Privacy notice – Breathe App
1. Intro
This document describes how Polestar processes your personal data when you use the Polestar Breathe application (the "Breathe App").
2. When do we process your personal data?
| Breath App | |
|---|---|
Purpose | To provide the Breathe App services. |
Categories of personal data | installation ID, car model and model year, which country you reside in, information on whether the car is standing still or moving, downloads, resets and uninstalls of the Breathe App, Breathe App updates, operating system updates, data regarding the notifications you receive, breathing techniques used, engagement and frequency, screen views, when and which excercise is initiated and completed or when it is aborted. |
Legal basis | This data processing is used for us to fulfil our contract with you as a part of your use of our service (GDPR, article 6.1 (b)). |
Retention | Until it has been anonymized or until you withdraw your consent. |
Controller(s) | Polestar Performance AB |
| Purpose | To receive insights into how the Breathe App is used and to improve your experience of the Breathe App. The processing does not include any automatic decision making, such as profiling, of you. |
Categories of personal data | installation ID, breathing techniques used, and engagement frequency, screen views, when and which excercise is initiated and completed or when it's aborted. |
| Legal basis | Your consent (GDPR, article 6.1 (a)). You can deny disclosing your data for app analytics and still use the app features. |
| Retention | Until it has been anonymized or until you withdraw your consent. |
| Controller(s) | Polestar Performance AB |
3. How we disclose your personal data and who we disclose it to?
Our processors supporting delivery of the Breathe App, which are limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with each data processing agreement in place:
- Google Ireland Limited and its sub-processors, data centre Europe-west1 (Belgium); data transfer also to Google LLC, USA, under the Standard Contractual Clauses adopted by the European Commission, available here. We use Google Firebase services for app analytics to better understand user behavior and to improve the usability and reliability of the Breathe App. You can deny disclosing your data for app analytics and still use the app features.
4. Transfer of your personal data
We transfer personal data to the following countries outside of the Canada: EU/EEA and the United Kingdom.
In providing its services Polestar may transfer the personal data to service providers outside of EU/EEA or back to Canada. Under EU privacy law this constitutes a reverse transfer. Transfers to the United Kingdom are carried out pursuant to its adequacy decision. For transfers to other countries outside of EU/EEA that do not have an adequacy decision, we use EU Model Clauses entered into by all relevant third parties (article 46 of the GDPR). In addition, we take additional technical and organizational security measures when needed, such as encryption (TLS) and pseudonymization.
5. Your rights
You have specific legal rights granted by the General Data Protection Regulation and privacy laws in Canada relating to the personal data we process about you.
You can object to our processing of your data, access the data we hold about you, ask for rectification or restriction of your data, request to have your data ported to another entity, request that we delete your data, and finally you can file a complaint to Polestar or with the data protection supervisory authority. In Sweden, you have the right to lodge a complaint with the Swedish Supervisory Authority for Privacy Protection (IMY). A list of European supervisory authorities is available here. Under PIPEDA, you have the right to complain directly to us regarding our alleged non-compliance with PIPEDA. We will review and respond to your complaint. PIPEDA-related complaints can be directed to our an be directed to our Data Protection Officer at dpo@polestar.com c/o Polestar Automotive Canada Inc.In order to exercise your rights, please use this web form or call us at (800) 806-2507. For requests submitted via telephone or email, you must provide us with information to allows us to reasonably verify that you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.
If you have any other questions regarding the subject matter of personal data protection, you can contact us or our Data Protection Officer on the contact details stated in the Contacts section below.
6. Contact information
Polestar Performance AB is a Swedish legal entity with company registration number 556653-3096, with mailing address Assar Gabrielssons Väg 9, 405 31 Gothenburg, Sweden, and visiting address Polestar HQ, Assar Gabrielssons Väg 9, 418 78 Göteborg.
Polestar has appointed a Data Protection Officer for the Polestar Group who can be reached via email or via post as set out below:
- E-mail address: dpo@polestar.com
- Postal address: Polestar Performance AB, Attention: The Data Protection Officer, 405 31 Göteborg, Sweden
7. Changes to our Privacy Notice
We reserve the right to change this privacy notice from time to time. We will inform you of any changes by posting the updated privacy notice on the website. If we make any material changes to our privacy notice, we will send a notification by e-mail. We encourage you to contact us if you have any questions about the privacy notice or about how we process your personal data.