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Privacy Policy

Privacy policy notice‍

Polaris Network Capital GmbH (“we”, “us”, “our”) protects your privacy and private information. With this privacy policy, we inform you how we do when you visit our website (www.polaris-network.com), handle data that relates to you personally, e.g. name, email address (hereinafter also called”personal data“), but also information about your visit to and use of the website.

1. Responsible person

‍Responsible for the collection and processing of your personal data within the meaning of Article 4 No. 7 of the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) is:

Polaris Network Capital
c/o CANEI AG
Phoenixseestrasse 22A
44263 Dortmund
email: info@polaris-network.com

For more information about visit our imprint.


2. Data protection officer

If you have any questions about the processing of personal data by Polaris Network Capital, you can contact us directly:

Polaris Network Capital
‍
email: info@polaris-network.com
‍

3. Data processing when visiting and using the website

We refrain from using personal data on our website. Protecting your data is important to us. When you visit our website, we only collect and process your data if you actively contact us via the contact form.

General information about cookies

Cookies are small text files that enable the storage of individual user data, in particular the identification of the user's terminal device. When using the platform, cookies are stored on your device. Cookies can transfer information from our server or third-party servers to the user's web browsers or apps, which are stored there for later retrieval. A cookie usually contains the name of the domain from which the cookie data was sent, information about the age of the cookie and an alphanumeric identifier.

Purpose‍
We use cookies to ensure the proper functioning of the platform and to optimize your user experience.

Legal bases and legitimate interest‍
The legal basis for data processing is Art. 6 (1) (f) GDPR. Our legitimate interests lie in providing and ensuring the operation of our website and IT security as well as in optimising the presentation of our offer and direct marketing measures.

Our platform does not process personal data in connection with analysis or tracking, for which we need your consent in accordance with Article 6 (1) (a) GDPR.

Transceivers
In addition to the transfers described below, we share your data with our IT and hosting service providers strictly for a specific purpose — if necessary at all — and only to the extent necessary.

‍Storage period
We store the data for as long as it is needed to fulfill the above purpose or until you delete the cookies.

Objection option
Insofar as data processing is based on the legal basis of Article 6 (1) (f) GDPR, you can object to data processing. You can exercise your right of objection by configuring your browser in accordance with your wishes, for example so that no third-party cookies (so-called third-party cookies) or no cookies at all are stored, or a message always appears before a new cookie is created. In addition, cookies that have already been saved can be deleted at any time via the browser settings.

You can find out how to configure cookies for common browsers under the links below:

Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en
Safari: https://support.apple.com/de-de/guide/safari/sfri11471/17.0/mac‍
Opera: https://help.opera.com/de/latest/web-preferences/#cookies

Obligation to provide data‍
The provision of your personal data is neither required by law nor by contract. However, without provision, the service and functionality of our platform are not guaranteed. In addition, individual services may be unavailable or restricted.

4. Website creation and hosting (Webflow)

We host our website with Webflow. The provider is Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter “Webflow”). When you visit our website, Webflow collects various log files, including your IP addresses.

Purpose
Webflow is a tool for building and hosting websites. Webflow stores cookies or other recognition technologies that are necessary to display the page, to provide certain website functions and to ensure security (necessary cookies).

Storing data
Webflow will not collect any further cookies without your consent. This is entirely up to you and can be set by yourself using the cookie settings on the website. For details, see Webflow's privacy policy: https://webflow.com/legal/eu-privacy-policy.

Legal basis
Webflow is used on the basis of Art. 6 (1) (f) GDPR. We have a legitimate interest in presenting our website as reliably as possible. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6 (1) (f) GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be withdrawn at any time. A transfer to the USA is protected by the EU Commission's contractual clauses in compliance with the GDPR. Details can be found here: EU & Swiss Privacy Policy in (Webflow).

Order processing
We have concluded an order processing contract (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that this personal relationship data on our website is processed only in accordance with our instructions and in compliance with the GDPR.

5. Data processing when contacting us via e-mail or telephone

You can contact us using the email addresses and telephone numbers provided by us. If you make use of this option, your personal data transmitted by e-mail or telephone call will be processed.

Purpose‍
We process your data for the purpose of processing your request.

Legal basis and legitimate interest
If the purpose of contact is to conclude a contract or if your contact concerns an existing contract, Art. 6 para. 1 lit. b GDPR is the legal basis for processing. The legal basis for processing your data in other cases is Article 6 (1) (f) GDPR. In these cases, the legitimate interest results from the fact that we can only carry out the action you have requested (e.g. answering inquiries) by processing your data accordingly.

Transceivers
As part of processing your request, your data will be transmitted as part of order processing to our IT service providers and to our employees, who will process your request.

Storage period
In principle, we store your data until your request has been answered in full.

Objection option
Data processing is necessary to process your request. You can prevent us from collecting your data by not sending us a request.

Commitment to provide your data
There is no legal obligation to provide your data. However, if you do not provide us with your data, it is not already possible to contact us or not via any means of communication.

