Privacy Policy Last updated: 24/02/2024
We are dedicated to protecting your Personal Data and your privacy.
This Privacy Policy aims to inform you about how We handle, collect, store, and use the information you provide in connection with the website try-pulseapp.com (the “Website”).
We will adhere to the following principles:
• To be transparent in respect of the collection and processing of your Personal Data:
We prioritize ensuring that you are always fully informed, enabling you to make informed choices regarding the use of your Personal Data on our Website or when initiating trade with a third-party trading platform. To achieve this, we employ a range of strategies and methods designed to offer you pertinent details on how your Personal Data is processed, ensuring this information is delivered accurately and timely.
Additionally, if We find that you need to be provided with specific information, We will provide it to you in a timely and appropriate manner.
We are also happy to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Us by sending an email to the following address: support@try-pulseapp.com
• To process your Personal Data solely for the purposes outlined in this Policy:
The purposes for which We may process your Personal Data include, among other things, making the Website available to you andprovide you with a connection to third-party trading platforms (the “Services”), enhancing your experience on the Website, improving the Services (including the Website), protecting our rights and interests, supporting business and administrative activities that facilitate the provision of the Services to Website users, and/or complying with legal and regulatory requirements.
Additionally, we will process your Personal Data to better understand your individual needs and preferences.
• Investing significant resources to uphold your rights concerning your Personal Data:
We dedicate substantial resources to enable you to exercise your rights as a data subject. Thus, you may contact us anytime to review your Personal Data, request amendments, erasure, restriction of use for specific purposes or in general, or transfer it to you or a third party. We will honor your requests in accordance with the law.
•Securing your Personal Data:
While we cannot guarantee absolute protection of your Personal Data, we assure you that we employ and will continue to employ a comprehensive range of measures to ensure its security.
Our Complete Privacy Policy
1. The Scope?
This Policy outlines the types of Personal Data the Company collects about natural persons, and how it is collected, used, shared with third parties, secured, and processed.
In this Policy, “Personal Data” refers to any information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified, directly or indirectly, by reference to additional information that we have or can access.
In this Policy, the “processing” of Personal Data encompasses any operation or set of operations performed on Personal Data, including its collection, recording, organization, structuring,storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
Our Services are designed for a general audience and are not intended for individuals under 18 years of age. We do not knowingly collect or request information from anyone under 18, nor do we knowingly permit such individuals to use our Services. If we discover that we have collected information about a child, we will take appropriate steps to delete such information promptly.
2. When Do We Collect Personal Data About You?
We gather Personal Data about you whenever you utilize the Services, engage with our service channels, or visit the Website. Sometimes, you will actively provide us with Personal Data, while other times, we will collect Personal Data by analyzing your interaction with Our Services and/or service channels or by receiving your data from our third-party partners.
3. No Obligation To Provide Personal Data To The Company And Its Implications
You are not required to provide us with any Personal Data. However, in certain cases, withholding such Personal Data may prevent us from offering you the Services, limit your access to the Website, and/or cause the Services and the Website to malfunction.
4. What Types of Personal Data Do We Collect? Personal Data We Collect Upon Each Visit to the Website:
This information includes online activity logs, traffic data (including, but not limited to, IP address, time of access, date of access, web and mobile pages visited, language used, software crash reports, and type of browser used), and information about the device you used. Some of this information may not identify you personally and therefore may not constitute Personal Data.
Personal Data We Receive From You: Any Personal Data you willingly provide to us when interacting with a third-party trading platform through Pulse App.
Personal Data You specifically provide for submission to third-party platforms in order to trade: This includes your full name, telephone number, and email address.
5. The Purposes of The Processing Of Personal Data And Their Legal Basis
Pulse App processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.
Pulse App will not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which Pulse App may process Personal Data about you are as follows:
- You have given consent to the processing of your Personal Data for one or more specific purposes. This refers to cases where you specifically provide your details through the Website, so that We may submit them to a third-party trading platform.
- Processing is necessary for the purposes of the legitimate interests pursued by Pulse App or by a third party. For example, for the purpose of improving Our Services, or for the exercise or defense of legal claims.
- Processing is necessary for compliance with a legal obligation to which Pulse App is subject.
