Privacy Policy

Introduction

• This Privacy Policy (together with the Terms of Use (“Terms of Use”) and any other documents referred to on it, hereinafter the “Policy”) informs you about the details of the processing of personal data you transmit, upload or otherwise make available during your use of the Site, the Platform and the use of the Services (“You” or “User” and “Services”, respectively) or which You provide Us through such use.

• In this Policy, “Pulseem” or “We” or “Us” will mean Pulseem Ltd., and our subsidiaries and other affiliates. If You are a user located in the European Economic Area (“EEA”) or if you intend to transmit or upload data concerning EEA residents, please carefully note the information in this Policy on your rights under the 2016/679 EU General Data Protection Regulation (“GDPR”).

• Pulseem recognizes the importance of keeping Your information secure and will ensure that the collection, use and sharing of Personal Information will be conducted in accordance with the terms of this Policy.

• This Policy may be updated from time to time if and when our privacy practice changes; each version will apply to information collected while it was in place. You are advised to consult this Privacy Policy regularly for any changes.

• In this Policy, anything that appears in a masculine form shall also mean the feminine form and vice versa.

• All Capitalized terms used but not defined herein shall have the meanings given to such terms in the Terms of Use.

Types of Information

• Pulseem may collect, receive, retain and process the following information (“Personal Information”):

o Information that You provide Us when You register to the Site or use the Services and the Platform, which may include your first and last name, address, email address, phone number, date of birth, username, password and your registration date.

o Technical information, such as your computer’s IP address, operating system, browser used to access the Site, the website from which you were linked to ours, the time and date of your visit, your searching history, the websites to which you were linked through the Site, and your activities in the Site.

o Information about the use of the Site and/or Services, such as how often users visit the Site, what pages they visit when they do so, and what other websites they used prior to coming to the Site (including by collecting the IP address assigned to you on the date you visit the Site).

o Information about activities made in the Site that directly linked to you, such as your purchase history (through affiliate programs or directly from us), data on loyalty dashboard program, details regarding the type of Services you used via the Site, details on orders you performed via the Site; we need to process this information to fulfill our contract with you and provide you with the personalized user experience we have promised you.

We need to process this information mainly to fulfill our contract with You and, if You are a user located in the EEA, our main legal basis for the processing of this Personal Information is Art. 6 (1) lit. b) of the GDPR.

o Information that You choose to provide Us, while using the Site or using a Service, such as when You submit, upload or otherwise transmit to the Site any text, document or other content, including personal information regarding Your names, telephone numbers, credit card details, email address etc. (all such information shall be referred to as “Content”).

We need to process this information to fulfil our contract with You and, if You are a user located in the EEA, our legal basis for the processing of this Personal Information is Art. 6 (1) lit. b) of the GDPR.

o In addition, We process this data when you decide to submit the Content to Us and because of these purposes represent our legitimate interests. Therefore, if You are a user located in the EEA, our legal basis for the processing of this Personal Information is also Art. 6 (1) lit. a) of the GDPR, and Art. 6 (1) lit. f) of the GDPR.

We need to process this information to fulfil our contract with You and if you are a user located in the EEA, our legal basis for the processing of this Personal Information is Art. 6 (1) lit. a) of the GDPR.

• Except as stated otherwise in this Policy, Pulseem stores Your Personal Information while You are using the Services. Pulseem may also store Personal Information, including Personal Information which may be included in the Content, for a period of time after You are no longer using the Site or after you have terminated the use of the Services, as this Personal Information might be required for various purposes even where Your contractual relationship with Us has ended. These purposes typically include business or legal reasons such as statutory retention periods or our defense against legal claims. You may ask to delete such information just letting Us know Your wish using the Contact Info detailed below.

• All information provided by You or collected by Pulseem is stored on our secured servers. Unfortunately, the transmission of information via the internet is not completely secure. Although Pulseem will take reasonable commercial effort to protect Your Personal Information, Pulseem cannot guarantee the complete security of Your data transmitted to the Services and therefore any transmission is at Your own risk. Once Pulseem has received Your information, Pulseem will use strict procedures and security features to try to prevent unauthorized access.

How will Pulseem use Personal Information

• Our main objective in storing and processing Your Personal Information, as described in this Privacy Policy, is to provide You with access to our Site and to allow you to use our Services and to perform our contract with You. We may also process some of Your information to support and fulfill our legitimate business interests, such as self-study and internal statistics, and to allow Us to comply with legal and contractual obligations or defense against legal claims.

• In addition, Pulseem may use the Personal Information collected in the following manners (We will treat all the aforementioned and the following as “Purpose”):

o Recognize You when You return to the Site and the Platform.

o For that reason, We also use cookies. Cookies are small text files that You load onto Your device when You use our Site and store Personal Information. We use our own cookies in order to identify and recognize You when You return to use the Site and provide You with an easier automated login. If you would like to know more about how cookies work, which cookies process which data on our Site for which purposes and how you can deactivate them, please refer to our Cookie Policy for an overview of all cookies and third-party tools embedded into our Site.

o Monitor the use of the Site and the Platform and administrate the Site, for Pulseem’s technical administration including for security reasons.

o Estimate the number of users logging into the Site, using the Services and monitoring usage patterns.

o To conduct research and for further development of Pulseem’s services in order to provide You with a better, more intuitive experience, including by way of development of new features.

o Pulseem may store and process Personal Information outside Your country on servers which are located in the European Union or any other state pre-approved by the European Commission or as otherwise permitted by law, including the GDPR. Pulseem processes data both inside and outside of the EEA and rely on legally-provided mechanisms to lawfully transfer data across borders.

