Privacy Policy
Last Modified | January 21, 2019
We are Pulsify, Inc. ("Pulsify"). This Privacy Policy describes how we protect your data and respect your privacy. Any questions or concerns with respect to your data or privacy should be directed to support@pulsifyapp.com.
Applicability of this Privacy Policy
This Privacy Policy applies to Pulsify's services, including web, mobile applications, and embedded add-ons (collectively, the "Services"), and any other interactions (e.g., customer support inquiries, etc.) you may have with Pulsify. Pulsify provides the Service which is utilized by employees (“Users”) of an enterprise (“Employer”). Accordingly, we are providing this Privacy Policy to explain our practices regarding the collection, use, security, and disclosure of personal data that we receive when users use our service.
Notice to End Users
By visiting the Websites, accessing or using the Services, or interacting with any aspect of our business, you accept the terms of this Privacy Policy and expressly consent to our collection, use, and disclosure of data, including Personal Data, provided to or otherwise received by us for the purposes and in the manner described in this Privacy Policy and the applicable Customer Subscription Agreement.
A separate agreement governs the delivery, access, and use of the Services (the "Terms of Service”).
Data We Collect and Receive
Sometimes you provide us with data and sometimes data about you is collected automatically. To the extent data is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as "Personal Data." You acknowledge and agree we may collect, process, store, access, and disclose Personal Data disclosed by you or your employer to facilitate the provision of Services and related support for the Services in the manner described in this Privacy Policy and the applicable Customer Subscription Agreement.
User Data
Employers and Authorized Users routinely submit User Data to Pulsify when using the Services. User Data is governed by the Customer Subscription Agreement. User Data may include Account Information, Hosted Data, Sync Data, or any User Data otherwise defined in the Customer Subscription Agreement. If you have any questions about your Personal Data with respect to User Data, please contact your Employer.
Hosted Data
When a User uses, or Authorized User interacts with, the Services, we may collect, process, and store any data that is created, posted, uploaded, stored, displayed, transmitted, or submitted on or through the Services as a function of rendering the Services. Data may contain Personal Data to the extent an Employer or Authorized User discloses Personal Data on or through the Services. Except to the extent necessary to render the Services or related support for the Services, Pulsify does not purposefully access any User Data.
Sync Data
Pulsify makes tools available to integrate data from Third Party Services used by Employer into the Services. When the Services are integrated with a Third Party Service for Sync Data, we will receive all data selected by the Employer to sync with the Services. Sync Data is imported into the Services as either Account Information, Hosted Data, or such other Employer Data.
Other Information
Pulsify may collect Other Information from Employers and Authorized Users related to their usage of the Services and interactions with Pulsify. Other Information may include Metadata, Log Data, Technical Data, Cookie Data, Third Party Services, and Additional Information provided to Pulsify. If you have any questions about your Personal Data with respect to Other Information, please contact Pulsify at support@pulsifyapp.com.
Metadata
When an Authorized User interacts with the Services, metadata is generated that provides additional context about the Services and the way Authorized Users use the Services ("Metadata"). Pulsify collects aggregated Metadata of the Services, so that the resulting data and statistics are not personally identifiable to any individual Authorized User.
Log Data
Like most websites and web-based technology services, our servers automatically collect data when you access or use our Websites or the Services and record it in log files ("Log Data"). The Log Data may include your Internet Protocol (IP) address, Internet service provider (ISP), browser type and settings, information about browser plugins, language preference, default email application, referring/exit websites, operating system, date and time stamp, cookie data, and certain user activities.
Technical Data
Pulsify collects technical data, such as information about devices accessing the Services, including the type of device, device settings, operating system, application software, peripherals, and unique device identifiers ("Technical Data"). Pulsify does not collect Personal Data with any Technical Data or relate any Technical Data to any individual Authorized User.
Cookie Information
Pulsify uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services. We use cookies and similar technologies to help with authentication, security, identifying your preferences, analytics, and otherwise monitoring the functionality and performance of the Services. If you do not wish to have cookies placed on your computer or in local storage, you may adjust your web browser settings accordingly. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to block cookies or to alert you when cookies are sent. However, restricting cookies may impede your ability to use the Services or certain features of the Services.
