Privacy notice - Event registration and participation
This document describes how Polestar processes your personal data when you register to and/or participate in a Polestar Event.
2. Who we are
Polestar Performance AB, a Swedish legal entity with company registration number 556653-3096 with address Assar Gabrielssons Väg 9 405 31 Göteborg, Sweden, hereinafter referred to as “Polestar AB”, and Polestar Automotive Canada Inc., a Canadian legal entity with company registration number 2021859588 with address 2500, 10303 Japser Avenue Edmonton, Alberta, T5J 3N6, hereinafter referred to as ”Polestar Canada”, process your personal data as described below.
For some events, Polestar AB will be the organizer of the event and may share information of the attendance with Polestar Canada; in this case, to the extent the EU General Data Protection Regulation (GDPR) applies, we would be joint controllers for the marketing activities in this information. For other events, Polestar Canada will be the organizer of the event and may share information of the attendance with Polestar AB; in this case, to the extent GDPR applies, we would be joint controllers for the marketing activities in this information. In addition, in such cases Polestar AB will assist Polestar Canada the sending of communications related to the event; in the case, to the extent GDPR applies, Polestar AB will be a data processor for Polestar Canada.
3. What personal data we collect and why
When you register and participate in a Polestar Event (the Event), we collect from you your identifiers such as name, street address, email address and phone number and date of birth. The purpose of our processing is to administer your participation in the Event. To the extent GDPR applies, the legal basis for our processing is the performance of a contract with you. Under Canadian law, you provide your consent by giving your registration details.
We may use your contact details for security reasons (e.g. in case of fire or other safety incident). To the extent GDPR applies, the legal basis for our processing is our legitimate interest.
Where we provide food during the Event, you may be asked to provide information about your food allergies or other conditions. The purpose of our processing is to adapt our menu. To the extent GDPR applies and under Canadian law, the legal basis for our processing is your consent.
We may take photos and record video footage on both physical and digital (e.g. webinars) Events. We store the photographs and video footage and audio recordings for reference. We use this footage for commercial, marketing and advertising campaigns in all types of media, printed and digital, internally, externally, nationally or globally to promote Polestar, its business, vehicles and brand. We may also use these to provide internal educational resources. To, the extent GDPR applies, the legal basis for our processing is our legitimate interest. Under Canadian law, by participating in the event you provide your consent to this recording.
If we interview you or want to use close-up photos or footage of you, we will ask for your authorization and will ask that you sign a consent. To the extent GDPR applies, and under Canadian law, the legal basis for our processing is your consent. You may revoke the consent, with effect going forward, by clicking the request form.
4. How long we keep your data
We will retain your personal data used for administration of your participation in the Event up to one (1) year after the end of the Event.
We will retain your personal data for the adaption of the menu during the Event up to one (1) week after the end of the Event.
In relation to processing of your personal data for marketing purposes, we will actively use these for a period of five (5) years from the date of the Event, where after published marketing materials will remain viewable for the public in our digital channels. Marketing materials that are not used or removed from our digital channels will be stored for reference.
5. How we protect your personal data
In order to help prevent unauthorized access to or disclosure of personal data, we have put in place physical, electronic, and organizational procedures to help safeguard and secure the personal data we collect. Personal data may be accessed by persons within our organization or our third-party service providers who require such access to carry out the purposes described in this Privacy Notice or are otherwise permitted or required by applicable law. Depending on the role played by Polestar Canada and Polestar AB, respectively, as explained in Section 1 above, Personal data we collect is managed from our offices in Canada and/or in the EU. Even though we have taken steps to help protect the personal data in our control, you should know that we cannot fully eliminate security risks associated with personal data. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.
6. Who we share your personal data with
Other than the sharing between Polestar AB and Polestar Canada as described in Section 2 above, we will share your personal data with the following categories of recipients, on a need-to-know basis:
- Processors (Service providers and other parties): Polestar shares your personal data with processors that assist us in the process. These service providers include our cloud software and data hosting providers. The processing is limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with the data processing agreement in place:
- SWOOGO (Ireland)
- SalesForce UK Limited (United Kingdom)
- Authorities: We may share your personal data to third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, for risk management purposes, and to comply with our legal obligations. To the extent GDPR applies, the legal basis for this sharing is compliance with legal obligations and our legitimate interest in compliance with laws applicable to Polestar.
- Business partners: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, we may share personal data. To the extent GDPR applies, the legal basis for this sharing is our legitimate interest in the efficient operation of our business.
7. Transfer of your personal data
Transfers of your personal data to our affiliates, data processors and business partners located outside of EEA, where the destination country is not subject to an adequacy decision by the European Commission, is based upon Standard Contractual Clauses adopted by the European Commission, available here. More information about which recipients we share personal data with can be found in Section 5.
8. Your rights
If our processing of your personal data is subject to Canadian law, the following section applies to you:Accessing and correcting your personal data: For residents of Canada, you have a right to request access to your personal data and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal data we have about you, or if you would like to have it corrected, please fill out this form, which will help us to handle your request properly. In some cases, we may not be able to allow you to access certain personal data in certain circumstances: for example, if it contains personal data of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal data, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. You will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal data we collected, and you must describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and correction requests using the information provided, we may ask you for additional pieces of information.Right to withdraw consent: If you have given consent for the processing of your personal data, you may withdraw your consent with effect for the future. Please note that if you withdraw consent that in necessary for us to provide you with products or services, we may no longer be able to provide those products or services to you. You may withdraw any consent you have provided to our use of personal data to market to you without withdrawing consent needed to provide our goods and services. Your withdrawal of consent does not have retroactive effect, and there may be cases where we are permitted under the applicable law to process certain personal data without consent.
To the extent GDPR applies, you have specific legal rights relating to the personal data we process about you. You can object to our processing of your data, access the data we hold about you, ask for rectification or restriction of your data, request to have your data ported to another entity, request that we delete your data, and finally you can file a complaint with a data protection supervisory authority.
9. Contact information
In order to exercise your rights, please use this web form. If you have any other questions regarding the subject matter of personal data protection, you can contact us or our Data Protection Officer on the contact details stated on polestar.com/privacy-policy.
10. Changes to our Privacy Notice
We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. For this reason, we encourage you to refer to this privacy notice on an ongoing basis. This privacy notice is current as of the date which appears at the top of the document. We will treat your personal data in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently. If the changes allow us to use personal data in ways that materially affect your rights, we will post a special note on our digital platforms and, if required by law, will prompt you for your consent for certain changes.