POLARI LABS
PRIVACY POLICY

Welcome to the Polari Group Ltd Privacy Notice (referred to as “Polari” or “we”, “us” or “our” in this Privacy Notice).

This Privacy Notice explains how Polari processes your personal data, whether it is collected through your use of our website, when you purchase a product or when you subscribe to our newsletter. It also sets out how we protect your personal data and outlines your privacy rights.

The website is not intended for children, and we do not knowingly collect data relating to children. If we have collected personal information on a child, please contact us immediately using the details in section 12, so we can remove this information without any undue delay.

It is important that you read this Privacy Notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. Other notices may supplement this Privacy Notice, but are not intended to override it.

1. CONTROLLER
The controller is a natural or legal person, who, alone or together with others, takes decisions on the purposes and means of processing data. This notice is issued by Polari Group Ltd (A company register in England. Company registration number 15010311) as a Data Controller. 

2. THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, or similar identifiers.

  • Contact Data includes delivery address, email address and telephone numbers.

  • Financial Data includes billing address. 

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

  • Profile Data includes your purchases or orders made by you.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.


3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or through the website or through our products provision. This includes personal data you provide when you:

  • purchase our products;

  • sign up to our waiting list;

  • subscribe to our publications and newsletter;

  • request marketing to be sent to you;

  • contact us.

  • Automated technologies or interactions. As you interact with our website we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies and other similar technologies. Please see our cookie notice for further details.

4. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA AND LEGAL BASES
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

  1. To provide you with our products and/or services, including managing our waiting list, delivery and manging payments

  2. To manage our relationship with you, including addressing concerns, dealing with complaints, and other service-related communications

  3. To register and manage your warranties

  4. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  5. To deliver relevant website content and advertisements to you, and to measure and evaluate the effectiveness of the advertising we provide

  6. To provide you with marketing communications, company updates, and newsletters relating to our products, services, and activities, and to evaluate the effectiveness of those communications

  7. To invite you to events, webinars, and other activities that we believe may be of interest to you

  8. To conduct surveys and request feedback

Type of data

  1. (a) Identity (b) Contact (c) Financial (d) Transaction

  2. (a) Identity (b) Contact (c) Profile

  3. (a) Identity (b) Contact (c) Profile

  4. (a) Identity (b) Contact (c) Technical

  5. (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

  6. (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

  7. (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

  8. (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

  1. Performance of a contract with you

  2. Performance of a contract with you

  3. Performance of a contract with you

  4. (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation

  5. (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent

  6. Necessary for our legitimate interests (to promote our company and products and to provide you with communications that we believe may be of interest to you) (b) Consent

  7. Necessary for our legitimate interests (to engage with our customers and provide information related to our products and services)

  8. Necessary for our legitimate interests (to evaluate your satisfaction with our products and improving our products and services)

5. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

You will receive marketing communications from us if you have requested information, purchased our products or subscribed to our newsletter.

You have the right to opt out of receiving marketing messages at any time by contacting us, using the “unsubscribe” option at the end of our emails or communications, or via the email address provided in Section 12 of this Privacy Notice.

Please note that opting out of marketing communications will not affect the processing of your personal data for service related communications, including information about product performance, warranties, and other essential updates relating to the use of our products.

6. SECONDARY USE OF YOUR PERSONAL DATA
In addition to the purposes described above, we may also use your personal data for secondary purposes, such as analytics, reporting, and generating business insights. Where we do so, your data will first be anonymised and/or aggregated so that it can no longer be used to identify you, whether on its own or in combination with other information.

As this data is no longer personal data once anonymised, its use for these secondary purposes falls outside the scope of data protection law, and we are able to use it for these purposes without further notice to you or additional legal basis.


7. DISCLOSURES OF YOUR PERSONAL DATA
We may need to share your personal data with the entities listed below for the purposes described in this Privacy Notice:

  • Service providers: To carry out certain aspects of our business operations, such as companies responsible for shipping merchandise or banks handling payments.

  • Third-party suppliers: To support the provision of our products and services, including cloud-based software services. Our service providers are contractually obligated to store all personal data securely and to use it only for the purposes for which they have been engaged by us.

  • Law enforcement or public authorities: Where we are legally required to share or disclose your personal data.

  • Business transfers: We may also share your data with third parties in connection with a sale, transfer, or merger of part of our business or assets, or if we acquire or merge with other businesses. In such cases, the new owners may use your personal data in accordance with this Privacy Notice.

8. INTERNATIONAL TRANSFERS
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).

We may share personal information to third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws. 

Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

  • International Data Transfer Addendum

  • EU Standard Contractual Clauses + UK Addendum

  • An exception as defined in Article 49 of the EU GDPR

For more information about transfers and safeguarding measures, please contact us using the information in section 12.

9. AUTOMATED DECISION MAKING
Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

10. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


12. YOUR LEGAL RIGHTS

The right to object: You have the right to ask us to stop processing your personal data if:

  • Processing relies on legitimate interest.

  • Processing includes automated decision making and profiling.

  • Processing is for direct marketing purposes.

The right of access: You have a right to obtain confirmation of whether we are processing your personal data, access to your personal data and information regarding how your personal data is being used by us, and:

  • You or any third party acting on your behalf may request a copy of the personal data we hold about you without charge. 

  • We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you. 

The right to be informed: We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right. 

The right of rectification: If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made. 

The right to erasure: If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.  

The right to restrict processing: You have a right to block the processing of your personal data in certain circumstances This means we will still hold your data but not process it. This is a conditional right which may only be exercised when:

  • Processing is unlawful and you oppose erasure and request restriction instead. 

  • We no longer need the personal data, but it is required for a legal process.

  • You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made. 

  • You are disputing the accuracy of personal data.

The right to data portability: You can request that your personal data is transferred to another controller or processor in a machine-readable format if:

  • Processing is based on consent.

  • Processing is necessary for the fulfilment of a contractual obligation.

  • Processing is by automated means (i.e. not paper based).

13. RIGHT TO COMPLAIN
If you have any concerns or would like to make a complaint about our processing of your Personal Data, please raise this with us in the first instance.

To make a complaint, please contact us via email CT@polarilabs.com

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By Website: Click Here 

By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)  

14. DOCUMENT REVIEW AND AMENDMENTS 

We keep this Privacy Notice under regular review. 

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. 

This notice was last updated on 25/06/2026