What is a Privacy Policy?

A Privacy Policy is a statement by Polar Krush to clients, our Associates and the public about how we collect, use, retain and disclose the personal information which we hold. It is sometimes also referred to as a Privacy Statement, Fair Processing Statement or Privacy Notice. This Privacy Policy is part of our commitment to ensure that we process your personal information/data fairly and lawfully.

Why have a Privacy Policy?

Polar Krush recognises the importance of protecting personal and confidential information in all that we do, and we take care to meet our legal and regulatory duties. This policy is one of the ways in which we can demonstrate our commitment to being transparent and open. This policy also explains what rights you have to control how we use your information.

Privacy Statement

For the purpose of the General Data Protection Regulation (GDPR) the Data Controller is NICC Ltd t/a The Polar Krush Group Reg No 2892944Polar Krush (collectively referred to as “Polar Krush”, “we”, “us” or “our” in this privacy statement) is registered as a Data Controller with the UK Information Commissioners Office (ICO), registration number ZA054600.

We are committed to safeguarding the privacy of our website visitors and clients. During the course of your engagement with Polar Krush, we will ask you to provide us with various information should wish to us to get in touch with you. This information is referred to as ‘Personal Data’.

This statement has been created to allow us to describe how we will use your Personal Data, and the various rights you have in relation to your Personal Data.

Personal Data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We may ask for or hold personal information about you such as your name and contact details which will be used to respond to your enquiries and enable us to deliver our services effectively and efficiently. This website collects and uses personal information for the following reasons:

Site Visitors Tracking

Third Party Processor: Google Analytics

Data Collected: Usage data & cookies

Data Processed in: USA

Expiry: Session

Google Privacy Policy: https://policies.google.com/privacy?hl=en

This site uses Google Analytics to monitor how users interact when they visit the website. Google Analytics provides us with impersonal data such as the number of people using the site, which pages they have visited, their journey through the site and how long they spent on the site.

Google Analytics is a third-party data processor and none of the data collected can be used to personally identify you. Google Analytics does however record your computer’s IP address which could be used to personally identify you, however this information is never shared with us or made public.

Google Analytics does use cookies and you can find more about their cookie policy here: Google’s developer guides. You can disable cookies on your internet browser at any time to prevent GA from tracking your visit to this website.

Contact Forms & E-mails

Data Collected: Name, Address, Telephone number & email address

If you contact us by completing one of the forms on our website, none of the data that you enter on the form will be stored on this website or processed by a third-party data processor. The data will be sent via e-mail and sent to us via SMTP which is protected by SSL meaning that the form/e-mail contents are encrypted. It is important to note that not all mail servers are secure, and you should not include personal, confidential or sensitive information within a contact form or e-mail.

Information about how you use our website is collected using cookies. If you want to know how we use cookies, please refer to our Cookies Policy.

How will Polar Krush use the personal data it collects about me?

The primary legal basis that we intend to use for the processing of your Personal Data is for the performance of our contract with you.

Polar Krush will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary.

The security of your Personal Data is paramount to us and we have invested in a number of Cyber Security and Privacy initiatives to ensure we have the right level of protection in place to protect your data.

We will always take reasonable steps to safeguard your Personal Data against it being accessed unlawfully or maliciously by any third party.

Will you share my information?

Polar Krush will never sell, rent or exchange personal information with any third party for commercial reasons.

Can I find out the personal data that the organisation holds about me?

Polar Krush at your request, can confirm what information we hold about you and how it is processed. If Polar Krush does hold personal data about you, you can request the following information:

• • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.

• • Contact details of the GDPR Owner, where applicable.

• • The purpose of the processing as well as the legal basis for processing.

• • If the processing is based on the legitimate interests of Polar Krush or a third party, information about those interests.

• • The categories of personal data collected, stored and processed.

• • Recipient(s) or categories of recipients that the data is/will be disclosed to.

• • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.

• • How long the data will be stored.

• • Details of your rights to correct, erase, restrict or object to such processing.

• • Information about your right to withdraw consent at any time.

• • How to lodge a complaint with the supervisory authority.

• • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

• • The source of personal data if it wasn’t collected directly from you.

• • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Polar Krush accepts either Passport or Driving License as valid forms of ID when information on your personal data is requested. This is to ensure that we are able to verify your identity before disclosing any personal information.

The right to lodge a complaint with a Supervisory Authority

Polar Krush are committed in protecting your personal information, however if you have any concerns regarding the way that we are storing or processing your personal information, you have the right to lodge a complaint with a supervisory authority. In the UK this is the Information Commissioners Office (ICO) and more information can be found on their website https://ico.org.uk/concerns/.