Effective date: January 10th, 2024

A Polser Inc. (“Polser”) is committed to raising awareness among users (“User” or “You”) of the Polser application (“Polser App”) regarding the collection and use of their information during the use of the Polser App. Therefore, we present our privacy policy (“Privacy Policy”), which aims to provide clear and accurate information to Users about the processing of personal data carried out by Polser within its Polser App.


Personal Data Collected in the Polser App

We collect the following information during your use of the Polser App:

Registration Information. Our services require the User to have an account. When registering, we collect your (i) email address for communication with the user, personalized experience in the application and partner flows, sending important information, purchase receipts, and notifying about news and promotions, (iii) contact phone number to validate the mobile device in the App, to improve security against fraud in the use of the application on the mobile device and for communication with the user, sending important information, and notifying about news and promotions.

Transaction Information Sent by Polser Partners. In addition to the information collected by the Polser App itself, we may process some information that we automatically receive from Polser Partners whenever using the Polser app features, such as user consumption or usage history.

Other Information. For better navigation in the Polser App, to improve security against fraud, and to offer personalized products/services, we may also collect specific information about the mobile devices accessing our Polser App. Thus, we may receive information about the brand and model of the device, the operating system used, device fingerprint, among others.

Purpose of Use of Collected Personal Data

The personal data collected by Polser is processed for the following purposes:

Validate the mobile device to ensure the security of the app’s use on that device;

Improve security against fraud;

Register the User in the Polser App so that the User can enjoy the products and services offered there;

Build a personalized experience in the application and the relationship with partners;

Process User orders and requests;

Intermediary the relationship between the User and its commercial partners by sharing information with partners involved in the provision of services or supply of products requested by the User;

Contact Users to inform them about the processing of their requests, changes in the Polser App, or documents governing their relationship with us, as well as to inform them about offers of Polser or its commercial partners;

Improve or facilitate services offered through our Polser App;

Develop internal studies about the interests, behaviors, and demographics of Users to better understand their personal preferences to enhance and customize their experience in using Polser App;

Classify and group User information, as well as consolidate statistical data about them, including defining the composition of the User base of the Polser App and the traffic volume on our server.

Sharing of Personal Data with Third Parties

Polser may share your personal information with third parties, commercial partners, or other companies in the same economic group, to enable the use of the Polser App by Users, processing transactions, and improving the User experience. Such sharing occurs primarily based on the following criteria and for the purposes described below.

Service Providers. These companies work with Polser to enable the use of the Polser App, improve it, and assist in managing services. Examples include (i) technology services, (ii) user support, (iii) product feature improvements, among others. These providers receive your information for the specific purpose of providing services to Polser and do not have any rights to use your information outside of these cases.

Commercial Partners. Registration information may be shared with Polser’s commercial partners offering their products or services in the Polser App, for processing and completing any technology services, as well as improving the User experience.

New Businesses. In the ongoing development of our business, processes of acquiring and merging companies, subsidiaries, and other businesses may occur. In this business transfer, personal data and other information from respective Users may also be shared.

In addition, by using our Polser App, you are aware that your personal data may be shared with third parties located in other countries that may not be subject to data protection laws similar to those in Europe. We may share your personal information (i) with our group companies or any entity that acquires any part of our business; (ii) with our service providers (including, for example, suppliers who develop or host our Polser App), among others.


Your Rights

Users have rights regarding their personal data, including:

Confirmation of the existence of personal data processing. Upon the User’s request through the Support Channel (support@polser.io), Polser will confirm the existence of personal data processing, in accordance with applicable law.

Access to Personal Data. The User may request access to their personal data collected and stored by Polser through the Support Channel.

Correction of incomplete, inaccurate, or outdated data. The User may, at any time, change and edit their personal data by logging into their account or through the Support Channel.

Information about shared data usage. Information about the sharing of personal data is found in this Privacy Policy. Polser is available to the User for additional clarification through the Support Channel.

Review of automated decision-making. The User may request a review of decisions made solely based on automated processing of personal data that affect their interests, including decisions aimed at defining their personal, professional, consumption, and credit profile or aspects of their personality through the Support Channel.

Deletion of personal data. The User may request the deletion of personal data collected by Polser through the Support Channel. The deletion of personal data can only be complete for personal data that is not necessary for Polser to comply with legal, contractual obligations

Revocation of Consent. The User may revoke the consent given to Polser for the processing of their personal data for certain purposes at any time, through a free and facilitated manifestation, via the Support Channel. It is important to note that treatments carried out before the revocation of consent are ratified, and the revocation request will not imply the deletion of previously processed personal data that is maintained by Polser based on other legal grounds.


Personal Data Protection

We adopt appropriate practices for the collection, storage, and processing, as well as security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data.

Links to Third-Party Sites

We may provide links to other websites on the Internet. POLSER IS NOT RESPONSIBLE FOR THESE WEBSITES AND CONTENT, AND ALSO DOES NOT SHARE, SUBSCRIBE, MONITOR, VALIDATE, OR ACCEPT HOW THESE WEBSITES OR CONTENT STORAGE TOOLS COLLECT, PROCESS, AND TRANSFER YOUR PERSONAL INFORMATION. We recommend that you consult the respective privacy policies of such websites to be adequately informed about the use of your personal information.


Messages via SMS, Whatsapp or Email

Polser reserves the right to send emails, SMS, push notifications, and/or WhatsApp to Users with promotions, product updates and other relevant information about Polser, which can be disabled by the User during registration or later, as mentioned below. In order to improve the relevance of our communication, we receive a notification when our emails are opened if this functionality is available on the User’s computer.

Regarding received emails, it is important to check the content of the entire email before accessing any internet address or clicking on any link. Be cautious of emails with suspicious headers and sender fields or strange content, messages with language errors, or even photographs and logos with flaws.

Polser alerts all Users that it will never send text messages or emails requesting confirmation of data, with attachments that can be executed (extensions: .exe, .com, among others), or with links for potential downloads.

Polser will not request any personal information via SMS. Therefore, Polser is not responsible for any fraudulent electronic communications that collect your personal data (phishing).

Changes to the Privacy Policy

We may update this Privacy Policy at any time. When we do, we will change the updated date at the top of this page. We recommend that Users frequently check this page for any changes and stay informed about how we are helping protect the personal information we collect. You acknowledge and agree that it is your responsibility to periodically review this Privacy Policy and become aware of modifications. In relevant situations, especially in the event of a modification of the purposes for which the data has been collected, the User will be informed of the changes.

The continued use of the Application after the publication of changes to this Privacy Policy will be considered your acceptance of these changes.

Identification of the Controller and the Data Protection Officer

POLSER INC., a Delaware corporation is the controller of customers’ personal data processed under this privacy policy.

If you have any doubts, visit the website https://polser.io/connect-with-us/, or contact Polser via Support Channel through the email support@polser.io.

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