6. Storage period of your personal data

Insofar as the remaining provisions of this data protection policy do not result in a shorter storage period, we only store your personal data for as long as is necessary to fulfill the respective purposes, then only to the extent and to the extent we are obliged to do so due to mandatory legal storage obligations. Insofar as we no longer need your data for the purposes described in this data protection notice, it will only be stored during the respective legal retention period and will not be processed for other purposes.

7. Your rights

If we process your personal data, you have the following rights against us:

Right to information

You can request confirmation from us as to whether personal data concerning you is being processed by us. If there is such processing, you can request information from us about the information listed in Article 15 GDPR. If you exercise your right without telling us what specific information you would like, we will provide you with all information in accordance with Art. 15 GDPR.

Right to rectification

You have the right vis-à-vis us to correct or complete your personal data if the processed personal data concerning you is incorrect or incomplete.

Right to restrict processing

You can request that the processing of personal data concerning you be restricted under the following conditions:

  • If you dispute the accuracy of the personal data concerning you. This is valid for a period of time that enables us to verify the accuracy of the personal data.
  • The processing is unlawful. They reject the deletion of personal data and instead demand that the use of personal data be restricted.
  • We no longer need your personal data for processing purposes. However, you need them to assert, exercise or defend legal claims.
  • If you have filed an objection to processing in accordance with Article 21 (1) GDPR and it is not yet clear whether our legitimate reasons for further processing outweigh your reasons. If the processing of personal data concerning you has been restricted, this data — apart from storage — may only be processed with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.

If processing has been restricted in accordance with the above conditions, we will inform you before the restriction is lifted.

Right to delete
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Obligation to delete

You can request that we delete the personal data relating to you immediately. We are obliged to delete this data immediately if one of the reasons listed in Article 17 GDPR applies. Anonymized data cannot be deleted.

‍Information to third parties‍
If we have made the personal data concerning you public in individual cases and are obliged to delete it in accordance with Article 17 (1) GDPR, we will take appropriate measures, including technical measures, taking into account the available technologies and implementation costs, to inform the data controllers who process the personal data that you, as a data subject, have deleted all links to this personal data or copies or replications from them of them have requested personal data. In principle, however, we do not make your personal data public.

‍Exemptions
The right to deletion does not exist insofar as the processing of personal data concerning you is necessary

  • to exercise the right to freedom of expression and information;
  • to fulfill a legal obligation that requires processing under Union or German law, or to perform a task that is in the public interest or in the exercise of official authority that has been transferred to us;
  • for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1) GDPR, insofar as the deletion is likely to make impossible or seriously impair the achievement of the objectives of this processing, or
  • to assert, exercise or defend legal claims.

‍Right to be informed

If you have asserted the right to correct, delete or restrict the processing of your personal data against us, we are obliged to inform all recipients of your personal data of this correction or deletion of the data or restriction of processing. This does not apply if the notification proves impossible or would involve disproportionate effort. You have the right vis-à-vis us to be informed about these recipients.

Right to data portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. You also have the right to transfer this data to another person responsible, provided that:

  • the processing is based on consent in accordance with Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR or on a contract in accordance with Article 6 (1) (b) GDPR, and
  • processing is carried out using automated procedures. If you wish to do so and insofar as it is technically feasible for us and the freedoms and rights of other persons are not affected as a result, we will transfer the personal data concerning you directly to the other person responsible.

The right to data portability does not apply to processing of personal data that is necessary for the performance of a task that is in the public interest or in the exercise of official authority that has been transferred to us.

Right to object

For reasons arising from your particular situation, you have the right to object at any time to the processing of personal data concerning you, which is carried out on the basis of Article 6 (1) (e) or (f) GDPR; this also applies to the creation of user profiles based on these provisions.

We will no longer process your personal data following your objection, unless we can prove compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to user profiling, insofar as this is associated with such direct marketing.

Automated decision on a case-by-case basis, including user profile creation

If certain decisions on our part are based exclusively on automated processing — including user profiling — you have the right not to be subject to such a decision, which has legal effect on you or similarly significantly affects you. However, this does not apply if

  • the decision is necessary to conclude or fulfill a contract between you and us,
  • the decision is admissible under Union or German law and this legislation contains appropriate measures to protect your rights and freedoms as well as your legitimate interests, or
  • This form of decision-making is made with your express consent.
Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of personal data concerning you violates data protection regulations, including the GDPR.

Withdrawal of consents granted

If you have given declarations of consent under data protection law, you have the right to freely withdraw these consents at any time. Withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the withdrawal. If you have given several declarations of consent under data protection law, please let us know which of the consents you withdraw. If we do not receive such a specification even upon request, we assume that your revocation applies to all consents granted up to that point. We will then stop all data processing activities based on your consent.

8. Links to third-party websites

Please note that our platforms may contain links to content from other providers to which this privacy policy does not apply. We have no influence on these websites and also on whether they comply with the applicable data protection regulations.

9. Updating the privacy policy

The continuous development of technology and the Internet requires adjustments to our data protection policy from time to time. We reserve the right to change this privacy policy at any time with effect for the future. The latest version is available on our platform. Please visit the platform regularly and find out about the latest data protection information.

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Last updated: January 2026

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