Privacy Policy

Here at Polytag Limited, we are committed to protecting and respecting the privacy of your personal data. This privacy notice explains how your data is collected, used, transferred, and disclosed. It applies to data collected when you:

• Use our websites
• Use our iOS and Android applications
• Interact with us through social media, email, or phone
• Participate in our competitions or events

We take the protection of your personal data seriously and will process your personal data fairly, lawfully, and transparently. This privacy notice describes the personal data we are collecting about you and how it is used. We will only collect and use your personal data for the following purposes:

• To fulfill your order(s)
• To keep you up to date with the latest offers and trends
• To help us make our marketing more relevant to you and your interests
• To improve our services
• To meet our legal responsibilities

Polytag Limited is the data controller for the personal data described in this privacy notice. If you have a question about it, or want to exercise your rights, email us at info@polytag.io.

Polytag Limited is a company registered in England and Wales (company number 11188703). Our registered office is Unit 13a Deeside Industrial Estate (Zone 1 Central), Drome Road, Deeside, Flintshire, Wales, CH5 2LR.

We have appropriate organisational safeguards and security measures in place to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved. We require any third party who is contracted to process your personal data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law. In the unfortunate event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so.

Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information have been removed. The following groups of personal data are collected:

• Identity Data includes information such as: first name, last name, title, date of birth (optional), occupation, personal description, photo and gender.
• Contact Data includes information such as: email address, delivery address, location, country, telephone number, loyalty programme membership number, and social media id (if you log in by social media).
• Transaction Data includes information such as: details of your product number; payments to and from you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your details of any rewards and bonuses awarded.
• Account information includes information such as: login name and password chosen by you, and details of the products and services added to your brand account.
• Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Usage Data includes information such as: how and when you use our website/app, how you moved around it, what you searched for; website/app performance statistics, traffic, location, weblogs and other communication data; loyalty programme activities; and details of any other products and services used by you.
• Marketing and Communications Data includes information such as: your preferences in receiving marketing.

What this website collects

• If you send us an enquiry through the contact form: your first and last name, email address, company and job title (if you give them), your message, the type of enquiry you chose, whether you ticked the newsletter box, and the page you sent it from.
• A record of your cookie choices at the moment you send an enquiry, and the exact consent wording shown to you.
• The campaign details of the page you sent the enquiry from (such as UTM tags, an advertising click ID and the website that referred you). If you have allowed marketing cookies, we also include the first and latest campaign details we stored on your earlier visits.
• A keyed, one-way hash of your IP address, used only to limit repeated or automated form submissions. We do not store the IP address itself and do not send it to HubSpot.
• If you have allowed analytics cookies: how you use the website, such as the pages you view and how you found us (Google Analytics).
• If you have allowed marketing cookies: pages you view and device details, collected by HubSpot, and the campaign details stored in our own attribution cookie.
• Technical details of website errors, which our error-monitoring service is set up to collect without names, email addresses, cookies or form contents.

We may collect personal data about you in the following ways:

Direct interactions

You may give us your Identity, Contact, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide, for example, when you:

• Contact us with an enquiry or to report a problem (by phone, email, social media, or messaging service);
• When you log in to our website or app.

Automated technologies or interactions

As you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted. We collect this data by using cookies, server logs and other similar technologies. Please see the section ‘Cookies we use’ below for further details.

We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it. We will only collect personal data from you when:

• we have your consent to do so, or
• we need your personal data to perform a contract with you (for example, to provide customer support connected with an enquiry), or
• the processing is in our legitimate interests and not overridden by your rights, or
• we have a legal obligation to collect or disclose personal data from you.

Uses made of your personal data

Your personal data is used by us to support a range of different activities. These are listed in the table below together with the types of data used and the legal bases we rely on when processing them, including where appropriate, our legitimate interests. Please be aware that we may process your personal data using more than one lawful basis, depending on the specific activity involved. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity: To create an account and register you as a new customer (either directly or via social media).
Type of data: Identity, Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you

Purpose/Activity: To process and deliver your circular reward including: recording your transaction details; keeping you informed about the order status; process payments and refunds, collect money owed to us; and automated decision making to assist fraud prevention and detection.
Type of data: Identity, Account Contact, Financial, Transaction
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you, Necessary for our legitimate interests (for automated decision making we consider that fraud detection and prevention is in our legitimate interests to ensure that fraudulent transactors are unable to benefit from our services and in the legitimate interest of the public as a whole due to the impact of fraud on the consumer market; we also consider it a necessary element of entering into a contract with you that we are able to verify your identity and prevent fraud).

