PRIVACY NOTICE - ORDER OF ADDITIONALS ON POLESTAR.COM
Last Updated: 2022-01-14
- information we process and why;
- how we share your information; and
- your rights about this use and sharing.
1. Who we are
When you purchase items in the store, Prominate and Polestar collect the information as described below. We set forth below our respective roles in the collection and processing of the information. Where UK or EU data protection law applies, Prominate and Polestar are joint controllers. In certain cases, Prominate collects the information and shares it with Polestar in order for Polestar to provide customer service to you. In this capacity, for the purpose of US data protection laws, Polestar is a service provider to Prominate. Polestar may use the information for its own marketing activities as described below. You may opt out of this sharing on this link.
2. Information we process, where from, why, how long do we keep it, and how we share it
When you use our website at https://additionals.polestar.com (the “Website”) to order Polestar branded merchandise (“Products”), or interact with us in various ways, Prominate and Polestar collect personal information, which is information that identities, relates to, describes, references, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, household or device. When you take the actions listed below, we collect personal information about you in the following ways.
Specifically, we collect personal information when you:
1. Order Additionals Through Our Website: When you order a product on our Website, Prominate collects from you identifiers (name, address, email, phone) payment information and order information (product details, quantity etc). Prominate uses this information to process your purchase and shares the payment information with the payment provider to this end. Where UK or EU data protection law applies, the legal basis is necessity for the performance of the contract with you. If you opt in, Prominate uses your identifiers and purchase information to gauge your satisfaction through surveys, to follow up on the delivery, to send you updates about recalls, product updates or other matters concerning the product(s); and to recognize you as a returning customer for statistical purposes and to enhance your experience by using your order history to deliver tailored marketing communication. Where UK or EU data protection law applies, the legal basis is your consent. Prominate also uses your information to provide customer support. Where UK or EU data protection law applies, the legal basis for this is that is it necessary to perform our contract with you.
Both Prominate and Polestar process the identifiers and purchase information to conduct statistical analysis and to facilitate research and development. Where UK or EU data protection law applies, the legal basis for this is our legitimate interest in the improvement of our products and customer support processes and in providing a seamless customer experience. No UK or EU data will be shared with the USA, only data pertaining to USA citizens collected in the UK or EU will be shared with the USA.
To comply with our USA legal obligations and respond to legal proceedings, we may use your Personal Information to comply with our legal obligations, including maintaining records of our compliance with federal and state law requirements. We may also use your Personal Information to establish, exercise, or defend legal claims.
2. Accept Cookies: If you consent, we will collect and access information from your devices through cookies and similar technologies. For more information and to exercise your choices see https://additionals.polestar.com/cookie-policy/. If you accept cookies on our Website, we combine the personal information collected through the cookies with other information we collect about you and use this to tailor our marketing communications with you. To the extent UK or EU data protection law applies, the legal basis for this is your consent. You have the right to withdraw your consent to our processing of your personal data related to marketing purposes at any time. Please direct a request for withdrawal of consent to Polestar using the contact information found in Legal contacts.
3. How we generally share your personal information
Your personal data will be disclosed to and processed by our affiliates and business partners (including, if applicable, financing company, pick-up and delivery partner, handover partner) for the above purposes. In relation to our business partners located outside of the UK and/or the EEA, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.
4. Specific sharing of your information
With service providers: We share personal information with service providers that support us in providing the Website and facilitating your purchases. These service providers include Software-as-a-Service providers of data storage, as well as customer care centers.
For a business purpose: We share, for a business purpose:
- Your personal identifiers and commercial information with our service providers to provide the Website services, including the above-mentioned categories.
- Your personal identifiers and commercial information for research and development purposes to better understand and to improve our products and services.
When Prominate transfers information to service providers located outside of the UK and/or the European Economic Area, we will transfer your personal data on the basis of the Standard Contractual Clauses adopted by the European Commission.
Prominate also shares your information with Polestar to conduct its own marketing. You may opt out of the sharing with Polestar for the purpose of marketing on this link.
Legal Compliance: In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
5. Retention time
We will retain your identifiers and purchase information for up to five (5) years, after your purchase or the statutory period of bookkeeping if that is longer. If you have a valid Polestar ID account, your personal data is retained with Polestar for as long as the Polestar ID account is active.
For use of your data for marketing purposes, please note that we will retain your personal data up to twelve (12) months after you have opted-out from receiving further marketing communication material from us for statistical purposes only.
6. Your rights and controller contact information
YOUR RIGHTS UNDER UK OR EU DATA PROTECTION LAW
For more information on your rights in relation to our processing of your personal data and contact details for further information and complaints as well as contact details to our Data Protection Officer, please see the links below.
