Polaris | Privacy Policy

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Privacy Policy

Last updated: 17 August 2023

1. INTRODUCTION

Welcome to "Polaris," operated by Holistic AI Inc.. This privacy policy outlines how we use, collect, protect and share your personal information. By accessing or using our website, you agree to the practices described here in Holistic AI Inc.'s Privacy and Data Protection Policy ("Privacy Policy").

At Holistic AI Inc. ("we", "us", or "our") we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation ("GDPR"), the Data Protection Act 2018 and all other applicable data protection laws.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

This Privacy Policy applies to all Personal Data processed at any time by us.

1.1 Who is Your Data Controller?

Holistic AI Inc. is your Data Controller and is responsible for your Personal Data.

We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us one mail at we@holisticai.comor sent in a letter to 18 Soho Square, London, W1D 3QL, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.2 Processing Data on Behalf of a Controller and Processors' responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). Therefore, the responsibilities described below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 5 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. INFORMATION WE COLLECT

We collect the following types of personal data:

Your name, email address, phone number, and other contact information
Your job title and company
Payment information
IP addresses

3. HOW WE USE YOUR INFORMATION

We may use your personal data for the following purposes:

To process your event registration and payment (if applicable)
To communicate with you about the event and any updates or changes
To personalize your event experience based on your preferences
To gather feedback on the event and improve our services
To comply with legal and regulatory requirements

4. LEGAL BASIS FOR DATA COLLECTION

4.1 Types of Data We Collect

"Personal Data" 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).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

Profile/Identity Data : This is data relating to your first name, last name, and date of birth.
Contact Data : This is data relating to your phone number, addresses, email addresses, and phone numbers.
Marketing and Communications Data : This is your preference in receiving marketing information and other information from us.
Payment information : This is data collected if you engage in a membership subscription to the site "Polaris".
Website use : This is data relating to website use, cookies and site analytics.
IP address : This is the unique address to identify a device on the internet or a local network.
Feedback on the site (if applicable)

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4.2 Purpose of Data Collection

We collect this data for the following purposes:

Account creation and management
Communication with users
Marketing and promotional emails, including user personalization
Analytics to enhance user experience and inform decision making

4.3 Data Collection Methods

We collect data through online forms and cookies. All information collected with the exception of necessary cookies is provided voluntarily by consenting to cookies or providing the information on sign-up. We use cookies to save login information and user preferences. Users can opt out of cookies or delete their account to stop data collection.

4.4 Data Usage

We use collected data for:

Sending promotional emails
Analyzing user behaviour to improve our services
Performance metrics to improve site services and search engine optimization

5. LEGAL BASIS FOR PROCESSING

We rely on the following legal bases for processing your personal data:

Performance of a contract : We need to process your personal data to fulfil our contractual obligations to you when you sign up for our events.
Legitimate interests : We may process your personal data for our legitimate interests in organizing and promoting events, as long as your fundamental rights and freedoms do not override these interests.
Consent : We will obtain your consent before sending you sales and marketing emails and sharing your personal data with our sponsors and partners for marketing and promotional purposes related to the event. You have the right to withdraw your consent at any time.

5.1 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow the collection and processing of Personal Data. The main avenues we rely on are:

"Consent": Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or 'opt in' to a service.
"Legal Compliance": We're required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
"Legitimate Interest": We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

6. SALES AND MARKETING EMAILS

If you have created an account and chosen to opt into receiving sales and marketing emails from us, we may email you information about our other events, products, and services. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

You can unsubscribe from these emails at any time by clicking on the unsubscribe link at the bottom of the email.

7. CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and signing off after you have finished accessing your account.

You will need to contact us if you would like to delete your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to we@holisticai.com.

8.1 User Rights

Under the GDPR, you have the following rights regarding your Personal Data:

Right to access: You have the right to request access to your Personal Data and to receive a copy of your personal data that we hold.
Right to rectification: You have the right to request that we correct any inaccurate or incomplete Personal Data that we hold about you.
Right to erasure: You have the right to request that we delete your Personal Data in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.
Right to restriction of processing: You have the right to request that we restrict the processing of your Personal Data in certain circumstances, such as when you contest the accuracy of your Personal Data.
Right to data portability: You have the right to receive a copy

Users can request access to and rectification of their data. Changes will be assessed on a case-by-case basis.

8.2 Opting Out of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by clicking a link at the bottom of the e-mail to unsubscribe from our marketing communications.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

8.3 How to Request Your Data and the Process for Obtaining It

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

9. DATA PROTECTION

User data is stored securely in a database to prevent unauthorized access to breaches.

