PULSARA PRIVACY POLICY

 

What does this Privacy Policy Cover?


Pulsara respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making our website available to you (“Site”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

Third party links.

This Privacy Policy aims to give you information on how Pulsara collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.

Please note that this Privacy Policy does not cover processing of Personal Data carried out via, or in the course of operating, our web-based platform and associated application(s). We process all such Personal Data upon the instructions of our enterprise customers, pursuant to the terms of the data processing agreements we have with them. Our enterprise customers may be your healthcare provider(s), your employer, or the organisation to whom you provide services, depending on the circumstances. For information regarding processing of Personal Data via, or in connection with the operation of, our web-based platform and associated application(s), please contact that organisation (as applicable).

We will post any modifications or changes to this Privacy Policy on this page or a successor page about which we may notify you from time to time.

Who we are and how to contact us.

Who we are

We, Communicare Technology, Inc. are a corporation registered in Delaware, USA which determines the purpose for which and means by which your Personal Data is processed. (referred to as either “Pulsara”, “we”, “us” or “our” in this Privacy Policy).

Our registered address is 2880 Technology Boulevard West, Suite 183, Bozeman, MT 59718, USA.

How to contact us

To contact us, you may either:

  • email DPO@pulsara.com; or
  • write to us at our address shown above.


Our Data Protection Officer
Certain laws and regulations require us to appoint a “Data Protection Officer”, a person who is responsible for overseeing and advising us in relation to our compliance with applicable laws and regulations (including compliance with the practices described in this Privacy Policy). If you would like to contact our Data Protection Officer directly, you can email: DPO@pulsara.com.

 

Your rights relating to your Personal Data.


If your local laws or regulations contain these provisions, you may have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown here.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or, 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 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 and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us by:

  • emailing DPO@pulsara.com; or
  • writing to us at our address shown above.

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that your applicable laws and regulations may provide additional assistance from a governing or regulatory body.

Marketing communications preferences.


You can ask us to stop sending you marketing messages at any time by:

  • following the opt-out or ‘Unsubscribe’ links on any marketing message sent to you; or
  • by contacting us at any time using the contact details shown here.


Where you opt out of receiving these marketing messages, this will not apply to Personal Data Processed in connection with service-related emails (e.g., emails regarding updates to this Privacy Policy).

What Personal Data we Collect

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

 

Category of Personal Data collected

What this means 

Contact Data

  • Your full name. 
  • Your email address.
  • The organisation you work for or represent (should you provide it to us).
  • Job Title (should you provide it to us).
  • Phone Number (should you provide it to us).
  • Physical address information including Street Address, City, State, and Postal Code (should you provide it to us)
  • Any Personal Data you provide in any free-text ‘message’ fields via which you can communicate with us on the Site, including any comments you provide on our blog articles.

Marketing and Communications Data

Your preferences and information relating to our promotional emails, including send date, open date, delivery status, open status, click rates and locations, and your communication preferences.

Technical Data

Internet protocol (IP) address, browser type and version, time-zone setting and location, date and time that you access our Site, operating system and platform and other technology on the devices you use to access this website or use our services.

Analytics Data

The specific pages you visit at our Site, the number of visits you make to our Site, the websites that referred you to our Site, the number of visits to specific pages you make at our Site, products or services viewed at our Site, number and location of clicks on links on our Site.

 

Aggregated Data

We also create, Process and / or share “Aggregated Data” such as statistical or demographic data for any purpose based on use of the Site. This Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute or be considered Personal Data as defined by applicable law or regulation as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

 

No Special Categories of Personal Data

 

We do not collect any “Special Categories of Personal Data” about you (this 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). Nor do we collect any information about criminal convictions and offences.

 

Please do not provide us with any such data types.

 

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

 

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

 

What is our “legal basis” for processing your Personal Data?  

In respect of each of the purposes for which we use your Personal Data, we follow all applicable laws and regulations to ensure we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

 

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”). 

 

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.



Purpose

Category(ies) of Personal Data involved

Why do we do this

Our legal basis for this use of data

Promotion - including direct email marketing

  • Identity Data
  • Contact Data 
  • Marketing and Communications Data
  • Analytics Data

To respond to your requests for information about our technologies and to monitor the level and type of engagement with marketing communications we send.

To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.  

Consent or Legitimate Interests.

We have a legitimate interest in providing you with updates on our technologies and related offers. 

Messaging and Community Forums

  • Identity Data
  • Contact Data 

To allow website visitors to comment and interact on blog articles.

Legitimate interests. 

We have a legitimate interest in creating a forum for feedback and discussion on the blog articles we post on our Site.

Troubleshooting and Security 

  • Identity Data 
  • Marketing and Communications Data 
  • Technical Data
  • Analytics Data

To track issues that might be occurring on our systems.

To keep our website, our services and associated systems operational and secure.

Legitimate Interests.

It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Site and associated systems and services.

We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.

