Last Update: 22 October 2023

Introduction

Pulse is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by Pulse. This Privacy Policy is an integral part of the Terms of Use (“Terms”) and the defined terms in the Terms of Use are used in this document as defined therein.

Please carefully read our Privacy Policy and contact us for any question about the collection and processing of your data or the Users’ data (“Personal Data”) at the following e-mail address: legal@ourpulse.io.

Scope of Application of this Privacy Policy

This Privacy Policy applies to our website, and its associated subdomains alongside our application. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your Personal Data as described in this Privacy Policy and our Terms of Use.

Relevant Legal Framework

This Privacy Policy is governed by the laws of United Kingdom without regard to its conflict of laws provisions. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy.

By creating User Account, using Pulse, or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, application or use our services. Continued use of the website, application, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your Personal Information will mean that you accept those changes.

According to the regulations in force, Pulse is the controller of your Personal Data.

In this capacity, Pulse undertakes to comply with the legal provisions in force and to carry out a lawful, fair, and transparent processing of Personal Data of Users. Pulse also guarantees to the Users that this processing is in accordance with the explicit and legitimate purposes determined in the Privacy Policy. The duration of processing does not exceed the time necessary for the purposes for which the Personal Data are collected and processed.

Information We Collect

Pulse may gather various types of Personal Data about you for different reasons, legal grounds for processing, and periods of retention, to enable access to its services on the platform. There are three categories of data that we collect: (1) information you provide to us, (2) information regarding your use and (3) information we collect from the Third Parties.

1. Information you provide to us:

To utilize our services, you must provide us with certain information upon account creation. This information includes your first name and surname, e-mail address, phone number, date of birth, and third-party single sign-in information (further elaborated in sub-section 3 below) provided that you opt in for it. Additionally, you can opt in to upload your address book to Pulse to assist in connecting you with the people you may know.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2. Information regarding your use:

Usage Data:

We gather information related to your use of Pulse (“Usage Data”), including but not limited to:

The Content you publish, including any relevant written and visual content, such as your mood.
Your interactions with other Users' Content, such as comments, likes, the links they provide to Third Parties and when other Users mention or tag you in their content.
How you engage with other Users on the platform, whether they are part of your tribe or not, and the nature of your interactions with them.
Any communications you have with us, such as via email or via application including reports you submit, and the details of the communication and its content.
We also collect data on the links you interact with across our services, including links within emails that we send you.

Geolocation Data:

For the Content including comments, photos, or videos that the Users share, you will have possibility to share, with your friends, your location where you shared the Content and the timing of your publication (“Geolocation Data”).

For the use of this Service, the Users should consent to the collection of Geolocation Data in their devices. If you do not want Pulse to collect your Geolocation Data, you may refuse to give the permission to access your location. You may withdraw your consent by changing the permissions given to Pulse in the system settings of your phone.

Device Data:

At Pulse, we gather data related to the devices you may use to access our platform (“Device Data”). This may encompass details such as your device, IP address device ID, operating system, and language. Moreover, if you opt to share it with us, we may also collect information from your device address book.

Aggregate Data:

We may also collect, use and share (“Aggregate Data”) such as statistical data to evaluate the performance of the application. Aggregated data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of Users accessing a specific application feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3. Information we receive from Third Parties:

Third Party Data:

We collect various data from the third parties such as other websites, applications and social media platforms (“Third Party Data”).

When you sign up Pulse using one of your Third Party accounts including but not limited to Apple, Facebook, Google and Twitter and/or link your Pulse account with any one of these accounts on Third Party platforms, you give permission to them to share with us information including but not limited to your user ID, name, surname, username, profile photo, date of birth, current location (e.g. town/city), e-mail address, friends and other connections (e.g. followers).

Third Party Data also includes Content that Users share or access on Pulse from Third Parties. We also occasionally collect information that is made publicly available on Third Parties. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, including your contact and location data. Please check these policies before you submit any personal data to these websites or use these services. You can control your Third Party Data by visiting these websites and changing your privacy settings.

If you remove Pulse from your linked account by Third Parties, Pulse will not be able to access such data any longer. However, we will still have the Personal Data that we received when you first linked your Pulse account to Third Parties.

If you wish to know more about the Personal Data we collect and the purposes of processing, you can refer to the following table for more details.

