This Policy may change over time, so please be sure to reread it from time to time. Amendments, modifications or changes to this Policy will be posted at this URL and will be effective when posted. Your continued use of this Site following the posting of any amendment, modifications or change to this Policy shall constitute your acceptance thereof. If you do not agree with the terms in this Policy, please do not use this Site and do not provide any information to us. Unless otherwise defined in this Policy, the terms used in this Policy have the meaning given to them in our Terms of Service, which you can access here: https://polopo.com/terms-conditions.
This Policy covers your access to our Services and to this Site. Our Site is not directed to and is not intended for access and use by persons under the age of 18. We do not intentionally collect or use Personal Data from users that we have reason to believe are under the age of 18.
Personal Data Collected
The type of Personal Data (defined below) and Other Data (also defined below) we collect depends on how you are specifically interacting with this Site how you are using our Services. Generally, we gather Personal Data and Other Data as described below.
Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, usage data, phone numbers, and unique device identifiers (“Personal Data”). We may need to collect and process Personal Data in order to provide requested information, products or Services to you (including this Site) or because we are legally required to do so.
- Account Registration. We requests Personal Data from you if this Site requires registration. The registration process requests that you provide your name, email address, address, phone number, company affiliation, if any, and other similar information. This information must be stored on this Site, and is accessible to anyone with whom you share your username and password. For this reason, please safeguard your username and password carefully and do not disclose it to any other person.
- Voluntary Disclosure. We may collect Personal Data voluntarily provided by you, including in emails to this Site, online forms, order and registration forms, surveys, promotion participation, phone calls and online chats with our customer service and through other means.
- Log data. We may collect log data, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
- Usage information. We may collect usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information), content interactions (including searches, views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction, and similar data.
- Other Means. We may collect information through various other means, including from selected third-party business partners who work with us in relation to our Services and that we may utilize to deliver certain content, products, or Services or to enhance your experience. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our Services.
We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.
Use and Disclosure of Personal Data
Our primary goal in collecting, using, and sharing your information is to enhance and improve our Services. To that end, we will only use Personal Data for legitimate business purposes, including the following:
- Fulfillment of Requests. We may use Personal Data about you (a) to deliver products and Services to you, (b) provide you with information about products and Services you’ve ordered, (c) for internal research and development purposes, (d) when it is necessary for employees, agents and contractors to operate or maintain this Site or to correct a technical problem, (e) to detect and prevent fraud and abuse to ensure the security and protection of all customers and others, such as to verify the existence or condition of your account; (f) to comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or government authority; and (g) to effectuate the sale, merger, acquisition, or other disposition of our assets or business (including in connection with any bankruptcy or similar proceedings). We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Other Communications. From time to time, we may use Personal Data about you to inform you of products, programs, Services and promotions that we believe may be of interest to you. If you or your employer is one of our customers, we may also inform you of such products, programs, Services and promotions using Personal Data about you that you or your employer provided to us. If you would prefer that we not send electronic marketing messages to you, please see the “opt-out” section below.
- Promotions. We may operate sweepstakes, contests and similar promotions (collectively, “Promotions”). If you choose to enter the Promotions, we typically ask you for certain Personal Data when you enter and, if applicable, win a Promotion. You should carefully review the rules of each Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you. To the extent that the terms and conditions of such rules concerning the treatment of your Personal Data conflict with this Policy, the terms and conditions of such rules shall control. We use this information to operate the Promotions.
- Other Business Purposes. We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of our Site and Services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of this Site, completing business transactions (for example, to confirm content requested is received by users), development of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of this Site are of most interest to users), product development, market research, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits, etc. We may also use Personal Data of journalist/media contacts for press release distribution or sharing other newsworthy developments related to our business activities. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
We may disclose Personal Data for the following purposes:
- Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfillment, payment processing, and other services.
- Affiliate Communications. We may transfer Personal Data among our affiliates to allow our affiliates to contact you regarding products, programs, Services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with this Policy. If you would prefer not to receive marketing communications from us or our affiliates, please see the “opt-out” section below. We will be the party responsible for jointly-used Personal Data.
- Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with us to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded web sites (“co-branded pages”). Any information, including Personal Data that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages will be shared with our third-party partners. You should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
- Third-Party Data Providers. If you subscribe to one of our products or Services that contains third-party data, we may be required to provide your Personal Data to the third party as part of our reporting obligations. We will only do so if a third-party data provider conditions your receipt of their data on knowing your identity.
- Conferences and Events. When you attend a conference or event organized by us, your name and contact information may be shared with other attendees.
- Promotions. We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions.
- Assignment. We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
Collection and Use of Other Data
Our service providers and we may also collect and use the following types of data, referred to in this Policy as “Other Data”:
- Monitoring Data. Our service providers and we may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of this Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses this Site and to improve and market it, as well as our other websites and services. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
- Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of this Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
- Strictly Necessary. These cookies are essential for our Services to perform their basic functions. These include cookies that are required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” for e-commerce functionality.