Compliance with Law

  • Identity Data
  • Contact Data 

We may Process your Personal Data (including sharing it with competent authorities or regulators, and/or our advisers (see below ) where necessary to comply with legal and regulatory requirements, and protect against fraud, illegal activity, and claims and other liabilities.

Compliance with Law.

Analytics

  • Technical Data
  • Analytics Data

To monitor the level and type of activity on our Site and the engagement with our Site and marketing communications we send.

To help operate our Site more efficiently and to make other improvements to our Site and the products and services we offer.

Consent or Legitimate Interests.

It is in our legitimate interests that we are able to monitor activity on our Site and make associated improvements to our Site and the products and services we offer.

 

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, respond to a request you made on our website, or to perform the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

 

In this case, we may have to stop you using our Site but we will notify you if this is the case at the time.

 

How we use cookies & other tracking or profiling technologies.

Cookies.

 

What are cookies?

 

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. 

 

We use two broad categories of cookies: 

  • first-party cookies, served directly by us to your computer or mobile device; and 
  • third-party cookies, which are served by our partners or service providers on our Site.

 

Cookies we use

 

Our Site uses the following types of cookies for the purposes set out below: 

 

Type of cookie

Purpose 

Essential Cookies

These cookies are essential to provide you with the core services available on our Site, and to enable you to use some of the Site’s features. Such core functionality includes security, network management, and accessibility.


Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies as described above.

Functionality Cookies

These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site. 

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. This data is aggregated with data pertaining to other users of our Site. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.


In addition to internal tools, we use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here:  https://developers.google.com/analytics/resources/concepts/gaConceptsCookies


You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.


These cookies may work with pixel tags included in emails we send to track which emails are opened and which links are clicked by recipients.

Advertising Cookies 

We use these cookies to display advertisements on third party websites that are relevant to you based on your behavior on our Site, and to track and manage the performance of those advertisements. 

 

Disabling cookies

 

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings. Please note that our site cannot function without Essential Cookies, and as such you are not able to decline the use of these cookies.

 

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may be served pop-ups or forms that you have already filled out or dismissed. 

 

For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, please visit www.allaboutcookies.org. At this time, we are not ‎honouring “do not track” signals from web browsers. If you do not wish for us to collect your information via cookies, ‎please follow the opt out procedure.‎

 

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.

 

Pixel Tags

 

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site and in our HTML formatted emails to track the actions of users on our Site and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our Site, so that we can manage our content more effectively.

 

Whom we share your Personal Data with. 

The table below describes to whom we share your Personal Data with, what we share, and why we share it. 

 

Recipients

Category(ies) of Personal Data we share.

Why we share it

Service Providers

  • Identity Data
  • Contact Data  
  • Technical Data
  • Analytics Data

Our service providers provide us with IT and system administration services.

Professional advisers

  • Identity Data
  • Contact Data

Our lawyers, bankers, auditors and insurers and other advisers who provide consultancy, banking, legal, insurance and accounting services.

Counterparties to Corporate Events  

  • Identity Data
  • Contact Data  
  • Technical Data
  • Analytics Data

In relation to actual or prospective corporate events (e.g., investments into Pulsara, or the sale, transfer or merger of all or part of our business, assets or shares), we may need to share certain personal data with prospective counterparties and their advisers. 


If we undergo any such corporate event, then the relevant counterparty should only use your Personal Data in the same way as set out in this Privacy Policy.

Revenue and Custom  regulators and other authorities

  • Identity Data
  • Contact Data

Authorities may require reporting of processing activities in certain circumstances.

 

Additionally, any of the recipients we share your Personal Data with may be located outside your country of residence.

 

Data transfers

We are a U.S.-based company. Although we do not have an establishment outside of the U.S., because we target the Site at individuals who are located in the United Arab Emirates, Kingdom of Saudi Arabia, and Qatar, local laws and regulations apply to us..

For this reason, we take appropriate steps to ensure that when we process your Personal Data (despite the fact that we are US-based) we do so in accordance with the requirements established by applicable laws and regulations. 

In addition, where we transfer your Personal Data to any of the third parties outlined above, we also take appropriate steps to ensure that we have implemented appropriate safeguards to ensure that such protection is maintained and is not undermined as a result of that disclosure. 

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data. 

How long we store your Personal Data.

We are committed to only keeping your Personal Data for so long as we reasonably need to use it for the purposes set out above. This general rule applies unless a longer retention period is required by law (for example for regulatory purposes). 

Our policy on children.

Neither our Site, nor our products or services, is intended for children below age 16, and we do not knowingly collect data relating to such children. If you believe your child has submitted personal data to us, please contact us at DPO@pulsara.com for further assistance.  

Updates

Pulsara may change this Privacy Policy from time to time. If we do, we will post the updated policy on our website and will indicate when this Privacy Policy was last updated. If we make any material changes, we will provide you with additional notice. You should periodically review our current Privacy Policy to stay informed of our personal data practices.

Third-party links.

This Site may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

 

Communicare Technology, Inc. (trading as “Pulsara”)

 

LAST UPDATED: May 24, 2021