Privacy Policy

Policy

General privacy statement

Pulse HF is committed to handling personal data with confidentiality and in compliance with applicable privacy and data protection laws, including the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA). Effective May 25, 2018, the GDPR grants persons in the European Economic Area (EEA) several rights, including the right to withdraw consent for collection of their data and to request access to or deletion of their personal data. CCPA, which took effect on January 1, 2020, confers similar rights on residents of California. This policy provides further information about both of those laws, and how you may exercise your rights under them. For GDPR information, click [here], and for CCPA, click [here].

 

Our privacy policy applies to all visitors to www.pulsehf.com as well as subscribers to our mailing list, regardless of location or country of residence. It explains which data is collected and how it is handled. This privacy policy does not apply to any third-party websites or pages linked through

our site or content. This policy does not address Pulse HF’s handling of research-related data; that information is contained in a separate policy.

How Pulse HF handle personal data

Pulse HF does not collect personal information when visiting our website, other than information automatically collected and stored (see “Cookies Policy” below), unless visitors actively choose to provide that information to us. Visitor information will never be sold to third parties.

By subscribing to the Pulse HF newsletter, events and updates mailing list, visitors are actively consenting to share specified personal data with us. Visitors email address will be used to send content to them. Other information visitors opt to provide upon subscribing (name, title, company, etc.) is used only to better customize content to our audience. Visitors may unsubscribe at any time by clicking the link in the footer of any of our email updates.

Keeping personal data safe is important to us. Pulse HF does not sell visitor information or share it with third parties for their own marketing purposes. If someone signs up to receive updates from us, we may use trusted email marketing, website analytics, and customer relationship management service providers to help us send communications, manage subscriptions, and understand basic engagement, such as email opens, link clicks, and website activity.

These service providers process personal data only on our behalf and only for the purposes we instruct. We require them to protect personal data appropriately and not to sell or use it for their own independent purposes. Subscribers can unsubscribe from our marketing emails at any time by using the unsubscribe link in our emails or by contacting us directly.

Before using a new platform or service provider that processes personal data, Pulse HF will confirm that the provider fits within the categories described in the Privacy Policy and will review appropriate privacy and data protection terms, such as a data processing agreement where applicable. If the provider does not fit within the existing categories, or if the processing materially changes, the Privacy Policy should be updated before the new processing begins.

Cookie policy

Pulse HF uses cookies to help us improve our site through audience and usage analytics. A cookie is a small amount of data, which often includes a unique identifier, that is sent to your browser and downloaded to your device’s hard drive when you visit a website. It is common for websites to do this every time a user visits to recognize repeat visitors, track web traffic, improve search results, and more. Our website includes content embedded from third parties, which may also set cookies of their own when you visit a page within our site. Visitors may adjust your browser settings to disable cookies, but this may restrict access to certain features of our site.

Data retention

Personal Data Retention: As a general matter, Pulse HF retains Visitor’s Personal Data for as long as necessary to carry out the activities described in this Policy, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. Please note that Pulse HF may retain this (and other) Information whenever and so long as Pulse HF have a significant legal or operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.

International Transfers

Pulse HF may store and process visitor information in the United States. By accessing the website or our Services, visitors understand that the information provided to us may be stored in or (if applicable) transferred to the United States. Visitors should be aware that certain privacy laws in the United States and the other countries regarding processing the information may be less stringent than in their country.

European Union General Data Protection Regulation (GDPR)

Basis for processing

The processing of personal data is based on the following legal grounds, if visitors are in the European Economic Area (EEA):

• Performance of a contract. When Pulse HF need to process personal data to enter into a contract with visitors or their employer or to perform a contract that visitors or their employer may have with us, the processing is based on Article 6, section 1 (b) For example, when visitors use our services, Pulse HF will use personal data to respond to your requests and provide you with such services.
• When Pulse HF process personal data based on visitor’s consent, the legal ground for processing is Article 6 section 1 (a) GDPR.
• Legal obligation. When the processing of personal data is necessary for compliance with a legal obligation to which Pulse HF are subject, the processing is based on Article 6 section 1 (c)
• Legitimate Pulse HF may process personal data for our legitimate interests, e.g. to improve our products and services and to provide visitors with relevant information including information for marketing purposes. When Pulse HF processes personal data based on our legitimate interests, the legal ground for such processing is Article 6, section 1 (f) GDPR.

