This is the privacy policy for Pollen Technologies Ltd (registered address; 123 Wellington Road, Cheshire, SK1 3TH). For the purposes of the General Data Protection Regulation (GDPR), we are the data controller of the personal data you submit via our website and application. Our ICO registration number is ZA210112.
We are committed to protecting your privacy and the security of the personal data we hold and process on your behalf. This Privacy Policy explains how we collect information, what we use the information for, our legal basis for doing so, and what controls you have.
We reserve the right to change this privacy policy from time to time by changing it on this website. This privacy policy was last updated on 1st November 2023.
What information do we collect from you?
Information you give to us
We may collect and process the following personal information about you:
General personal details, which may include:
Your name
Your residential address
Your contact details (email address and/or your telephone number)
Your date of birth
Account sign-in information, which will include the following as set by you:
Username
Password
Information we collect about you
With regard to each of your visits to the Website we may automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system;
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We may receive information about you if you use any of the other websites we operate or the other services we provide.
The information detailed above will not constitute personal data.
What we do with your data?
We use your personal data for the following purposes:
Providing our services to you
We need to process certain personal information in order to provide our payment services to you. In order to deliver our services, your personal data may also be transferred to third parties, including the following:
Our cloud hosting provider, AWS, to store your personal data securely.
Our customer service provider, Zendesk, to help offer customer support.
KYC
We may conduct searches through an identity-referencing agency and through other sources of information and use scoring methods both to allow us to provide you with the Services and to assess our risks in doing so, including credit standing and compliance with all KYC/CDD requirements. A record of this process will be kept and may be used to allow our Group Companies to similarly provide you with services and to assess our risks in doing so. Information may also be passed to other organisations or persons to prevent fraud. Additionally, information may be passed to governmental, regulatory or judicial organisations to prevent fraud or financial crime where we consider it appropriate. The foregoing use of Personal Data may render us a Data Controller.
Contacting you about our services
You may opt out of this at any time by telling us, or if we have contacted you via email, you will be given an option to opt out by clicking the relevant email link.
Improving our services
We may use your personal data to analyse how you are using the Pollen Technologies service and to gain insights into how we can improve our products and services.
Customer Support and account administration
We may use your personal data to provide you with customer support or to investigate complaints or concerns about your account.
Our lawful basis for processing your personal data
Under Article 6 of the UK General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data.
We will only collect and process your personal data in accordance with one of the below lawful bases:
Performance of a contract: This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract, such as providing you with a quote.
This lawful basis covers the following purposes:
Providing our services to you
Our legitimate interests: This is where we collect and process data in accordance with our “legitimate interests”. Our legitimate interests include:
Improving our service
Providing you with marketing information about our services
Providing you with customer support and administering your account
Providing you with information about related products and services offered by Pollen Technologies
Compliance with our legal obligations: We may be required to process or share your personal data in compliance with a legal obligation, such as in response to a request by law enforcement or when investigating a civil claim.
By asking us to provide you with the Services, you will be providing us with information which includes Personal Data. In relation to such Personal Data, we shall act as: (i) a Data Controller in respect of our use of such Personal Data to (a) conduct KYC, CDD and other checks as part of our process of accepting you as a Client, (b) comply with any legal and/or regulatory requirements to which we are subject from time to time, including but not limited to FCA requirements, (c) determine how best to provide the Services and our risks in doing so, and (d) prevent fraud or financial crime; and (ii) a Data Processor in respect of our use of Personal Data relating to You and where applicable End Customers in order to provide the Services.
Data storage and international transfers
We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the GDPR. Your data will be stored on cloud servers within the UK and we will only store your data outside the UK in the event that the jurisdiction in question has been assessed as compliant with the GDPR.
Your rights
You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice.
If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.
You have the right to “portability” of your personal data that we have collected with your consent or in performance of a contract. This means that you can request copies of all the personal data we hold for this purpose in a structured, commonly used, and machine readable form, and we will supply this to you free of charge on request. We will respond to these requests within one month, unless the request is particularly complex, in which case we will inform you of how long it will take as soon as possible.
Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails.
You can exercise any of your rights by contacting us.
How long we will keep your data for
We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary for the purposes which it is stored.
What happens if you don’t provide us with the information we need
As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations. Should you not provide us with the data we require to offer our service or request that we erase the personal data we hold, it is likely that we will not be able to deliver our services to you.
Complaints
If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided above. Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage.
https://ico.org.uk/global/contact-us/