- Analytics and Performance. Performance cookies collect information on how users interact with our Services, including what pages are visited most, as well as other analytical data. We use these details to improve how our Services function and to understand how users interact with our Services.
- Functionality. These cookies are used to store preferences set by users, such as account name and language.
- Security. We use these cookies to help identify and prevent potential security risks.
- Advertising. These cookies are used to display relevant advertising to users who use our Services, as well as to understand and report on the efficacy of ads served on our Services. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build user profiles, including showing you ads based on products or Services you’ve viewed or acts you have taken.
- Third-Party / Embedded Content. Services hosted by us make use of different third-party applications and services to enhance the experience of our Services. As a result, cookies may be set by third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
- IP Addresses. When you visit and interact with this Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit this Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how this Site is used by our users, to improve this Site and to enhance user experience of this Site. We may also use your IP address to help diagnose problems with our server and to administer our Site. We may also derive your approximate location from your IP address.
We may use third-party advertising companies to serve advertisements regarding products and Services that may be of interest to you when you access and use this Site, our apps and other websites or online services, based on information relating to your access to and use of this Site and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
We may store your Personal Data. This information is retained and used in accordance with existing laws, rules, regulations, and other policies.
While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to insure the safety of your Personal Data. Personal Data is stored on our server and is not publicly accessible. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we take reasonable precautions and have security measures in place to protect the loss, misuse and alteration of the information under our control. Although we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information. We are not responsible for any breach of its security or for the actions of any third parties that may obtain any Personal Data. You are prohibited from violating or attempting to violate security for or otherwise interfering with the operation of this Site. We do not make, and expressly disclaim, any representation or warranty, express or implied, regarding the security or integrity of this Site and your Personal Data.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by sending an email to email@example.com.
Data Integrity; Retention Period
We will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Policy, or authorized by you. We will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you). We depend on you to update or correct your Personal Data whenever necessary.
We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
By visiting our Site, you expressly consent to the collection and use by us of Personal Data according to this Policy.
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.
- If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an email to firstname.lastname@example.org.
- If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an email to email@example.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you exercise the second option as described above, we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request). Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing emails from us. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving Services from us.
You may also indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using our contact information below, or if you have a profile/account, by changing your preferences on the profile/account at any time.
Correct; Update; Accessibility; Conflicts
If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may make a request by contacting us by sending an email to firstname.lastname@example.org. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We are committed to ensuring this Policy is accessible to individuals with disabilities. If you wish to access this Policy in an alternative format, please contact us by sending an email to email@example.com. Depending on the specific interactions you have with us, we may provide different or supplemental privacy statements that describe and govern how we use your personal information. When we do so, those different or supplemental privacy statements apply to those specific interactions you have with us.
Use of this Site is governed by Hong Kong SAR law. If you are accessing this Site or Services from a physical location outside of the Hong Kong SAR with laws or regulations governing personal data collection, use, and disclosure that are different from Hong Kong SAR laws, you agree that by accessing this Site, you are transferring your Personal Data and Other Data to the Hong Kong SAR and you consent to the application of the laws of the Hong Kong SAR and the State of Arizona with respect to use of this Site and Services and any dispute regarding this Site or this Policy. You further consent to the exclusive jurisdiction of, and agree that venue is proper in, the state and federal courts located in Hong Kong SAR; provided, however, that if the state and federal courts in Hong Kong SAR are found not to have exclusive jurisdiction, then you agree to settle all disputes arising out of or relating to this Site or this Policy by binding arbitration in Hong Kong SAR in accordance with the International Arbitration Rules set by the International Centre for Dispute Resolution.
If any provision of this Policy is held by a court of competent jurisdiction to be illegal, unenforceable, or in conflict with any applicable law, the validity of the remaining portions or provisions shall remain in full force and effect.
Do Not Track Disclosures
We do not respond to Do Not Track (“DNT”) signals at this time. Some third party sites may track your actions when you are browsing and accessing content. Various browsers offer a DNT option that sends a signal to third parties that you do not want to be tracked.
For the purposes of this Policy, you are the Data Controller of your Personal Data. “Data Controller” means a person who (either alone or jointly or in common with other persons) determined the purposes for which and the manner in which any Personal Data is, or will be, processed. We should be considered only as a processor on your behalf as to any Personal Data that is subject to the requirements of Hong Kong SAR. We may use the services of various third-party service providers in order to process your data more effectively.
Cross Border Transfer of Personal Data
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. If you are accessing this Site from outside the Hong Kong SAR, you may be sending information, including Personal Data to the Hong Kong SAR where our servers are located. That information may be transferred within the Hong Kong SAR or back out of the Hong Kong SAR to other countries outside your country of residence. These countries do not necessarily have data protection laws as comprehensive as those in your country. Information transferred to the Hong Kong SAR or another country is subject to the laws of that country and may be disclosed or accessed in accordance with those laws. By transferring information or allowing information to be transferred to us, you consent to the transfer, processing and storage in countries outside your country of residence. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.
If you have any questions about this Policy or the practices of this Site, you can email us at firstname.lastname@example.org.