Privacy Policy

1 - Data Controller

1.1 - POLKAMARKET OÜ, with head offices at Harju Maakond, Tallinn, Kristiine Linnaosa, Keemia tn 4, 10616 (“Polkamarket”), owner of Polkamarket website and web application, is the entity responsible for processing the personal data of Polkamarket users.

1.2 - Polkamarket users can contact the data controller through the following addresses to raise any questions or get clarification regarding personal data protection:

- By email to [email protected];

- By mail to: POLKAMARKET OÜ, Harju Maakond, Tallinn, Kristiine Linnaosa, Keemia tn 4, 10616, Estonia.

2 - Principles applicable to the protection of your personal data

Polkamarket processes your personal data in accordance with the general principles laid down in the General Data Protection Regulation (GDPR) and in other legislation applicable to the protection of personal data, namely:

- "Principle of lawfulness, fairness and transparency": Polkamarket guarantees that your personal data is subject to lawful, fair and transparent processing;

- “Principle of purpose limitation": Personal data are processed by Polkamarket for specified, explicit and legitimate purposes, and are not further processed in a manner incompatible with those purposes;

- "Data minimisation principle": In the interests of minimal and limited data collection, Polkamarket only processes data that is strictly necessary, appropriate and relevant to the purposes for which it is processed;

- “Principle of accuracy": Polkamarket undertakes to delete or rectify any personal data that is found to be inaccurate or imprecise as soon as possible.

- “Principle of conservation": personal data shall be stored by Polkamarket for the period of time strictly necessary to fulfil the purposes for which they were collected;

- “Principle of integrity and confidentiality": Polkamarket undertakes to process your data securely, implementing technical and organisational measures to ensure a high level of protection of personal data, particularly those necessary to ensure the confidentiality and integrity of this data.

3 - Concepts/definitions

3.1 - Personal data: any information that, whatever its medium, directly or indirectly identifies or is likely to identify a natural person, in particular by reference to an identifier, such as a name, an identification number, a location data, an electronic identifier, or other specific elements of that natural person's physical, physiological, genetic, mental, economic, cultural or social identity.

3.2 - Personal data subject: any natural person to whom the personal data refers. Within the scope of the activities pursued by Polkamarket, the following are data subjects: the users of Polkamarket´s website, web application or other pages, its clients, employees, service providers and suppliers.

3.3 - Processing of personal data: operation or set of operations performed on personal data, by automated or non-automated means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction. In short, the concept of Processing of Personal Data is comprehensive and shall apply to all operations or sets of operations carried out by Polkamarket with reference to your personal data.

4 - Use of your personal information

We may use Personal Information for the following purposes:

1. i) To provide and maintain the website, including to monitor the usage of our website and to keep it safe;
2. ii) To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;
3. iii) To attend and manage Your requests and queries to Us;
4. iv) To comply with our legal obligations, including court orders and other legal or regulatory requirements.
5. v) and for other purposes, such as data analysis, identifying usage trends, improve the Website, products, services, marketing and your experience.

Polkamarket may share your personal information with Service Providers to monitor and analyse the use of our Website and to contact You, whenever requested by You

a. CONSENT

Consent is required for the collection of Personal Information and the subsequent use of disclosure of Personal Information. The form of consent may vary depending upon the circumstances and the type of Personal information obtained. Your agreement with this Privacy Policy and the Terms and Conditions constitutes your consent to the collection and use of Personal Information as described in this Privacy Policy. We reserve the right to use and disclose Personal Information without your knowledge or consent as permitted by applicable law.

b. DISCLOSURE OF PERSONAL INFORMATION

Polkamarket uses the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. Polkamarket may make available the Personal Information that you provide to us, to our affiliates, agents, representatives, service providers and contractors for these purposes. Polkamarket also reserve the right to disclose Personal information that believes, in good faith, is appropriate or necessary to enforce the Terms and Conditions, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to a court order or official requests, to protect, security or integrity of our company. In the event that Polkamarket is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganisation, receivership, assignment or the application of laws or change of control, there may be a disclosure of your information to another entity related to such an event.

