Pole Star Global Privacy & Cookie Policy

INTRODUCTION

Pole Star Space Applications Limited (“Pole Star”, “we” and/or “us”) are a maritime technology company, providing solutions to the government, financial, shipping and offshore sectors. (the “Services”) to commercial shipping companies, governments, and financial organisations (“you”). Pole Star respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

  1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Pole Star collects and processes your personal data through your use of this website including the domain name: www.polestarglobal.com and all related subdomains and our app(s), APIs, products and service enquiries, including any data you may provide through this website or our app(s), when you sign up to our Services or to receive our information, promotions and newsfeeds.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing 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.

CONTROLLER OF PERSONAL DATA

POLE STAR GLOBAL (is the controller and responsible for your personal data).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us for the attention of the Data Privacy Manager, using the details set out below.

Our full details are:

Full name of legal entity: Pole Star Space Applications Limited

For the attention of: The Chief Compliance Officer

Email address: support@polestarglobal.com

Postal address: 1 Nicholas Road, London W11 4AN

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us as set out above in the first instance.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • 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, API data requests, 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 username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Profile Data includes purchases or requests made by you, your interests, preferences, feedback and survey responses.
  • Student Learning Data includes student responses to activity questions, aggregate scores across subject and/or topic area and progress made over time.
  • Usage Data includes information about how you use our website, app(s) and services.
  • Marketing Data includes your preferences in receiving marketing from us and your engagement with our marketing activities.
  • Communications Data includes your communication preferences and email, voicemail and telephone records to customer support.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

  1. 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 Identity, Contact and/or Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
    • apply for or use our services;
    • subscribe to our service;
    • request marketing communications or content to be sent to you;
    • correspond with our Customer Service or Sales teams;
    • partake in a promotion;
    • complete a survey; or
    • provide us with feedback.

 

  • Automated technologies or interactions. As you interact with our website, platforms or app(s), we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our Cookie Policy further down for details.

 

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

 

Technical Data from the following parties:    

(a)  analytics providers such as Google and Amazon based outside the EU;

(b)  advertising networks based inside and outside the EU; and

(c)  search information providers for the purpose of due diligence in or outside the EU.

 

  • Contact, Financial and Transaction Data from providers of technical, credit checking, payment and delivery services based both inside and outside the EU.
  • Identity and Contact Data from data brokers or aggregators based inside and outside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

 

  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

The lawful basis that we will rely on to process your personal data shall be either:

  • Where you have given their consent to the processing of their data for one or more specific purposes.
  • It is necessary for entering into or performing a contract with you
  • It is necessary for compliance with a legal obligation to which we or you are subject.
  • It is necessary to protect the vital interests of you or another person
  • It is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us as set out above. 

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

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 as set out above  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

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity 
(b) Contact

Performance of a contract with you

To process and deliver your subscription including: 
(a) Manage payments, fees and charges 
(b) Collect and recover money owed to us

(a) Identity 
(b) Contact 
(c) Financial 
(d) Transaction 
(e) Marketing and Communications

(a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include: 
(a) Notifying you about changes to our terms or privacy policy 
(b) Asking you to leave a review or take a survey

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

(a) Performance of a contract with you 
(b) Necessary to comply with a legal obligation 
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a Promotion

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

(a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

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

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

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

To deliver relevant website and app content, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

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

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)

To use data analytics to improve our website, app(s) products/services, marketing, customer relationships and experiences

(a) Technical 
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and app(s) updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about features that may be of interest to you

(a) Identity 
(b) Contact 
(c) Technical 
(d) Usage 
(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To deliver learning content to you and measure the effectiveness of that content

(a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Student learning data 
(f) Technical

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to keep our product/services up to date and relevant, to provide personalised feedback to individual users)

 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

 

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details and in all cases have opted in to do so.

 

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Pole Star group of companies for marketing purposes.

 

OPTING OUT

You can ask us to stop sending you marketing messages at any time by contacting us as set out above . We endeavour to make the opt out process as simple as possible.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or a service experience.

 

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us as set out above. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

  1. COOKIES INTRODUCTION

Our website uses cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

ABOUT COOKIES

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser, and which may then be sent back to the server each time the browser requests a page from the server. Cookies can be used by web servers to identify and track users as they navigate different pages on a website, and to identify users returning to a website. 
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

OUR COOKIES

We use both session and persistent cookies on our website. The type of cookies that we use on our website, and the purposes for which they are used, are set out below:

Persistent cookie which may be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website, and to personalise our website for you.

Session cookies. These cookies do not operate once you log off completely from the website whereas persistent cookies remain on your hard drive for an extended period afterwards. We do not store Personally Identifiable Information in our cookies nor do we link the information in our cookies to our users’ Personally Identifiable Information.

 

HOW WE USE COOKIES

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies. We may use the information we obtain from your use of our cookies for the following purposes:

  • To recognise your computer when you visit our website;
  • To track you as you navigate our website, and to enable the use of the functions within it;
  • To improve the website’s usability;
  • To analyse the use of our website;
  • In the administration of this website.

Analytics cookies

We use an analytics service to collect information about how visitors use our site. Our analytics service provider generates statistical and other information about website use by means of cookies. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and pages visited.

Tracking cookies

Tracking cookies are used to track users’ web browsing habits. This can also be done to some extent by using the IP address of the computer requesting the page or the referer field of the HTTP request header, but cookies allow for greater precision.

Operational cookies

Operational cookies allow us to identify you as an individual user of our service and provide access to appropriate services and content. We also use operational cookies to maintain service stability, improve service performance and/or provide device-specific functionality (for example, serving mobile-friendly pages).

