Legal
Privacy Policy
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Polele (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used and disclosed by Polele.
This Privacy Policy applies to our website, polele.co and its subdomains (including the online stores we host for merchants at yourname.polele.co), and to our applications, including Polele Studio (collectively, our “Service”). By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.
Definitions and key terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, they are strictly defined as:
- Cookie: a small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics and remember information about you such as your language preference or login information.
- Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to Polele SA, 2 Wamba, Punda, Ngaliema, Kinshasa, Democratic Republic of the Congo, which is responsible for your information under this Privacy Policy.
- Country: where Polele or the owners/founders of Polele are based, in this case the Democratic Republic of the Congo.
- Customer (or Merchant): the company, organization or person that signs up to use the Polele Service to sell to and manage the relationships with its own customers.
- End user: a person who buys from, books with or otherwise interacts with a Merchant through the Service, for example on a Merchant's online store.
- Device: any internet-connected device such as a phone, tablet or computer that can be used to visit Polele and use the Service.
- IP address: the number assigned to every device connected to the Internet. IP addresses are usually assigned in geographic blocks and can often be used to identify the location from which a device is connecting to the Internet.
- Personnel: individuals who are employed by Polele or are under contract to perform a service on behalf of one of the parties.
- Personal Data: any information that directly, indirectly, or in connection with other information, including a personal identification number, allows for the identification or identifiability of a natural person.
- Service: the service provided by Polele as described in our Terms of Service and on this platform.
- Third-party service: providers that help us operate the Service, and partners whose products or services we think may interest you.
- Website: Polele's site, which can be accessed via https://www.polele.co.
- You: a person or entity that uses the Service, whether as a Merchant, a member of a Merchant's team or an end user.
What information do we collect?
We collect information from you when you visit our website, create an account, open a store, place an order or booking, subscribe to a membership, contact us or fill out a form. Depending on how you use the Service, this may include:
- Name and username
- Phone numbers (including your WhatsApp number, used to sign in and to receive messages)
- Email addresses
- Delivery and mailing addresses
- Store information you publish, such as products, services, prices and photos
- Order, booking, membership and payment history
- Payment details needed to complete a payment, such as a Mobile Money number. Card details are entered with and processed by our card payment provider; we do not store full card numbers.
- Technical information such as IP address, device and browser type, and pages visited
How do we use the information we collect?
Any of the information we collect from you may be used in one of the following ways:
- To provide the Service: running stores, processing orders, bookings, memberships and payments, and sending receipts, confirmations and reminders
- To personalize your experience and better respond to your individual needs
- To improve our website and apps based on the information and feedback we receive from you
- To improve customer service and respond to your support requests
- To keep the Service secure and prevent fraud
- To administer a promotion, survey or other site feature
- To send periodic emails or messages about the Service
When does Polele use end user information?
Polele collects the end user data necessary to provide the Polele Service to our Merchants. For example, when you place an order on a Merchant's online store, we process your contact details and order so the Merchant can fulfil it and you can receive your receipt. The Merchant decides how it uses this information for its own business.
End users may voluntarily provide us with information they have made available on social media websites. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
When does Polele use information from third parties?
We receive some information from third parties when you contact us or sign in. For example, if you sign in with Google or Apple, we receive your name and email address from that provider, and payment providers tell us whether a payment succeeded. We also occasionally collect information that is made publicly available on social media websites.
How do we use your email address and phone number?
We use your email address and phone number to operate your account and to send you messages related to the Service, such as sign-in codes, receipts, booking confirmations and reminders. We only send marketing messages to people who have agreed to receive them, and you can opt out at any time using the unsubscribe option included in each message or by contacting us. We do not send unsolicited commercial emails.
Contact details submitted only to complete an order will be used for that order and its related messages.
How long do we keep your information?
We keep your information only as long as we need it to provide the Service to you and fulfil the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need your information and there is no need to keep it to comply with our legal or regulatory obligations, we either remove it from our systems or depersonalize it so that we can't identify you.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information. Data is transmitted over encrypted connections (HTTPS/TLS), and payment details are handled by our payment providers, which are required to keep them confidential. We do not keep full card numbers on file.
