This Cookies & Privacy Policy is part of our website Terms (‘the Terms’), which, by continuing to access  www.polo.works (‘the Site’), you are deemed to accept and to have agreed to be bound by.  The Site is provided by Polo Managing Agency Ltd and Polo Commercial Insurance Services Ltd (together, ‘PoloWorks’).  The Terms are set out in full in the Legal Notice .

Collection of personal information

The information that we collect and store during normal use of the Site and our landing pages is used to monitor and analyse how parts of the Site are used.  This may result in personal data about the device you are using being collected and stored, eg its IP address.

You have the option on certain pages within this site and on our landing pages to submit additional personal information to PoloWorks, so that we might send you further information.  The description below provides details as to how this information may be used.  By submitting your personal information through the Site or through our landing pages and forms, it will be processed by Polo Managing Agency Ltd or Polo Commercial Insurance Services Ltd in the manner described in this privacy notice.

We may collect and process the following data about you,  which may include personal data:

• Information you provide by completing forms on our website or landing pages. This could include your name, company name, job title, telephone number and e-mail address.
• We may ask you about your interests and preferences in order that we provide you with relevant information and communications.
• We may use information about what you have browsed on our website to contact you with information that might be of interest to you and your company.
• If you contact us, we may keep a record of that correspondence.
• We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of your visits to our website and landing pages, including traffic data, location data, weblogs, the resources that you access and other communication data.
• We may ask you for information when you report a problem with our website or landing pages.
• If you interact with us via our social media channels, we may ask for further information in order to process your request.

How we use your data

Information that you provide to us about you, which may include personal data and/or special-category data, will be used only for the following purposes and subject to any preferences you have notified us of:

• We may retain and disclose your personal data in order to comply with any statutory, legal or regulatory obligations.  We are required to report details of any suspicious transactions to the National Crime Agency and may need to forward information including personal data to them or related organisations, such as those with statutory powers, such as the Department of Work and Pensions.
• We may disclose your personal data to third parties if we are under a duty to disclose or share such information in order to comply with any legal obligation, or in order to enforce or apply the Terms of use or other agreements, or to protect the rights, property or safety of PoloWorks or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• PoloWorks intends to continue to improve the content and function of the Site.  For this reason, we may monitor customer traffic patterns and site usage to help us improve the Site’s design and layout and to provide content of interest to you.
• If you request specific types of marketing communications from us, we will use your data to deliver this to you.  Depending on your specified preferences, this could include research, thought leadership, newsletters, articles, events and webinar invitations, information about new products and promotions, or opportunities to participate in our research.
• Our marketing system collects data on your visits to our website and landing pages, including traffic and location data.  You can only be identified by this process if you choose to provide your personal data to us through a form, or if you specifically ask a PoloWorks employee to record your data on your behalf.  The content you opt in to, the other information you have provided, including your job title, and your interaction with our content, will determine what communications are sent to you.

Lawful basis for processing

Marketing (Legitimate Interest) – PoloWorks provides administration services on behalf of its corporate clients and their policyholders.  We sometimes undertake business-to-business marketing activity and have a legitimate business interest in processing your personal data as set out in this privacy policy in order to provide you with marketing information and communications relevant to you and your organisation.  This applies to existing clients, prospective clients and users who show an interest in particular information on behalf of their organisations.  Our Legitimate Interest Assessment is available upon request to compliance@polo.works .

If you do not wish to be contacted or to receive any further communications, you can opt out using the unsubscribe link in any communication we send you.  You can also exercise your right to object to this direct marketing at any time by contacting us at compliance@polo.works .

Marketing (Consent) – In order to meet the requirements of the Privacy and Electronic Communications Regulations (PECR), we will not be able to automatically contact you with relevant information if you are a sole trader, a small partnership or an individual acting for yourself.

If you fall into one of these categories and would like to receive information, you will need to provide us with your consent to receive it.  You can do this by completing a dedicated form to subscribe to a public list, or by ticking an opt-in checkbox on one of our forms, hosted either on the Site or our landing pages.  Once this consent has been provided, you have the option to opt out or unsubscribe at any time, using the e-mail preferences centre or by contacting us at compliance@polo.works .

Financial Crime (Legal Obligation) – We process information about our clients (beneficial owners and officers) to comply with Anti-money laundering legislation. This includes verifying an individual’s identity and screening them against crime and sanctions databases.

Data sharing and disclosures

We may share your information with the following types of organisation:

• Data Processors – other PoloWorks or external companies that work under contract to enable us to provide our services.
• Financial services regulators, law enforcement agencies such as the National Crime Agency, Action Fraud or a police authority.
• Fraud prevention and detection organisations and credit reference agencies.

Transfers outside of the EEA

It may sometimes be necessary to transfer your data outside of the EEA.  Should this be necessary it will be done in accordance with the applicable regulations and with suitable safeguards in place, using either the International Data Transfer Agreement or the International Data Transfer Addendum to the EU’s Standard Contractual Clauses.

Retention periods

PoloWorks has a Data Retention Policy which mandates how long records, including personal data, must be retained.  All personal data will be held in accordance with this policy.

Retention periods are determined by legislation and business requirements.  In most cases, we will hold your data for three years beyond the last contact, unless a legal or regulatory obligation requires that we hold the data for another period.  All information will be kept securely on our systems.  

