Version: 2.2 — Last updated: 2026-10-22
This Privacy Policy describes how and when Pole Star France and its subsidiary Pole Star USA Inc. collects, uses and shares your information when you use Pole Star's NAO Cloud® platform, NAO SDK®, indoor location deployment tools and indoor positioning software, as well as other services provided by Pole Star in connection with same.
Pole Star will collect certain information from its users as described below. Therefore, when using the Service, you consent to the collection, transfer, storage, disclosure and other uses of your information as described in this Privacy Policy, regardless of your location while using the Service.
If you have any questions or comments about this Privacy Policy, please contact our data privacy contact at: dpo@polestar.eu.
Our Privacy Policy only applies to our Services. We are not responsible for the privacy practices or content of other websites, or third-party services provided through our Service.
API: Application Programming Interface. Software interface enabling software publishers or integrators to use services provided by Pole Star software under the terms of this agreement.
Consent: Any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Contract: The contract is an agreement between the parties defining the specifications and obligations of each party.
End-user: The end-user is the person who is going to use the geolocation system through the Customer's application or service.
French Data Protection Act: The French DPA is a French law that regulates the freedom to process personal data, i.e. the freedom to put people on file.
GDPR: The General Data Protection Regulation (GDPR) is a European regulatory text that regulates data processing on an equal footing throughout the European Union. It came into force on 25 May 2018.
Personal data breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, or otherwise processed.
NAO Cloud®: NAO Cloud® is a platform for setting up geo-localized services, in complete autonomy.
NAO Logger®: NAO Logger® is an application allowing the configuration of indoor geolocation.
NAO SDK®: NAO SDK® corresponds to Pole Star's integrated software for indoor geolocation.
NAO® Suite: NAO® Suite corresponds to all products and services provided by Pole Star.
SDK: A geolocation SDK is a code snippet provided to application or services publishers by geolocation technology specialists. Application publishers integrate these SDKs into the code of their software mobile applications. It was designed around the following objectives: to strengthen the rights of individuals and to make data processors accountable.
Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
User/Customer: The User/Customer is the person or company that wishes to integrate our geolocation solution.
Pole Star is a public limited company with a board of directors established in TOULOUSE (31100). The head office is located at 11 RUE PAULIN TALABOT, 31100 TOULOUSE, and is represented by its current CEO, Mr. Christian Carle. Pole Star France is the data controller for the processing described in this policy.
The company Pole Star acts on behalf of its users within the framework of the implementation of the geolocation system. Pole Star is a provider of geolocation processing as a subcontractor of the Customer.
Pole Star undertakes to respect the laws concerning the protection of personal data, in particular the GDPR and the French Data Protection Act of 1978.
The purpose of this data processing is to identify and authenticate Users/Customers or End-users of the NAO Cloud® platform and associated components such as NAO Logger®, in order to enforce data protection and subscription profiles.
The data collected are: first name, last name, mail address (expected to be a professional mail address, but no obligation on that), company name, type of job occupation, IP address logged and stored to database with date of connection.
The data is stored on a secure cloud server throughout the contractual relationship and until the end of use of the service, and will be destroyed after termination of the duration of services as defined by Contract. You may also request deletion of your information at any time by contacting our data privacy contact at dpo@polestar.eu.
The data is stored on AWS RDS servers hosted in Ireland, Europe, in compliance with European personal data protection rules (GDPR).
The purpose of this data processing is to collect RF and location data on the field with the operator's location from a smartphone app (NAO Logger®), upload these data to the NAO Cloud® server in order to generate a calibration file for our location services and in order to evaluate the accuracy of the location.
The data collected are identity or a code to identify the logger, limited to data collection sequences ("logs") intentionally taken by the operator of the smartphone:
The data is stored on a secure cloud server throughout the contractual relationship and the end of use of the service, and will be destroyed after termination. You may also request deletion of your information at any time by contacting our data privacy contact at dpo@polestar.eu.
The data is stored on two AWS datacenters: one hosted in Ireland, Europe, in compliance with European personal data protection rules (GDPR), and the other hosted in the USA. You can choose the datacenter upon site creation.
The purpose of this data processing is to compute analytics based on location information reported from smartphone applications that integrate the NAO SDK®.
The NAO SDK® identifies each device using a random identifier that is renewed every 24 hours, ensuring the data is anonymous and cannot be linked to a real person.
In addition to location information, the SDK collects: device model, site and zone names, and visit durations. These data are collected from the moment the end user gives their consent.
Only NAO Cloud® users who have an "Analytics manager" or "platform administrators" role in the NAO Cloud® platform can access the analytics data.
Analytics data is retained until deletion is requested by the Customer. Deletion requests are executed within 30 days of verified request.
End users wishing to request deletion of their data should contact the application operator (Pole Star's customer) through the application's own privacy policy or settings.