Should you require additional details on how the processing of your Personal Data aligns with the legitimate interests of Pulse App or an external party, please feel free to reach out to us via email at any moment.
Below, we present a summary of the reasons we might process your Personal Data, along with the legal grounds for such activities:
Purpose | Legal Basis | |
1 |
To share your details with third parties upon your request to facilitate digital and trading interactions. We may gather your Personal Data to forward it to third parties, but only if you have explicitly requested us to do so. |
You have given consent for your Personal Data to be processed for one or more specific purposes. |
2 |
To address your inquiries, requests, and/or complaints Processing your Personal Data is necessary to respond to any questions or concerns you have about using the Services. |
Processing is essential for the legitimate interests pursued by Pulse App or by a third party. |
3 |
To fulfill any legal obligations or comply with judicial or administrative orders We handle your Personal Data to meet Our diverse legal responsibilities. |
Processing is essential to comply with a legal obligation to which the Company is bound. |
4 |
To enhance Our Services We may utilize your Personal Data to improve Our Services. This processing includes, among other things, any crash logs or malfunction reports related to the Services. |
Processing is necessary to serve the legitimate interests pursued by the Company or a third party. |
5 |
To prevent fraud and misuse of Our Services |
Processing is necessary to serve the legitimate interests pursued by the Company or a third party. |
6 |
To conduct and support various activities related to the provision of Our Services Such activities encompass back-office functions, business development efforts, strategic decision-making, and oversight mechanisms, among others. |
Processing is essential for pursuing the legitimate interests of the Company or a third party. |
7 |
To conduct analysis, including statistical analysis We employ a variety of analytical methods (including statistical analyses) to inform decisions on various matters. |
Processing is essential for pursuing the legitimate interests of the Company or a third party. |
8 |
To safeguard our interests, rights, and assets, as well as those of third parties, including the initiation, exercise, or defense of legal claims We may process your Personal Data to protect our interests, rights, and assets, or those of third parties, in accordance with any applicable law, regulation, or agreement, including our terms and conditions and policies. |
Processing is essential for pursuing the legitimate interests of the Company or a third party. |
6. Transfer Of Personal Data To Third Parties
The Company may also share Personal Data about you with third parties that provide services to us, such as storage and hosting providers, IP address information, user experience analysis, and research, as well as analytical, technical, and diagnostic services.
Additionally, you may specifically request that we submit certain Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data that you provide to us for this purpose with those third parties. Their use of your Personal Data will be governed by their own privacy policies. We may share your Personal Data with multiple third-party trading platforms.
The Company may also share Personal Data about you with its related entities and business partners. These entities provide resources that enable the Company to enhance and improve the quality of services and products offered to its users.
The Company may share Personal Data about you with governmental, local, official, and regulatory authorities, particularly if such disclosure is required to protect our and third parties' interests, rights, and assets, including the initiation, exercise, or defense of legal claims.
Furthermore, we may disclose Personal Data about you to potential purchasers, investors, or lenders to the Company and/or any company within the group of companies to which the Company belongs. This includes scenarios involving similar transactions (such as the sale of assets of the Company and/or any company within the group of companies), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of the Company and/or any company within the group of companies to which the Company belongs.
7. Cookies and Third-Party Services
We may use certain third-party services, such as analytics companies or companies delivering advertisements on our Website. These third parties may also use cookies or other technologies, and their practices and policies are subject to their own terms.
A cookie (which is a small text file) is installed on the device through which you visit or access the Website. These cookies allow us to collect information about you and your behavior, in order toenhance your user experience, remember your preferences and settings, and tailor our products and services to your interests. Cookies may also be employed to gather statistics and perform analytics.
We may utilize both session cookies, which are temporarily downloaded to your device and last until you close your web browser, and persistent cookies, which remain on your device after you finish browsing and help the Website recognize you as a returning visitor.