Keeping your data safe

PoloWorks will keep your information for a reasonable period of time for the purposes outlined above.

The Site maintains security arrangements to ensure that any personal data entered are protected against loss, misuse or alteration.

We take appropriate steps to maintain the security of your data.  However, you should understand that the open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data are intended.  While we use all reasonable endeavours to protect your security, we consider that it is only appropriate to advise users that the security of data transmission over the internet and the Web cannot be guaranteed.  Therefore, you use the Site at your own risk.

Your privacy rights

Your privacy is very important to us and data protection legislation gives you a number of rights.  To exercise any of these rights please contact us, detailing which right in particular you would like to exercise.

For this purpose, you may contact us at compliance@polo.works  or by writing to PoloWorks, 4th floor, 65 Gresham Street, London EC2V 7NQ.

The right to be informed

This includes an obligation to explain to you how your information is used.  This privacy notice provides you with this information.

The right of access

You have the right to obtain confirmation that your information is being processed and to obtain access to your information, eg by receiving a copy of it.

The right to rectification

You have the right to have your information corrected if it is inaccurate or incomplete.

The right to erasure

You have the right to request the deletion or removal of your information in certain circumstances.  Please note that there may be circumstances where it is not possible to fulfil the request for your information to be deleted, eg if there is a legal reason to retain it, or if it is still required to provide our services to you.

The right to restrict processing

You have the right to request that the processing of your information is restricted in certain circumstances.  Again, there may be circumstances where we are legally entitled to refuse such a request.

The right to data portability

You have the right to receive the information you have provided in a usable electronic format and/or to request that it be transmitted to a third party where this is technically feasible.  This will only apply where we process your data based on consent or if you as an individual have a contract with us.

The right to complain to the supervisory authority

You have the right to make a complaint to the Information Commissioner if you think that any of your rights has been infringed.  Such a complaint may be made through the Information Commissioner’s website at this address, https://ico.org.uk/concerns.

Cookies

A cookie is a tiny text file that a website can store on your machine and read on subsequent visits.  This allows the website to identify you and, for example, remember to log you in the next time you visit.

Our website may use cookies and similar technologies to remember any preferences that the Site may allow you to set or to track your progress through the Site so we can make improvements to the service we offer you.  Cookies may be required to allow you to access and participate in certain areas of the website.  The cookies we store on your computer do not contain any personally identifiable information.

There are different types of cookie.  The cookies we use are listed below under the four categories proposed by the International Chamber of Commerce:

• Strictly necessary cookies – These are cookies that are directly required to fulfil an action requested by you, such as logging in or adding an item to a shopping basket.
• Performance cookies – These are cookies that are used to improve a website, for example, that let companies see how their site is used and where to make improvements.
• Functionality cookies – These are cookies that are needed for a specific function but are not directly requested by you.  For example, in order to stop you from being repeatedly offered a service that you have previously declined.  We do not use any functionality cookies.
• Targeting cookies – These cookies can be quite intrusive as they track a user’s browsing behaviour from website to website and are often used for targeted advertising.  PoloWorks does not set any targeting cookies itself, although they may be used on our website by third parties (see below).

We also use third-party cookies.  These are cookies used by an external party that provide additional functionality to our website.

How to manage your cookies

Cookies are sent to your browser (whether you use Internet Edge, Google Chrome, Safari or another browser) by a website and then stored in the cookies directory of your device.

To check and update your cookies settings, you will need to know what browser you are using and what version of it you have.  You can usually find this out by opening the browser (as if you were going to use the internet) and clicking on ‘Help’ and then ‘About’.  This will give you information about the browser version you are using.

To find out how to allow, block, delete and manage the cookies on all standard web browsers, go to www.aboutcookies.org and select the browser and version you are using.  You will also find information there about how to delete cookies from your computer.

If you use a mobile phone to browse this site or other sites that use cookies, please refer to your handset manual for guidance.

Google analytics

This site uses Google Analytics, a web analytics service provided by Google.  Google Analytics sets a cookie in order to evaluate your use of the site and compile reports for us on activity.

Google stores the information collected by the cookie on servers in the United States.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.  Google will not associate your IP address with any other data held by Google.  By using this site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.  Should you wish to reject or delete this cookie please refer to Google’s own privacy policy, at www.google.com/intl/en/privacypolicy.html.

Cookies set by third-party sites

We sometimes embed content from other third-party sites.  As a result, when you visit a page with content embedded from, for example, YouTube, you may be presented with cookies from these websites.  PoloWorks does not control the dissemination of these cookies.  You should check the relevant third-party website for more information about these.

Contact us

If your personal details change, if you change your mind about any of your marketing or other preferences, if you wish to receive further information about how we use your personal data or have any other queries, please let us know by contacting us at compliance@polo.works

Related information

Please note that if our business, or any part of it, is sold or transferred at any time, the information we hold may form part of the assets transferred, although it will still only be used in accordance with this policy.

We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time.  Please read this Cookies & Privacy Policy carefully and re-visit this page from time to time to review any changes that may have been made.

This Cookies & Privacy Policy applies to you whether you use the Site or our landing pages for personal purposes, or have entered into a contract with PoloWorks in relation to the supply of specific services and/or products.  In the event of any conflict between this Cookies & Privacy Policy and the terms of a contract you have with PoloWorks, the relevant provision of the contract shall prevail.