Rights in the EEA

As a data subject in the EEA, visitors have the following rights:

• The right to Under Art. 13 of GDPR, visitors have the right to be informed whether and to what extent Pulse HF process your personal data.
• The right of Under Art. 15 of GDPR, visitors have the right to request confirmation of whether Pulse HF process your personal data, and to request access to data Pulse HF may have about you.
• The right to rectification. Under Art. 16 of GDPR, visitors have the right to request correction or completion of personal data, if Pulse HF has data that is incorrect or
• The right to Under Art. 17 of GDPR, visitors have the right to request deletion of their personal data. Immediate deletion may not be possible if the retention of personal data is still required to meet legal or regulatory obligations.
• The right to restrict processing. Under Art. 18 of GDPR, visitors have the right to request a restriction of the processing of personal data under certain conditions: a) If you have reasons to doubt the accuracy of your personal data, you may request that its processing is restricted while Pulse HF verify its accuracy, b) If the processing of your personal data is considered unlawful, but you do not request the deletion of your personal data, c) If Pulse HF no longer need the data for the purposes of its processing, but you need it for the establishment, exercise or defense of legal claims, d) If you object to the processing of your personal data based on our legitimate interests under Art. 6(1) (f) GDPR, or where the processing is based on Art. 6(1) (e) GDPR.
• The right to data Under Art. 20 of GDPR, where the processing takes place based on visitor consent or contract and is carried out by automated means, visitors have the right to request that Pulse HF provide your personal data to you in a machine-readable format.
• The right to object to the Under Art. 21 of GDPR, visitors have the right to object to the processing of personal data in certain situations.
• Rights in relation to automated decision making and Under Art. 22 of GDPR, visitors have the right to object to decisions based exclusively on the automated processing of personal data.
• The right to withdraw If personal data is processed based on consent (Art. 6 (1) (a) or Art. 9 (2) (a) GDPR), visitors have the right to withdraw their consent at any time. The withdrawal of their consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Visitors also have the right to file a complaint with a competent supervisory authority. For more information, please contact the local data protection authority. Contact details for data protection authorities in the European Union are available at europa.eu.

Addendum for California consumers’ Privacy Rights

This section applies to Personal Information that Pulse HF handle as a “business” (as defined under the California Consumer Privacy Act of 2018 (“CCPA”)) if visitors are a California resident. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In addition, this section does not apply to Personal Information reflecting communications or transactions with visitors in their capacity as an employee, controlling owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency, where  communications or transactions with us occur solely within the context of our provision of services to, or receipt of services from, such an entity. Pulse HF does not sell (as that term is defined in the CCPA) the Personal Information Pulse HF collects (and will not sell it without providing a right to opt out).

YourCaliforniaprivacyrights.

Visitors have the following rights under the CCPA:

• To request the following information about how Pulse HF have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that Pulse HF have
  • The categories of sources from which Pulse HF collected Personal
  • The business or commercial purpose for collecting Personal
  • The categories of third parties with whom Pulse HF share Personal
  • Whether Pulse HF have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third-party recipient.
• To request a copy of the Personal Information that Pulse HF have collected about you during the past 12 months.
• To request that Pulse HF delete the Personal Information that Pulse HF have collected from
• To exercise the rights described above free from discrimination as provided in the CCPA. Pulse HF do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights
• Pulse HF do not knowingly collect personal information from minors under 16 years of age in California unless Pulse HF have received legal consent to do If Pulse HF learn that personal information from such California residents has been collected, Pulse HF will take reasonable steps to remove their information from our database (or to obtain legally required consent)

How to exercise your rights under CCPA.

Visitors may submit a request to exercise your information, access or deletion rights by emailing privacy@pulsehf.com. Pulse HF will need to verify your identity to process your information, access and deletion requests and Pulse HF reserve the right to confirm your California residency. Government identification may be required. If visitors wish to designate an authorized agent to make a request on your behalf, Pulse HF will need to verify both them and their agent’s identities and their agent must provide a valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. Pulse HF cannot process a request if not provided with sufficient detail to allow us to understand and respond to it. In certain cases, Pulse HF may be required or permitted by law to deny a request.

Collection, use and disclosure of Personal Information.

The categories of Personal Information that our website collects include location data and related device and internet activity information as described in Section 1798.140(o) of the CCPA. The business/commercial purposes for which Pulse HF use these categories of Personal Information and the categories of third parties with whom Pulse HF share this information are described above in the sections “How Pulse HF Handle Personal Data” and “Cookie Policy.” The foregoing describes our practices as of, and during the twelve-month period preceding, the effective date of the Privacy Policy.

Changes to our privacy policy

Any future changes Pulse HF make to our Privacy Policy will be posted to our site and, where appropriate, communicated directly by newsletter or email.

Questions

If visitors have any questions about Pulse HF’s Privacy Policy or wish to contact us to exercise any of the rights outlined in this policy they are recommend to contact privacy@pulsehf.com.