Third Party Services
Employers may choose to permit or restrict integrations with Third Party Services for their Workspace. Once enabled, the enabled Third Party Services may share certain data with Pulsify to effectuate the integration. You should check the privacy settings and notices of these Third Party Services to understand what data may be disclosed to Pulsify. When the Services are integrated with Third Party Services to enhance the Services, we may receive data regarding your credentials for and use of the applicable Third Party Services, such as your user name, your unique identifier, and your information transmitted from or made available with permissions by such Third Party Services (e.g., account profile, gender, age range, language, geographic region, etc.). When the Services are integrated with Third Party Services for the login and authentication process (e.g., Google Sign-In, OneLogin, ADFS, and many other SAML 2.0 compatible services) and an Authorized User logs in to the Services using a Third Party Services authenticator, we may receive data regarding your credentials for the applicable Third Party Services, such as your log-in, your user name, your email, your unique identifier, profile picture, and your information transmitted from or made available with permissions by such Third Party Services (e.g. account profile, gender, age range, language, geographic region, etc.).
Additional Information Provided to Pulsify
Pulsify receives data when submitted to our Websites or through our Services, or if you contact us (e.g., by email, telephone calls, written correspondence, web based forms, or otherwise), request support, apply for or take a job with us, contract with us, interact with our social media accounts, or otherwise communicate with Pulsify.
No Sensitive Personal Data
Pulsify does not intentionally collect, process, or store, and we request that you do not post, upload, store, display, transmit, or submit Sensitive Personal Data on or through the Services or in Employer Data. "Sensitive Personal Data" includes, but is not limited to, government-issued identification numbers; financial account numbers; credit or debit card numbers; consumer reports; background checks; any code or password that could be used to gain access to personal accounts; genetic data or biometric data; any Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; or data concerning health or sex life or sexual orientation. Pulsify is not responsible and will not be liable for any loss or damages you or another individual may experience due to your disclosure of Sensitive Personal Data while using the Services.
No Children's Data
Pulsify's business activities are directed to other businesses and the Services are intended for use only by those who are 18 years of age and over. The Services are not directed to or intended for children, and Pulsify does not intentionally collect, process, or store any Personal Data from any person under 13 years of age. In the event we discover we have inadvertently collected, processed, or stored any Personal Data from a person under 13 years of age, we will promptly take the appropriate steps to delete such data or seek the necessary verifiable parental consent for that collection in compliance with the Children's Online Privacy Protection Act ("COPPA").
How and Why We Use Data
User Data will be used by Pulsify in accordance with Employer’s instructions, including any applicable terms in the Customer Subscription Agreement and Employer’s use of Services functionality, and as required by applicable law. Employer may, for example, use the Services to grant and remove access to create Authorized Users accounts, assign roles and configure settings, access, modify, share, restrict, export, and remove User Data and otherwise apply its own policies to the Services.
Other Information will be used by Pulsify in furtherance of our legitimate interests in operating our business and providing the Websites and Services, to perform contractual obligations, and/or pursuant to your express consent for a specific purpose. Specifically, Pulsify may use Other Information for these purposes and legal bases:
Providing the Websites and Services
To make the Websites available and support delivery of the Services under a Customer Subscription Agreement, manage Authorized Users requests interacting with the Services (e.g. login and authentication, remembering settings, etc.), hosting and back-end infrastructure, analyze and monitor usage, monitor and address service performance, security, and technical issues.
Improving the Websites and Services
To test features, manage landing pages, heat mapping, traffic optimization, data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this.
Support Services
To respond to support requests via live chat, phone, or email and otherwise provide support for and resolve problems with the Services.
Communications
To send service, technical, and administrative emails, messages, and other communications. Service-related communications about changes to the Services and important Services-related notices, such as maintenance and security announcements, are essential to delivery of the Services and you cannot opt-out. Marketing communications about new product features, service offerings, and other news about Pulsify are optional and you have the choice whether or not to receive them.