5 - Personal data category

5.1 - Polkamarket processes personal data of varying nature and sensitivity, depending on each area of activity and the purpose underlying the processing of such data.

5.2 - Depending on the purpose, Polkamarket processes various categories of personal data, including: identification data (e.g. signature); address and contact data (e.g. e-mail address);

6 - Purposes of processing the data and legal grounds

6.1 - Polkamarket user’s personal data is processed in pursuit of specific, explicit and legitimate purposes and cannot later be processed in a way that is incompatible with these purposes.

6.2 - In order to ensure a minimum and limited collection of data, Polkamarket only handles data that is strictly necessary, adequate and important for the purposes for which it is handled.

6.3 - Our user’s personal data can be processed namely for the following purposes:

i) To manage your access, usage or interaction on Polkamarket website and web application, i.e. if you want to access or use the website or web application, we need to handle some data related to you to grant you access to various functions, products and Polkamarket services, as if we did not process the data this would not be possible.

- Compliance and enforcement of applicable Anti-money laundering/Counter terrorism financing (AML/CTF) legislation if applicable, regulators requests, sanctions and PEP screenings, fraud suspicious investigations (including anti-cheat logs), purchases, and general platform usage.

- Marketing and communication of products and services. Polkamarket handles your data to send you written notices, warnings, disclosures and announcements, by email and/or by other electronic communications, in order to advertise or promote a particular Polkamarkets’ product or service. This data processing occurs in pursuit of the data controller's legitimate interests and/or when a customer has given their free, informed and explicit consent for this purpose.

- To send invitations to the users, by email and/or by other electronic communications, in order them to participate in competitions or other Polkamarket events;

- Customer support. Polkamarket considers its legitimacy to process Polkamarket customers' data to answer requests and/or questions raised regarding Polkamarket products and services.

- information management;

- management of complaints, compliments and incidents;

- dissemination of external communications;

- quality control;

- accounting and management;

- payment management;

- execution of internal or external audits;

- receiving and processing requests for IT support;

- information security control;

- access management, logs;

- backups management;

- management of security incidents;

- management of litigation and other conflicts;

- In the pursuit of statistical or similar purposes;

- Polkamarket will still be able to proceed to the treatment of the users' data in the accomplishment of other legitimate interests.

7 - Personal data recipients

7.1 - For the purposes mentioned above and in compliance with its legal obligations, Polkamarket may have to send the user’s personal data to third parties, namely:

- To entities that are subcontractors pursuant to the General Data Protection Regulation, to provide the contract enforcement services, information technologies, data storage, auditing, document management and litigation, namely with service providers in the security services, AML/CTF if applicable, accounting, information systems, auditing and litigation areas. Polkamarket shall only use subcontracted entities who act according to its instructions and as long as they present sufficient guarantees they can undertake the proper technical and organisational measures, so that the processing satisfies, among other things, the security, confidentiality and integrity requirements and these guarantees are formalised in an agreement signed by Polkamarket and the entities.

- Entities that are considered to be third parties for the purpose of the General Data Protection Regulation such as the Tax and Customs Authority, Judicial Entities and Regulators.

8 - Storage period

8.1 - Polkamarket will retain personal data for the period of time strictly necessary for the performance of the respective purposes or, as the case may be, until the data subject withdraws the consent given or exercises his or her right to object or erasure.

8.2 - Polkamarket may be required to retain some of the personal data for a longer period taking into account factors such as legal obligations, under the laws in force; statute of limitations under applicable laws; (possible) litigation; guidelines issued by competent data protection authorities.