Types of cookies:
The cookies we may use are categorized by their functionality, as follows:
Type of Cookie | Purpose | Additional Information |
Strictly Necessary Cookies |
These cookies are essential for you to navigate the Website and utilize requested features. They provide you with our content, products, and services that you have requested. These cookies are crucial for your device to download or stream information, enabling you to move around the Website, use its features, and revisit pages you have previously accessed. |
These cookies gather Personal Data about you, such as your username and last login date, and identify you as logged in to the Website. These cookies are removed once you close your web browser (session cookies). |
Functionality Cookies | These cookies help us recognize you when you return to Pulse App, allowing us to remember your preferences and settings. | These cookies persist even after you close your web browser and remain active until their designated expiry time. |
Performance Cookies | These cookies are used to compile aggregated statistics on the performance of Pulse App, helping us test and enhance our platform for a superior user experience. They also enable us to conduct analytical functions. |
These cookies gather anonymized data that cannot be traced back to an individual. The validity of these cookies varies; some are removed when you close your browser, while others may have a longer or indefinite lifespan. |
Blocking and Removing Cookies
You can adjust your browser settings to block and delete certain or all cookies. Refer to the following links for instructions on how to manage cookies in some of the most popular web browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please be aware that disabling cookies may impact the functionality and performance of the Pulse App.
ONLINE TRACKING NOTICE
AT THIS TIME, PULSE APP DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.
8. Retention Of Personal Data About You
The Company will retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, or for a longer duration as required by applicable laws, regulations, policies, and orders.
We may share your information with third-party trading platforms for a period of 12 months and, subject to your consent, for an additional 12 months.
To ensure that your Personal Data is not kept longer than necessary, we periodically review the retained data to determine if any can be safely deleted.
9. Transfers of Personal Data To A Third Country Or An International Organization
Your Personal Data may be transferred to countries outside of your residence jurisdiction or to international organizations. In such cases, the Company will implement appropriate safeguards to protect your data and ensure that enforceable data subject rights and effective legal remedies are available.
If you are a resident of the EEA (European Economic Area), please note that these safeguards will be in place if any of the following conditions are met:
- The transfer is to a third country or an international organization that the EU Commission has determined offers an adequate level of protection for the Personal Data transferred to it, in line with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is based on a legally binding and enforceable instrument between public authorities or bodies in accordance with Article 46(2)(a) of the GDPR; or
- The transfer adheres to standard data protection clauses adopted by the EU Commission as per Article 46(2)(c) of the GDPR. You can view the clauses adopted by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
You may request that Pulse App provide you with details concerning the safeguards employed to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address: support@try-pulseapp.com
10. Protection Of Your Personal Data
We implement appropriate technical and organizational measures to ensure an adequate level of security for Personal Data, taking into account the risks posed by processing, particularly from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.
We cannot guarantee, nor do we represent, that there will be error-free performance regarding the privacy of your Personal Data, and we will not be liable for any indirect, incidental, consequential, or punitive damages related to the use or release of Personal Data about you, including but not limited to, disclosure of Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control.
We may be required, due to legal or other obligations beyond our control, to transfer Personal Data about you to third parties,such as public authorities. In such cases, our ability to control the level of protection for your Personal Data by these third parties is limited.
Any transfer of Personal Data via the internet carries some level of risk. Consequently, Pulse App cannot guarantee the absolute security of your Personal Data when transmitted over the internet to us.
11. Links To Websites of Third Parties
The Website may contain links to third-party websites and/or applications. Pulse App does not manage these websites and applications, nor their collection and processing of your Personal Data. We are not accountable for these websites and applications or their privacy and data protection practices. This Policy does not cover any actions taken on such websites and/or applications.
Whenever you visit these third-party websites and/or applications, we advise you to thoroughly review their privacy policies before using them and before sharing any Personal Data.
13. Your Rights in Respect Of The Personal Data About You
Generally, you have the right to request confirmation from us regarding whether your Personal Data is being collected. You can ask to review such data, correct it if necessary, and request the deletion of Personal Data that we no longer need. You may also limit your consent to certain types of processing of your Personal Information.