BLOCKING COOKIES

Most browsers allow you to refuse to accept cookies; for example:

  • Internet Explorer: you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced” and/or “Block all Cookies” using the sliding selector;
  • Firefox: you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”;
  • Chrome: you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.

Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

 

DELETING COOKIES

You can delete cookies already stored on your computer; for example:

  • Internet Explorer, you must manually delete cookie files;
  • Firefox, you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”;
  • Chrome, you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.

Obviously, doing this may have a negative impact on the usability of websites.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties Other companies in the Pole Star Group acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting.
  • External Third Parties Service providers acting as processors based internationally who provide aggregrate information and licences, IT and system administration services.
  • Professional advisers acting as joint controllers including lawyers, bankers, auditors and insurers based internationally who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as joint controllers based in the United Kingdom and internationally who require reporting of processing activities in certain circumstances.
  • Government agencies and authorities acting as joint controllers based internationally who require information for the purpose of regulatory sanctions.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Where we are required to do so for legal or regulatory compliance.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

We may provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

  1. INTERNATIONAL TRANSFERS

We share your personal data within Pole Star. This may involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us as set out above if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

  1. 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.

 

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: please contact us as set out above for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

The GDPR provides the following rights for individuals:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling

We value your rights highly within our Group and more details about your rights can be found Individual rights | ICO

 

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

  

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND 
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  

 

ADDENDUM TO POLE STAR SPACE APPLICATIONS LIMITED’S GENERAL TERMS AND CONDITIONS

 

INTRODUCTION

This Addendum is added with immediate effect to the Terms and Conditions and shall be incorporated into the Agreement between the Parties.

Clause references set out in this Addendum refer to Clause numbers within this Addendum.

Unless otherwise stated in the Definitions Section of this Addendum shall be interpreted in accordance with the Terms and Conditions.

 

DEFINITIONS   

Data Protection Legislation:  the UK Data Protection Legislation and (for so long as and to the extent that the law of the European Union has legal effect in the UK) the General Data Protection Regulation ((EU) 2016/679) and any other directly applicable European Union regulation relating to privacy.

Privacy Policy: The Policy as set out here and incorporated into this Addendum.

Provider: Pole Star Space Applications Limited

UK Data Protection Legislation:  any data protection legislation from time to time in force in the UK including the Data Protection Act 1998 or 2018 or any successor legislation.

 

You: Customer

  1. DATA PROTECTION  

1.1  Both parties will comply with all applicable requirements of the Data Protection Legislation. This Addendum is in addition to, and does not relieve, remove or replace, a party’s obligations under the Data Protection Legislation. In this clause 1, Applicable Laws means (for so long as and to the extent that they apply to the Provider) the law of the European Union, the law of any member state of the European Union and/or Domestic UK Law; and Domestic UK Law means the UK Data Protection Legislation and any other law that applies in the UK.

1.2  The parties acknowledge that for the purposes of the Data Protection Legislation, the Customer is the data controller and the Provider is the data processor (where Data Controller and Data Processor have the meanings as defined in the Data Protection Legislation). Your privacy and Personal Data within the meaning of the Data Protection Legislation is important to us. You agree that we may collect, store and use information about you in accordance with our Privacy Policy.  You agree to be bound by the terms of our Privacy & Cookie Policy as set out in the Privacy Policy here.

1.3  Without prejudice to the generality of clause 1.1, the Customer will ensure that it has all necessary appropriate consents and notices in place to enable lawful transfer of the Personal Data to the Provider for the duration and purposes of this agreement.

1.4  Without prejudice to the generality of clause 1.1, the Provider shall, in relation to any Personal Data processed in connection with the performance by the Provider of its obligations under this agreement:

(a)  process that Personal Data only on the written instructions of the Customer unless the Provider is required by Applicable Laws to otherwise process that Personal Data. Where the Provider is relying on laws of a member of the European Union or European Union law as the basis for processing Personal Data, the Provider shall promptly notify the Customer of this before performing the processing required by the Applicable Laws unless those Applicable Laws prohibit the Provider from so notifying the Customer;

(b)  ensure that it has in place appropriate technical and organisational measures, reviewed and approved by the Customer, to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of its systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by it);

(c)  ensure that all personnel who have access to and/or process Personal Data are obliged to keep the Personal Data confidential; and

(d)  not transfer any Personal Data outside of the European Economic Area unless the prior written consent of the Customer has been obtained and the following conditions are fulfilled:

(i)  the Customer or the Provider has provided appropriate safeguards in relation to the transfer;

(ii)  the data subject has enforceable rights and effective legal remedies;

(iii)  the Provider complies with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred; and

(iv)  the Provider complies with reasonable instructions notified to it in advance by the Customer with respect to the processing of the Personal Data;

(e)  assist the Customer, at the Customer’s cost, in responding to any request from a Data Subject and in ensuring compliance with its obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;

(f)  notify the Customer without undue delay on becoming aware of a Personal Data breach;

(g)  at the written direction of the Customer, delete or return Personal Data and copies thereof to the Customer on termination of the agreement unless required by Applicable Law to store the Personal Data; and

(h)  maintain complete and accurate records and information to demonstrate its compliance with this clause 1.4.

1.5  The Customer does not consent to the Provider appointing any third party processor of Personal Data under this agreement.

1.6  The Provider may, at any time on not less than 30 days’ notice, revise the Privacy Notice by replacing it with any applicable controller to processor standard clauses or similar terms forming party of an applicable certification scheme (which shall apply when replaced by attachment to this agreement).