PRIVACY NOTICE

Premiurly OÜ (“Premiurly”, “we”, “us”) collects, uses, and handles your personal information when you use our products like Polkassembly.

What does this notice cover?

This notice applies to Premiurly’s website https://premiurly.in and Premiurly’s online forum Polkassembly at https://kusama.polkassembly.io and https://polkadot.polkassembly.io (together the “Forum”). This notice describes how Premiurly will use data collected as part of the Forum.

It also describes your data protection rights, including a right to object to some of the processing which Premiurly carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What information do we collect?

We collect and process the following information:

Information you provide to us.

• Account and account preferences information. We collect the information you provide when registering for the Forum including your username, name, email and password, profile information, including preferences and settings, e.g. subscription to a topic or post. Where you choose to link your on-chain identity with your Polkassembly account, we will also store your verified Kusama / Polkadot address.

• Post information; information provided in your forum comments and posts, including drafts, as well as interaction with content on the forum and between users. This may also include any direct messaging to other users;

• Support: We collect information when you interact with us, such as to provide us with feedback or, contact us for user support. This may include name, email, the date, time and reason for contacting us, transcripts of any conversations, and if you call us, your phone number and call recordings.

• We store your marketing preferences, including any consent you have given us.

• Device and browser information: We collect information about the browsers and devices you use to access the Forum. Such as access logs of IP address, user-agent string, browser type, browser extension, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, the requested URL and the time of page visits.

• Please see our Cookie Policy for more information: https://premiurly.in/policy/cookie-policy/

How do we use this information?

We process this information for the following purposes:

To fulfil a contract, or take steps linked to a contract including:

• To provide the Forum, including ancillary services such as customer support.
• To verify user on-chain identity and enable users to use the voting feature;
• To send you service, technical and other administrative emails relating to the Forum, messages and other types of communications.

As required by Premiurly to conduct our business and pursue our legitimate interests, in particular:

• To ensure our Forum is working as intended, such as tracking outages or troubleshooting issues that you report to us.
• To ensure the security of the Forum.
• To make improvements to the Forum and help us develop new services.
• To conduct surveys and other market research to ensure our services are relevant to your needs.

Where you give us consent:

• Where required by law to send you direct marketing in relation to our relevant services;
• We place cookies and use similar technologies. See our Cookie Policy; and
• On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

For purposes which are required by law:

• In response to requests by government or law enforcement authorities conducting an investigation.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.

In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication within an electronic message, or by contacting us at [email protected]

Who will we share this data with, where and when

• Vendors and service providers. We will share your personal data with third party service providers who support our business, who will process it on behalf of Premiurly for the purposes identified above. Such third parties include providers of hosting services and technical infrastructure including browser extension developers, blockchain infrastructure providers, third party account management services, customer support services, and marketing services.
• Third party direct communication and marketing services. We will share your email address with third party service providers to send direct marketing emails on our behalf with your consent. Premiurly group companies. We may share your information with our group of companies for the purposes of business administration, maintaining security and regulatory compliance, providing support services to end users (including IT support, where relevant), marketing and analytics.
• Legal reasons. We will share personal information outside of Premiurly if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to (i) enforce applicable terms of service or other agreements, including investigation of potential violations and audits, (ii) detect, prevent, or otherwise address fraud, abuse, security risks, or technical issues, and (iii) protect against harm to the rights, property or safety of Premiurly, our users, or the public as required or permitted by law.
• Business transfers. In the event that Premiurly undergoes any reorganisation, restructuring, merger, sale, or other transfer of assets your information will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to any new owners of the business.

In connection with the purposes identified above, your personal data will be shared in the UK and EEA, and may be transferred outside the UK and the EEA . Where information is transferred outside the UK or EEA that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules.

What rights do I have?

Where required by applicable law or regulation, you have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller. If you are a registered user of the Forum, you may also review and change your personal information on your account profile page.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights - or get a copy of our legitimate interest balancing tests - you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred.

For the provision of information marked as mandatory when you register to use the Forum, if such information is not provided, then you will not be able to use the Forum. All other provision of your information is optional. If you do not provide such information, our provision of certain services to you may be detracted from.

How long will you retain my data?

We store data for as long as necessary to provide our services. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. Some personal data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time. For example:

• We will keep the account information you provide to us for as long as you remain an account holder.
• We will keep a record of the fact that you have asked us not to send you direct marketing indefinitely, so that we can respect your request in future.
• We will keep usage information and analytics data for a reasonable length of time that allows us to provide our services and to understand how people use the Forum.

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. Reasons we might retain some data for longer periods of time include security, fraud prevention, financial record-keeping, complying with legal or regulatory requirements, ensuring the continuity of our services, and when there have been direct communications with Premiurly.

How do I get in touch with you?

If you have any questions or concerns about how we process your data, please contact us at [email protected].

Who is my data controller?

Any personal information provided to or gathered by Premiurly is controlled by Premiurly OÜ. For more information on who is considered the specific data controller in connection with the collection of your personal information please contact us at [email protected]

Changes to our privacy notice

We reserve the right to change this privacy notice from time to time to reflect changes in the law or regulation, our information practices, our services, or our operational requirements. Depending on the type of change, we may notify you by updating this page or by email. We encourage you to periodically review this page to see any changes we have made.

Last updated: 28 November 2020, Version 1