PRIVACY POLICY

Effective Date: January 5, 2024

This Privacy Policy (“Privacy Policy”) is issued by PolarLabs Technologies, Inc. (“PolarLabs”, “we”, “us”, and “our”) and applies to the Personal Data (as defined below) collected or processed when you use the Blinq mobile application (“Blinq”, the “app”, or the “application”), including activities such as downloading, installing, registering, accessing, or any other form of usage (collectively referred to as “Use”).

We present this Privacy Policy to clarify our methods for collecting, using, processing, and disclosing the Personal Data of Blinq users (“users”, “you”, or “your”). 

This policy informs you about your rights concerning your Personal Data and the choices you may have regarding it. By Personal Data, we refer to (i) information linked to an identified or identifiable individual, and (ii) information protected as personal data under relevant data protection laws.

This Privacy Policy governs Personal Data collected by us or any third parties, whether offline or on the app or our websites.

WE URGE YOU TO READ THIS PRIVACY POLICY CAREFULLY TO COMPREHEND OUR PRIVACY PRACTICES. IF YOU PREFER NOT TO HAVE YOUR PERSONAL DATA PROCESSED AS OUTLINED IN THIS PRIVACY POLICY, PLEASE REFRAIN FROM USING BLINQ.

If you have inquiries regarding this Privacy Policy, feel free to reach out to us at info@polarlabs.ai

Changes to this Privacy Policy

We may update or revise this Privacy Policy. The latest revision date is indicated at the top of the document. We'll notify you of significant changes through methods like email, in-app notifications, or updates to the policy date. Some changes may not require your consent, but for those that significantly impact your rights, we will seek separate consent.

We recommend regularly reviewing this policy to stay informed of how we protect your information.

Personal Data We Collect

Data Provided Directly by Users

You may directly provide Personal Data to us or our service providers when using Blinq. The nature of the data depends on how users interact with the App and its features:

• Photos: If you grant permission to access your camera or photo library, we process the photos you upload to Blinq for app functionalities.

• Account Information: Creating an account is not necessary to Use some of our features. If you opt to create an account using your e-mail, we receive your e-mail address. If you log in via Apple ID or Google Account, we may receive corresponding email addresses based on your account settings.

• Correspondence Data: Any communication with us, including inquiries, will involve collecting the relevant contact details you provide.

  
  

Data Collected Automatically

When using Blinq, PolarLabs or authorized third parties automatically collect certain information, subject to your consent where required:

• Device Information: Includes details about your mobile device, such as IP address, unique device identifier, operating system, mobile network, and device language.

• App and Country Information: The version of Blinq you Use and the country version of the app store where it was downloaded.

• Usage Details: Frequency of app Use, accessed areas and features, and engagement with specific functionalities.

• In-App Purchases and Subscription Data: Details about purchases within the app, including time and nature of purchases, subscription details, and redacted cardholder data (excluding full card details).

• Advertising IDs: If consented, we collect IDFA or Android Advertising ID, which you can disable following provided instructions.

  
  

Data Collected from Third Parties

PolarLabs and our service providers, vendors, and partners, including third parties, use technologies like cookies and SDKs to collect information:

• Analytics Tools: Tools like Google Firebase, and Mixpanel help measure app usage. These collect data on feature interaction, subscription information, and actions within Blinq.

• Interest-Based Advertising: We may partner with ad networks to provide personalized ads based on information collected over time. This includes relationships among different browsers and devices.

• User Choices: Users can limit tracking technologies through browser or device settings, and opt out of interest-based advertising via organizations like the DAA or NAI. Opting out may affect app functionality and ad personalization.

  
  

Your choices regarding these technologies are typically specific to each device and browser. We are not liable for the practices of external websites or services linked to or from the app. This includes their management of information and content. We advise you to review the privacy policies of these external sites or services before engaging or providing personal information.

How We Process Your Personal Data 

We use your Personal Data for various purposes, depending on its type and your interaction with the app:

• Service Delivery: To offer you Blinq's features and functionalities. This processing is based on our contractual obligations or your explicit consent.

• Contractual Obligations: To fulfill our obligations and enforce rights under any contract with you, including our Terms of Service. This is vital for our legitimate interests in contract performance and defense against claims.

• Personalization: To tailor our products and services, such as customized pricing and discounts, using automated decisions based on device data. Consent is sought where required by law, with opt-out options provided.

• Support Services: To offer customer and technical support, address inquiries, and improve response quality. Providing high-quality support aligns with our legitimate interests.

