Pulse
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Last updated on 16 September 2024

Welcome to https://pulse.bz/ (the “Website”)! We are committed to safeguarding your privacy and personal data. This Privacy Notice (also “Notice”) details how we collect, use, and protect your information. Please review it thoroughly. If you have any questions, reach out to us at any time. You may find our contact details below.

By using our Services or accessing our Website, you consent to the practices outlined here. If you do not agree with any aspect of this Notice, please refrain from using our Services or Website.

We take your privacy seriously. As the data controller under EU General Data Protection Regulation ("GDPR") and Data Protection Act 2018 (“UK GDPR”), we determine the purposes and methods of processing your personal data and ensure compliance with data protection laws. For any questions or concerns, contact us at:

OUR CONTACT DETAILS

Company: COMPANY LTD Company No. 123456789 Registered Address: Suite 4838 Unit 3a, 34-35 Baker Street, Holborn, London, United Kingdom, EC16 1CE Email: support@pulse.bz

INFORMATION WE COLLECT

We may collect and process the following types of personal data for the purposes described in this Notice: • User Account Information: e.g., login credentials, username, user activity logs, settings, profile information; • Contact Details: e.g., phone number, email address, country of residence, postal address; • Identity Verification Data: e.g., full name, government-issued identification, authentication details, ID document details; • Communication Records: e.g., phone conversations, chat logs, email correspondences; • Transaction Information: e.g., order and purchase history, account balance; • Payment Data: e.g., payment history, preferred payment methods, bank account and payment card details; • Technical Information: e.g., device details, IP address, operating system, browser type, and settings; • Customer Support Data: e.g., issues reported, resolution details; • Compliance Data: e.g., data related to AML/CFT activities, KYC procedures, and other legal compliance; • Marketing Preferences Data: e.g., your preferences regarding marketing communications, participation in loyalty programs; • Video Surveillance Footage and Visitor Data: i.e., video footage from our premises and related data (including metadata).

HOW WE USE YOUR INFORMATION

We utilize personal data for the following purposes, each with the appropriate legal basis: • Account Management: To create and manage your account (Legal Basis: contractual necessity); • Service Provision: To provide the services you request (Legal Basis: contractual necessity); • Identity Verification: To verify and authenticate user identities (Legal Basis: legal obligation, legitimate interests); • User Communication: To communicate with you and provide customer support (Legal Basis: contractual necessity, legitimate interests); • Order Fulfilment: To process and manage orders (Legal Basis: contractual necessity); • Transaction Management: To execute and manage transactions (Legal Basis: contractual necessity, legitimate interests); • Legal Compliance: To comply with legal and regulatory requirements (Legal Basis: legal obligation, public task); • Risk Management: To manage business risks and make informed decisions (Legal Basis: contractual necessity, legal obligations, legitimate interests); • Marketing Activities: To send marketing materials and personalized content (Legal Basis: consent, legitimate interests); • Fraud Prevention: To prevent fraud and misuse of our services (Legal Basis: legal obligation, legitimate interests); • Technical Support: To address technical issues and troubleshoot problems (Legal Basis: contractual necessity); • Security Measures: To ensure the security of our information and assets (Legal Basis: contractual necessity, legal obligation, legitimate interests); • Dispute Resolution: To address claims and resolve disputes (Legal Basis: contractual necessity, legal obligation, legitimate interests); • Service Improvement: To improve and develop our services (Legal Basis: legitimate interests).

DATA COLLECTION METHODS

We collect your information through various methods: • Direct Interactions: Data provided by you through forms, subscriptions, or direct contact; • Automated Technologies: Data collected automatically via legitimateies and similar technologies on our Website. See our Cookie Notice for details. • Third-Party Sources: Data received from our service partners, government institutions, or publicly available sources.

All collected data is pertinent and limited to what is necessary for our purposes.

MANDATORY AND OPTIONAL INFORMATION

Certain information is necessary for us to provide our services effectively. This essential data will be clearly indicated when we request it from you. Without this mandatory information, we may be unable to offer you some of our services. In addition to the essential data, there is also optional information that you may choose to provide. While not required, sharing this additional data can help us to enhance your experience and offer more personalized services. If you have any questions about the data we collect or how it is used, please do not hesitate to contact us.