If you are an EEA resident please read this section below:
You have the following rights concerning your Personal Data. To exercise these rights, please send your request to the following email address:
Right of access
You have the right to obtain confirmation from Pulse App about whether or not your Personal Data is being processed. If it is, you have the right to access the Personal Data along with the following information:information: (1) the objectives behind the processing; (2) the types of Personal Data involved; (3) the recipients or categories of recipients who have received or will receive the Personal Data, especially those in third countries outside the European Economic Area (EEA) or international organizations; (4) if feasible, the intended duration for which the Personal Data will be retained, or if not feasible, the criteria used to establish that duration; (5) the existence of the right to request from the Company the correction or deletion of Personal Data or restriction of processing of Personal Data about you or to oppose such processing; (6) the right to file a complaint with a supervisory authority; (7) if the Personal Data is not obtained from you, any available information regarding its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards pertaining to the transfer.
Pulse App shall provide a copy of the Personal Data undergoing processing and may impose a reasonable fee for any additional copies requested by you. If you make the request via electronic means, and unless otherwise specified by you, the information shall be provided in a commonly used electronic format.
The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request compromises the rights and freedoms of others, Pulse App may not fulfill your request or may do so in a limited manner.
Right to rectification
You have the right to request from Pulse App the correction of inaccurate Personal Data concerning you. Considering the purposes of the processing, you have the right to have incomplete Personal Data about you completed, including by providing a supplementary statement.
Right to erasure
the following grounds apply: (a) the Personal Data is no longer necessary for the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal basis for the processing; (c) you object at any time, on grounds related to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) thePersonal Data has been unlawfully processed; or (f) the Personal Data concerning you must be erased to comply with a legal obligation under European Union or Member State law to which the Company is subject.
This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing under European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.
Right of restriction of processing
You have the right to request that Pulse App restricts the processing of your Personal Data if one of the following conditions applies: (a) the accuracy of your Personal Data is contested by you, allowing Pulse App time to verify its accuracy; (b) the processing is unlawful and you oppose the erasure of your Personal Data, requesting instead that its use be restricted; (c) Pulse App no longer needs your Personal Data for processing purposes, but you require it for the establishment, exercise, or defense of legal claims; (d) if the processing of your Personal Data is necessary for the legitimate interests pursued by Pulse App or a third party, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling, to the extent it relates to such direct marketing.
If the processing of your Personal Data has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a Member State.
Right to Data Portability
You have the right to obtain your Personal Data, which you've supplied to Pulse App, in a structured, commonly used, and machine-readable format. Additionally, you have the right to transfer that data to another entity if the processing is based on your consent or a contract to which you are a party, and if the processing is automated.
When you exercise your data portability right, you can have your Personal Data transferred directly from the Company to another entity, if it is technically feasible. This right does not interfere with your or the Company's rights concerning data deletion. Additionally, exercising this right should not adversely affect the rights and freedoms of others.
Right to Withdraw Consent
You can withdraw your consent for us to process your Personal Data at any time. This withdrawal will not impact the legality of any processing carried out before your consent was revoked.
Right to Object
You have the right to object to the processing of your Personal Data at any time, particularly if it relates to your specific situation and the processing is based on the legitimate interests of the Company or a third party. This includes any profiling based on these interests. If you object, we will cease processing your Personal Data unless we can present compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
You also have the right to object to the processing of your Personal Data for direct marketing purposes at any time, including any related profiling.
Right to Lodge a Complaint with a Supervisory Authority
You have the right to file a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons concerning the processing of Personal Data within the European Union.
Your rights regarding Personal Data as outlined in this section 13 may be limited by European Union or Member State law to which the Company is subject.
We will provide you with the requested information according to your rights outlined in this section 13 without undue delay and within one month of receiving the request. This period may be extended by two additional months if necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, along with the reasons for the delay.
The information requested according to your rights outlined in this section 13 shall be provided free of charge, unless stated otherwise in this section 13. Where requests are manifestlyunfounded or excessive, particularly due to their repetitive nature, we may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the requested action; or (b) refuse to act on the request.
The Company may require you to provide additional information necessary to verify your identity to fulfill your request according to your rights outlined in this section 13, if we have reasonable doubts about the identity of the individual making the request.
12. Changes To This Policy
We may update the terms of this Policy from time to time. Whenever we make changes to this Policy, we will notify you by publishing the updated Policy on the Pulse App website. Additionally, when we make significant changes to this Policy, we will endeavor to inform you through means we consider reasonably appropriate and by posting a notice on the website. Unless specified otherwise, all changes will take effect upon the publication of the updated Policy on our website.