Pulse Education & Business Services Limited
Privacy Notice
Version: 1.1
Release date: May 21st 2018
Revised date: July 7th 2019 (minor typing corrections and updates – no change to content)
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data, including any personal data received through our website at pulsecsi.com
By providing us with your personal data, you warrant to us that you are over 13 years of age.
Pulse Education & Business Services Limited (referred to as “we”, “us” or “our” within this privacy notice) is the data controller and we are responsible for your personal data that is collected and processed as described herein.
If you have any questions about this privacy notice, please contact us using the details provided:
Our Contact Details
Full name of legal entity: Pulse Education & Business Services Limited
Company number: 9529324
Name of data compliance contact within the company: Jacqui Thompson
Email address: info@pulsecsi.com
Postal address: The Studio, Farrier’s Gate, Cranwell Village, Lincolnshire, NG34 8NT
Your Contact Details
It is important that all information we hold about you is accurate and up to date. Please let us know of any changes to your personal information by email to info@pulsecsi.com
2. PERSONAL DATA WE COLLECT AND PROCESS
This section explains what data we collect about you, the purpose and lawful ground we process it.
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data. This includes any communication that you send to us whether it is through the contact form on our website, telephone call, email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of ongoing communication with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data. This includes data relating to any purchases of goods and/or services and will include personal data such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your payment details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data. This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain backups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business. Please note, unless otherwise indicated, the ‘user data’ referred to does not identify individual users and while the data helps us to see how our website is used (which content is most popular, etc), it cannot determine who (name etc) is using our website.
- Technical Data. This is closely related to ‘User Data’ (above) and includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system (eg: Google Analytics). We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and (if and where applicable) advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data. This includes your preferences about receiving marketing from us and your communication preferences (preferring to be contacted by phone or email for example). We store and process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and to measure and/or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
2.1 Personal Data Collection and Processing – Additional Notes
- Unless you have opted not to allow us to process your personal data (one of your rights discussed later in this document) or restricted what we may process (also referred to later) we may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts and/or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
- Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
- We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@pulsecsi.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
- We may process your personal data without your knowledge or consent where this is required or permitted by law.
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Automated Decision Making and Profiling
We do not carry out automated decision making or any type of automated profiling.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example over the phone, by filling in forms on our site or by sending us emails) or the data may have been provided to us in order for us to carry out contracted work for a third party; your employer, training provider, school or other third party appointed to provide the services that incorporate Pulse Education and Business Services workshop services.
If you have any concerns about personal data that has been provided to us by a third party in order for Pulse CSI to carry out contracted works, please contact your employer, training provider, school or another third party.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent (which may be withdrawn) or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations (PECR),we may send you marketing communications from us if
(i) you made a purchase or asked for information from us about our goods or services or
(ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing info@pulsecsi.com
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers.
Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer or store your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees who have a business need to know and access such data. Authorised employees will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances, we may anonymise (make individuals not identifiable by obscuring parts of the data, for example) your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under data protection laws (The Data Protection Act 2018 and The General Data Protection Regulation) you have the following rights in relation to your personal data;
- The right to be informed about intended usage and the retention period of your personal information. We (the data controller) must provide clear (no corporate or legal jargon) and unambiguous details about how we use (process) your data and the retention period.
- The right to access to data that is stored and/or processed (also known as a Subject Access Request).
- The right to rectification. If your data is incorrect or incomplete, we must correct it in a timely manner once we’ve been notified. Should this occur, we are required to verify your identity before making the changes.
- The right to erasure (also known as the Right to be Forgotten), which also includes the right to withdraw consent, gives you the right to have all your personally identifiable data deleted (excluding data that is necessary to be retained for contractual or legal reasons).
- The right to restrict processing. You have the right to request the restriction or suppression of your personal data. This not an absolute right and only applies in certain circumstances.
- The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services.
- The right to object to specific types of processing (ie: opting out of marketing without any need for a reason).
- Rights in relation to automatic decision making and profiling (you have the right to have a human intervention in the decision) and, if you are not satisfied with the outcome/decision, you can request an explanation and challenge it.
9.1 More about Your Legal Rights
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at info@pulsecsi.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive or excessive and we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate and reasonable requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10.THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
11. WEBSITE & COOKIES
Our website uses cookies to collect information that includes anonymous browsing behaviour by visitors, pages viewed and how users navigate around our website. Detailed information is set out in our Cookie Policy.
We use Google Analytics to collect anonymous internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone.
We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website. To view Google’s full privacy policy please visit Google’s own privacy page at policies.google.com/privacy/update.