Disclosure of Information

• Pulseem may disclose the Personal Information to third parties or governmental authorities, under the following obligations: Pulseem is engaged with certain selected third parties which provide services to Pulseem, including, cellular or communication networks, hosting, database storage and maintenance (such as AWS), billing and ecommerce (such as Tranzilla) and process services (such as Microsoft. In addition, and in order to provide You with the Services, Pulseem may be engaged with third parties who provide services similar to that provided by the Company to You.

• Pulseem may share Your information with these third parties, but only to the extent necessary for the Purpose unless otherwise permitted by law, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of Your information.

• It is hereby clarified that some of the Personal Information collected and processed by these third parties are collected directly by them (and not transferred by us). We provide these third parties with access to the Site and Services and enable them to collect and use the Personal Information in order to provide You with excellent Services. In case You object to the process of any of these third parties of Your Personal Information, You can contact Us and ask Us to stop granting them with access to Your Personal Information. Please note that in such case some or all of the Services may not be available to You.

• When We believe in good faith that disclosure is necessary to protect our rights, protect Your safety or the safety of others, investigate fraud, or respond to a government request (including court order, search warrant).

• Pulseem may disclose the Personal Information in the event where Pulseem shall transfer in any way the operation of the Services to any third party and should it merge with another entity or merge the operations of the Services with the activity of a third party, provided that this corporation will assume the terms of this Privacy Policy.

• Pulseem may disclose the Personal Information where You are performing any act in the Services which constitutes a violation of any law or the Terms of Use.

Security

• The security of Your Personal Information is important to us. Pulseem employs administrative, contractual, physical and electronic measures and security safeguards designed to protect Your information from unauthorized access. To protect the confidentiality of Personal Information, You must keep your password confidential and not disclose it to any other person. If other people have access to Your email, they may be able to obtain access to Your password and obtain personal information about You, or change information about Your Account. However, Pulseem cannot warrant the security of any information that You provide. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of Pulseem physical, technical, or managerial safeguards. If You have any questions about the security of the Services, You can contact Us as using the Contact Info detailed below.

Your Rights with respect to the Personal Information

• Pulseem offers You to control and manage the Personal Information Pulseem has about You. You are entitled to ask Pulseem to:

o Withdraw the consent – You may, at any time, withdraw your consent and no longer permit Pulseem to use and keep Your Personal Information. Please note that by doing so, Your experience of the Services may be affected and You may not be able to use all or part of the Services that Pulseem offers.

o Delete Data – You can ask Pulseem to erase or delete all or some of the Personal Information (e.g., if it is no longer necessary to provide the Services).

o Change or Correct Data – You can ask Pulseem to edit some of the Personal Information by asking Pulseem to change, update or fix Your Personal Information in certain cases, particularly if it is inaccurate.

o Object to, or Limit or Restrict, Use of Personal Information – You can ask Pulseem to stop using all or some of your Personal Information (e.g., if Pulseem has no legal right to keep using it) or to limit Pulseem use of it (e.g., if the Personal Information is inaccurate or unlawfully held).

Further, you have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is processed on the basis our legitimate interests; this also applies to any profiling based on this processing. If you object, we will no longer process your personal data in the future unless we can prove compelling grounds for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise, or defend legal claims.

You also have the right to object at any point in time to the processing of your data for direct marketing purposes (i.e. receiving newsletters or other direct marketing communications). If you exercise your right to objection, we will no longer use your Personal Information for sending you any marketing communications.

o Right to Access and/or Take Your Data – You can ask Pulseem for a copy of your Personal Information and can ask for a copy of the Personal Information You provided, in machine readable form.

o In case any of the foregoing actions is not available through Your account, You can contact Pulseem at the Contact Info (as detailed below) and ask Us to perform it. You acknowledge that by asking Pulseem to not store or process the Personal Information or by performing any of the foregoing actions on its own, You may prevent Us from providing You with the Services, and be prevented from using all or part of the Services. You hereby waive any claim or demand You might have against Pulseem in this matter.

o If You believe that the process of the Personal Information is not complying with the law applicable to You or Pulseem’s response have not satisfied You, You may lodge a complaint to the relevant Supervisory Authority (as defined in the GDPR).

Lawful Bases for Processing

• Pulseem has lawful bases to collect, use and share data about each user of the Site. The primary lawful basis is based on your engagement with Us, in order for Pulseem to provide You with the Services and to be able to contact You from time to time (where processing is necessary for the performance of a contract with You).

• In addition, lawful bases include consent (where You have given consent), our legitimate interests and may also be a legal obligation to which We are subject.

• In case there are more than one lawful bases for processing Personal Information, We may rely on any of the lawful bases even if the lawful basis is not explicitly stated in this Policy.

• Where Pulseem relies on Your consent to process Personal Information, You have the right to withdraw or decline consent at any time and where Pulseem relies on legitimate interests, You have the right to object to the processing of Your Personal Information for reasons arising from Your particular situation. If You have any questions about the lawful bases upon which Pulseem collects and use Personal Information, please contact Us through the Contact Info.

• At any time, You can withdraw the consent You have provided Us by contacting Us using the contact information detailed below.

Children

• By using the Site and/or the Service and approving the Terms of Use and this Policy, You also approve that You understand that the services provided are not intended for children under the age of 18 and addressed solely to a natural person who is at least 18 years old. We do not use the Services to knowingly solicit data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided Us with information without their consent, he or she should contact Us at the Contact Info provided below. We will delete such information from our files within a reasonable time.

Questions or Concerns

If You have any questions or concerns about this Policy or would like to contact Us for any reason, You can e-mail Us at Privacy@pulseem.com (the “Contact Info”).

Effective date:

This Policy was last updated in November 2024.