Purpose/Activity: To manage our relationship with you, including: providing you with any information, products and services that you request from us; notifying you about changes to our services, terms and conditions or privacy notice; asking you to leave a review or take a survey.
Type of data: Identity, Account, Contact, Profile, Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you, Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)

Purpose/Activity: To enable you to take part in a competition, event, survey, or receive a reward for transacting with us.
Type of data: Identity, Contact, Profile, Usage, Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products and services, to develop and grow our business), Where you have entered a competition or event,for the performance of a contract

Purpose/Activity: To administer, protect and improve our business and our website/app, including: troubleshooting, data analysis, testing, system maintenance, support, data analysis, reporting and hosting of data; setting default options for you, such as language and currency.
Type of data: Identity, Account, Contact, Profile, Technical, Transaction, Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to detect and prevent fraud), Necessary to comply with a legal obligation

Purpose/Activity: To deliver relevant website content, online advertisements and information for you; and measure the effectiveness of the advertising provided.
Type of data: Identity, Account, Contact, Profile, Technical, Usage, Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity: To use data analytics to: improve our website, products, services, marketing, customer relationships and experiences; and for market research, statistical and survey purposes.
Type of data: Technical, Usage
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity: To recommend products, services, discounts and offers that may be of interest to you, including to send you such information by email, post or SMS.
Type of data: Identity, Contact, Profile, Technical, Usage, Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products and services and grow our business) or Consent. See further details in the section ‘Marketing preferences, adverts and cookies’

Purpose/Activity: To inform or remind you by email of any task carried out via our website/app which remains uncompleted.
Type of data: Identity, Contact, Usage
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate experience of our customers

Purpose/Activity: To protect our customers, group companies and website from fraud and theft
Type of data: Identity, Contact, Profile
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to detect and prevent fraud)

Purpose/Activity: To receive, answer and keep a record of enquiries sent through our website contact form, and to pass them to our customer-relationship system (HubSpot).
Type of data: Identity, Contact, enquiry details (company, job title, message, enquiry type), page submitted from
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to respond to people who contact us and to run our sales and partnerships) or, where you ask us about a service, steps taken at your request before entering a contract

Purpose/Activity: To send you Polytag news and insights where you tick the newsletter box on the contact form.
Type of data: Identity, Contact, Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Consent (the box is never pre-ticked; you can withdraw at any time)

Purpose/Activity: To measure how the website is used, with Google Analytics.
Type of data: Technical, Usage
Lawful basis for processing including basis of legitimate interest: Consent (analytics cookies)

Purpose/Activity: To understand which campaigns and sources bring visitors and enquiries, with HubSpot tracking and our own attribution cookie.
Type of data: Technical, Usage, campaign details (UTM tags, click IDs, referrer, landing page)
Lawful basis for processing including basis of legitimate interest: Consent (marketing cookies). Campaign details of the page you send an enquiry from are part of that request and are kept whether or not you accepted marketing cookies, under our legitimate interests (to understand what prompts enquiries)

Purpose/Activity: To find and fix errors on the website, with Sentry.
Type of data: Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to keep the website secure and working)

Purpose/Activity: To keep the contact form secure and limit repeated or automated submissions.
Type of data: Technical (a hashed form of your IP address)
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to prevent abuse and spam)

Purpose/Activity: To remember your cookie choices.
Type of data: Technical (your cookie choices and when you made them)
Lawful basis for processing including basis of legitimate interest: Strictly necessary to provide the cookie settings you ask for, and to meet our legal obligations on cookies

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 we wish 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. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law.

We will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request.

• Enquiries sent through the contact form are stored in our website database and in HubSpot. We keep them for as long as needed to handle your enquiry and any follow-up relationship, and delete them when they are no longer needed or when you ask us to.
• The hashed IP address kept with an enquiry is used for rate limiting only; submissions from the last 24 hours are counted. It is deleted with the enquiry.
• Cookies last for the periods in the cookie list under ‘Cookies we use’. Your cookie choice is remembered for 180 days, after which we ask you again.
• Google Analytics keeps data for the period set in our Google Analytics account.
• Error reports are kept by Sentry for the period set in our Sentry plan.

Marketing Preferences, Adverts, and Cookies

We may send you marketing communications and promotional offers:

• If you have opened an account with us or registered for a promotion or event, and you have not opted out of receiving that marketing (in accordance with your preferences, as explained below);
• By email, if you have signed up for email newsletters;
• If you have provided us with your details when you entered a competition and have consented to receiving such marketing (in accordance with your preferences, as explained below).

We may use your Identity, Contact, Technical, Transactional, Usage, Profile Data, and Marketing and Communications Data to form a view on what we think you may like or what may be of interest to you and send you details of products and offers that may be relevant to you.

We will ask you for your preferences in relation to receiving marketing communications by email, post, SMS, and other communication channels. From time to time, we may also include with your transactions inserts advertising goods, services, or offers from other third-party companies that may interest you.