• Communication: To inform you about app updates, account notices, and other service-related information, including through in-app or push notifications (with an option to opt-out).

• Research and Analytics: To conduct research and analyze metrics related to app usage, enhancing our understanding and improvement of our product. Consent is relied upon where necessary.

• Product Improvement: To test and enhance app’s effectiveness, understanding our product and business metrics as part of our legitimate interests.

• Personalized Advertising: To deliver personalized content and advertising, including building targeted advertising audiences. Consent is obtained where required by law, with opt-out options available.

• Marketing Communications: To send promotional messages via email, push notifications, or in-app messaging, based on your consent or as permitted by law.

• Legal Compliance: As required or permitted by law, including for auditing, fraud, and security purposes

• Other Purposes: As described at the point of data collection or as directed by you or your consent.

Recipients of Your Data

We may share your Personal Data collected through the app with certain third parties under specific conditions:

• Business Operations and Service Providers:

  • We share data with third parties involved in our business operations, acting either as data processors (like IT and storage service providers) or autonomous data controllers.

  • We use cloud providers such as Amazon Web Services (USA) for data storage, and for hosting analytics data.

  • Email delivery services and other essential business partners may also access your data.

• Subsidiaries and Affiliates:

  • PriorLabs Teknoloji A.Ş. based in Turkey acts as our data processor and may perform data processing on our behalf.

• Advertising and Analytics:

  • With your consent, we may share data with or allow access to third-party analytics providers and advertising partners.

• Corporate Transactions:

  • In events like mergers, acquisitions, restructurings, or asset sales, your Personal Data may be transferred as part of the transaction.

• Legal and Safety Obligations:

  • We may disclose data in response to legal, governmental, or regulatory requests if we believe it's legally required.

  • For fraud prevention, protecting rights, or addressing security concerns, we may share information as necessary.

• User Consent:

  • We may also share your data if you provide explicit consent for specific scenarios.

WE DO NOT SELL YOUR DATA, INCLUDING IMAGES, TO THIRD PARTIES. OUR SHARING IS GUIDED BY LAWFUL GROUNDS AND YOUR CONSENT WHERE REQUIRED.

Data Security

We are committed to safeguarding your Personal Data in the app with reasonable and appropriate security measures. Our aim is to protect your data from accidental loss and from unauthorized access, use, alteration, and disclosure.

Key Points of Our Data Security Approach:

• Robust Safeguards: We implement robust information security safeguards to maintain the integrity and privacy of your data.

• User Responsibility: The security of your Personal Data also depends on you. For example, we are not liable for the way you choose to share information, like photos or videos, from your Blinq account on social media or other platforms.

• Continuous Vigilance: We continually monitor and update our security practices to address emerging threats and vulnerabilities.

• User Awareness: We encourage users to be mindful of their own security practices, especially in how they handle and share their personal information.

Risks:

• Risk of Online Transmission: We acknowledge the inherent risks of data transmission over the internet. Despite our best efforts to secure your data, complete security cannot be guaranteed.

• No Absolute Guarantee: It's important to recognize that no technology or security measure can provide absolute protection against all potential security breaches.By using Blinq, you acknowledge that the transmission of your Personal Data is at your own risk. While we strive to protect your information, we cannot eliminate all security risks. We are not responsible for bypassing any security measures implemented in the app.

Data Retention

We will store your Personal Data only for as long as is necessary for us to achieve the purposes set out in “How We Process Your Personal Data” section.  This means that our data retention periods will vary according to the reason for collection. Generally, your Personal Data will be kept for as long as you remain our user.

Notwithstanding the foregoing, please note that we may retain your Personal Data for longer.duration in certain circumstances. These include situations below:

• Privacy-Related Requests: We may retain data longer if it pertains to your privacy-related requests or communications with us.

• Legal Obligations: Compliance with legal obligations may necessitate longer data retention periods.

• Dispute Resolution: In instances of disputes, data may be retained for as long as necessary to resolve the issue.

• Enforcement of Agreements: To enforce our agreements, data retention might extend beyond standard timeframes.

Even if we delete some or all of your Personal Data, we may still retain and use data that has been anonymized and can no longer be linked to your personal identity.

Your Rights Regarding Your Personal Data and Your Communication Choices 

We acknowledge your rights concerning your Personal Data collected through the app and offer you choices regarding our communications.

Access, Modification, Correction, and Erasure:

• You can request access, modification, correction, update, erasure, or portability of your Personal Data by emailing us at info@polarlabs.ai

• You may also delete your account directly within the Blinq app, for both iOS and Android users.