9 - Data Subject' Rights

9.1 - Polkamarket users, as the data subjects, through the collection and processing of their data, have the following rights:

1. i) Right to access your personal data: you have the right to obtain information regarding the processing of your personal data and to the following information: the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the right to lodge a complaint with a supervisory authority;when personal data are transferred to a Non-EU-Member State or to an international organization, the appropriate safeguards relating to the transfer.
2. ii) Right to Data Rectification: you have the right to obtain with undue delay the rectification of your personal data. Considering the purposes of the processing, you have the right to have your incomplete personal data completed, including by means of providing a supplementary statement.
3. iii) Right to Data Erasure: you have the right to erasure your personal data concerning where one of the following grounds applies: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; if you withdraw the consent on which the processing is based; if you object to the processing and there are no overriding legitimate grounds for the processing; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligation in Union or Member State law.
4. iv) Right of limiting the Data processing: you have the right to the restriction of processing where one of the following grounds applies: if you contest the accuracy of the personal data; if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; if your personal data is no longer needed for the purposes of the processing; if you have objected to the processing.
5. v) Right to data portability: if your personal data is in a structured format that is in current use and of automatic reading, the processing is based on the express consent or by contractual form and if it is done by automatic means, you have the right to send them to another controller as long as if that is technically possible.
6. vi) Right to withdraw your consent: in situations where the processing in question is undertaken based on your consent, you have the right to withdraw the consent you gave at any time. In this case, the controller will stop processing the data in question, unless there are other grounds that justify the processing.
7. vii) Right to lodge a complaint with supervisory authorities: you have the right to lodge a complaint with the Republic of Estonia Data Protection Inspectorate regarding the matters concerning the processing of your personal data.

All such requests, or any questions or comments regarding this policy or our handling of your personal data, should be addressed to [email protected]

10 - Minors

Our services are not intended for anyone under 18 (eighteen) years old and we do not knowingly collect personal information from anyone under this age.

11 - Links

Our website contains links to other websites. Those websites have their own privacy practices, for which we do not accept responsibility or liability. Please review those policies before submitting any personal data.

12 - Updates

This Privacy Policy was updated in July 2022. We reserve the right to amend this Privacy Policy from time to time to reflect changing legal requirements or our processing practices. Any such changes will be posted on this website and will be effective upon posting.

13 - Use of Cookies

13.1 - We collect cookies when you visit our site. A cookie is a small text file that is placed on your hard drive by a web page to improve performance and the user's browsing experience, increasing the speed and efficiency of replies while eliminating the need to enter the same information several times.

13.2 - There are two kinds of cookies:

- permanent cookies - which are saved in the browser used on your equipment (e.g. PC, mobile and tablet) and that are used whenever you return to any of our sites. They are normally used to direct the browser according to the user's interests, allowing us to provide a more personal service.

- session cookies - these are temporary cookies that stay in your browser's cookie folder until you leave the website. The information these cookies collect is used to analyse web traffic patterns, enabling us to identify problems and provide a better browser experience.

13.3 - The cookies are used for the following purposes: - strictly necessary cookies - Allow you to browse the website and use the applications as well as letting you access secure areas on the website. Without these cookies, the services you request cannot be provided.

- analytical cookies - These are used anonymously to create and analyse statistics to improve the website's operation.

- functional cookies - Save the user's preferences regarding its use of the site so they do not need to be configured every time you visit it.

- third-party cookies - Save These measure the success of the applications and the effectiveness of third-party publicity. They can also be used to customise a widget with the user's details.

- Ads cookies - provide direct advertising, depending on each user's interests so as to give ads campaigns taking into account the user's preferences and they also limit the number of times an advert is seen, helping to measure the effectiveness of publicity and the success of the website organisation.

13.4 - Depending on how you manage the cookies on our site and your interaction with us, we use some of the information that is collected by the cookies to make sure the site works properly, highlighting the proper views of the contents, remembering your registration, adjusting the screen resolution to improve our offers among other things. This information includes registration details, location, session duration, the services you selected, your equipment, your browser and your IP address.

13.5 - When you browse our site and then later visit platforms where there is a publicity format (social networks, Google and other partners of these networks) you may be shown adverts about our brand. We also use the data to reach new potential customers who may be interested in our products.

13.6 - Cookies do not harm your processor and do not contain viruses. You can deactivate the use of cookies at any time in the configuration of your browser or directly on our site. However, if you deactivate certain cookies this may stop some web services from working properly, partially or completely affecting the browsing on the website.