If you want to exercise any of your rights, you may direct your request to either Prominate or Polestar. However we recommend that you direct your request to Prominate, as Prominate will be primarily responsible for handling your request according to our data sharing arrangement.
Prominate: [email protected]
Polestar: Legal contacts
YOUR RIGHTS UNDER CALIFORNIA LAW
Under California law, certain California residents have the privacy rights listed below. The rights listed below under the California Consumer Privacy Act and Shine the Light are not the same. To exercise your rights, you will need to follow the directions below.
- California Consumer Privacy Act (“CCPA”)
We adhere to the California Consumer Privacy Act of 2018 (“CCPA”) which gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. This landmark law secures new privacy rights for California consumers, including:
- Right to Access: You have the right to request what personal information we collected, used, shared for a business purpose, and sold about you within the preceding 12 months. Once we receive your request and confirm your identity, we will disclose to you the information we collected about you.
- Right to Deletion: You have the right to request the deletion of your personal information that we collect about you, subject to certain exceptions. Once we receive your request and confirm your identity, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies under applicable law. If we deny your request to delete, we will let you know the reason for the denial.
- Right to Opt-Out: You have the right to opt-out of the sale of your personal information by us to Third Parties for monetary or other valuable consideration.
- Right to Non-Discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out. For example, this means we cannot deny goods and services to you or charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, due to you having exercised your rights.
- California "Shine the Light” Law
Prominate adheres to the California Shine the Light Law of 2003. Like the California Customer Records Act, the CCPA requires businesses to implement and maintain reasonable security measures to protect personal information. Like Shine the Light, the CCPA requires businesses to respond to requests to disclose which third parties they are sharing personal information.
How to exercise your rights:
To exercise your rights, you may submit a request through our online webform, via e-mail at [email protected]. You may only make a request for access twice within a 12-month period. To exercise your rights directly towards Polestar, you may submit a request through our online webform, via e-mail at [email protected] or by calling us toll-free at (800) 806-2504.
To exercise your right to opt-out of the sharing of your personal information to advertising partners, which may be a sale under the CCPA, please e-mail us at [email protected].
Authorized agents may make a verifiable consumer rights request related to your personal information. If you are an authorized agent making a request on behalf of a California consumer, you must provide us with signed permission by the consumer that you are authorized to act on behalf of that customer. If you are a legal entity, you must also provide us with documentation of your registration with the California Secretary of State. To submit such a request, please contact us via e-mail at [email protected] and [email protected] respectively.
How we respond to your requests:
Our webform for access, opt-out of future sales of personal information contains the information that we need to verify your identity and review your request. For requests submitted via telephone or e-mail, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information (based on the personal information maintained by Polestar US). This information must include your:
- First and Last Name
- Address, City, State, and ZIP Code
- E-mail Address
- Telephone Number
You must provide us with sufficient information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we cannot reasonably identify you with the information you provided, we may ask you to provide us with additional information, such as your purchase or service history, or how you first provided us with your personal information, such as signing up for marketing e-mails or other communication channels.
We aim to respond to your request for access or deletion within the time required by the CCPA or other applicable laws. If we need more time to respond to your request, we will let you know of the reason and the extension period in-writing.
To protect your personal information from loss, theft, and unauthorized access, use, or disclosure, we have implemented technical, administrative, and physical security measures including encryption of transmitted and stored data, and access right concepts. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure or impenetrable.
Our products and services are not intended to be used by children. We do not knowingly solicit or collect any personal information about children under the age of sixteen (16) nor knowingly allow children to communicate with us or use any of our services. If a child has provided us with personal information, a parent or guardian of that child may contact us to have that information deleted from our records. If you believe that we might have any information from a child under the age of sixteen (16), please tell us using the Contact Information listed below. We will take all reasonable steps to delete the child’s information as soon as possible except where necessary to protect the safety of the child or others as required by law. We do not have actual knowledge that it sells personal information of children under the age of sixteen (16) years.
YOUR RIGHTS AS A RESIDENT OF NEVADA
If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at [email protected]. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.
DO NOT TRACK
We do not respond to Do Not Track (DNT) signals. DNT is a preference you can set on your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
CHANGES TO OUR PRIVACY NOTICE AND PRIVACY POLICIES
We reserve the right to amend this Privacy Notice at our discretion and at any time. If the changes allow us to use personal information in ways that materially affect your rights, we will post a special note on our website and, if required by law, will prompt you for your consent for certain changes. When we make changes this Privacy Notice, we will post the updated Privacy Notice and update the “Last Updated” date. Each version of this Privacy Notice will be identified by the Last Updated date.
If you have any questions or comments about this Privacy Notice, please do not hesitate to contact us at:
Polestar Performance AB
Attention: The Data Protection Officer
Assar Gabrielssons väg 9
SE-405 31 Gothenburg, Sweden