or merger of our business: We may transfer your personal information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets).
  • Advertisers and advertising networks: Advertisers and advertising networks place ads (including sponsored links in search results) on our site. These companies may collect information, such as your computer’s IP address, browser information, and search queries, as you use our Site and Services. They also may use cookies and other technologies to collect this information when you visit our site as described below.

IV. How Do We Use Cookies and Tracking Technology?

We use cookies, pixel tags, web beacons, and similar files or technologies to collect and store the information we automatically collect about your computer, device, and product usage. We use the term "cookies" in this policy to refer to cookies and all such similar technologies that collect information automatically when you are using Polarity Services. You can find out more about cookies at our cookie policy here

How Long Do We Keep the Information?

We retain the information we collect about and from you for as long as necessary to fulfill a business purpose or comply with a legal request. We may also choose to anonymize certain information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.

VI. How Do We Protect Your Personal data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls.

VII. Age Limitations.

The Sites and Services are not directed to children under the age of 13. We do not knowingly collect information, including personal data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected personal data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

VIII. International Data Transfers

Polarity may transfer your personal data to countries other than the one in which you live. In particular, your personal data will be transferred to and processed in the United States where many of our central databases operate. By using the Services, you acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive or protective standard of protection than those in your country, and consent to your personal data being collected, processed and transferred as set forth in this Privacy Policy and US law. Polarity offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our users that operate in the European Union.

IX. Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to personal data, as well as to seek to update, delete or correct this Information. If you wish to exercise any of these rights, please contact gdprcontact@polarity.com.cy. To the extent that Polarity’s processing of your personal data is subject to the General Data Protection Regulation, Polarity relies on your consent. If we have collected and process your personal data with your consent, then you can withdraw your consent at any time.

X. Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Polarity’s use of your personal data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority.

Commissioner for Personal data Protection
1 Iasonos Street,
1082 Nicosia
P.O. Box 23378, CY-1682 Nicosia
Tel. +357 22 818 456
Fax +357 22 304 565
E-mail: commissioner@dataprotection.gov.cy
Website: http://www.dataprotection.gov.cy/

XI. More Information.

For more information about protecting your privacy, you may wish to visit http://www.netcoalition.com and http://www.privacyalliance.org. In addition, the Federal Trade Commission Consumer Response Center offers a helpline at 1-877-FTC-HELP (1-877-382-4357) to allow consumers to make comments or inquiries regarding companies and business practices. If you have questions about this Privacy Policy, or if you would like access to personal information we may have about you in our files, to correct, update or to have us delete it, or if you would like to notify us of your choice to opt-out of any sharing of your personal information, please contact us at the address below.

XII. Contact Us

Please also feel free to contact Polarity if you have any questions about this Privacy Policy or Polarity’s practices, or if you are seeking to exercise any of your statutory rights.

Polarity Technologies LTD
Nora Court, 3rd floor, office 301
Limassol, Cyprus 3040
support@polarity.com.cy