Privacy Policy

Last updated: 19 June, 2018

This privacy policy ("Privacy Policy") is issued by Pulse Global Limited (Company Registration No. 2455493), a company incorporated in Hong Kong with its registered address at Block A, 2/F Hong Kong Industrial Building 444-452 Des Voeux Road West, Kennedy Town, Hong KongSuite 1803, 18/F, Beautiful Group Tower, 77 Connaught Road, Central, Hong Kong ("Pulse" or "us"). This Privacy Policy sets out the terms on which Pulse will collect, use, disclose, process and manage personal data.

This Privacy Policy applies to Personal Data collected by Pulse and Personal Data in Pulse's possession. By creating an account on the Platform, using our services, the Platform and/or the App, or providing Pulse with the Personal Data, visitors and users (referred to in this Privacy Policy as "you") consent to Pulse's collection, use, disclosure, processing and management of your Personal Data, in accordance with this Privacy Policy. If you do not agree to the terms of the Privacy Policy, please do not provide Pulse with any Personal Data, and cease your use of any of Pulse's services.

If you need to contact us in relation to this Privacy Policy, you may email our support team at support@pulseid.com

1. Definitions and interpretation

1.1  In this Privacy Policy, unless the context otherwise requires, the following definitions shall apply:"App" means the Catalyst XP mobile app developed by Pulse, which can be downloaded, but not limited to, from the Apple App Store and the Google Play Store."Applicable Laws" means all applicable statutes, enactments, acts of the state legislature or parliament, laws, ordinances, rules, bye-laws, regulations, notifications, guidelines, directions, directives and orders of any governmental authority, statutory authority, tribunal, board, court or recognised stock exchange, and (as may be applicable) international treaties and regulations."Catalyst Terms of Use" means the terms and conditions governing the use of the Platform and/or the App, and as amended by Pulse from time to time, the latest version of which can be accessed athere."Data Protection Legislation" means the PDPA and all Applicable Laws and regulatory requirements relating to (i) the collection, use, disclosure, security, protection and/or processing of personal data and/or (ii) privacy, including where applicable the guidance and codes of practice issued by the Personal Data Protection Commission of Singapore. "PDPA" means the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore."Personal Data" means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which an organisation has or is likely to have access."Platform" means the products, developed by Pulse, which can be accessed via a private link shared by Pulse iD's support team.

1.2  Any capitalised expression used but not otherwise defined in this Privacy Policy shall have the meaning given to such expression in the Catalyst Terms of Use issued by Pulse.

2. Collection of Personal Data

2.1 Pulse may collect Personal Data such as:
(a) name, contact information such as your email address and telephone number, mailing address and your company name;
(b) transactional information based on your activities on the Platform and/or App, including how you use our services, the Platform, and/or the App;
(c) if you use the Platform:
(i) technical information provided by your internet browser, including but not limited to the computer's internet protocol address, browser type, webpage you were visiting prior to arriving at the Platform, the browsing history on the Platform, the time spent on the Platform's pages, the items and information searched for on the Platform, access times and dates, and other statistics;
(ii) information collected by cookies, web beacons, and other similar technologies; and
(d) if you use the App:
(i) non-personal information about your device, including your device type, operating system, local time and timezone, language settings;
(ii) information about your device identifier, location data (latitude, longitude, velocity, altitude, heading, direction), accuracy of location data, time stamp for each location reading, and movement activity type;(iii) sensor data from your device, such as accelerometer and gyroscope data; and
(iv) connectivity information on how your device is connected to the Internet, including but not limited to your device's internet protocol address, wi-fi connection details, and your internet service provider; and

2.2 Pulse may collect Personal Data when:
(a) a third party provides us with your Personal Data
(b) you register with Pulse for any of Pulse's services, the Platform and/or the App;
(c) when you install the App on your device, and your Personal Data may be collected for so long as the App is installed on your device, even if you are not actively using it;
(d) you use any of Pulse's services, the Platform and/or the App
(e) you provide us with any Personal Data or document containing Personal Data to us;
(f) you report a problem with our services, the Platform or the App, provide your feedback to Pulse, or otherwise communicate with Pulse.

2.3 Cookies
(a) We use cookies, for example, to remember your settings (e.g. language preference) and for authentication. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Platform and/or the App, but your ability to use some features or areas of the Platform and/or the App may be limited.
(b) Third parties may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
(c) You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform and/or the App. You consent to our use of these cookies when you log in to the Platform and/or the App.

2.4 To the maximum extent permitted by law, you agree to indemnify us against any complaint, claim, damage, loss, penalty or fines relating your provision of Personal Data to us.

2.5 By providing us with any Personal Data relating to a third party, you represent, warrant and undertake that you are duly authorised to provide Pulse with such Personal Data, and that the relevant third party has given its consent for Pulse's collection, use, disclosure, processing and management of such Personal Data.

2.6 To the maximum extent permitted by law, you agree to indemnify us against any complaint, claim, damage, loss, penalty or fines relating to your provision of Personal Data to us, including but not limited to the representation, warranty and undertaking in respect of a third party's Personal Data.