• Note: We may not fulfill a request if it leads to the violation of laws or incorrect information.

Rights for EEA/UK Individuals:

• Access: You have the right to know if we hold your Personal Data and to obtain a copy.

• Rectification: You can ask us to correct incomplete or inaccurate Personal Data.

• Restriction of Processing: Request us to limit processing of your Personal Data.

• Erasure: You may ask us to erase your Personal Data in specific scenarios.

• Data Portability: In certain cases, request your data in a machine-readable format or transfer it to another party.

• Object to Processing: Object to our processing based on legitimate interest. This may affect your ability to Use the app.

• Withdraw Consent: You can withdraw your consent at any time for specific data processing.

• Complaint with Authority: You have the right to complain to a supervisory authority under the GDPR.

We will respond to your requests within one month, with a possible extension of two months for complex or numerous requests.

Communications from PolarLabs:

• Necessary Communications: We send essential communications, like subscription and security notices, as part of our contract or based on legitimate interest.

• Marketing Communications: We will seek your consent for promotional emails, in-app messages, and push notifications, unless otherwise permitted by law.

Opt-Out Options:

• Emails: Unsubscribe via the opt-out link in marketing emails or through app settings.

• Push Notifications: Opt-out via your mobile device settings.

Cross-border Data Transfer

We use Amazon Web Services for storing data collected through the app. Data storage is mainly set in the United States, but occasionally we may opt for the closest available location to your usage point to be able to provide a faster service.

Be aware that your Personal Data may be accessed by our service providers or our technical support team in various locations outside your local jurisdiction. These accesses may occur across different states, provinces, or countries, depending on operational requirements.

For international data transfers, particularly from the European Economic Area Switzerland or United Kingdom, we adhere to the established standards such as UK GDPR and EEA GDPR.

For more detailed information or inquiries about how we handle cross-border data transfers, please contact info@polarlabs.ai

Children

General Age Limitation:

BLINQ IS NOT INTENDED FOR OR DIRECTED AT INDIVIDUALS UNDER THE AGE OF 16. IF YOU ARE OVER THE AGE OF 16 BUT HAVE NOT REACHED THE LEGAL AGE OF MAJORITY IN YOUR JURISDICTION, YOUR USE OF THE APP MUST BE SUPERVISED AND CONSENTED TO BY YOUR PARENT OR GUARDIAN, WHO MUST REVIEW AND AGREE TO THESE TERMS ON YOUR BEHALF.

Age Limitation for European Economic Area (EEA), the United Kingdom (UK) or Switzerland:

We do not permit individuals under 18 from the EEA, the UK or Switzerland to use our Service.

If you are aware of any such usage by individuals younger than our age limit please contact us via email at info@polarlabs.ai, and we will take necessary actions, including deleting any information provided by these users.

California Residents: CCPA Disclosures and Rights

This section provides disclosures required by the California Consumer Privacy Act (“CCPA”) and applies to Personal Data of California residents.

California Children Under 16 and Advertising:

We do not target advertising to California residents under the age of 16. We do not knowingly collect information from California children under 16 for advertising purposes. If we are notified at info@polarlabs.ai that a California minor under 16 has provided Personal Data, we will take steps to delete it promptly.

Personal Data We Collect and Disclose for Business Purposes:

We collect categories of Personal Data from social networks, service providers, and directly from California consumers. This includes personal and online identifiers (username, email address, IP address), internet or network activity (advertisement interaction), geolocation information, and inferences about preferences. This information is used for business purposes as described in this Privacy Policy. We disclose this Personal Data to service providers, government entities, operating systems, platforms, and social networks for business purposes.

Your Rights Regarding Personal Data:

• Right to Know: You can request details about the Personal Data we collect, use, and disclose.

• Right to Deletion: You may request the deletion of your Personal Data.

• Right to Non-Discrimination: Exercise your CCPA rights without discriminatory treatment.

To exercise these rights, contact us at info@polarlabs.ai or through the provided address provided below. Verification of identity or authorization may be required, especially for requests via authorized agents.

Additional information may be requested to verify your identity or the scope of your request. You are not required to create an account to make or fulfill a CCPA request.

Data Controller and Contact Details

PolarLabs Technologies, Inc. is the data controller with registered offices at 50 Peter Kristof Way, Unit 306, Medfield, MA 02052 US.

If you have any questions about this Privacy Policy, Blinq or would like to contact our Data Protection Officer, please contact us via email at info@polarlabs.ai.