Privacy &
Cookie Policy

(last updated 04 Oct 2019)

ABOUT US
Pollen (which is the trading name of StreetTeam Software Limited, with registered company number 09750608 and collectively referred to as “Pollen”, “we”, “us” and “our”) is committed to protecting your privacy and personal data.

This Privacy and Cookie Policy (“Privacy Policy”) describes how we collect and use your personal data, the steps we take to protect your personal data and your rights in relation to your personal data.

This Privacy Policy is incorporated into our Terms and Conditions.

CHANGES TO THIS PRIVACY POLICY
We may occasionally update this Privacy Policy.

When we do, we will revise the “last updated” date at the top of the Privacy Policy. Please ensure that you frequently check this Privacy Policy for any updates.

COLLECTION OF INFORMATION
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).

The personal data we collect and use from you may include:

Information you submit when you contact us, which may include:

  • your name,
  • email address,
  • phone number,
  • your job title,
  • your work address,
  • Information through your use of this website.

HOW IS YOUR PERSONAL DATA USED?
If you have consented to the processing of your personal data, we may use the personal data you provide to us to:

administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
contact you; and
send out email alerts that you may have signed up for.

We will only use your personal data where we are allowed to. Most commonly, we will use your personal data in one of the following circumstances:

(i) it is necessary for the performance of a contract we have with you;

(ii) where you have provided your consent;

(iii) it is necessary for us to comply with legal obligation that we are under; or

(iv) it is in our (or a third party’s) legitimate interests and such interests do not prejudice your rights or freedoms.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We may disclose your personal data to third parties but only when it is necessary to do so, and subject to our obligations of confidentiality.

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 occasionally be required by law, court order or governmental authority to disclose certain types of personal data.

USE OF COOKIES
We and our service providers may collect information through the use of “cookies” and similar technologies to understand how you use our site for authentication, operations, and analytics purposes.

Cookies are small files that websites save to your hard disk or to your browser’s memory.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer.

Please note that if you choose to decline cookies, you may not be able to fully experience the features of websites that you visit.

To learn more about cookies and how to disable them we recommend you:

  • click here;
  • consult the help page of your browser; and/or
  • visit the website of your national data protection authority.

Furthermore, and by way of information only you can learn more about third party marketing cookies generally these and how to delete them here.

INTERNATIONAL TRANSFERS
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:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

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

SECURITY
We are committed to protecting the security of your personal data.

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.

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.

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, regulatory, tax, accounting or other requirements.

YOUR RIGHTS
You have the following rights in relation to your personal data:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You may exercise any of the above rights by contacting us at: support@pollen.co.

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 could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

If you are unsure about your rights or are concerned about how your personal data may be processed you should contact your national data protection regulator. In the UK, this is the Information Commissioner’s Office (ICO) (https://ico.org.uk/).

You can unsubscribe from our promotional emails at any time via the unsubscribe link provided in the emails. Please note that you may continue to receive administrative messages from us even if you opt out of receiving promotional messages.

It is important that the personal data we hold about you is accurate and current. Please contact us at support@pollen.co if your personal data changes during your relationship with us.

CHILDREN’S INFORMATION
Our services are not aimed at children and we do not knowingly collect personal information from children under the age of 16. If we find out that a child under 16 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 16 has given us personal information, please contact us at legal@pollen.co.

LINKS TO OTHER WEBSITES
Our site 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 policy of every website you visit.

CONTACT US
If you have questions regarding this policy or our handling of your personal data, please contact us at legal@pollen.co.