Account Management
To contact for billing, account management, feedback, and other administrative matters.
Security Purposes
To help prevent and investigate security issues and abuse.
Legal Obligations
To comply with legal obligations as required by applicable law, legal process, or regulations.
How We Share and Disclose Data
Except as described in this Privacy Policy or the applicable Customer Subscription Agreement, Pulsify will not use or disclose your Personal Data for any purpose other than to the extent necessary to perform the Services and related support for the Services, unless you expressly consent to any other use or disclosure.
Pulsify may share and disclose data with respect to:
Employer’s Instructions
Pulsify will share and disclose User Data in accordance with an Employer’s instructions, including any applicable terms in the Customer Subscription Agreement and Employer’s use of the Services functionality, and as required by applicable law. Pursuant to the Customer Subscription Agreement, User Data is generally treated as the confidential information of Employer unless stated otherwise.
Employer Access
Administrators, Authorized Users, and other Employer representatives and personnel may be able to access, modify, or restrict access to your data. For example, your Employer may use the Services administrative controls and features to access or modify your account details or view certain activities.
Displaying the Services
When an Authorized User submits data on the Services, it may be displayed to the Employer and other Authorized Users. You are solely responsible for all data you post, upload, store, display, transmit, or submit on the Services, including Personal Data, and the consequences thereof. Pulsify is not responsible and will not be liable for the data disclosed on the Services.
Rendering the Services
Pulsify employees and contractors may have access to your data on a need to know and confidential basis to the extent necessary to render the Services and related support for the Services.
Third Party Services
Employer may enable or permit integrations with or use of Third Party Services in connection with the Services. When enabled, Pulsify may share certain data with such Third Party Services as requested to effectuate the integration. Third Party Services are not owned or controlled by Pulsify and third parties that have been granted access to your data may have their own policies and practices for its collection and use.
You should check the privacy settings and notices of these Third Party Services to understand their privacy practices.
Changes to Pulsify's Business
If Pulsify engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of its assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), Pulsify may share or disclose data in connection therewith, subject to standard confidentiality obligations.
Aggregated or De-identified Data
If any data is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use or disclose such aggregated or de-identified data for any purpose. For example, we may share aggregated or de-identified data with prospects or partners for business or research purposes, such as statistical analysis, to research trends and predictive analysis, or to develop or improve the Services.
Enforcement of Agreements
Pulsify may disclose data to ensure compliance with and enforce Employer Agreements and any other contractual or legal obligations with respect to the Services and our business.
Protection of Rights
Pulsify may disclose data to protect and defend our rights and property, including intellectual property rights, and to ensure compliance with applicable laws and enforce third party rights, including intellectual property and privacy rights.
Legal Compliance
If we are compelled by law, such as to comply with a subpoena, court order, or other lawful process, or in response to a lawful request by public authorities to meet national security or law enforcement requirements, Pulsify may disclose data if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
Safety and Security
Pulsify may disclose data to protect your safety and security; to protect the safety, security and property of Employers; and to protect the safety, security, and property of Pulsify and our employees, agents, representatives, and contractors.
Your Consent
Pulsify may disclose your data to third parties when we have your express consent to do so.
Retention
Pulsify will retain User Data in accordance with a Employer’s instructions, including any applicable terms in the Customer Subscription Agreement and Employer’s use of the Services functionality, and as required or permitted by applicable law. Pulsify may retain Other Information and any data pertaining to you, including Personal Data, for as long as your Authorized User account is active and thereafter for as long as necessary for the purposes described in this Privacy Policy, including for the period of time needed to pursue our legitimate business interests, provide your Employer with the Services, conduct audits, resolve disputes, comply with contractual obligations (including but not limited to Customer Subscription Agreements), and comply with (and demonstrate compliance with) legal obligations.
Security Measures
Pulsify maintains physical, technical, and administrative procedures to safeguard and secure the data we collect. We work hard to protect data in our custody and control from loss, misuse, and unauthorized access, use, disclosure, modification, or destruction.
