Polocam Limited (Polocam) respects your privacy and is committed to protecting your personal data. This privacy policy and terms of use informs you how we look after your personal data when you visit our website and how the law protects you.

Purpose

This policy explains how we collect and process your personal data through your use of our website, including any data you provide through this website when you provide any personal data. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. This privacy policy supplements any other notices and privacy policies issued by us from time to time and is not intended to override them.

Controller

Polocam is the data controller and is responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, please contact our data protection officer, Michael Esteves, at production@polocam.tv.

Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). Please contact us directly before contacting the ICO, however, so that we have an opportunity to resolve any issues.

Changes

We keep our privacy policy under regular review and it is subject to changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website might include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections might allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements.

Types of data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed and made anonymous. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together into the following non-exhaustive categories. Identity data includes without limitation first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Contact data includes without limitation billing address, delivery address, email address and telephone numbers. Financial data includes without limitation bank account and payment card details. Transaction data includes without limitation details about payments to and from you and other details of products and services you have purchased from us. Technical data includes without limitation internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Profile data includes without limitation your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Usage data includes without limitation information about how you use our website, products and services. Marketing and communications data includes without limitation your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you such as 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. We do not collect any information about criminal convictions and offences.

Where we film or sound record any interaction, event, match, training session or other activity which takes place on the premises of a polo club or is arranged by a polo club, that polo club is responsible for obtaining the express consent to the processing of the personal data of any person, including any child, whose personal data is processed by us.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In those circumstances, we may have to terminate any contract we have with you.

How is your personal data collected?

We use different methods to collect data from and about you including without limitation through filming, sound recording, direct interactions, automated technologies, third parties and information in the public domain.

How we use your personal data

We will use your personal data to perform a contract with you, where necessary for our legitimate interests or those of a third party and where required by law. You have the right to withdraw consent to marketing at any time by contacting us.

Promotional offers from us

We may use your personal data to decide what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We will not send you marketing communications if you have requested information from us or purchased goods or services from us and you have opted out of receiving those marketing communications.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can contact us to ask that we or third parties stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of entering into any transaction with us.

Cookies

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

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 would like 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 explain the legal basis which allows us to do so. We may process your personal data without your knowledge or consent where required or permitted by law.

International transfers

We may share your personal data within our company and this may involve transferring your data outside the UK. We will only transfer your personal data to countries which have been deemed to provide an adequate level of protection for personal data. Please contact us if you would like further information.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need for access. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it. We may retain your personal data for a longer period in the event of a complaint or if we consider that there is a reasonable prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You will not usually have to pay a fee to access your personal data or to exercise any of your other applicable rights. We may charge a reasonable fee or decline to comply with your request, however, if your request is unfounded, repetitive or excessive.

You have the right to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure. If applicable, we will notify you of this at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data where you would like us to establish the data's accuracy, our use of the data is unlawful but you do not want us to erase it, you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. If applicable, we will inform you of this at the time.

What we might need from you

We might need to request specific information from you to help us confirm your identity and ensure your 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 might also contact you to ask you for further information in relation to your request to speed up our response.

Time limit

We try to respond to all legitimate requests within one month. It could take us longer than this if your request is particularly complex or you have made multiple requests. In that case, we will notify you and keep you updated.