The "Pulse Application" is an Online Project Management & Collaboration System. The "Pulse Application" collects some Personal Data from its Users.
Owner and Data Controller
Pulse Collaboration Systems PTY LTD, Clarence Street, Sydney, Australia.
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that "Pulse Application" collects, by itself or through third parties, there are: first name, last name, phone number, email address, Cookies, Usage Data, city, country.
Complete details on each type of Personal Data collected are available by request via the Owner contact details provided above. We will aim to process any request for details within 1 month.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using "Pulse Application".
Unless specified otherwise, all Data requested by "Pulse Application" is mandatory and failure to provide this Data may make it impossible for "Pulse Application" to provide its services. In cases where "Pulse Application" specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through "Pulse Application" and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of "Pulse Application" (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Sub-Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
- Users have given their consent for one or more specific purposes.
- Processing is necessary for compliance with a legal obligation to which the Owner is subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can contact the Owner via the Owner contact information.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
- The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Analytics and Registration and authentication.
Users can request detailed information about such purposes of processing and about the specific Personal Data used for each purpose by contacting the Owner via the Owner's contact details provieded at the start of this document.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the Owner contact details provided at the start of this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of "Pulse Application" or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
For operation and maintenance purposes, "Pulse Application" and any third-party services may collect files that record interaction with "Pulse Application" (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the start of this document.
How "Do Not Track" requests are handled
"Pulse Application" does not support "Do Not Track" requests.
To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User's consent, the Owner shall collect new consent from the User, where required.
3rd Parties and Sub-Processors
Sometimes the "Pulse Application" will use 3rd parties to act as "Sub-Processors" for the "Pulse Application", for the purposes of hosting, security management, analytics and performance mangaement of the system.
Sub-Processors used by the "Pulse Application" are:
- Google Analytics (Usage statistics).
- New Relic (System performance monitoring).
- Havas Health USA (Hosting Partner).
- 'Mail-Gun' (Email sending Partner).
- Havas Health UK (Hosting Partner).
Additional information about Sub-Processors can be requested from the Owner at any time via the Owner contact information at the start of this document. Where technically and physically possible, requests for information will be processed within 1 month of request.
Definitions and legal references
The "Pulse Application" is the Online Project Management and Collaboration System provided by Pulse Collaboration Systems Pty Ltd Australia. The "Pulse Application" is sometimes known simply as "Pulse". The "Pulse Application" may be provided to a User via any online URL or Domain address. Example Domains and URL's for the provision of the "Pulse Application" are, but not limited-to; havaspulse.com, havasnext.com, pulse.ms, havasorbit.com, pulse.extranet-system.com, havas.extranet-system.com.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through "Pulse Application" (or third-party services employed in "Pulse Application"), which can include: the IP addresses or domain names of the computers utilized by the Users who use "Pulse Application", the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using "Pulse Application" who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Sub-Processor (or Data Sub-Processor)
The natural or legal person, public authority, agency or other body which the "Pulse Application" usees as a 3rd-Party for the provision of the "Pulse Application".
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of "Pulse Application". The Data Controller, unless otherwise specified, is the Owner of "Pulse Application".
The service provided by "Pulse Application" as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small piece of data stored in the User's device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: May 23, 2018