The data is stored on two AWS datacenters: one hosted in Ireland, Europe, in compliance with European personal data protection rules (GDPR), and the other hosted in the USA. You can choose the datacenter upon site creation.
The purpose of this data processing is to compute locations of tags in the NAO Cloud® platform or import location events reported by a smartphone application that integrates the NAO SDK®, and to store the location results in a place selected by the customer. Location results are used either through an integrated web app or exported to a customer-selected destination as a real-time data stream through an API.
Capabilities include:
Devices can be either an electronic tag that emits Bluetooth Low Energy signals, or a smartphone that embeds a specific mobile application (NAO Track® App), intentionally configured to operate on a given site and to report a stream of location data to the NAO Cloud® platform.
The purpose of device tracking depends on customer needs: security enforcement, safety, operational efficiency (such as quickly finding assets).
The data collected are Device IDs related to the tag or smartphone being tracked. In the NAO® Suite, authorized users ("Tracking manager", "platform administrator") are allowed to enter a name associated with the Device ID. Such users can potentially enter additional information.
Storage duration is configurable and defined with the Customer at contract start, in compliance with GDPR. The available retention periods are 6, 12, or 24 months, enforced by automatic deletion at the end of the configured period.
Deletion requests are executed within 30 days of verified request.
The data is stored on two AWS datacenters: one hosted in Ireland, Europe, in compliance with European personal data protection rules (GDPR), and the other hosted in the USA. You can choose the datacenter upon site creation. In addition, live location events for all sites — including EU sites — transit through AWS IoT in the USA before being stored in the selected datacenter.
Pole Star uses Google Analytics on its public website (www.polestar.eu) to analyze website traffic. Google Analytics is not used within the NAO Cloud® platform. Google Analytics collects information sent by your browser as part of a web page request, including cookies and your IP address, and its use of it is governed by Google's Privacy Policy.
Additionally, Pole Star may use software, hardware, or other services provided by third parties as part of or in connection with the Service. By using the Service, you are consenting to the foregoing third-party services.
We do not sell or share any information about you with anyone. However, we may enter into partnerships or other business arrangements with third parties who may be given access to personal information — including your name, address, telephone number and email — for the purpose of improving the Service and your experience in connection therewith. We may also transfer such information in the course of corporate divestitures, mergers, or any dissolution.
Additionally, we will share personal information with companies, organizations or individuals outside of Pole Star when we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
The following third-party sub-processors may process personal data on behalf of Pole Star:
| Sub-processor | Role | Location |
|---|---|---|
| Amazon Web Services (AWS) | Cloud hosting (compute, storage, database, IoT, AI services) | EU (Ireland) and USA |
| Have I Been Pwned (Pwned Passwords API) | Breached-password check at sign-in | USA |
| Sentry | Exception tracking and error reporting | USA |
| Zoho Desk | Customer support ticketing | USA (transfer basis: EU-US Data Privacy Framework) |
Pole Star cares about the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Pole Star or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.
Your privacy settings may also be affected by changes to the functionality of our distributors, such as third-party websites or social networks. Pole Star is not responsible for the functionality or security measures of any third party.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications to and from Pole Star, at any time.
Pole Star cares about the security of your information and your end-user information. We apply reasonable physical, technical and organizational measures — including an organization and team dedicated to information system security, an updated personal data protection policy, use of strong authentication, restricted access, anonymization and archiving, and control of connections — designed to preserve the integrity and security of all information we collect and share with our service providers.
In addition, all Pole Star employees attend awareness sessions on privacy and system security. Pole Star is committed to respecting and ensuring that its partners comply with all laws concerning the protection of personal data, by working closely with our customers and partners. We are also committed to stopping any activities that would be contrary to the protection of personal data.
A few components of the NAO Suite, such as NAO Cloud® and NAO Logger®, propose free text fields to be filled in by the Customer, User or End-User, as defined in this Privacy Policy. Pole Star is NOT responsible for content entered by Customers, Users or End-Users in these fields. By using the Services, Customer, User and End-User agree to enter neither personal nor sensitive information in such text fields, unless specifically stated.
The NAO Suite includes Graphical User Interfaces (GUI) and APIs that may be used by Customers to access data and the Service. In cases where the people tracking service is activated in the Contract with the Customer, a specific API is able to deliver tracking data to the Customer. Pole Star is not responsible for the way GUIs and APIs are used by the Customer.
In the event that personal information is compromised as a result of a breach of security, Pole Star will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.
You have the right:
You can address all your questions about your rights to:
If we change our Privacy Policy and/or procedures, we will post those changes on the Site to keep you aware of what information we collect, how we use it, and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted.
In some cases, we may also notify you (via email or otherwise) of such changes, at our sole discretion. However, you are encouraged to check the Site frequently for any posted changes.