In respect of third-party marketing communications, we will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us (or any third party, if applicable) at any time:

• You can unsubscribe or ‘opt-out’ by using the unsubscribe button and following the link included in the footer of any marketing email; or
• Account holders may withdraw their consent by simply logging into "My Account" and editing your ‘Contact Preferences’.

We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers, it may take a few days for any opt-out request to be implemented.

Cookies

Our website uses cookies to distinguish you from other users and to keep track of your visits. Cookies help us provide you with the best experience when browsing our website and making improvements. They also assist us and our advertising networks in making advertising relevant to you and your interests.

You can set your browser to refuse all or some browser cookies or alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly.

For detailed information on the cookies we and our third-party providers use and why we use them, please see the section ‘Cookies we use’ of this notice.

Cookies are small text files stored on your device. This website sets only the cookies it needs to work until you choose otherwise: nothing for analytics or marketing is set, and no analytics or marketing service is loaded, before you say yes.

Categories

• Necessary: remember your cookie choices. They do not need your consent.
• Analytics: Google Analytics, loaded only if you accept analytics cookies.
• Marketing: HubSpot tracking and our own campaign-attribution cookie, loaded or set only if you accept marketing cookies.

Cookies on this website

Cookie: polytag_consent
Provider: Polytag (first party)
Purpose: Remembers your cookie choices: analytics yes or no, marketing yes or no, the version of this policy and when you chose.
Category: Necessary
Duration: 180 days
Consent required: No

Cookie: polytag_attribution
Provider: Polytag (first party)
Purpose: Records where you came from on your first and latest visit: UTM campaign tags, advertising click IDs, the website that referred you (without its query string) and the page you landed on. Attached to an enquiry if you send one.
Category: Marketing
Duration: 90 days
Consent required: Yes (marketing)

Cookie: _ga
Provider: Google
Purpose: Tells Google Analytics apart one visitor from another so it can count visits and pages.
Category: Analytics
Duration: 2 years
Consent required: Yes (analytics)

Cookie: _ga_<container-id>
Provider: Google
Purpose: Keeps the state of a Google Analytics session.
Category: Analytics
Duration: 2 years
Consent required: Yes (analytics)

Cookie: hubspotutk
Provider: HubSpot
Purpose: Identifies you as a visitor so HubSpot can link your visits to an enquiry you send.
Category: Marketing
Duration: 6 months
Consent required: Yes (marketing)

Cookie: __hstc
Provider: HubSpot
Purpose: HubSpot’s main tracking cookie: visitor identity, first, latest and current visit times, and number of visits.
Category: Marketing
Duration: 6 months
Consent required: Yes (marketing)

Cookie: __hssc
Provider: HubSpot
Purpose: Keeps track of the current browsing session and counts page views within it.
Category: Marketing
Duration: 30 minutes
Consent required: Yes (marketing)

Cookie: __hssrc
Provider: HubSpot
Purpose: Detects whether you have restarted your browser, to help HubSpot start a new session.
Category: Marketing
Duration: Session (until you close your browser)
Consent required: Yes (marketing)

Cookie: messagesUtk
Provider: HubSpot
Purpose: Recognises you if you use a HubSpot chat widget. Set only if chat is switched on.
Category: Marketing
Duration: 6 months
Consent required: Yes (marketing)

If you allow marketing cookies, Google Analytics also runs with Google’s advertising storage switched on, and Google may set advertising cookies of its own. If you allow analytics but not marketing, it runs with advertising storage switched off.

Our content-management system sets a sign-in cookie for Polytag staff only. Visitors never receive it.

The vendors’ own cookie lists are at Google and HubSpot.

How to change your cookie choices

When you first visit, a banner lets you accept all, reject all, or manage cookies by category. Rejecting is as easy as accepting. To change your mind at any time, use the ‘Cookie settings’ link at the bottom of every page to reopen the settings dialog. If you withdraw consent, we delete the cookies we can for that category and reload the page. We ask again if this policy changes materially, and in any case after 180 days.

Withdrawing consent does not remove data already collected: to ask us to delete data we hold in HubSpot or elsewhere, see ‘Your Rights’. You can also set your browser to block or delete cookies, as described in ‘Marketing Preferences, Adverts, and Cookies’ above.

We may disclose and share your personal data with the parties set out below:

• Business partners, suppliers, sub-contractors, and other third parties we use in connection with running our business, such as:
  • Third-party service providers that we engage to provide IT systems, software, and to host our website and app;
  • Analytics and search engine providers that assist us in improving and optimising our website;
• Any third party to whom we may choose to sell, transfer, or merge parts of our business or assets. If a change occurs in our business, the new owners may use your personal data as described in this privacy notice;
• If we are under a duty to disclose or share your personal data to comply with legal obligations;
• Our professional advisers, including lawyers, bankers, auditors, and insurers who provide consultancy, legal, and insurance services.

