Responsibility for your personal data
Polaron is responsible for your personal data. Polaron comprises Polaron Language Services and Polaron European Citizenship (ABN 99 120 446 362).
Types of data we collect
The personal data we collect may include:
- Contact information, such as your name, address, phone numbers and email address;
- Payment data necessary for processing payments, including credit/debit card numbers, security code numbers and other related billing information;
- Further business information necessarily processed in a contractual relationship with Polaron or voluntarily provided by you, such as instructions given, payments made, requests and projects;
- Information collected from publicly available resources, archival institutions and databases;
- In connection with an event or seminar, we may ask for information for the purpose of identifying any disabilities or dietary requirements you may have. Use of such information is based on your consent.
- Other personal data regarding your preferences where it is relevant to legal services that we provide.
How we collect your personal data
We may collect personal data about you in a number of circumstances, including:
- When you seek advice from us or use any on-line client services;
- When you browse, make an enquiry or otherwise interact on our website;
- When you attend a Polaron event or sign up to receive personal data from us, including training; or
- When you offer to provide or provide services to us.
In some circumstances, we collect personal data about you from a third-party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, government agencies, a credit reporting agency, an information or service provider or from a publicly available record.
Are you required to provide personal data?
You will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, there are circumstances in which Polaron cannot take action without your personal data, for example because this personal data is required to process your instructions or orders or provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant personal data and we will notify you accordingly.
How we will use your personal data
We may use your personal data for the following purposes only (“Permitted Purposes”):
- Providing services or things you may have requested, including on-line or legal technology services or solutions as instructed or requested by you or your organisation;
- Managing and administering your or your organisation’s business relationship with Polaron, including processing payments, accounting, auditing, billing and collection, support services;
- To analyse and improve our services and communications to you;
- Protecting the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
- For monitoring and assessing compliance with our policies and standards;
- To identify persons authorised to trade on behalf of our clients, customers, suppliers and/or service providers;
- For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.
Where you have expressly given us your consent, we may process your personal data also for the following purposes:
- Communicating with you through the channels you have approved to keep you up to date on the latest legal developments, announcements, and other information about Polaron services, products and technologies (including client briefings, newsletters and other information) as well as Polaron events and projects;
- Customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events; or
- Collecting information about your preferences to create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).
With regard to marketing-related communication, we will – where legally required – only provide you with such information after you have opted in and provide you the opportunity to opt out anytime if you do not want to receive further marketing-related communication from us. We will not use your personal data for taking any automated decisions affecting you or creating profiles other than described above.
In addition, the processing may be based on your consent where you have expressly given that to us.
Sharing your personal data
We may share your personal data in the following circumstances:
- We may share your personal data between the Polaron Entities on a confidential basis where required for the purpose of providing advice or other products or services and for administrative, billing and other business purposes. A list of the countries in which Polaron Entities are located can be found on our website;
- If you are a client of Polaron, or are contracted to or are an agent of a client of Polaron, we may disclose your personal data to:
- Lawyers, researchers, consultants or experts engaged in your matter; or
- Foreign authorities for the purpose of obtaining foreign advice;
- We may disclose your contact details on a confidential basis to third parties for the purposes of collecting your feedback on the company’s service provision, to help us measure our performance and to improve and promote our services;
- We may share your personal data with any third party to whom we assign or novate any of our rights or obligations;
- We may also instruct service providers within or outside of Polaron, domestically or abroad, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. Polaron will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers;
- We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
Otherwise, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
Personal data about other people which you provide to us
Keeping personal data about you secure
We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.
Transferring your personal data abroad
Polaron is a global company. We may transfer your personal data abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by relevant laws. You may contact us anytime using the contact details below if you would like further information on such safeguards.
All Polaron offices throughout the world will at all times ensure a level of data protection at least as protective as that required in the European Economic Area and Australia. We will also require our staff, agents, consultants and sub-contractors and others who are outside the European Economic Area and to whom we transfer your personal data to ensure a similar level of data protection.
When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data.
Updating personal data about you
If any of the personal data that you have provided to us changes or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to firstname.lastname@example.org. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.
Retaining your personal data
Your personal data will be deleted when it is no longer reasonably required for the Permitted Purposes or you withdraw your consent and we are not legally required to continue storing such data. We will retain your personal data where required for Polaron to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.
You have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected and to object to or restrict our using your personal data. You may also make a complaint if you have a concern about our handling of your personal data.
If you wish to do any of the above please contact us at email@example.com. We will consider any requests we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator.
How to contact us
If at any time you believe we have not adhered to the principles referred to in the privacy statement or have any other comments, please contact us at firstname.lastname@example.org. If you do not wish to send your comments by email then please write to the following postal address:
Polaron Language Services
Suite 301/22-26 St Kilda Road
St Kilda VIC 3182