DATA SHARING

We share your information only with trusted partners if necessary for provision of our Services, and authorities when legally required. Your data is never sold or misused. Contact us if you have any concerns about data sharing.

DATA PROTECTION

The security of your data is our top priority. We employ a range of measures to ensure that your personal information is protected, for instance: • Encryption: We use advanced encryption technologies to secure your data both in transit and at rest, ensuring that your information is protected from unauthorized access; • Access Controls: We implement strict access controls to ensure that only authorized personnel have access to your data. These controls include multi-factor authentication and role-based access permissions; • Regular Training: Our staff undergo regular training on data protection and privacy best practices to ensure they are aware of their responsibilities and the importance of protecting your data; • Security Audits: We conduct regular security audits and assessments to identify and address potential vulnerabilities in our systems and processes; • Data Minimization: We follow the principle of data minimization, collecting only the data that is necessary for our purposes and retaining it only for as long as required; • Incident Response: We have an incident response plan in place to promptly address and mitigate any data breaches or security incidents that may occur.

You can further protect your data by taking at least the following steps:

• Use Strong Passwords: Create unique, complex passwords for your accounts and change them regularly. • Enable Two-Factor Authentication (2FA): Add an extra layer of security to your accounts by enabling 2FA wherever possible. • Be Vigilant: Be cautious of phishing attempts and do not share your passwords or personal information with untrusted sources. • Keep Software Updated: Regularly update your devices and software to protect against security vulnerabilities.

INTERNATIONAL DATA TRANSFERS

There may be instances where your personal data needs to be transferred outside the European Economic Area (EEA), European Union (EU), and the United Kingdom (UK). When such transfers occur, we take great care to ensure your data remains secure and protected. We employ legal safeguards, such as Standard Contractual Clauses (SCCs), in accordance with GDPR and UK GDPR requirements. These measures ensure that your data enjoys the same level of protection as it would within the mentioned territories. Should you have any concerns or questions about our data transfer practices, please feel free to reach out to us.

YOUR DATA RIGHTS

You have the following rights regarding your personal data:

• Access: Obtain a copy of your data. • Correction: Request corrections to inaccurate or incomplete data. • Deletion: Request deletion of your data under certain conditions. • Restriction: Limit the processing of your data. • Objection: Object to specific processing activities. • Portability: Receive your data in a structured format for transfer to another service. • Withdraw Consent: Revoke consent at any time if processing is based on consent.

To exercise these rights, contact us at info@pulse.bz. We may need to verify your identity before processing your request. Please note that data subject rights are not absolute and may be subject to certain limitations. In specific situations, legal or regulatory requirements may prevent us from fully accommodating your request. We will inform you if such limitations apply when you make your request.

DATA RETENTION PERIODS

We keep your personal data only for as long as it is necessary to achieve the purposes for which it was collected, or as mandated by relevant laws. In some instances, legal requirements dictate the retention period (for example, data related to Anti-Money Laundering (AML) purposes is generally retained for up to 5 years). In other scenarios, we determine the retention period based on our business needs and legal obligations, typically aligning with the limitation period for potential claims against us (for instance, up to 10 years). Once the appropriate retention period has elapsed, we ensure that your data is either securely deleted or anonymized to protect your privacy.

AGE RESTRICTIONS

Our services are intended for users aged 18 and older. We do not knowingly collect data from children under 18. If we discover such data, we will delete it promptly. Contact us if you believe your child has provided personal data without your consent.

AUTOMATED DECISION-MAKING

We do not engage in automated decision-making or profiling that significantly affects you.

HOW TO COMPLAIN

If you’re concerned about how we handle your data, we’d like to address it directly. However, you can also file a complaint with your local data protection authority. In England, this is the Information Commissioner's Office (ICO).

The ICO’s address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 Website: https://www.ico.org.uk/make-a-complaint

UPDATES TO THIS NOTICE

We may update this Notice periodically to reflect changes in our practices or for regulatory reasons. Please revisit this notice regularly. Significant changes will be communicated via our website or direct notification.