PLEASE REMEMBER:
You provide Personal Data at your own risk.
Unfortunately, no data transmission over the Internet is guaranteed to be 100% secure, and we cannot guarantee that unauthorized access, hacking, data losses, or other breaches will never occur.
You are responsible for safeguarding your Authorized User account and password.
If you believe your privacy has been breached, please contact us immediately at support@pulsifyapp.com.
Identifying the Data Controller and Data Processor
Data protection laws in certain jurisdictions differentiate between the "controller" and "processor" of data. In general, Employer is the controller of Employer Data. In general, Pulsify is the processor of User Data and the controller of Other Information.
International Data Transfers
Pulsify primarily processes and stores data in connection with the Services in the United States. However, the Services are global and all data, including Personal Data, may be processed and stored in any country where we have operations or where we engage Third Party Service Providers. We may transfer data, including Personal Data, to countries outside of your country of residence, which may have data protection laws that are different from those of your country. We will take measures to ensure that your Personal Data remains protected to the standards described in this Privacy Policy and any such transfers comply with applicable data protection laws. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.
Your Rights
Individuals located in certain countries and jurisdictions have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to exercise your rights and request certain actions with respect to your Personal Data.
General Privacy Rights
Pulsify is committed to maintain accurate information that you share with us and will use commercially reasonable efforts to allow you to access your Personal Data. Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data. To request this information or if you wish to access, modify, or remove your Personal Data, please contact us at support@pulsifyapp.com. Pulsify will endeavor to respond to all reasonable written requests to access, modify, or remove Personal Data in a timely manner within thirty (30) days.
If you seeks to access, modify, or remove Personal Data held or processed by us on behalf of an Employer, you should direct your inquiry to your Employer (the data controller). Upon receipt of a request from one of our Employers for us to remove the data, we will respond to their request in a timely manner within thirty (30) days.
If you consent to receiving communications from a third party, such third party may have its own privacy policy which will apply to you and you will need to communicate with them directly if you wish to access, modify, or remove the Personal Data you provided to them, or later decide that you no longer wish to receive such third party's communications.
California "Shine the Light" Notice
Pulsify does not disclose Personal Data to third parties for any third parties' direct marketing purposes, unless the Employer or Authorized User affirmatively consents to such disclosure. Since Pulsify provides its California users with notice of its rights as described above, pursuant to Section 1798.83(c)(2) of the California Civil Code, Pulsify is in compliance with California's "Shine the Light" law and is not obligated to provide California users with the names and addresses of all the third parties that received Personal Data from Pulsify for the third parties' direct marketing purposes during the preceding calendar year.
Enforcement
Pulsify will actively monitor its relevant privacy and security practices to verify adherence to this Privacy Policy. Any agents, contractors, service providers, or other third parties subject to this Privacy Policy that Pulsify determines is in violation of this Privacy Policy or applicable data protection laws will be subject to disciplinary action up to and including termination of such services. If you believe there has been a violation of this Privacy Policy or applicable data protection laws, please contact us immediately at support@pulsifyapp.com.
Changes to this Privacy Policy
Pulsify may change, modify, or update this Privacy Policy from time to time, in whole or in part, in Pulsify's sole discretion, at any time without prior notice by posting updated versions on the Pulsify website. When we do, we will revise the "last updated" date. If and when we make such changes, we will make commercially reasonable efforts to notify you by email, through the Services, or by posting a prominent notice on our Website. Any changes, modifications, or updates to this Privacy Policy will become effective immediately upon such posting. Your continued use of the Services constitutes your agreement to be bound by such changes to this Privacy Policy. If you disagree with the changes to this Privacy Policy, your only remedy is to discontinue use of the Services and deactivate your account.
Contact Pulsify
We encourage you to contact us with any questions, complaints, or requests with respect to your Personal Data, this Privacy Policy, and/or our privacy practices.
You may contact us at:
Email: support@pulsifyapp.com
Pulsify, Inc.
Attn: Chief Privacy Officer
200 Portland St., Boston, MA 02114 US