Pulse Privacy Notice
This is the privacy notice of Pulse Management UK Ltd. In this document, “we”, “our”, or “us” refer to Pulse Management UK Ltd.
We are company number 06163294 registered in England.
Our registered office is at 12 Deer Park Road, London SW19 3TL United Kingdom.
Under the new GDPR law which takes effect from 25thMay 2018, any person within the EU now has greater levels of protection and access to their own information. This means that people have the right to decide whether or not their details are kept by organisations, to review that information and ultimately the right to ‘be forgotten’ meaning organisations are obliged to remove people’s information if requested.
Under the new rules organisations must have a legal basis to hold your information and if they cannot show that they have a legal basis to hold your information then they must remove your details from their files, be that electronic or on paper.
The 6 lawful areas are:
- Consent – Where a person has given consent to an organisation to keep their information and contact them.
- Contract – Where a person has entered into a contract with an organisation and in order to meet the terms of that contract the organisation needs to have the person’s details.
- Compliance – Where the organisation is required under law to process or pass on information relating to a person e.g. under employment law.
- Vital Interest – Where an organisation needs to use a person’s information to protect their vital interests.
- Public Interest – Where an organisation is obliged in the interests of the public or in exercising official authority to process a person’s information.
- Legitimate Interests – Where an organisation believes it is in a person’s legitimate interest for them to process their information.
An organisation must show that the keeping and processing of your data falls into one or more of the legal categories above.
- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below regarding our website with which you are not happy, your only recourse is to leave our website immediately.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website and all of our customers, contractors and employees are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
- Except as set out below and in the normal course of our business we do not share, or disclose to a third party, any information collected. We never sell any data we have. Any information you provide us will only be used for the purpose you provided it to us.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
This applies to our employees, customers, suppliers and any other persons who would like to or are engaged with us through a contractual capacity. When you buy a service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. inform you of matters relating to the contract
1.3. schedule works, meetings or appointments
1.4. provide you with our services
1.5. request or make payments
1.6. provide you with suggestions and advice on our products and services.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent to receiving e mails from us at any time by instructing us at firstname.lastname@example.org. If you would like us to remove your information from our systems then please inform us that you wish for your details to be removed from all of our files and systems by e mailing us at email@example.com. Please note that after we process your request we will have no information relating to you and will be unable to contact or interact with you. Please allow 30 days for us to remove you from our systems.
3. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
In order to make payments we are required to provide information to banks and government organisations.
Employee records are also required to be kept for legal reasons and your personal information is processed and shared with relevant government bodies in relation to Employment Law obligations.
This may include your personal information.
Specific uses of information you provide to us
4. Information relating to your method of payment
We do not store information about your debit or credit card or other means of payment. All payments are made to our bank account and they store the information.
For contractors we store your bank account details for the sole purpose of making payments to you for services rendered. We do not use this information for any other purpose or share this information with any third parties.
4.1. Access to your payment information is restricted to authorised staff only.
5. Job application and employment
If you send us information in connection with a job application, we may keep it for up to six months in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
6. Sending a message to our team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our organisation.
We keep personally identifiable information associated with your message, such as your name, phone number, business address and email address so as to be able to track our communications with you to provide a high quality service.
This information may be shared with a third party only for the express purpose of dealing with the request at hand. It will not be passed on for any other purpose.
For our employees we also may share your personal address but only if it is relevant e.g. to send an engineer to a job close to their home or to plan a route for work based on where the employee lives.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Use of information we collect through automated systems
Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
9. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not browsing our website.
Access to your own information
10. Access to your personal information
10.1. To obtain a copy of any information we hold on you, please send us a request at mailto:firstname.lastname@example.org.
10.2. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
11. Removal of your information
If you wish us to remove personally identifiable information from our records, you may contact us at mailto:email@example.com.
This may limit the service we can provide to you.
12. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before taking any action. This is important to safeguard your information.
13. Use of site by children
13.1. We do not sell products or provide services for purchase by children, nor do we market to children.
13.2. If you are under 18, you may use our website only with consent from a parent or guardian
14. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
Disclosure and sharing of your information
15. Third party data processors
We use Xero Accounting Software (www.xero.com/uk), SimPro Job Management Software (www.simpro.co.uk), Apple i Cloud (www.apple.com), Capsule Customer Relationship Management (www.capsulecrm.com), Mac Mail (www.apple.com), Gmail (www.google.co.uk) and Google (www.google.co.uk).
At any given time one or more of the above organisations may process or hold your personal data but only for the purposes of fulfilling our contractual obligation, except Capsule.
Capsule hold data for individuals and companies we wish to contact with the intention of direct marketing. You can request information as to whether or not your personal details are held on our Capsule system. All information held on Capsule is taken from the public domain e.g. news articles, company websites, LinkedIn etc.
Some of the above companies host the data they hold outside of the EU. We will do everything we can within reasonable terms to ensure your data is secure when held with our partners.
Please refer to the individual organisations GDPR policies below:
Google – https://policies.google.com/privacy
Capsule – https://capsulecrm.com/privacy/
As an individual you have the right to object your personal information being processed by a third party. However, it may be that we cannot meet our contractual obligations to you should you choose this option.
If you request us to remove your details from third parties we will not be liable to any loss of services or earnings.
You can contact us at mailto:firstname.lastname@example.org to inform us that you do not wish any of the above organisations to process your personal information.
Please allow 30 days for this process to be completed.
16. How you can complain
16.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
16.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
17. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
17.1. to provide you with the services you have requested;
17.2. to comply with other law, including for the period demanded by our tax authorities;
17.3. to support a claim or defence in court.
18. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our services.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.