PULSE PRIVACY AND COOKIE POLICY (Last updated May 28, 2018)

Pulse Business Solutions bv is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Pulse is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected online.

Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Privacy Statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the PII that we have obtained.

  1. Collection and use of personal information

1.1. What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to Pulse. When you register or submit personal information to Pulse we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a Pulse website and provide information about your preferences we will use this information to personalize your user experience. If you send us a resume or curriculum vitae (CV) to apply online for a position with Pulse, we will use the information that you provide to match you with available Pulse job opportunities.

1.2 The legal grounds we have to use your personal information

Pulse generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

The law in Europe allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

  • Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
  • Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
  • Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting Pulse at info@pulse.nl.

Pulse does not collect special categories of personal data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences.

1.3 Automatic collection of personal information
In some instances, Pulse and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, except when you did not authorize us to do so when you first visited us online. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of Pulse’s online presence, and to measure the effectiveness of our marketing activities.

1.3.1 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

1.3.2 Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.

BY NAVIGATING ON OUR WEB SITE, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

1.3.3 Google Analytics

Pulse uses Google Analytics. More information about how Google Analytics is used by Pulse can be found here: Google Analytics

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1.3.4 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Pulse only uses web beacons in accordance with applicable laws.

Pulse or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1.4 Social media widgets and applications

Pulse websites may include functionality to enable following Pulse via third party social media applications, such as Facebook and Twitter widget. These social media applications may collect and use information regarding your use of Pulse websites. Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

  1. Sharing and transfer of personal information

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs and/or as required or permitted by law or professional standards. Pulse will not transfer personal information outside of the EEA nor store personal information there. Pulse will not sell nor transfer the personal information you provide to any third parties for their own direct marketing use.

  1. Choices

In general, you are not required to submit any PII to Pulse online, but we may require you to provide certain PII in order for you to receive additional information about our services and events. Pulse may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

  1. Your rights

If Pulse processes personal information about you, you have the following rights:

Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.

Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more.

Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting Pulse at info@pulse.nl and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

  1. Data security and integrity

Pulse has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite Pulse’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual’s request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted.

  1. Changes to this statement

Pulse may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

  1. Policy questions and enforcement

Pulse is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at info@pulse.nl. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement. In any event, you always have the right to lodge a complaint with the Dutch regulator in charge of protecting personal information, the Dutch Data Protection Authority / De Autoriteit Persoonsgegevens (AP).

References to Pulse in this document refer to Pulse Business Solutions bv, with its address at Noorderpoort 21, 5916 PJ Venlo, The Netherlands.