3. Use and Disclosure of Personal Data

3.1 Pulse may store and use Personal Data to:
(a) verify your identity, update our records and generally maintain your account with us;
(b) provide our services, the Platform and/or the App and/or customise the content shown to you;
(c) develop, improve and deliver our services, the Platform and/or the App,(
(d) operate and maintain our services, the Platform and/or the App including but not limited to:
(i) detecting and preventing fraud;
(ii) keeping our websites, apps, products and systems secure;
(iii) ensuring that our own processes, procedures and systems are as efficient as possible;
(iv) analysing and enhancing the information that we collect;
(v) to use internet protocol addresses, device and location identifiers to identify the location of users and block any unauthorised users;
(e) create and maintain a location history from the location data provided, which will be collected by the App or provided by a third party, and which will be transmitted, retained and used by Pulse to provide its services
(f) the location history may be used with your personal data by Pulse only when you report a problem with our services, the Platform or the App, or provide your feedback to Pulse;
(g) create, operate and confirm the geographic area targeting of campaigns created by Pulse Customers on the Platform, and to send you notifications through the App, and to provide Pulse Customers with research and analytics on their campaign performance and your movement patterns;
(h) send you location-based notifications through the App;
(i) respond to your queries and resolving complaints;
(j) carry out polls, surveys, analysis and research on how our services, the Platform and the App are being used and how these can be improved;
(k) conduct research into the development of new products and services, or improvement of existing products and services;
(l) carry out research, planning and statistical analysis;
(m) update you on the Platform, the App and the services;
(n) send you service-related messages;(o) perform functions or services as otherwise notified to you at the time of collection;
(n) prevent potentially prohibited or illegal activities;
(q) comply with our legal obligations and requirements, whether pursuant to the terms of use of the Platform and/or the App, or any other agreement, under any applicable laws, or otherwise; and
(r) enforce obligations owed to us.3.2 Pulse will take reasonable steps to protect Personal Data against unauthorised disclosure.

3.3 Pulse may disclose Personal Data to third parties, including to Pulse Customers:
(a) for any of the purposes listed in clause 3.1 above;
(b) to provide necessary products or services on behalf of or for Pulse, including but not limited to:
(d) operate and maintain our services, the Platform and/or the App including but not limited to:
(i) human resource management, debt collection, hosting and maintenance services, delivery services, handling of payment transactions, and marketing;
(ii) professional services such as bookkeeping, legal advice, audit, and tax advice;
(iii) assisting Pulse in the provision of products and services to you, including but not limited to IT infrastructure providers and support service providers;
(c) for Pulse Customers to create, operate and confirm the geographic area targeting of their campaigns created on the Platform;
(d) to fulfil Pulse's respective contractual obligations; and(e) as required or permitted by law, including to regulatory authorities, statutory bodies or public agencies pursuant to any legislation, regulations, requirements, policies, directives, guidelines, orders and contracts.3.4 Pulse may also transfer Personal Data to any location outside of Singapore for any of the purposes listed in clause 3.1 above, provided that the requirements of the PDPA are complied with. Pulse shall ensure that the Personal Data transferred outside of Singapore is protected at a standard that is comparable to the protection under the PDPA.

3.5 Pulse shall retain Personal Data for as long as the purpose for which the Personal Data was collected remains, and until such time when retention of the Personal Data is no longer necessary for any other legal or business purposes.

4. Withdrawal of Consent

4.1 You may withdraw your consent to Pulse's continued use and/or disclosure of your Personal Data for any of the purposes and in the manner as stated in this Privacy Policy at any time by contacting Pulse.
4.2 However, the withdrawal of your consent may result in Pulse not being able to continue to provide our products or services to you or perform our contractual obligations to you, and you release and hold harmless Pulse from any complaint, claim, damage, loss, penalty or fines which you may have against Pulse or which you may incur as a result. Pulse's legal rights and remedies are expressly reserved.

5. Access, correction and update of Personal Data

5.1 You shall ensure that all Personal Data provided to Pulse is accurate, complete and up-to-date. If there are any changes to your Personal Data, or if you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us at support@pulseid.com so that we may take steps to update your Personal Data.
5.2 You may request access to your Personal Data held by Pulse, subject to any fees which Pulse may charge for processing your request for access. Such fees will depend on the nature and complexity of your access request. Information on the processing fee will be made available to you.

6. Security of Personal Data

6.1 Pulse shall make reasonable security arrangements to protect Personal Data in our possession or under our control, to prevent unauthorised access, collection, use, disclosure, copying, modification, deletion or similar risks.
6.2 While we will comply with our obligations under the PDPA and under clause 6.1, the security of any system or network storing or handling Personal Data cannot be fully assured, and we do not guarantee, in respect of the Platform and/or the App:(a) that there will be no security incidents; or(b) that there will be no malicious code (such as viruses, bugs, Trojan horses, spyware or other malware).

7. Changes to the Privacy Policy

Pulse may, from time to time in our sole discretion, update this Privacy Policy, to ensure its consistency with Pulse's needs, to satisfy legal or regulatory requirements, and/or to ensure consistency with future developments. The latest version of the Privacy Policy can be found at this web page: pulseid.com/privacypolicy. You are responsible for checking this web page to ensure that you are aware of any updates to the Privacy Policy. You acknowledge and agree that you are bound by the Privacy Policy and any such changes to the Privacy Policy.

8. Governing Law and Dispute Resolution

This Privacy Policy (including non-contractual disputes or claims arising from or in connection with this Privacy Policy) is governed by and shall be construed in accordance with the laws of the Republic of Singapore.