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our site. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Holistic AI Inc. to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

10. DATA RETENTION

Users will be notified of data retention changes via the email address they have provided.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

11. YOUR DATA AND THIRD PARTIES

We may also share Personal Data with interested parties in the event that Holistic AI Inc. anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Holistic AI Inc. is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with

that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations, your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

12. GOOGLE ANALYTICS

We use the web analytics service Google Analytics from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; 'Google') on our website.

The data processing serves the purpose of analyzing this website and its visitors as well as for marketing and advertising purposes. For this purpose, Google will use the information obtained on our behalf as the operator of this website to evaluate your use of the website, to compile reports on website activity and to provide us with other services related to website activity and internet usage.

12.1 Data Collection

The following information, among others, can be collected: IP address, date and time of the page view, click path, information about the browser you are using and the device you are using (device), pages visited, referrer URL (website from which you accessed our website) and location data. The IP address of your browser transmitted by Google Analytics is not linked to any other Google data.

Google Analytics uses technologies such as cookies, web storage in the browser and tracking pixels, which enable an analysis of your use of the website. The information about your use of our website generated by the Google Analytics cookies is normally transmitted to a Google server in the USA and stored there. There is no adequacy decision by the EU Commission for the USA. The data transmission takes place e.g., on the basis of standard contractual clauses as appropriate guarantees for the protection of personal data and is available at: https://policies.google.com/privacy/frameworks and https://business.safety.google/adsprocessorterms/.

Both Google and US government agencies have access to your data. Your data may be linked by Google with other data, such as your search history, your personal accounts, your usage data from other devices and any other data that Google has about you.

12.2 Data Processing and IP Anonymization

IP anonymization is automatically activated on this website. However, when you activate IP anonymization on our website, Google shortens your IP address within the Member States of the European Union or in other countries that are parties to the European Marketing Area Treaty. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

Cookies or comparable technologies are used with your consent on the basis of § 25 (1) TTDSG in conjunction with Art. 6 (1) (a) GDPR. Your personal data will be processed with your consent on the basis of Art. 6 (1) (a) GDPR. You can revoke your consent at any time without affecting the legality of the processing carried out on the basis of the consent up to the revocation.

You can find more information on terms of use and data protection at:

https://marketingplatform.google.com/about/analytics/terms/us/

https://policies.google.com/?hl=en&gl=US

https://policies.google.com/technologies/cookies?hl=en.

Our website also uses Google Analytics reports for performance, based on demographic characteristics and interests as well as reports to impressions in the Google Display Network. You may deactivate Google Analytics for display advertising and set the displays in the Google Display Network by accessing the personalized display settings under this link: https://adssettings.google.us/anonymous?hl=us.

12.3 Tag Manager

This website uses Google Tag Manager.

Google is a group of companies and consists of the companies Google Ireland Ltd. (provider of the service), Gordon House, Barrow Street, Dublin 4, Ireland and Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA and other affiliated companies of Google LLC.

This service allows you to administer so-called website tags centrally via an interface. Google Tag Manager implements only tags. No cookies are used and no personal data is collected. Google has a privacy policy for such data collection by third-party providers: https://marketingplatform.google.com/intl/de/about/analytics/tag-manager/use-policy/. However, Google Tag Manager does not access this data. If certain domains/websites or cookies were deactivated, it remains in place for all tracking tags provided that they are implemented using Google Tag Manager.

13. CHILDREN'S PRIVACY

Polaris is not aimed at persons under 16. If you are a parent or guardian and you become aware that your child has provided us with personal data without your consent, please contact us.

14. INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the UK or other countries or jurisdictions outside the UK where Holistic AI Inc. has facilities. By using Holistic AI Inc., you are permitting and consenting to the transfer of information, including Personal Data, outside of the UK.

Some of our third-party service providers may be located in countries outside of the European Economic Area (EEA) that do not provide the same level of protection for personal data as the GDPR. In these cases, we will ensure that appropriate safeguards are in place to protect your Personal Data, such as EU Standard Contractual Clauses or certification under the EU-U.S. Privacy Shield Framework.

15. UPDATES TO THE POLICY & NOTIFICATION

We keep our Privacy Policy under review and will place any updates on this webpage. We will also notify users of policy changes via the email address they provided. This version is dated 17 August 2023.

By using Holistic AI Inc., you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Holistic AI Inc. will constitute your express acceptance of any modifications to this Privacy Policy.

16. CONTACT FOR PRIVACY CONCERNS

For privacy-related questions or concerns, please contact us at we@holisticai.com.