Last updated: November 2022
Depending on your usage, we collect different types of data and we and any of our third-party subcontractors and service providers use the data we collect for different purposes, as specified below. You have no legal obligation to provide us with Personal Data, but if you refuse to provide such Personal Data we may not be able to provide you with certain Services or part thereof.
1.1. Contact and Clinical Education Hub. When you (a) contact us through the Site’s contact forms or otherwise or (b) register for our Clinical Education Hub, we collect any data you provide, including your role (e.g., patient, physician, investor), your name, title, organization, email address, phone number, country, and the content of your message.
How we use this data: To respond to your request or inquiry or to register you to the Clinical Education Hub. If you consent, we also use this Personal Data to provide you with newsletters about our products and services.
Legal Basis. When we respond to your inquiry, we process this Personal Data based on the performance of a contract with you. When we process this Personal Data to provide you with our newsletters, we do so based on your consent. You may withdraw your consent at any time by emailing us at [email protected].
1.2. Automatically Collected Data. When you visit the Site, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system and browser type, and Personal Data such as your IP address, device ID, as well as your browsing history and any information regarding your viewing, use of our Site collected through cookies, web beacons, pixels, clear gifs and similar technologies. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.
How we use this data. (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and Services; (2) to prevent fraud, protect the security of our Site, and address any problems with the Services; (3) to provide you with customized content, targeted offers, and advertising related to our products and Services, on the Site, on other third-party sites, apps, or social media platforms you may visit and/or use, or via email, based on your usage history; (4) to create profiles of prospective customers. We use these profiles to narrow the scope of our targeted advertising on third party sites to users and/or locations that are similar to the profiles we create.
Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights and to market our own products and services. Additional information regarding direct marketing is provided below.
1.3. Job Applicant Data. If you apply for a job with us, we collect your Personal Data when we process your job application. This includes your email, the content of your email, and any files you attach to it. Additionally, this may include your name, full contact details, resume, recommendations, and any other information we may request or that you choose to share with us.
How we use this data: We use this data to process your job application, including to contact you for scheduling purposes and to provide you with updates.
Legal Basis: We process this Personal Data based on our legitimate interests to attract and assess candidates for employment.
1.4. Event/Webinar Participant Data. From time to time, we hold special events, including webinars, in which you may be able to participate. We may collect your Personal Data when you register for the event, such as your name, contact details, and any other information we may request or that you choose to share with us.
How we use this data: We use this data for event planning and logistical purposes, to contact you with updates or to ask for your feedback regarding the event, to improve our events and services, and for marketing purposes.
Legal Basis: When we process this Personal Data in the course of planning for and running the event, we do so in order to perform a contract with you. When we process this personal data to improve our events and services, including to contact you for marketing purposes, we do so based on our legitimate interest to grow and improve our business and services..
2.1. Statistical Information and Analytics. We and/or our service providers use analytics tools, including “Google Analytics” to collect and analyze information about the use of the Site and/or Services, such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Site and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.
2.2. Direct Marketing. As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:
2.2.1. We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
2.2.2. You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at [email protected].
2.2.3. You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below. If our marketing activities are based upon your consent, you may withdraw this consent at any time.
We share your information, including Personal Data, as follows:
3.1. Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Services; (2) aid in their understanding of how users are using our Services; (3) for the purpose of direct marketing (see above for more details).
Such service providers and subcontractors provide us with IT and system administration services, data backup, data analysis, security and storage services, advertising and other marketing services.
3.4. Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
3.5. Advertisers. When you click on an advertisement for a Pulsenmore product or service, whether or not it’s on our Site, the relevant advertiser will be alerted that someone has visited the page on which the relevant advertisement was displayed, and may be able to identify that it was you by using certain mechanisms, like cookies. Advertisers are able to combine the Personal Data they collect independently with the Personal Data we share.
4.2. Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA“) and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
4.2.1. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
4.2.2. Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
4.3. Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
5.1. Safeguards. The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, SSL encryption of data and additional security controls.
5.2. Access Control. We dedicate efforts for a proper management of system entries and limit access only to designated and relevant authorized personnel on a need-to-know basis of, review permissions regularly, and revoke access immediately after employee termination.
5.3. Internal Policies. We maintain and regularly review and update our privacy related and information security policies.
5.4. Personnel. We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
5.5. Encryption. We encrypt the data in transit using secure https protocols.
5.6. Database Backup. Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.
5.7. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
5.8. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
6.1. Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
6.2. Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
6.3. Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
6.4. Deletion of Personal Data (“Right to Be Forgotten”). If you are an EU Individual, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (v) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should clear our cookies from any device where you have accessed our Site. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
6.5. Right to Restrict Processing. If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
6.6. Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at [email protected]. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
6.7. Right to Object. If you are an EU Individual, you can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
6.8. Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.
6.9. Right to Lodge a Complaint with Your Local Supervisory Authority. If you are an EU Individual, you may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
7.1. Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy.
7.2. In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
7.3. Please contact us at [email protected] if you would like details regarding the retention periods for different types of your Personal Data.
8.1. What are Cookies? A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns. First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies. We use the term “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.
|Type of Cookie||Why We Use These Cookies|
|Necessary||These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.|
|Functionality||These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.|
|Security||These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.|
|Performance/Analytics||These cookies can help us collect information to help us understand how you use our Site, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site.|
|Advertising||These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites. Such cookies may track your browsing habits and activity when visiting our Site and those of third parties.|
8.3. Third-Party Cookies and Pixels. We use the following third-party Cookies on our Site:
Additionally, HubSpot cookies may be placed in email messages we send in order to track your interaction with such emails.
8.4. How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting within your browser settings so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.
8.5. By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device. Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisements that you do see will be less relevant to your interests.
All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies.
We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may contact us at [email protected].
We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) is using the Services without parental permission, please advise us immediately.