Privacy Notice

Version: 2
Date of version: 21/10/2020

1. Purpose, Scope and Users

The purpose of this document is to provide a general privacy notice, applicable to all services and products Pulso Europe BV provides, and act as a template or starting point for a service or product specific privacy notice or informed consent.

This document must be presented to data subjects before processing personal data and made public on the services’ or products’ website.

Users of this document are all employees of Pulso Europe BV, client organizations, and end users of products and services.

2. Reference documents

• EU GDPR 2016/679 (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC)
• Information Security Policy
• List of Legal, Regulatory and Contractual and Other Obligations
• Data Breach Response and Notification Procedure
• Data Retention Policy
• IT Security Policy
• Data Subject Access Request Procedure
• Personal Data Protection Policy
• Cross Border Personal Data Transfer Procedure

3. What we need

Our Personal Data Protection Policy governs the use and storage of your data. You can see our Personal Data Protection Policy at https://pulso-europe.eu/policies/personal-data-protection-policy

Pulso Europe BV is a Controller of the personal data you (data subject) provide us. The types of personal data listed below provides a global overview of what kind of data Pulso processes. Each service or product has its own privacy notice that clearly defines which types of personal data are processed for that service or product. Please refer to the service or product specific privacy notices for more accurate information.

Pulso may collect the following types of personal data from you to provide our services:

• Personal Data: name, email address and other contact details, socio-demographic factors such as age, sex, education level, profession, employment and birthdate, and general information about your relation with your employer
• Data concerning health: information about your well-being, physical and mental health, risk situations and risk behaviors and other healthcare related data

Pulso processes your personal information on one of the following lawful bases depending on the purposes:

• Pulso processes your information for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Pulso processes your information for compliance with a legal obligation to which the controller is subject.
• Pulso processes your information in order to protect the vital interests of the data subject or of another natural person.
• Pulso processes your information for the performance of a task carried out in the public interest or in the exercise of official authority vested in Pulso.
• Pulso processes your information for the purposes of the legitimate interests pursued by Pulso or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject (you) which require protection of personal data, in particular where the data subject is a child.
• If no other lawful basis applies, Pulso processes your information after you have given consent to the processing of your personal information for the purposes described in this document and/or the privacy notice or informed consent of the provided service or product.

As the data subject you may refuse or decline to provide personal data, or in certain cases you may be obliged to provide the personal data. Refusing or decling to provide the required personal data may have certain consequences to the performance or provision of services or products provided by Pulso where the collection of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

4. Why we need it

We need your personal data in order to provide you with the following services:

• Providing a direct or indirect Employee Assistance Programme
• Providing consultancy related to strategies and policies
• Providing workshops and trainings
• Providing adequate assistance
• Granting access to various systems
• Providing adequate assistance

5. What we do with it

Pulso Europe BV may anonymise your personal information and further process the anonymised information for statistical purposes and product improvement, compatible with the initial purposes for which the information was collected.

Your personal data is processed by Pulso Europe BV located in Kessel-Lo, Belgium.
Hosting and storage of your data takes place in the datacenters of:

• Antwerp Datacenter located in Antwerp, Belgium
• Rackspace Limited located in Slough, United Kingdom
• Amazon Web Services, Inc. located in Frankfurt, Germany

No third party providers have access to your data, unless specifically required by law.

In certain cases your personal data may be used in an automated decision-making or profiling process.

In certain cases your personal data may be used for a purpose other than that for which your personal data was collected. In that case Pulso will provide you with information on that other purpose prior to that further processing.

6. How long we keep it

Under EU law, we are required to keep your documents for a certain time according to the Data Retention Policy. After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information. Please see the Data Retention Policy located at https://pulso-europe.eu/policies/data-retention-policy for more information on our personal data retention schedule.

7. What are your rights?

Should you believe that any personal data we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted. If the legal basis for the processing relies on consent you have the right to withdraw your consent at any time. You have the right to obtain from the controller restriction of processing, as well as the right to object to the processing of your personal data and automated individual decision-making and profiling. As the data subject you can exercise your rights through the Data Subject Access Request Form located at https://pulso-europe.eu/policies/data-subject-access-request-form

In the event that you wish to file a complaint about how we have handled your personal data, please contact the Data Protection Officer at the contact details listed below. Our Data Protection Officer will then look into your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you have the right to lodge a complaint with the supervisory authority.

8. Contact details

Contact details of the controller for the service subject to this Privacy Notice:

Pulso Europe BV
Diestsesteenweg 52 bus 0201
3010 Kessel-Lo
Belgium
Tel: +32 16 20 85 96
Fax: +32 16 20 86 60

You can contact the Data Protection Officer at dpo@pulso-europe.eu or in writing at address listed above.