The services below process personal data for us, or on our behalf, through this website. Each has its own privacy notice, linked below. Fonts on this website are served from our own servers, not from Google Fonts.

Google Analytics 4

Purpose: To measure how the website is used: pages viewed, how visitors found us, and approximate location and device.
Lawful basis: Consent (analytics cookies). Google Analytics does not load until you accept.
Data shared: Page views, device and browser details, approximate location, referrer, and the identifier in the _ga cookies.
Location and transfers: Google processes data in the United States and other countries; it publishes the safeguards it relies on in its privacy notice.
Privacy notice: Google Privacy Policy

HubSpot

Purpose: To receive and manage the enquiries you send, to send newsletters you ask for, and (with your consent) to understand how visits lead to enquiries.
Lawful basis: Enquiries: our legitimate interests, or steps at your request before a contract. Newsletter and tracking: consent.
Data shared: Enquiry form: name, email, company, job title, message, enquiry type, the page (without its query string) and page title, your newsletter choice and the consent wording shown, and campaign details. With marketing cookies: the hubspotutk cookie value, plus the pages you view, device and browser details and IP address collected by HubSpot’s tracking code. We do not send your IP address from our own servers.
Location and transfers: Our HubSpot account uses HubSpot’s EU data centre. HubSpot is part of a US-headquartered group and publishes the safeguards it relies on for transfers in its privacy notice.
Privacy notice: HubSpot Privacy Policy

Sentry

Purpose: To find and fix errors and keep the website secure and working.
Lawful basis: Our legitimate interests. We set Sentry up to collect no personal data, so it does not use cookies or ask for consent.
Data shared: Error messages and technical traces, the page address (with sensitive values and email addresses removed), browser and device type, and a small sample of performance timings. Not collected: names, email addresses, cookies, form contents or session recordings.
Location and transfers: Reports are sent through our own website to Sentry’s EU service. Sentry is a US company and publishes the safeguards it relies on in its privacy notice.
Privacy notice: Sentry Privacy Policy

Vercel

Purpose: To host and deliver the website and store its images and files.
Lawful basis: Our legitimate interests (running and securing the website).
Data shared: Standard server and network logs: IP address, the page requested, browser and device details and time of request. We do not use Vercel Analytics or Speed Insights.
Location and transfers: Website code runs in London; Vercel’s network delivers pages from locations worldwide. Vercel is a US company and publishes the safeguards it relies on in its privacy notice.
Privacy notice: Vercel Privacy Policy

Neon

Purpose: To host the database that holds website content and the enquiries you send us.
Lawful basis: As for enquiries: our legitimate interests, or steps at your request before a contract.
Data shared: Enquiry details and the other data described under ‘What this website collects’.
Location and transfers: The database is hosted in London (AWS eu-west-2). Neon is a US company and publishes the safeguards it relies on in its privacy notice.
Privacy notice: Neon Privacy Policy

YouTube

Purpose: To play videos embedded on some pages.
Lawful basis: Our legitimate interests (showing a video preview); your action in pressing play for the player.
Data shared: Videos use YouTube’s privacy-enhanced mode (youtube-nocookie.com) and only load after you press play. Before that, a preview image may be requested from Google’s servers, which reveals your IP address to Google. After you press play, Google may collect data as described in its privacy notice.
Location and transfers: Google processes data in the United States and other countries; it publishes the safeguards it relies on in its privacy notice.
Privacy notice: Google Privacy Policy

The personal data we collect from you may be transferred to and stored at destinations outside the European Economic Area (“EEA”) using legally-provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in processing and providing support services.

We will take all necessary steps to ensure your data is treated securely and in accordance with this privacy notice. Whenever we transfer personal data outside the EEA, we will ensure a similar degree of protection by ensuring appropriate safeguards, as required by law, are in place. This may include using specific contractual clauses approved by the European Commission. More information about these is available here.

In particular, Google, HubSpot, Sentry and Vercel are part of groups headquartered in the United States. Where they process your data outside the UK and EEA, they rely on safeguards such as the UK and EU–US data privacy frameworks or standard contractual clauses, which each describes in its own privacy notice (linked under ‘Third Parties We Use’).

Please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your data outside the EEA.

You have several rights under data privacy legislation. This includes, under certain circumstances, the right to:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Request restriction of processing of your personal data
• Request the transfer of your personal data
• Object to the processing of your personal data
• Request human intervention for automated decision-making
• Withdraw your consent at any time, where we rely on it (use ‘Cookie settings’ at the bottom of any page, or the unsubscribe link in an email)

For further information or to exercise your rights, please email us at info@polytag.io.

You also have the right to complain to the UK Information Commissioner’s Office. Details are at ico.org.uk.