Purpose/Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

To register you as a new User and/or for account management including integrations with your accounts from Third Parties

Mandatory profile data (name, surname, date of birth, phone number, e-mail address)

Contract Performance

Optional profile data (motto, profile photo)

Consent

Integrations with Third Parties and information received from them to register your account

Contract performance and Consent

Functioning of the application and the delivery of its services

Usage Data including Contents you choose to share including access to your device (e.g. photo library, camera)

Geolocation Data

Consent

Aggregate Data

Legitimate interest

Device Data

Contract performance

Administrative management of the platform, management of the relationship with the Users, administration of the Content in accordance with our Terms

Information regarding your use as described above, communications with Pulse

Legitimate interests

Legal management of content (for such objectives as prevention of illegal activities, fraud, cyber harassment)

Usage Data

Compliance with our legal requirements

Connection with other Users

Contact data (e.g. address book)

Third Party Data

Consent

We process the Personal Data in accordance with the requirements of the relevant legal framework for various purposes on the bases of:

Contract performance: Pulse needs to process information provided by you to provide the Services described in our Terms of Use.
Legitimate interests: We collect and process certain types of Personal Data in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. In all cases, we ensure that the collection and processing of personal data is necessary, proportionate, and respectful of individual rights and freedoms. Those interests are as outlined below:
- Providing and improving our services: We collect and process Personal Data to enable Users to access and use our platform, and to continuously improve the user experience. This includes analysing user behaviour and preferences, developing new features and services, and personalizing content and your experience of Pulse.
- Ensuring platform security, in particular to protect our users and our platform from harmful activities. We may collect and process personal data to monitor and detect such activities, as well as to enforce our Terms of Use and Community Guidelines.
- Conducting research and analytics: We may use personal data to conduct research and analytics on user behaviour and preferences, as well as market trends and insights.
Compliance with legal requirements: We may collect and process personal data to comply with legal obligations, such as data retention, reporting, and disclosure requirements. This includes cooperating with law enforcement agencies and government authorities when required by law.
Consent: By giving explicit and informed consent, Users are allowing us to collect and use their personal information for specific purposes that they have agreed to.

Information We Share with Third Parties

We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest.

We may engage trusted Third Parties to perform functions and they provide services to us, such as hosting and maintaining our servers and the app, database storage and management, e-mail management, storage marketing, payment processing, customer service and fulfilling orders for products and services you may purchase through the app. We may share your Personal Data, and possibly some non-personal information, with these Third Parties to enable them to perform these services for us and for you.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the app in a shared location, and type of the device used to visit the app. They may aggregate information about our advertising and what you see on the app and then provide auditing, research and reporting for us and our advertisers.

We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

Protection of your Personal Data and Data Retention

We implement a variety of security measures to maintain the safety of your Personal Data when you place an order or enter, submit, or access your Personal Data. We offer the use of a secure server located in the UK. We cannot, however, ensure or warrant the absolute security of any information you transmit to Pulse 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.

We may transfer your personal data outside of the country where you are located for processing and storage purposes. This may include transferring your data to countries that have different data protection laws than the country where you are located. We take appropriate steps to ensure that your personal data receives an adequate level of protection in the countries where we process it but we cannot guarantee that there would be no breach independently from us.

We will keep your information for as long as it is necessary to provide the services offered by the platform and to fulfil our contractual and legal obligations. We may also retain your information for legitimate business purposes, such as improving and developing the platform, as well as for legal defense. The length of time we retain your information varies depending on factors such as the type of information and the purpose for which it was collected. For example, we will keep your profile information for as long as you have an account with us, but if you violate our policies, we may remove your profile while retaining certain information about you to address the violations to the extent that our legal obligations require so.

Age Limitation

Pulse is not intended for Users under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that Your child has provided Us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.

Respect of the rights of the Platform Users

As a user, you may have certain rights under the privacy laws in your country including the laws of the UK and the GDPR. Your rights include the following:

The right to know what personal data an organization is processing and why, which we provide to you in this Privacy Policy.
The right to access a copy of your data.
The right to correct inaccurate data that is held about you.
The right to request the deletion of your data in certain circumstances.
The right to request that the processing of your data is stopped, but the data is retained in limited circumstances.
The right to receive a copy of certain data in a machine-readable format that can be transferred to another provider.

Please note that the specific rights that apply to you may vary depending on your country, and you should familiarize yourself with your rights under applicable privacy laws.

If you are a resident of California, you may have additional rights under the California Consumer Privacy Act, which include:

The right to request that we disclose specific information to you about how we collected, used, and shared your personal information over the past 12 months.
The right to request that we delete your personal information that we collected from you, subject to certain exceptions.

Please note that we will not discriminate against you for exercising your rights under the California Consumer Privacy Act.

If you make a request, we have 30 (thirty) days to respond to you. If you would like to exercise any of these rights, please contact us. Before we can respond to a request to exercise one or more of your rights, we may ask you to confirm some of your Account information to verify your identity. In case of reasonable doubt, we may ask you for identification.

For more information about these rights, please contact us.

Acceptance and Modification of This Privacy Policy

By registering to and using Pulse and accepting our Terms of Use, you accept the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use our services and not accept our Terms of Use. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

As provided for in its Terms, Pulse reserves the right to modify the Privacy Policy at any time to the extent that the relevant framework allows. In this case, we will publish the new versions of the Privacy Policy on our website and will also send an email to you relating to the amendments 15 (fifteen) days prior to the taking effect of such amendments.

In general, this policy is always easily accessible at Privacy Policy or directly from your user profile and account settings via mobile application.

Contact

You can exercise any of these rights at any time by contacting us at legal@ourpulse.io.

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