We take precautions to protect your information, with physical, electronic and managerial procedures to help safeguard it, prevent unauthorized access and use it correctly. However, no method of transmission or storage is completely secure. While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
Could my information be transferred to other countries?
Polele is incorporated in the Democratic Republic of the Congo. Our service providers may store and process information in other countries, which may not have the same data protection laws as your country. To the fullest extent allowed by applicable law, by using the Service you consent to the transfer and hosting of your information outside your country.
Can I update, correct or delete my information?
Merchants and their team members can update most of their information directly in Polele Studio. You can also contact us to (1) update or correct your personal information, (2) change your preferences regarding the communications you receive from us, or (3) delete your account and the personal information we maintain about you, subject to the information we must keep for legal, accounting or security reasons.
To protect your privacy and security, we may take reasonable steps to verify your identity before making changes. Because of backups, a copy of your information may remain for a limited time in our backup systems before it is deleted.
If you are an end user and wish to update, delete or receive the information a Merchant holds about you, please contact that Merchant. We will help the Merchant respond to your request.
Personnel
If you are a Polele worker or applicant, we collect the information you voluntarily provide to us and use it for human resources purposes, such as administering benefits and screening applicants. You may contact us to update or correct your information, change your communication preferences or receive a record of the information we hold about you.
Sale of business and affiliates
We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Polele or any of its Corporate Affiliates, or that portion of Polele to which the Service relates, or if we discontinue our business or are subject to bankruptcy, reorganization or a similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.
We may disclose information about you to our Corporate Affiliates, meaning any person or entity which directly or indirectly controls, is controlled by or is under common control with Polele. Any information we provide to our Corporate Affiliates will be treated in accordance with this Privacy Policy.
Children's privacy
The Service is intended for businesses and adults and is not directed at children under 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us and we will take steps to remove that information.
Links and third-party services
The Service may contain links to, or display content from, websites and services not operated or controlled by Polele, including Merchants' own links and social media pages. We are not responsible for the content or privacy practices of those websites and services. When you leave the Service, your browsing and interaction on any other website is subject to that website's own rules and policies.
Information for people in the European Economic Area (GDPR)
If you are in the European Economic Area, the General Data Protection Regulation (GDPR) gives you rights over your personal data. We treat its principles as our baseline standard for everyone, wherever they are located:
- Personal data is processed in a fair, lawful and transparent way, only as a person would reasonably expect.
- Personal data is collected for a specific purpose and used only for that purpose.
- Personal data is kept no longer than necessary to fulfil its purpose.
- You can access your personal data, request a copy, and ask for it to be updated, deleted, restricted or moved to another organization.
We process personal data on the basis of providing the Service you requested (contract), our legitimate interests in running and improving the Service, your consent where required, and our legal obligations. We store conversation and personal data for up to 6 years unless your account is deleted. When you delete your account, we dispose of your data in accordance with our Terms of Service and this Privacy Policy, and we will not hold it longer than 60 days, except where we must keep it longer for legal reasons.
California residents (CCPA and CalOPPA)
The California Consumer Privacy Act (CCPA) and the California Online Privacy Protection Act (CalOPPA) require us to disclose the categories of personal information we collect, how we use it, the sources we collect it from and the third parties we share it with, which we have explained above. California residents have the following rights:
- Right to know and access: you may request the categories and specific pieces of personal information we have collected, used or shared, the purposes, and the sources.
- Right to delete: you may request that we close your account and delete the personal information we have collected about you.
- Right to equal service: we will not discriminate against you for exercising your privacy rights.
- Right to opt out of sale: we do not sell the personal information of our users.
If you make a request, we have one month to respond. To exercise any of these rights, please contact us.
Governing law
This Privacy Policy is governed by the laws of the Democratic Republic of the Congo, without regard to its conflict of laws provisions. Your use of the Service may also be subject to other local, national or international laws.
Your consent and changes to this policy
By using the Service, you consent to this Privacy Policy. We may update it to reflect changes to the Service or the law. Unless otherwise required by law, we will notify you, for example through the Service, before significant changes take effect. If you continue to use the Service after an update, you accept the updated Privacy Policy. If you do not agree, you can delete your account.
Contact us
Don't hesitate to contact us if you have any questions about this Privacy Policy or your personal information.
Email: info@polele.co