Date of version: 21/10/2020
1. Purpose, scope and users
This document provides the necessary information regarding the processing of your personal data that is directly collected from you as the data subject through this website.
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 the controller for the personal data you as a data subject provide us through this website. The types of personal data listed below provides an overview of what kind of data Pulso processes from you.
Pulso may collect the following types of personal data from you to provide our services:
- Identifiable personal data such as your name, e-mail address, telephone number and other contact or address information
- Any questions or remarks you enter
- If necessary, in subscription forms more specific socio-demographic information such as age, gender, languages, education level, profession, diploma's, date of birth, and general information to enter into an agreement
Pulso processes your personal information on one of the following lawful bases, depending on the purpose of the processing:
- Pulso processes your information for the performance of a contract to which you as a data subject are a party or in order to take steps at your request prior to entering into a contract.
This processing ground applies to all subscription forms to participate in a collaboration of the delivery of services.
- Pulso processes your information for compliance with a legal obligation to which the controller is subject.
This processing ground applies to the Data Subject Access Request form.
- Pulso processes your information for the purposes of the legitimate interests pursued by Pulso, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
This processing ground applies to contact forms, subscription forms for events and subcriptions to newsletters or other communication.
- If no other processing ground applies, Pulso processes your personal dat after you have given consent to the processing of your personal data for the purposes described on that particular page and / or the privacy notice or informed consent of the 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:
- To answer your questions
- To provide our products and services
- To participate or collaborate for the provision of common products or services
- To provide advice regarding our products and services
- To provide information tailored to the organisation you represent
- To inform bout new products or services that may be interessant for you or the organisation you represent
5. What do 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 do 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
Tel: +32 16 20 85 96
Fax: +32 16 20 86 60
You can contact the Data Protection Officer at firstname.lastname@example.org or in writing at address listed above.